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[Cites 2, Cited by 0]

National Green Tribunal

V.P. Krishnamoorthy vs Union Of India Rep By Its Secretary ... on 22 June, 2020

Author: K. Ramakrishnan

Bench: K. Ramakrishnan

Item No.7 to 16
             BEFORE THE NATIONAL GREEN TRIBUNAL
                      SOUTHERN ZONE, CHENNAI
                  Original Application No. 176/2013 (SZ)
                     (Earlier O.A. No. 562/2018)(PB)
                                    With
                  Original Application No. 34/2014 (SZ)
                    (Earlier O.A. No. 563/2018) (PB)
                                    With
                  Original Application No. 35/2014 (SZ)
                    (Earlier O.A. No. 564/2018) (PB)
                                    With
                  Original Application No. 36/2014 (SZ)
                    (Earlier O.A. No. 565/2018) (PB)
                                    With
                  Original Application No. 37/2014 (SZ)
                    (Earlier O.A. No. 566/2018) (PB)
                                    With
                  Original Application No. 38/2014 (SZ)
                     (Earlier O.A. No. 567/2018) (PB)
                                    With
                  Original Application No. 39/2014 (SZ)
                    (Earlier O.A. No. 568/2018) (PB)
                                    With
                  Original Application No. 40/2014 (SZ)
                     (Earlier O.A. No. 569/2018) (PB)
                                    With
                  Original Application No. 41/2014 (SZ)
                     (Earlier O.A. No. 570/2018) (PB)
                                    With
                  Original Application No. 42/2014 (SZ)
                    (Earlier O.A. No. 571/2018) (PB)

                       (Through Video Conference)

                  Original Application No. 176/2013 (SZ)

     V.P. Krishnamoorthy                                     ....Applicant(s)
                                        Versus
     The Union of India & Ors.                             ....Respondent(s)
     Original
     ApplicationNo.34/2014(SZ)
     K.S. Jayaraman                                          ....Applicant(s)
                                        Versus
     The Union of India & Ors.                              ....Respondent(s)


                                    1
 Original
ApplicationNo.35/2014 (SZ)

R. Selvi                                    ....Applicant(s)
                                 Versus
The Union of India & Ors.                 ....Respondent(s)

Original Application No.
36/2014 (SZ)

K. Umachandran                              ....Applicant(s)
                                 Versus
The Union of India & Ors.                  ....Respondent(s)

Original Application No.
37/2014 (SZ)
Smt. S. Shanthi                             ....Applicant(s)
                                 Versus
The Union of India & Ors.                 ....Respondent(s)

Original Application No.
38/2014 (SZ)
                                            ....Applicant(s)
G. Mahesh Kumar
                                 Versus
                                           ....Respondent(s)
The Union of India & Ors.
Original Application No.
39/2014 (SZ)
                                            ....Applicant(s)
Smt. R. Vijaya
                                 Versus
                                          ....Respondent(s)
The Union of India & Ors.
Original Application No.
40/2014 (SZ)

K. Sampath Kumar
                                            ....Applicant(s)
                                 Versus
The Union of India & Ors.                 ....Respondent(s)

Original Application No.
41/2014 (SZ)

K. Kamalakannan
                                 Versus     ....Applicant(s)
The Union of India & Ors.
                                           ....Respondent(s)



Original Application No.

                             2
      42/2014 (SZ)

      G. Purushothaman
                                            Versus                        ....Applicant(s)

      The Union of India & Ors.                                        ....Respondent(s)


Date of hearing: 22.6.2020

CORAM:
         HON'BLE MR. JUSTICE K. RAMAKRISHNAN, JUDICIAL MEMBER

         HON'BLE MR. SAIBAL DASGUPTA, EXPERT MEMBER

                     Original Application No. 176/2013 (SZ)

For Applicant(s) :             Mr. S. Saravanan represented
                               Mr. A.Yogeshwaran

For Respondent(s):             M/s. M. Mani Gopi for R2
                               Mr. Arjun Suresh and
                               Mr.Krishna Srinivasan for BPCL.
                               Mr. D.S. Ekambaram
                               Mrs. Jayalakshmi for R12
                               Mr. S. Saravanan represented
                               Mr.M.R.Gokulkrishnan      appearing                 for
                               MoEF & CC

                               Original Application No. 34/2014 to 42/2014 (SZ)

For Applicant(s) :             Mr. Kandhan Duraiswamy

For Respondent(s):             M/s. Abdul Saleem represented through
                               Mr. S. Saravanan for TNPCB.
                               M/s. M. Mani Gopi for R4.
                               M/s. Krishna Srinivasan and
                                Mr. Arjun Suresh for BPCL.
                               M/s. M.R. Gokul Krishnan rep.
                               S. Saravanan for MoEF&CC.
                               M/s. A.A.V.Partners rep by Saravanan for
                               IOCL




                                        3
                                 ORDER

As per order dated 18.3.2020, we have considered the earlier orders and also the report made by the counsel and posted the case to 6.5.2020. Thereafter, it was taken up through Video Conference on 9.6.2020 and adjourned to today to consider the objections filed by Bharat Petroleum Corporation Ltd., to the report of Central Pollution Control Board.

2. Today, we have received a request for an adjournment through e-mail dated 21.6.2020 from Mr. Krishna Srinivasan, learned counsel for M/s. Bharat Petroleum Corporation Ltd.,

3. Bharat Petroleum Corporation Ltd., had filed their reply statement to the status report dated 16.3.2020 submitted by Central Pollution Control Board which reads as follows:

"REPLY FILED BY BHARAT PETROLEUM CORPORATION LTD TO THE STATUS REