National Green Tribunal
Isanaka Vedavathi vs Ministry Of Environment, Forest And ... on 3 February, 2021
Author: K. Ramakrishnan
Bench: K. Ramakrishnan
Item No.5:
BEFORE THE NATIONAL GREEN TRIBUNAL
SOUTHERN ZONE, CHENNAI
Original Application No. 221 of 2015 (SZ)
(Through Video Conference)
IN THE MATTER OF:
Isanaka Vedavathi,
H.No. 16-4-966, Pinakini Avenue,
Near Apollo Hospital,
Nellore - 524 003.
... Applicant(s)
Versus
Union of India
Rep. by its Secretary,
Ministry of Environment, Forest & Climate Change,
New Delhi and Ors.
... Respondent(s)
Date of hearing: 03.02.2021.
CORAM:
HON'BLE MR. JUSTICE K. RAMAKRISHNAN, JUDICIAL MEMBER
HON'BLE MR. SAIBAL DASGUPTA, EXPERT MEMBER
For Applicant(s): None.
For Respondent(s): Smt. Me. Saraswathy for R1.
Smt. Madhuri Donti Reddy for R2 to R4.
Sri. C. Seethapathy for R5.
Sri. D. Srinivasan for R6, R7, R9, R10.
M/s. Snegha represented
[1]
M/s. Apparajitha Vishwanath for R8.
Sri. Parthasarathy represented
Sri. Lakshmi Kumaran for R11.
ORDER
1. As per order dated 07.01.2021, this Tribunal had directed the 5 th respondent to submit details regarding the change of identity of the 5th respondent unit as according to them, it has been amalgamated with M/s.
Adani Wilmar Limited vide order of the Hon'ble High Court of Gujarat, passed in Company Petition No.309 of 2015 dated 28.10.2015. We have also directed the committee to submit a further report on the basis of the observations made by them in the report filed and posted the case to today for that purpose.
2. When the matter came up for hearing today through Video Conference, there was no representation for the applicant. Smt. Me. Saraswathy represented 1st respondent, Smt. Madhuri Donti Reddy represented respondents 2 to 4, Sri. C. Seethapathy represented 5th respondent, Sri. D. Srinivasan represented respondents 6, 7, 9 & 10, M/s. Snegha represented Sri. Apparajitha Vishwanath, learned counsel appearing for 8th respondent and Sri. Parthasarathy represented Sri. Lakshmi Kumaran, the learned counsel appearing for the 11th respondent.
3. The learned counsel appearing for the 11th respondent submitted that in respect of 11th respondent also, there is a change in ownership and now [2] the unit is amalgamated with M/s. Adani Wilmar Limited group and they wanted some time to furnish the details regarding the same.
4. The report of the Joint Committee dated 01.12.2020 which was received on 06.01.2021 by this Tribunal reads as follows:
"I Preamble Cluster of Edible Oil Industries are operating in Krishnapatnam Portregion in SPSR Nellore district. The applicant Smt. Isanaka Vedavathi submitted a representation stating that pollution has been caused by edible oil units. Hon'ble National Green Tribunal Southern Bench in order to ascertain the present status of the functioning of the edible oil refinery units and also to find out as to whether they are complying with the conditions of "consent" issued and whether the pollution control mechanism provided by them are proper and sufficient and whether they are complying with the norms and whether the "Zero Liquid Discharge"
system said to have been established by them are properly functioning and whether there is any violation by any of the edible oil refinery units and if so, what is the action taken by Pollution Control Board in this regard has appointed a joint committee comprising of (1) a Senior Officer from the Central Pollution Control Board, Regional Office, Bangalore (2) Senior Officer from the Regional Office of MoEF & CC, Chennai and (3) Senior Scientist from Andhra Pradesh Pollution Control Board.
II Orders of the Hon'ble National Tribunal dated 16.03.2020 in OA No 221/2015 Hon'ble NGT vide order dated 16.03.2020 has directed the following " So in order to ascertain the present status of the functioning of the edible oil refinery units and also to find out as to whether they are complying with the conditions of "consent" issued and whether the pollution control mechanism provided by them are proper and sufficient and whether they are complying with the norms and whether the "Zero Liquid Discharge"
system said to have been established by them are properly functioning and whether there is any violation by any of the edible oil refinery units and if so, what is the action taken by Pollution Control Board in this regard, we appoint a joint committee, comprising of (1) a Senior Officer from the Central Pollution Control Board, Regional Office, Bangalore (2) Senior Officer from the Regional Office of MoEF & CC, Chennai and (3) Senior [3] Scientist from Andhra Pradesh Pollution Control Board to inspect the units in question and submit a factual as well as action taken, if there is any violation found. The committee shall also go into the question as to whether the units are strictly complying with the conditions imposed either in the "consent to operate" or any other permission granted, whether there is any violation in the use of surface water and whether necessary permission has been obtained by the units for drawal of surface water for their purpose, whether pollution control mechanism provided to suppress the air pollution or water pollution are sufficient to meet the requirements as has been provided under the Environment (Protection) Act, 1984, whether these units are properly disposing the fly ash generated during their manufacturing process and if there is any violation found, what is the action taken, including the imposition of environment compensation against the erring units on the basis of the guidelines given by Central Pollution Control Board in this regard and also what is the status of the implementation of the action plan if any, evolved during the review meeting conducted by Pollution Control Board and whether those actions have been brought into action by the units, as undertaken by them and if not, what is the action taken by Pollution Control Board against those erring units and submit a comprehensive report to this Tribunal within a period of two months through e-mail at [email protected]." Hon'ble NGT order dated 16.03.2020 and 29.09.2020 is enclosed as Annexure-I and Annexure-II respectively.
III Composition and Scope of Committee In compliance to Hon'ble NGT order, the following committee was composed:
1. Smt. Mahima T, Scientist-D, Central Pollution Control Board, Regional Directorate, Chennai
2. Dr. C. Palpandi, Scientist-C, Ministry of Environment Forest and Climate Change, Regional Office, Chennai
3. Sri. M.Pramod Kumar Reddy, Environmental Engineer, Andhra Pradesh Pollution Control Board, Regional Office Nellore (Nodal agency) The Committee has been vested with the mandate to visit and inspect the site inquestion and vested with followingscope vide the Order dated 16.03.2020:
a. to ascertain the present status of the functioning of the edible oil refinery units [4] b. to find out whether edible oil units are complying with the conditions of "consent" issued and whether the pollution control mechanism provided by them are proper and sufficient and whether they are complying with the norms and whether the "Zero Liquid Discharge" system said to have been established by them are properly functioning c. action taken by Andhra Pradesh Pollution Control Board d. to find out whether whether there is any violation in the use of surface water and whether necessary permission has been obtained by the units for drawal of surface water for their purpose e. to find out whether pollution control mechanism provided to suppress the air pollution or water pollution are sufficient to meet the requirements has been provided under the Environment (Protection) Act, 1984 f. to determine whether these units are properly disposing the fly ash generated during their manufacturing process g. imposition of environment compensation against the erring units IV Site Visit by the Committee The committee constituted by Hon'ble NGT vide order dated 16.03.2020 convened its first meetingon 27.07.2020 through video conference (VC) with the officials of Regional office, Nellore and reviewed the status of operation of Edible oil industries with respect to Pollution control issues.The committee inspected the units on 13.10.2020 and 14.10.2020. As per the scope vested on the committee, the information is compiled in tables VIa to VIg.
V Process Description- Edible Oil Refining Process V.a.General information:
Seven edible oil units are operating in KrishnapatnamPort region. The units are involved in refining of crude palm and sunflower oil. The Palm Oil extraction is to be done with the fresh Palm fruit to avoid the deterioration of Palm Oil. Hence, palm oil is extracted in the countries where it is cultivated to avoid its deterioration. All the seven edible oil units are importing crude palm oil from Indonesia, Singapore and Malaysia. Crude Palm Oil is yellow red or dark yellow in color and contains certain impurities which are removed by physical refining. During refining, Phospholipids, free fatty acids, colouring pigments (Carotenoids), Moisture, oxidative material, metal impurities, and water soluble impurities (glycerol, Phenols, Sugars) are removed. Crude sunflower oil is [5] imported from Ukraine, Argentina, Malaysia. The crude palm oil is physically refined while the sunflower oil is chemically refined. All units are practising similar refining process with only minor modifications in the stages of refining. (carotenoids).
V.b Physical refining of crude palm oil: Crude palm oil contains 3.5%to 4.5% fatty acids that comes out as waste. Around 1% to 2% of fats or oil is lost in bleaching section. Total loss will be around 4.5% to 6.5%. The stages in physical refining 8 are as follows:
a. De-gumming: It is the process of removal of gums or phosphatides. It comprises the treatment of crude oil with water, salts, enzymes, caustic soda, or dilute acids such as phosphoric acid to remove phosphatides, waxes, pro-oxidants, and other impurities.
b. Bleaching: Trace metal complexes such as iron & copper, colouring pigments and oxidative 7products 2 9 are removed by adsorption using bleaching earth. Spent Earth 5 is sold to soap manufacturing units.c. 4
De-odorizer: Deodorization / De-acidification is6 done to remove the volatile components, mainly aldehydes and ketones, which causes smell in refined oil. In Deodorization process, free fatty acid removes in the form of Palm fatty acid distillate as a refining waste. During deodorization, bleached palm oil is steam distilled or boiled. The vapors from this section is the palm fatty acid distillate.
d. Crystallization: Portion of palm oil will crystallize on cooling and is known as palm-stearin or margarine and the other portion remains as liquid and is called palm-olien or cooking oil. Waste from physical refining: gums and other impurities and wastewater from degumming section, refining waste from refining section. The waste water contains oil and it is removed by centrifuge principles. V.c Chemical refining of Sunflower oil/ Soybean oil: The steps involved in chemical refining are as follows:
a. Neutralization: Addition of caustic to reduce FFA (gum/ phospho lipid) from crude palm oil b. Bleaching: Removal of colouring pigments and other impurities c. De-waxing: The wax so removed is sold to cosmetic industry d. De-odorization: Removal of fatty acids and other volatile components.
e. Fractionation: separation of hard fraction from refined palm oil [6] VI. The status of edible oil industries is as follows VI.a Compliance Status of M/s Gemini Edibles & Fats India Pvt Ltd a Name & complete address of the unit M/s Gemini Edibles & Fats India Pvt Ltd, Sy.No. 1607/2, Industrial Park, Pantapalem (V), Muthukur (M), SPSR Nellore district b Contact Details Sh. Prathap Vice- President Operations +91 -9866556188 c Geo-cordinates 14°15'36.3"N 80°04'19.0"E d Area 15.2 acres e Status of CFO & Authorizations and its The combined Consent and Authorization issued by APPCB is compliance valid till 30.06.2021.
f Year of commissioning 2010 g Production capacity Refined Vegetable Oil (Physical refining)-550TPD
Refined Vegetable Oil (Chemical refining)-250 TPD Fractioned vegetable oil- 600 TPD Interesterified fats- 125 TPD Vanaspathi-100 TPD By-products Distilled fatty acids-13386 Tons Per annum Acid oil-1690 Tons Per annum h Coal and flyash storage measures taken The unit has constructed separate shed for coal storage but to control fugitive emissions however, it was observed during inspection that the size of the shed is small and coal was stored in open. The unit has installed water sprinklers in storage yard.
The unit has installed flyash silo of capacity 100 Tonnes (10 days storage capacity against the direction of APPCB to install silo for 30 day storage.The flyash is sold to brick manufacturers.
Partially complied.
i Source of water and quantity of water Through water tankers and bore wells. used per day The total water requirement of the unit is 610 KLD including domestic requirement.
Quality of water will be having TDS of more than 1200 ppm, which has to be treated through RO.
Ground water and water audit department has given permission to the unit to utilize 350 KLD of ground through four bore wells but three of them have become dry and the unit has constructed three new bore wells and is drawing 180 KLD of ground water and has obtained fresh permission to draw [7] additional 70 KLD of water. The unit has permission to utilize 250 KLD of ground water by 10hrs of pumping from the filter points. But however the major water requirement is met by procuring water in tankers.
j Effluent generation Around 30 KLD of effluent is generated from physical refining and is Low TDS effluent which is treated in ETP of capacity 200KL. ETP comprises of collection tank oil recovery system primary settling tankDAF aeration tank secondary clarifier RO. Raw water is treated in two stage RO system and RO rejects (70 KLD) is also treated in MEE. Outlet effluent from ETP is treated in RO of 200 KLD capacity. RO permeate is taken to cooling tower and for dust suppression. RO reject is taken to MEE.20 KL of HTDS effluent is generated from chemical refining section and after oil recovery it is treated in MEE followed by ATFD .ATFD salts sent to TSDF. MEE condensate is used for gardening and dust suppression.
There is no proper effluent conveyance system, the open drains carry both effluent and storm water. Though the effluent generation is only 30 KLD and capacity of ETP is 200 KLD.The industry has not given justification for providing higher capacity of the ETP and RO even the industry is generating 30 KLD and 20 KLD of LTDS and HTDS effluents, hence it prevails the industry is operating ETP in phased manner. During storage in collection tank, settling and putrefaction of effluent takes place which is likely to emanate odour.
There is no proper mechanism for sludge collection and transferring to sludge drying beds. Sludge was haphazardly stored in ETP area.
Part of sewage generated from the unit is also treated in ETP even the industry provided STP of 30 KLD capacity. Not complying TableVI.a 1: Analysis results of samples collected by APPCB during 30.06.2020 S.No Parameter APPCB Inlet of Outlet of MEE MEE MEE RO RO in mg/L standard ETP ETP feed condens concentr permeat reject except pH ate ate e 1 pH 5.5-9.0 7.26 7.5 8.85 8.53 10.09 6.74 8.35 [8] 2 TSS 200 184 136 201 12 186 4 76 3 TDS 2100 3256 4018 10170 2486 52500 90 7240 4 COD 250 960 196 928 192 19680 <10 116 5 BOD 100 364 62 350 56 6152 BDL 34 6 Oil & 10 12.6 8.4 25 47 226 BDL 4.0 grease The results indicate that MEE condensate is not complying with discharge standards stipulated by APPCB. Therefore MEE condensate shall be treated in RO. ETP outlet is around 30 to 35 KLD and RO capacity is 200 KLD, treated effluent is stored in a tank and RO is operated once in a week during which oxidation may take place resulting in BOD & COD reduction. RO reject is having TDS of 7240 mg/L against APPCB stipulated standard of 2100mg/L. Hence RO reject will be treated in MEE. k Installation of magnetic flow meters with Partially complied totalizer The unit has installed flow meters and totalizer at the inlet and outlet of ETP but however the unit has not installed flow meter at raw water inlet. Since both ground water and water from tankers is utilized, the unit has not quantified the total water consumption and water used for various utilities. Partially complied l Boiler of capacity 20 TPH Multi cyclone dust Thermic fluid heater of capacity collector followed by 16.0 Lakh k.cal/hr (2Nos.-6.0 Bag filters Air pollution sources and type of Lakh K.cal/hour + 10 Lakh APCDs, status of stack, porthole, K.cal/hour capacity) OCEMS installation, location 3x 1000 KVA DG Sets Acoustic enclosures with silencer & Muffler OCEMS has been installed at 24 mtr height of chimney. Not complying TableVI.a.2: Stack monitoring at M/s Gemini Edibles by APPCB on 30.06.2020 Source SPMmeasured value APPCB emission standards Stack attached to 20 TPH boiler 129.7 mg/Nm 3 115 mg/ Nm3 TableVIa.3: Ambient air quality monitoring at M/s Gemini Edibles by APPCB on 30.06.2020 Source PM 10 measured value APPCB emission standards Near the main gate within unit 132.2 µg/m3 100 µg/m3 premises m Status of installation of online stack The unit has installed online continuous stack monitoring monitoring equipment system to measure SPM and it is connected to APPCB server. n Status of green belt Partially complied.
[9]The unit has developed green belt in an area of 3.5 acres against the requirement of 5.0 acres (33%) with avenue plants. It was informed to the committee that the unit has taken compensatory plantation in their own 32 acres of land in other area. Rain water harvesting pit of 50MtrX40mtr is established inside the plant.
o Hazardous waste generation Unit is generating MEE salts, ETP sludge, used oil and spent nickel catalyst. MEE salts and ETP sludge are disposed to TSDF. The quantity of MEE salts & ETP sludge sent to TSDFis around 9 to 10 MT every three months against consented quantity of 10 MT / month.
ETP sludge is not properly removed and stored. Used oil and oil recovered from ETP is sold to soap manufacturers/ oil reclamation units, however no records were shown to committee.
No records were shown to the committee on disposal of spent nickel catalyst. There is no proper covered shed for hazardous waste storage.
p Actions taken by APPCB during last one The APPCB has issued directions to the industry 15.02.2018, year 27.12.2018, 17.01.2020. The APPCB has forfeited Bank Guarantee of Rs.5.0 Lakhs on 17.01.2020 for non-compliance of Board directions.
Directions were again issued on 28.09.2020.
The APPCB has again forfeited Bank guarantee of Rs 10.00 lakhs on 28.09.2020 for non compliance of the Board directions.
Overall Compliance status APPCB issued directions to the unit vide order dated 15.02.2018. The unit has taken steps for improvement but partially complied with few of the directions as detailed above. But the committee observed that APPCB has not received specific complaints against the unit for discharging of effluent outside the industry premises. As per OCEMS records available with APPCB, the unit is not complying with APPCB standards for Particulate Matter. ZLD system installed. The actual water requirement of the unit is more than available water resources in the region. Since the unit is partially complying the committee calculated environmental compensation using CPCB formulaEC=PI x N x R x S x LF S.N Period of PI S LF R (Rs) N Environmental noncompliance compensation (Rs) (days) 1 17.01.2020 to 80 1.5 1 250/- 270 81,00,000/-
13.10.2020*
[10]
Total EC for violation 270 81,00,000/-
Compensation levied by APPCB from 17.01.2020 onwards 15,00,00
Net Compensation to be paid by M/s Gemini Edibles 66,00,000/-
Rupees Sixty-Six Lakhs Only
List of major non-compliances
stack emission and ambient air not complying with APPCB standards w.r.t SPM and PM 10 respectively MEE condensate and RO reject which is used for green belt development/ dust suppression is not complying with APPCB discharge standards w.r.t TDS and O&G No proper effluent conveyance system from production block to ETP VI.b Compliance Status of Emami Agrotech Limited a Name & complete address of the unit M/s Emami Agrotech Limited, Sy No.s 501, 502/1 etc., Pantapalem (V), Muthukur (M), SPSR Nellore b Contact Details Sri M.V.Narayana Murthy- Unit Head Mobile: 9677167862 c Geo-cordinates 14°15' 40.2"N 80° 04' 23.2"E d Area 29.78 acres e Status of CFO & Authorizations and its The CFO and Authorization are valid till 30.11.2021 compliance f Year of commissioning 2013 g Production capacity Refined Palm oil 1886 TPD Sunflower oil 186TPD Interesterfied oil 100 TPD Hydrogenated Oil 100 TPD Vanaspathi 200 TPD Refining of Soft Palm oil 130 TPD Palmolein 800 TPD Bakery Fat 210 TPD Palm stearine 200 TPD By Product Distilled Palm Fatty Acids 106.325TPD Distilled sunflower Fatty acids 0.5 TPD Acid Oil 14 TPD [11] h Coal and flyash storage measures The unit has constructed separate shed for storage of rice husk and coal however it was stored both inside and outside the shed. 41 TPD of ash is generated per day. The unit has installed a silo of 150 Tonnes (roughly six days storage capacity) against APPCB direction of 30 days storage capacity. Fly ash spillage was observed in the area.The fly ash is also dumped in North east side of the industry. On the day of inspection, chemical refining plant was not in operation Not complying i Source of water and quantity of water The total water requirement of the unit is 902 KLD and used per day majority (80 to 90%)of the water requirement is met from tankers. The total water consumed is not quantified by means of flow meter but however the units have maintained registers for the no. of tankers of water received. The quantity of water drawn from borewells is amounted by no. of pumping hours which is not accurate.
j Effluent generation Source Wastewater generation
Process & Washings 23.0 KLD
Acid Oil Plant 6.0 KLD
Boiler Bleed off 28.0 KLD
Cooling Tower Blow 32.0 KLD
down
RO Reject 60.0 KLD
Domestic 6.0 KLD
The quantity of the effluent collected in the ETP is not proportionate with their production and water consumption. The effluent is transferred in open drains from production block to ETP and committee observed that effluent spillage, over flow into adjoining areas. Storm water drains were filled with effluent and drains were clogged. The MEE and Sludge Centrifuge were not in operation since chemical refining was not taking place.
STP is provided for treatment of sewage.
k Installation of magnetic flow meters with Flow meters installed at inlet and outlet of ETP& STP but total totalizer water consumed is not quantified l The ETP is very poorly maintained. The aeration was not in Quantity of effluent discharged and operation. Sludge is not removed and oily sludge was mode of disposal. Components of ETP.
accumulated in all components of ETP and which results in [12] improper operation of ETP . The unit has to first scrap and remove the accumulated sludge and send it to TSDF. After sludge removal, the mixing chambers and aerators has to be repaired and ensure that ETP is properly operated. Presently, effluent from filter press is pouring down and not recycled into ETP and sludge is lying below the filter press. Periodically, the sludge is manually removed, packed in bags and stored in ETP area. The unit has not provided dedicated storage shed for storing hazardous wastes. Provision shall be made to recycle the effluent from filter press into ETP. A bin will be provided to collect the sludge from filter press. MEE condensate and RO permeate as well as RO reject is used for dust suppression and green belt development. A periphery drain carrying the effluent and storm water drain was found to join the creek at south-east corner of the unit. Though it is temporarily closed but during heavy rains, there are likely chances of effluent joining the drain. Not complying TableVI.b 1: Analysis results of samples collected by APPCB during 18.06.2020 S.No Parameter in APPCB Inlet of Outlet of MEE feed RO RO reject mg/L except standard ETP ETP permeate pH 1 pH 5.5-9.0 6.63 7.29 2.00 7.30 7.54 2 TSS 200 132 118 156 4 120 3 TDS 2100 2352 2798 11955 198 5137 4 COD 250 1960 320 7800 <10 176 5 BOD 100 627 104 2496 BDL 40 6 Oil & grease 10 13.4 10.8 15.8 BDL 12.0 The unit is using RO reject for dust suppression and green belt. From the analysis results it is found that RO reject is not meeting APPCB discharge standards and hence the unit will treat RO reject in ETP. The outlet of ETP /treated water of ETP not meeting the APPCB stipulated standards.
m Source Air pollution control device
installed
Air pollution sources and type of FBC Boiler of capacity 16 Multi cyclone dust
APCDs, status of stack, porthole, TPH collector followed by Bag
OCEMS installation, location Thermic fluid heater of filters and attached to
capacity 8.0 lakh k.cal/hr Common stack of height
(Coal or husk fired) 30m
[13]
Thermo siphon of capacity Bag filters
20 lakh k.cal/hr
Thermic fluid heater of Bag filters
capacity 6.0 lakh k.cal/hr
(Coal or husk fired)
DG sets of 1x750 KVA, Acoustic enclosures
1x1500 KVA
FBC Boiler of capacity 36 Electro-static
TPH precipitators(ESP)- 3 no. of
fields with stack height of
35 mtrs
Thermo siphon of capacity Bag filter
20 lakh k.cal/hr
TableVI.b.2: Stack monitoring at M/s Emami Agrotech Limitedby APPCB on 18.06.2020 Source SPM measured value APPCB emission standards Stack attached to 36 TPH boiler 123.5 mg/Nm3 115 mg/ Nm3 TableVI.b.3: Ambient air quality monitoring at M/s Emami Agrotech Limited by APPCB on 18.06.2020 Source PM 10 measured value APPCB standards Near the main gate within unit 125.5 µg/m3 100 µg/m3 premises The unit is not complying with stack emissions and ambient air standards. Odour problem was also observed in the industry.
n Status of installation of online stack FBC boilers are connected with continuous online PM monitoring equipment monitors and connected to APPCB servers o Status of green belt Reported that the unit has planted 7000 trees along the unit boundary but is not complying with 33% green belt. Unit shall further develop green belt in vacant spaces.
p Hazardous waste generation MEE Centrifuge salts and ETP sludge are the hazardous wastes generated from the unit. As per the production records and as per consent, the unit has to generate 30TPM of MEE- centrifuge and 8.4 tons of ETP sludge but from the hazardous waste manifest copies it is observed that the unit has despatched only 10-15 tons of hazardous waste to TSDF. This implies that either the unit is not properly operating ETP and [14] MEE&MEE Centrifuge or the hazardous waste so generated is haphazardly disposed.It was observed that sludge was lying in open in the unit premises. There is no dedicated hazardous waste storage shed.
Oil recovered from ETP is sold to soap manufacturers. q Actions taken by APPCB during last one APPCB has vide order dated 17.01.2020 issued directions for year not complying with APPCB discharge and emission standards and for exceeding the consented production in terms of chemical refining. The unit was again inspected by APPCB officials on 31.01.2020 & 04.02.2020 and found non- complying. APPCB vide order dated 20.03.2020issued directions to the unit to ensure compliance. APPCB carried out analysis and monitoring on 18.06.2020 and found non- complying. Directions were issued on 28.09.2020.The APPCB has forfeited Bank guarantee of Rs 10.00 lakhs on 28.09.2020 for non compliance of the Board directions.
Overall Compliance status APPCB issued directions to the unit vide order dated 15.02.2018. The unit has taken steps for improvement like replacement of old MEE with new MEE and installation of Centrifuge in place of ATFD which is not adequate for converting MEE concentrate in to salts. During APPCB inspections during January and February, 2020, unit was found discharging effluent into adjoining drains. Further, the unit is not complying with effluent discharge and emission standards stipulated by APPCB, with APPCB directions dated 20.03.2020, no proper effluent transfer system. Since the unit is partially complying the committee has assessed environmental compensation using CPCB formula EC=PI x N x R x S x LF S.N Period of PI S LF R (Rs) N Environmental noncompliance compensation (Rs) (days) 1 17.01.2020 to 80 1.5 1 250/- 63 18,90,000/-
20.03.2020* 2 21.03.2020 to 80 1.5 1 250/- 206 61,80,000 x 2 (for 13.10.2020 repeated violation) =1,23,60,000 3 Compensation levied by APPCB on or after 17.01.2020 10,00,000/-
Total Environmental Compensation for violation 269 1,32,50,000/-
Rupees One Crore Thirty-two lacs fifty thousand Only Major Non-Compliances [15] The unit has not achieved ZLD. Instead of MEE-ATFD the unit has installed MEE-centrifuge which is not adequate to convert MEE concentrate to salts. The unit is not complying with effluent discharge and emission standards stipulated by APPCB. No proper effluent transport system is provided, the drains are completely clogged. The effluent generated and hazardous waste generated is not matching with the production details and water consumption. Flyash is found dumped adjacent to the unit in north-eastern direction During APPCB inspections in January and February, 2020, the unit was found discharging the effluent into storm water drains located outside the industry.
VI.C. Compliance Status of M/s Adani Wilmar Limited (Unit-I) a Name & complete address of the unit M/s Adani Wilmar Limited (Unit-I) (Formerly M/s.Krishnapatnam Oils & Fats Pvt. Ltd.), Sy. No.292, 317, Pantapalem (V) (Epur 1B), Muthukur (M), SPSR Nellore Dist.
b Contact Details Sri. Vishal Jain,Unit Head
Email: [email protected] Mobile
No.: 8886060496
c Geo-cordinates 14°15' 27.14"N 80° 03' 16.38"E
d Area 14.91 acres
e Status of CFO & Authorizations and its The CFO and Authorization are valid till 31.03.2021
compliance
f Year of Commissioning 2011
g Production capacity
Refined vegetable Oils (Physical 600 TPD
Refining)
Interesterfied Vegetable Fats 100 TPD
Hydrogenated Vegetable Oils 100 TPD
Refined vegetable Oils (Chemical 200 TPD
refining)
Bakery Fat 145 TPD
By Products
Distilled Fatty Acid 45.55 TPD
[16]
h Coal and flyash storage measures taken The industry has provided shed for storage of coal with water
to control fugitive emissions sprinklers.
The unit is generating 480 TPM of flyash and unit has installed ash silo of 100MT (around seven days' storage capacity) against APPCB direction of installing silo of 30 days' storage capacity. Reported that unit is disposing the flyash on alternate day basis.
i Source of water and quantity of water The total water requirement of the unit is 260 KLD and used per day additional 4KLD is recycled from RO plant. The unit is having permission from Ground Water and Water Audit department to draw 150 KLD of ground water. But due to high salinity the unit 75% of water requirement is met from tankers. j Effluent generation The unit is generating 90 KLD of effluent. Low TDS effluent is treated in ETP of 115KL capacity comprising of Fat trap, equalisation tank, chemical dosing tank, primary settling tank, aeration, Secondary settling tank, Aeration tank2, clarifier, Tube settler and filter press. Treated effluent from ETP is further treated in RO. It is a ZLD plant.
Source Wastewater
generation
Process & washings include ( 73.0 KLD
Boiler Bleed Off, Cooling Towers blow
down, RO rejects)
Acid wash 8.0 KLD
Domestic 10.0 KLD
High TDS effluent is treated in three stage MEE-15KL capacity followed by ATFD.
Sewage is treated in septic tank followed by soak pit. Rainwater harvesting pits and Summer storage tank is available. Summer storage tank capacity is 180MT k Installation of magnetic flow meters with Flow meters installed at inlet and outlet of ETP and MEE feed totalizer tank. Flow meter is not installed to quantify raw water consumption.
Table VI.C 1: Analysis results of samples collected by APPCB during 23.06.2020 [17] S.No Parameter APPCB Inlet of Outlet of MEE MEE MEE RO RO in mg/L standard ETP ETP feed condens concentr permeat reject except pH ate ate e 1 pH 5.5-9.0 6.42 7.22 5.56 4.09 5.94 6.5 7.69 2 TSS 200 200 122 136 12 200 20 120 3 TDS 2100 2642 1380 28925 208 38051 740 4990 4 COD 250 1712 260 34000 24 67200 32 112 5 BOD 100 420 60 8500 2.6 16800 52 28 6 Oil & 10 20.2 16.4 28.2 BDL 20 BDL BDL grease MEE condensate is not complying with discharge limits stipulated by APPCB for pH. The unit shall neutralize the MEE condensate before discharging.
RO reject is not complying with APPCB discharge limits for TDS. RO reject shall be treated in MEE before discharging. RO permeate is complying with standards. From the analysis results it is found that RO reject is not meeting APPCB discharge standards and hence the unit will treat RO reject in ETP.
l Boiler of capacity 1 x 16 TPH
Mechanical dust
collectors fol.by bag
Boiler of capacity 1 x 12.0 TPH
filters
Air pollution sources and type of Thermic Fluid Heater 2 x 6 Dust collectors
APCDs, status of stack, porthole, Lakh. K.Cal/ hour & 1 x 10
OCEMS installation, location Lakh. K. Cal/hour
Thermo siphon of capacity 4
lakh k.cal/hr
DG sets of 1x1250 KVA, 2x625 Acoustic enclosure
KVA
Table VI.C.2: Stack monitoring by APPCB on 23.06.2020 Source SPM measured value APPCB emission standards 3 Stack attached to 36 TPH boiler 101.8 mg/Nm 115 mg/ Nm3 Table VI.C3: Ambient air quality monitoring at M/s, Adani Wilmar Limited (Unit-I) by APPCB on 23.06.2020 Source PM10measured value APPCB standards 3 Near the main gate within unit 95.5 µg/m 100 µg/m3 premises [18] The unit is complying with stack emissions and ambient air standards. m Status of installation of online stack Stack attached to boiler is provided with continuous online PM monitoring equipment monitors and connected to APPCB servers n Status of green belt The unit has developed green belt in around 4acres of land. o Hazardous waste generation MEE salts (0.2 TPD) and ETP sludge (0.4 TPD) are the hazardous wastes generated from the unit and it is stored in 40 MT covered shed and it is disposed to TSDF p Actions taken by APPCB during last one APPCB has vide order dated 17.01.2020 issued directions for year not complying with APPCB discharge and emission standards.
The unit was again inspected by APPCB officials on 27.07.2020 and found non-complying. Directions were issued on 28.09.2020.The APPCB has forfeited Bank guarantee of Rs 7.50 lakhs on 28.09.2020 for non compliance of the Board directions.
Overall Compliance status:
As compared to other units in the region, M/s Adani Wilmar Unit-I has implemented lot of corrective measures. There were proper effluent transfer system, Emissions are complying with APPCB norms. Major non-compliances observed in the unit are MEE condensate is not meeting the APPCB stipulated standards w.r.t pH. The unit shall be directed to check for pH and neutralize the effluent before final discharge. Illegal drawal of ground water through tankers from outside agencies. Not provided ash silo for 30 days storage capacity VI.d. Compliance Status of M/s. Adani Wilmar -(Unit-II) a Name & complete address of the unit M/s. Adani Wilmar -(Unit-II) Previously M/s. Louis Dreyfus Commodities India Pvt. Ltd., Sy. No.1601, Epuru Bit-1B, APIIC, Pantapalem (V), Muthukur (M), SPSR Nellore Dist b Contact Details Sri G. Sreenivasulu, Plant Head +91- 9444398011 [email protected] c Geo-cordinates 14°15' 20"N 80° 04' 25.9"E d Area 15.58 acres e Status of CFO & Authorizations and its The CFO and Authorization are valid till 29.02.2024 compliance f Year of Commissioning 2011 g Production capacity S.N Products Quantity 01 Physical Refining Refined Vegetable 600 TPD Oil (Palm Oil, Palmolein, Palm Stearin) [19] 02 Chemical Refining Refined Vegetable 200 TPD Oil (Soya bean Oil, Sunflower Oil, Groundnut Oil, Rice Bran Oil, Cotton Seed Oil, Mustard Oil, Rapeseed Oil, Sesame Oil) 02 Fractionated Vegetable Oil 800 TPD 03 Interesterified Vegetable Oil 150.0 TPD 04 Vanaspathi 150.0 TPD Co-Product 1 Palmstearin 167.0 TPD By-products 1 Distilled Fatty Acids (Physical 48.0 TPD refining) (Palm Oil, Palm kernel, Palmolein) 2 Distilled Fatty Acids (Chemical 0.8 TPD refining) (Soya bean Oil, Sunflower Oil, Groundnut Oil, Rice Bran Oil, Cotton Seed Oil, Mustard Oil, Rapeseed Oil, Sesame Oil) 3 Acid Oil 4.0 TPD 4 Soap Stock 4.0 TPD 5 Acid Sludge 0.6 TPD 6 Gums 9.0 TPD h Coal and flyash storage The unit is generating 940 TPM of flyash and unit has installed silo of 40 tonnes (roughly around Two days storage) against APPCB direction of 30 days storage capacity storage capacity.
Lot of Fly ash spillage was observed in the area. Reported that unit is disposing flyash on alternate days. The unit should have had minimum of 10 days storage capacity.
i Source of water and quantity of water Source Water
used per day consumption
Floor washings,plant washings from 15.0 KLD
physical refining process, inter-
esterfied fats, vanaspathi unit
Chemical refining Manufacturing 25.0 KLD
Process
[20]
Washings in chemical refining (Acid 30.0 KLD
Oil Wash)
DM/ Softener 5.0 KLD
Boiler R.O. (Fresh water for Boiler 275.0 KLD
feed-210 KLD)
Cooling towers (Non contaminated) 70.0 KLD
Cooling towers (contaminated) 60.0 KLD
Gardening 30.0 KLD
Domestic 20.0 KLD
Total 530
Though the unit has obtained permission to withdraw 380 KL of ground water but 75% of the water requirement is met from tankers.
j Effluent generation Process & Washings physical and 100.0 KLD chemicals, Cooling tower, Boiler blow down Feed water RO Reject & DM/ Softener 70.0 KLD back wash Acid Oil Wash 30.0 KLD Domestic 15.0 KLD The unit has installed an ETP of 200 KLD capacity followed by RO plant of 10 KLH capacity for treatment of LTDS. HTDS effluent is treated in three stage three stage MEE -60 KLD followed by ATFD to meet ZLD system but ATFD is completely worn out and is not in operation. Sewage is treated in Septic tanks followed by soak pits. But it was observed that ETP is not properly maintained. ETP sludge is stored in the ETP section in open and leachate was flowing. ETP comprises of Fat Trap, Equalization tank, Chemical Dosing tank, Primary Clarifier, Collection tank, Aeration tank, Secondary Clarifier, secondary Collection tank, Filter Press (2No.). Effluent carrying drains were clogged.
Unit has constructed rainwater harvesting pits and summer storage tank of 1600 KL capacity.
k Installation of magnetic flow meters with Flow meters with totalizers at ETP inlet, Primary clarifier totalizer outlet, RO inlet, RO outlet, MEE outlet. Table VI.d 1: Analysis results of samples collected by APPCB during 18.06.2020 [21] S.No Parameter in APPCB Inlet of Outlet of MEE MEE MEE mg/L except standard ETP ETP feed condensate concentrate pH 1 pH 5.5-9.0 5.27 7.64 7.13 8.08 6.24 2 TSS 200 186 122 206 4 180 3 TDS 2100 4279 2516 5100 80 22840 4 COD 250 772 360 404 BDL 58020 5 BOD 100 290 114 136 BDL 14876 6 Oil & grease 10 18.2 12.6 15 BDL 158 On the day of APPCB inspection RO was not in operation and treated effluent was directly discharged without treating in RO. The outlet of ETP /treated water of ETP not meeting the APPCB stipulated standards l Air pollution source Air pollution control device provided FBC Boiler of capacity 20.0 TPH Multi cyclone dust collector followed by Bag filters Thermic fluid heaters of capacity Chimney to disperser 5.0 lakh k.cal/hr, 12.5 lakh the flue gases Air pollution sources and type of k.cal/hr & 6.0 lakh K.cal/hr ; APCDs, status of stack, porthole, OCEMS installation, location FBC boiler of Capacity 7.0 TPH Dust Collector & Bag filter Thermo Syphon 1x15 Lakh.k.cal Mechanical dust collectors fol.by bag filters DG sets of 1x1010 KVA, Acoustic enclosure 1x1250KVA The unit has installed online emission monitor system to measure SPM and is connected to APPCB server.
TableVI.d.2: Stack monitoring at by APPCB on 30.06.2020 Source SPM measured value APPCB emission standards Stack attached to 7 TPH boiler 85.5 mg/Nm3 115 mg/ Nm3 TableVI.d.3: Ambient air quality monitoring by APPCB on 30.06.2020 Source PM10 measured value APPCB standards [22] Near the main gate within unit 90.5 µg/m3 100 µg/m3 premises The unit is complying with stack emissions and ambient air standards. Odour problem was observed in the industry.
m Status of installation of online stack FBC boilers are connected with continuous online SPM monitoring equipment monitors and connected to APPCB servers n Status of green belt Unit has planted trees in vacant spaces and along roads in the unit. The unit has developed green belt to an extent 3.5 to 4.0 acres against APPCB requirement of 5 acres (33%) o Hazardous waste generation 5.5 TPD of ATFD salts and ETP sludge are the hazardous wastes generated from the unit. Though there is separate shed but hazardous waste was found lying in ETP area. Oil recovered from ETP is sold to soap manufacturers. Spent earth is disposed to incense sticks manufacturers p Actions taken by APPCB during last one APPCB has vide order dated 17.01.2020 issued directions for year not complying with APPCB discharge and emission standards.
The unit was again inspected by APPCB officials on 28.07.2020 and found non-complying. Directions were issued on 28.09.2020.The APPCB has forfeited Bank guarantee of Rs 7.50 lakhs on 28.09.2020 for non compliance of the Board directions.
Overall Compliance status APPCB issued directions to the unit vide order dated 15.02.2018. Further, the unit is not complying with APPCB directions dated 17.01.2020, no proper effluent transfer system, effluent clogging in drains, flyash and hazardous waste spillage, flyash silo of storage capacity of Two days against requirement of 30 days. Since the unit is partially complying the committee has assessed environmental compensation using CPCB formula EC=PI x N x R x S x LF S.N Period of PI S LF R (Rs) N Environmental noncompliance compensation (Rs) (days) 1 17.01.2020 to 80 1.5 1 250/- 271 81,30,000/-
14.10.2020
EC for violation 271 81,30,000/-
EC levied by APPCB after 17.01.2020 7,50,000/-
Total EC to be paid by unit 73,80,000/-
Rupees Seventy-Three lacs and Eighty thousand Only [23] VI.E Compliance Status of M/s South India Krishna Oil & Fats Pvt.Ltd a Name & complete address of the unit M/s.South India Krishna Oil & Fats Pvt.Ltd., Sy.No.275,279,280 & 281,Epuru Bit - 1B, Pantapalem (V), Muthukur (M), SPSR Nellore Dist b Contact Details Sri B. Muthu Krishnan, GM +91-7799800065 [email protected] c Geo-cordinates 14°15' 19.7"N 80° 02' 50"E d Area 16.12 acres e Status of CFO & Authorizations and its The CFO and Authorization are valid till 31.03.2022 compliance f Year of Commissioning 2014 g Production capacity Refined Oil (Physical Refining) 1000 TPD RBDPalmolein 800 TPD TBD Stearine 200 TPD Vanaspathi 200 TPD Palm Powder 72 TPD Palm Flakes 50 TPD By Product Distilled Fatty Acid (Physical 42 TPD Refining) Refined Vegetable Oil 192 TPD (Soyabean,Sunflower,Round Nut, Ricebean, Cotton Seed, Mustarad, Rape Seed by Chemical Refining) By Product Distilled Fatty Acid (Chemical 0.488 TPD Refining) Acid Oil 4.0 TPD Soap Stock 8.0 TPD Wax 2.05 TPD g Coal and flyash storage Unit is generating 14 TPD of flyash and is equipped with ash pneumatic conveying system for conveying ash from different points to ash silos and ash shed to avoid the ash escaping into the air.
Ash storage yard having a capacity of 30 days including silo & [24] closed storage shed. Lot of fugitive dust is emitted while loading from storage shed into trucks.
h Source of water and quantity of water
used per day Source of water Consumption in
KLD
Process & washings (physical & 21.0 KLD
chemical)
Cooling Make up 319.0 KLD
Boiler 586.0 KLD
Domestic 23.0 KLD
Total 949 KLD
Though the unit has obtained permission to withdraw 360 KL of ground water but entire water requirement of 949 KLD is met from tankers.
i Effluent generation
Source Effluent generation
Trade effluents ( Boiler &
Cooling tower blow down,
136.0 KLD
Process, Primary dual RO, back
wash)
HTDS effluents from Acid plant
53.0 KLD
and dual RO rejects
Primary RO rejects
93.0 KLD
Domestic 16.0 KLD
ETP of 300 KLD & Dual RO Plant, MEE of 18 KLD followed by ATFD provided to meet ZLD . STP of 20 KLD provided for domestic purposes. ETP comprises of Collection tank, Oil & grease trap, Equalization tank, Primary clarifier, Aeration tank 1 & 2, buffer tank, Secondary clarifier, Sludge drying beds & Filter Press, Pressure Sand filter, activated carbon filter etc. The effluent is transferred in drain which is completely clogged. Thick oily scum is accumulated on the surface of aeration and clarification tank. Aerator was not working. Effluent and oil spillage in production block and ETP section. The unit has not installed rain water harvesting pits.
[25]Table VI.e 1: Analysis results of samples collected by APPCB during 18.06.2020 S.No Parameter in APPCB Inlet of Outlet of MEE feed MEE MEE mg/L except standard ETP ETP condensate concentrat pH e 1 pH 5.5-9.0 6.99 7.02 4.89 6.99 5.62 2 TSS 200 132 86 156 12 145 3 TDS 2100 2982 1874 32669 128 36278 4 COD 250 456 216 90800 72 38000 5 BOD 100 146 68 29056 16 12160 6 Oil & grease 10 12.4 6.2 16.5 --- 17.0 From the analysis results it is evident that MEE is not properly operated, the concentration of COD and BOD is high in MEE feed rather than in MEE concentrate. There is only slight variation in TDS concentration in MEE feed and concentrate.
j Installation of magnetic flow meters with Flow meters with totalizers at ETP inlet, Primary clarifier totalizer outlet, RO inlet, RO outlet, ATFD inlet, MEE outlet. k Boiler of capacity 1x24 TPH Mechanical dust collectors fol.by bag filters Boiler of capacity 1x15.0 TPH Thermo Syphon 1x20 Air pollution sources and type of Lakh.k.cal.
APCDs, status of stack, porthole,
Thermic Fuel Heater 2x6 Lakh. Mechanical dust
OCEMS installation, location
K.cal/hour collectors fol.by bag
filters
4x750 KVA D.G. Sets Acousic enclosures
The unit has installed online emission monitors to measure SPM and is connected to APPCB server.
Table: Stack monitoring by APPCB on 16.06.2020. Source SPM measured value APPCB emission standards Stack attached to 16 TPH boiler 105.8 mg/Nm3 115 mg/ Nm3 Table: Ambient air quality monitoring by APPCB on 16.06.2020 Source PM10 measured value APPCB standards [26] Near the main gate within unit 89.5 µg/m3 100 µg/m3 premises The unit is complying with stack emissions and ambient air standards. Odour problem was observed in the industry.
l Status of installation of online stack OCEMS installed in both the chimnies attached to Boiler -24 monitoring equipment TPH & common chimney provided to 15 & 16 TPH boilers which is connected to APPCB Server.
m Status of green belt Unit has planted trees in vacant spaces and along roads in the unit. The unit has developed green belt to an extent 3.5 acres against APPCB requirement of 5 acres (33%). The unit has developed 1.0 Acre of green belt towards South Side outside of the industry.
n Hazardous waste generation 0.6 TPD of ATFD salts and 0.037 TPD of ETP sludge are the hazardous wastes generated from the unit. Though there is separate shed but hazardous waste was found lying in ETP area.
Oil recovered from ETP is sold to soap manufacturers. Spent earth is disposed to incense sticks manufacturers o Actions taken by APPCB during last one APPCB has vide order dated 17.01.2020 issued directions for year not complying with APPCB discharge standards. The unit was again inspected by APPCB officials on 28.07.2020 and found non-complying. Directions were issued on 28.09.2020.The APPCB has forfeited Bank guarantee of Rs 10.0 lakhs on 28.09.2020 for non compliance of the Board directions. Overall Compliance status APPCB issued directions to the unit vide order dated 15.02.2018. The unit has taken steps for improvement like compliance of stack, AAQ and ETP discharge standards. MEE shall be operated properly Further, the unit is not complying with APPCB directions, no proper effluent transfer system, effluent clogging in drains, flyash and hazardous waste spillage, flyash silo of storage capacity of Five days against requirement of 30 days. Since the unit is partially complying the committee has assessed environmental compensation using CPCB formula EC=PI x N x R x S x LF S.N Period of PI S LF R (Rs) N Environmental noncompliance compensation (Rs) (days) 1 17.01.2020 to 80 1.5 1 250/- 271 81,30,000/-
14.10.2020
[27]
EC for violation 271 81,30,000/-
EC levied by APPCB on or after 17.01.2020 10,00,000/-
Total EC to be paid by the unit to APPCB 71,30,000/-
Rupees Seventy- One lacs and thirty thousand Only VI.F Compliance Status of M/s. Santhoshimatha Oils and Fats Private Limited a Name & complete address of the unit M/s. Santhoshimatha Oils and Fats Private Limited, Sy.No.252, Epuru Bit-IB, Pantapalem Village, Muthukur Mandal, SPSR Nellore District b Contact Details Sh. Ganesh Vidhun Kota [email protected] 9963329792 c Geo-cordinates 14°15' 18.1"N 80° 02' 39.1"E d Area 5.52 acres e Status of CFO & Authorizations and its The CFO and Authorization are valid till 31.01.2022 compliance f Year of Commissioning 2016 g Production capacity Refined Palm oil 225 TPD By product Distilled Fatty Acids 15 TPD h Coal and flyash storage Unit is generating 8 TPD of flyash and has installed ash silo of 30 tonnes(4- 5 days storage capacity). In addition a covered shed is provided for flyash storage.
i Source of water and quantity of water Source Water consumption
used per day Process & Wash 12 KLD
Boiler Feed & Cooling 70 KLD
Tower Make up
Domestic 8.0 KLD
Total 90 KLD
The unit has obtained permission from Ground Water and Water Audit Department, Government of Andhra Pradesh vide order dated 01.10.2020 to draw 70 KLD of ground water.
[28]Previously the water requirement was met through tankers. As per the Ground water report the quality of ground water is moderate saline in nature. The water is procured through tankers.
j Effluent generation
Trade effluents 20 KLD
Domestic 5.0 KLD
The unit is involved in only physical refining and only LTDS effluent is generated. The effluent is treated in ETP of 50 KLD followed by RO Plant. ETP comprises of bar screens, oil & grease trap, equalization cum neutralization tank, aeration tank, primary clarifier, aeration tank, secondary clarifier, sand filter, carbon filter, sludge drying beds. ETP outlet is treated in RO plant of 5m3/hr capacity. The treated effluent is utilized for green belt development and RO reject is used for ash quenching.
TableVI.f 1: Analysis results of samples collected by APPCB during 19.06.2020 S.No Parameter in APPCB Inlet of Outlet of RO feed RO RO reject mg/L except standard ETP ETP permeate pH 1 pH 5.5-9.0 4.94 6.69 7.56 7.11 7.28 2 TSS 200 183 150 160 140 120 3 TDS 2100 4506 2844 1310 521 3460 4 COD 250 860 320 104 20 96 5 BOD 100 326 112 22 2.8 15 6 Oil & grease 10 22.4 18.3 40 BDL BDL The unit is not complying with effluent discharge standards with respect to TDS, COD, BOD and Oil & Grease. The RO reject is having TDS higher than the APPCB discharge limits and hence RO reject shall be recycled back to ETP for treatment.
k Installation of magnetic flow meters with Flow meters with totalizers at inlet and outlet of ETP
totalizer
l Boiler of 8.0 TPH Mechanical dust
Air pollution sources and type of
collectors fol.by bag
APCDs, status of stack, porthole,
Thermic Fluid Heater -15 filters
OCEMS installation, location
Lakh. K.cal/hr
[29]
DG sets of 1x750 KVA, 1x125 Accoustic enclosures
KVA
Table VIf 2: Stack monitoring at by APPCB on 16.06.2020 Source SPM measured value APPCB emission standards Stack attached to 8TPH & boiler 92.5 mg/ Nm3 115 mg/ Nm3 Table VI f 3: Ambient air quality monitoring by APPCB on 16.06.2020 Source PM10 measured value APPCB emission standards Near the main gate within unit 118.5 µg/m 3 100 µg/m3 premises The unit is not complying with ambient air standards. M Status of installation of online stack The industry has installed small boiler of 8.0 TPH , hence not monitoring equipment installed Online Stack monitoring. n Status of green belt Unit has planted trees in vacant spaces and along roads in an extent of 1.4 Acres. But unit is yet to develop green belt in 0.4 acres of land to meet 33%.of Green belt area.
o Actions taken by APPCB during last one APPCB vide order dated 17.01.2020 issued directions for not year complying with APPCB discharge and emission standards. The unit was again inspected by APPCB officials on 28.07.2020 and found non-complying. Directions were issued on 28.09.2020.The APPCB has forfeited Bank guarantee of Rs 5.0 lakhs on 28.09.2020 for non compliance of the Board directions.
p Overall Compliance status The industry is not a respondent in the hon'ble NGT OA No 221/2015 as the industry was not established at that time. But as it is located in the cluster at present, the APPCB issued directions to the unit vide order dated 15.02.2018. This is small scale edible oil refinery unit operating with only physical refinery section with 225 TPD capacity.
The unit has taken steps for improvements. Further, the unit is not complying with APPCB directions, flyash silo of storage capacity of Four days against requirement of 30 days, not meeting the effluent discharge standard and ambient air quality.
VI. G Compliance Status of M/s. 3F Industries Limited a Name & complete address of the unit M/s. 3F Industries Limited (Formerly Foods fats & Fertilizers Ltd.,) Sy.No. 1604, APIIC- IALA, EPURU 1-B Pantapalem (V) Muthukuru (M) SPSR Nellore Dist.
b Contact Details P. Srinivasa Rao, Plant Manager [30] 91-9642225502 [email protected] c Geo-cordinates 14°15' 28.8"N 80° 04' 09.4"E d Area 11.62 acres
e Status of CFO & Authorizations and its The CFO and Authorization are valid till 31.03.2022 compliance f Year of Commissioning 2011.
g Production capacity Refined Edible Oils 670.166 TPD
(Physical Refining)
Refined Edible Oils (Chemical 100 TPD
Refining)
Vanaspathi & Bakery Shortenings 90 TPD
Margerine 30 TPD
Fatty Acids 200 TPD
Toilet Soap Noodles 50 TPD
BY PRODUCT
Fatty Acids 27.74 TPD
Glycerine 18 TPD
Pitch Oils 7 TPD
Filter Cake/ Spent Earth 1.22 TPD
Fatty acids/ Acid Oils 3.35 TPD
h Coal and flyash storage Unit is generating 27 TPD of flyash. Unit has provided ash
silo of 60 Tonnes capacity which is sufficient for ash storage for 2 days against APPCB direction of 30 days storage.
i Source of water and quantity of water Source Water consumption
used per day Process & Washings 50.0 KLD
Boiler make up & Cooling 360 KLD
tower make up
RO reject water (used for 253 KLD
cooling tower makeup)
Total 663 KLD
Entire water requirement of 663 KLD is met from Tankers.
j Effluent generation Source Quantity of
effluent
Process & Washings Boiler blow down, 152 KLD
Cooling tower bleed off, Acid Oil plant
waste water
Fresh Water RO rejects 110 KLD
[31]
Domestic 15 KLD
ETP of 200 KLD & RO plant , MEE-100 KLD provided with ATFD to meet ZLD system. Septic tanks followed by soak pits are provided for treatment of domestic effluents. On the day of inspection, it was observed that the ETP was not in operation. Thick Sludge was deposited in ETP section. The oil was spilled all over the plant. MEE and ATFD were not properly operated. The pumps were not working and effluent was leaking. There was no proper effluent transfer system from production block to ETP. There were lot of temporary arrangements.
TableVI.g 1: Analysis results of samples collected by APPCB during 23.06.2020 S.No Parameter APPCB Inlet of Outlet of MEE feed Ro feed RO RO reject in mg/L standard ETP ETP permeate except pH 1 pH 5.5-9.0 5.34 6.85 7.92 7.53 7.09 5.74 2 TSS 200 160 90 204 76 54 4 3 TDS 2100 3772 1248 5826 1248 3134 430 4 COD 250 1580 232 3580 128 368 12 5 BOD 100 410 68 1124 40 106 1.8 6 Oil & 10 22.4 9.0 20.8 1.8 1.2 BDL grease The Outlet of ETP is meeting the Board stipulated standards.The MEE is not in operation during the Board officials inspection and sample collection. ON the day of committee inspection MEE was not in operation.
K Installation of magnetic flow meters with Flow meters with totalizers at ETP inlet, MEE inlet and outlet
totalizer
L Boiler of capacity 1x35 TPH ESP
Boiler of capacity 1x2.0 TPH Bag filters
Boiler of capacity 1x8 TPH; Fuel: Bag filters
Coal/Husk
Thermo Fluid heater of capacity
Air pollution sources and type of
1x20.0 Lakh.k.cal/hr; Fuel: Bag filters
APCDs, status of stack, porthole,
Coal/Husk
OCEMS installation, location
Thermo Fluid heater of capacity
Bag filters
1x40 Lakh.k.cal/hr;Fuel: Coal/Husk
Thermic Fluid heater of capacity Dust collectors
1x6 Lakh.k.cal/hour;Fuel :
Coal/Husk
[32]
Coal Mill of capacity 10 TPH Bag filters
DG sets of 3x750 KVA Acoustic enclosure
The unit has installed online emission monitors to measure SPM and is connected to APPCB server.
Table VIg 2: Stack monitoring at by APPCB on 23.06.2020 Source SPM measured value APPCB emission standards Stack attached to 35TPH boiler 133.5 mg/Nm3 115 mg/Nm3 Table VI g 3: Ambient air quality monitoring by APPCB on 23.06.2020 Source PM10 measured value APPCB emission standards Near the main gate within unit 138.6 µg/m3 100 µg/m3 premises The unit is not complying with stack emissions and ambient air standards. Odour problem was also observed in the industry.
M Status of installation of online stack OCEMS installed in the stack connected to 35 TPH boiler and monitoring equipment connected to APPCB Server. N Status of green belt The plantation is very sparse and is not complying with 33% of green belt.
O Hazardous waste generation The unit is generating 1TPD of MEE salts and 0.034 TPD of ETP sludge. The quantity of sludge generated is very less and sludge is not properly disposed.
P Actions taken by APPCB during last one APPCB has vide order dated 16.02.2018 issued certain year directions to the industry and forfeited Bank Guarantee of Rs.5.0 Lakhs for non-compliance of the directions. The APPCB has again issued modified directions on 17.01.2020 for not complying with APPCB discharge and emission standards. The unit was again inspected by APPCB officials on 28.07.2020 and found non-complying. Directions were issued on 28.09.2020.The APPCB has forfeited Bank guarantee of Rs 10.0 lakhs on 28.09.2020 for non compliance of the Board directions.
Overall Compliance status The committee observed major violations in the unit w.r.t effluent handling and treatment and sludge disposal. ETP was accumulated with sludge. The unit is not complying with emission monitoring, ambient air quality. The industry has constructed and commissioned hydrogenated stearine and stearine beads manufacturing plant inside the existing industry without obtaining consent for establishment and consent for operation of the APPCB. Since the unit is partially complying the committee has assessed environmental compensation using CPCB formula EC=PI x N x R x S x LF S.N Period of PI S LF R (Rs) N Environmental noncompliance (days) compensation (Rs) [33] 1 17.01.2020 to 80 1.5 1 250/- 255 76,50,000/-
28.09.2020
2 29.09.2020 to 80 1.5 1 250/- 15 4,50,000/- * 2 for
14.10.2020 repeated violation
Total EC for violation 271 85,50,000/-
EC levied by APPCB on or after 17.01.2020 10,00,000/-
EC to be paid by unit to APPCB 75,50,000/-
Rupees Seventy- Five lacs and Fifty thousand Only VII Actions taken by APPCB
1. The APPCB is continuously reviewing the status of air pollution/ water pollution control equipments provided and compliance of the APPCB standards etc for control of pollution problems from the edible oil industries operating at Krishnapatnam port area from last Five years in connection with the O.A. NO.221 of 2015 filed before the Hon'ble NGT.
2. The status of industries with regards to compliance of the directions are reviewing before External Advisory Committee meetings held at Board office, APPCB and issuing directions time to time. It is to submit that the status of implementation of action plan by the edible oil units was reviewed before Task Force Committee at Board Office during its meetings held on 25.06.2016, 15.07.2016, 05.08.2016, 27.08.2016, 16.09.2016, 30.09.2016, 11.11.2016, 03.12.2016, 30.12.2016, 20.01.2017, 04.02.2017 & 09.11.2017.
3. The board has issued directions to the Edible oil industries on 15.02.2018, 17.01.2020 & 28.09.2020.
4. The APPCB has also forfeited Bank Guarantee amount of Rs.65 Lakhs in the year 2020 from the above 7 nos of Edible oil industries for non compliance of the APPCB directions.
VIII Overall Observations
1. Presently all edible oil units were operational but on the day of committee inspection ponly physical refining of palm oil was in operation.
2. The units have made improvements, augmentation of ETP and air pollution control devices. The units have installed facilities like ETP followed by RO, MEE & ATFD to achieve " Zero Liquid Discharge" but there are no proper effluent transport system. But units are yet to achieve 100% compliance to consent conditions of APPCB.All units shall make improvements in drains/ pipelines used for transporting [34] effluent from production block to ETP. The units shall ensure that storm water is not mixed with effluent.
3. The flyash generated from the units is sold to brick manufacturers. The units have provided ash silo and covered shed for storage of flyash. But the units are not complying with APPCB condition of 30 days silo capacity. The units represented to the unit that installation of such large silo is difficult. The flyash is sold to brick manufacturers at frequency of two to three days in a week. Since the condition was imposed by APPCB, the committee suggests APPCB to review the condition.
4. APPCB is continuous vigil on the edible oil units and issued directions, forfeited bank guarantees due to which no discharge of effluent outside the unit premises was observed during committee inspection.
5. Based on CPCB formula the committee has assessed environmental compensation on the the erring units for violating the directions issued by APPCB vide order dated 17.01.2020.
6. Fly ash is being dumped in the North-Eastern Direction of M/s Emami Agrotech Ltd in public lands adjacent to M/s Gemini Edible and M/s Emami Agrotech. The land does not belong to any edible oil unit, and none of the industry are ready to take responsibility for removing the flyash. Since the flyash is dumped in land adjacent to M/s Emami and M/s Gemini, both of these industries as part of CSR activity will take complete responsibility to remove the dumped flyash and send it to brick manufacturers.
7. The committee submits to Honble NGT that the units shall carry out performance evaluation of ETP and ZLD system. Based on the TDS concentration in RO reject, the unit shall either treat RO reject in ETP or MEE. (If TDS> 5000mg/l in RO reject, it may be treated in MEE or else in ETP). The units in any case shall not discharge the RO reject without further treatment.
IX Conclusions
1. Construction of CETP: Previously all the units had proposed for construction of common effluent treatment plant but the district administration and the units could not find a suitable land for construction of CETP. Currently all seven units have established their individual effluent treatment plants and hence the proposal of CETP is shelved.
2. As per the Ground Water and Water Audit Department, Government of Andhra Pradesh, the ground water in the region is saline in nature due to sea water intrusion. The units have to treat the ground water in RO system for use for domestic and industrial purpose. Due to high salinity there are high chances of frequent clogging of RO membranes. In addition, the available ground water resources are not sufficient to meet the industrial water requirements. Considering [35] this the committee recommends that all edible oil units in Krishnapatnam Port area to install common desalination plant thereby sea water may be drawn, treated and to be used by all edible oil industries by requesting the management of the Krishnapatnam port Ltd who is nodal agency for importing the crude edible oil on behalf of the edible oil industries management. Thereby withdrawal of ground water and procurement of water from tankers will be avoided. The units shall install desalination plant within a period of one year and entire water requirement has to be met from desalination only. The units shall install electromagnetic flow meters with totalizer to quantify the water consumption.
3. The units have not disposed spent nickel catalyst to authorized re-processors stating that the small quantity of waste is generated. The committee submits to Hon'ble NGT to instruct APPCB to direct APPCB to safely store the spent nickel catalyst and to dispose the same to authorized re-processors. The units shall be directed to comply with Hazardous Waste Rules, 2016 and shall dispose the hazardous wastes as directed in the consent within 90 days period.
4. During the inspection, the committee did not observe any discharge of effluent into the Budhakaluva drain, Pantapalem irrigation channel or into land outside the industry premises. But however, in all the units except M/s Adani Wilmar unit-I, there is no proper effluent conveyance system/ pipelines to transfer effluent from production blocks to effluent treatment plant. The committee observed that open drains were used for effluent transfer and during rains, effluent and rain water may overflow into the peripheral drains (drains are provided all along the boundary of the units to collect the effluent). The units informed that during rains, water/effluent is taken to ETP from peripheral drains and no effluent is let out of the unit. The units shall be directed to close the peripheral drains at the exit point near unit boundary. The drains used for transfer of effluents from production block to ETP are clogged, thick oily scum is floating on top and sludge is settled at bottom of drains. Under these circumstances very little effluent may be transferred to ETP and effluent may overflow into area/ soil adjacent to the drains. The committee submits to Hon'ble NGT to instruct APPCB to direct the industries to establish proper effluent pipelines within a period of two months of adequate size to transfer effluent from production block to ETP and for utilization of treated effluent. The pipelines shall be periodically cleaned and cleaning water shall be routed to ETP to prevent any clogging. The status of cleaning shall be submitted to APPCB while submitting compliance reports.
5. The units shall maintain proper records for fullers earth (bye-product) generated and oil recovered from the ETP and its mode of its disposal. Though all units [36] informed that the same were disposed for incense sticks manufacturer and soap industries, however no records were shown to committee.
6. The units are importing crude palm oil and sunflower oil from Malaysia, Singapore and Indonesia. The Port Authorities are testing the crude oil for presence of any mineral oil and after ensuring that no mineral oil is present, the consignment is handed to the units. While verifying the documents, the committee observed that the quantity of the imported crude is around 60% to 70% of the unit production. The units are locally procuring crude oil from other industries (it was reported that these industries purchase palm and sunflower from farmers and extract crude and sell to edible oil refineries in Krishnapatnam). The crude that is locally purchased is not tested for the presence of mineral oil content or Hydrocarbons. The committee humbly submits to Hon'ble NGT that the units have to carry out mineral oil test with every batch of consignment locally procured also. These reports have to be submitted to APPCB along with their compliance report.
7. The flyash generated from the industries are sold to brick manufacturers. APPCB directed the units to install flyash silo of 30 day storage capacity with an objective that during rainy season, if the ash is not taken by the brick manufacturers on a daily or weekly basis, the ash could be safely stored in silo for a period of atleast 30 days and from silo it can be transferred directly into trucks. But all seven units have not complied with this condition and have installed a silo of capacity handling flyash for period varying from seven to ten days. Further it was informed to the committee that the units are disposing the flyash on alternate days and is not stored in the unit beyond a week. The committee submits to Hon'ble NGT to direct APPCB to hold a meeting with edible oil units, brick manufacturers, flyash transporters and any other flyash users and review the direction. Fly ash is being dumped in the North-Eastern Direction of M/s Emami Agrotech Ltd in public lands adjacent to M/s Gemini Edible and M/s Emami Agrotech. The land does not belong to any edible oil unit, and none of the industry are ready to take responsibility for removing the flyash. Since the flyash is dumped in land adjacent to M/s Emami and M/s Gemini, both of these industries as part of CSR activity will take complete responsibility to remove the dumped flyash and send it to brick manufacturers.
8. The units have not made proper arrangements for flyash storage and loading into the trucks. It was observed during inspection that lot fugitive dust was emitted during loading operations. The units shall ensure wetting or water spraying at the time of loading of flyash and also the feeding hopper is covered.
[37]9. The committee has assessed environmental compensation for serious violationand for not meeting conditions stipulated in the consent. The units shall pay Environmental Compensation to APPCB as summarized below:
Sl. No Name of the Unit Environmental
Compensation to
be paid by the unit
to APPCB in INR
1 M/s Gemini Edibles & Fats India Pvt Ltd 66,00,000/-
2 M/s Emami Agrotech Limited 1,32,50,000/-
3 M/s. Adani Wilmar -(Unit-II) 73,80,000/-
4 M/s.South India Krishna Oil & Fats Pvt.Ltd 71,30,000/-
5 M/s. 3F Industries Limited (Formerly Foods fats & 75,50,000/-
Fertilizers Ltd.,)
10. The units have provided online emission monitoring system to measure PM10. The porthole provided for manual monitoring are utilized by the units to install online dust monitors. The Committee submits that Hon'ble NGT instructs APPCB to direct the units to establish fresh points for online dust monitors. The units have to ensure that all the stacks connected to boilers are provided with APCD's and OCEMS including the stand-by boilers. The units shall augment their pollution control devices so as to ensure that they comply with the standards stipulated by APPCB. The units shall take measures to prevent fugitive dust generated during loading, unloading of raw materials, products, flyash etc so as to meet the National Ambient Air Quality Standards.
11. The units shall upgrade the effluent treatment plants, periodically remove the accumulated sludge and oil from the tanks and send the same to TSDF. The units shall properly operate the ETP and ensure that they comply with the effluent discharge standards stipulated by APPCB.
12. The public roads surrounding the industries are in very poor condition due to movement of heavy vehicles. All the edible oil units shall collectively construct new concrete roads as part of CSR activity. The units shall develop green belt all along the boundary of the units and in vacant spaces and ensure that the 33% of total area is covered with green belt. In addition as part of CSR activity the units can take up compensatory green belt in public lands."
[38]5. The 5th respondent has filed their objection to the report of the Joint Committee along with certain documents to show that the observation made by the committee regarding the alleged insufficiency of the system that is being operated in their unit is not correct.
6. Though the applicant is absent, we feel that on the basis of the objections raised by the 5th respondent regarding the change in ownership of the 5th respondent unit, we direct the office to substitute the name of the 5 th respondent as M/s. Adani Wilmar Limited represented by its Managing Director having its registered office at Fortune House, Near Navrangpura Railway Crossing, Ahmedabad - 380009, Gujarat, India.
7. The Office is directed to carry out the amendment in the cause title.
8. Other respondent units who have not filed their objections to the committee report are directed to file their objections within a period of 15 (Fifteen) days to this Tribunal by e-filing with a copy to the committee so that the committee can go into the objections and come with their findings on that aspect, apart from filing their further action taken report, after considering the objections to the findings arrived at by them to this Tribunal on or before 26.03.2021 by e-filing in the form of Searchable PDF/OCR Supportable PDF and not in the form of Image PDF along with necessary hardcopies to be produced as per Rules.
[39]9. The Registry is directed to communicate this order to the members of the committee by e-mail immediately so as to enable them to comply with the direction.
10.For consideration of further report, objections if any, to the report, post on 26.03.2021.
......................................J.M. (Justice K. Ramakrishnan) .................................E.M. (Shri. Saibal Dasgupta) O.A. No.221/2015, 03rd February, 2021. Mn.
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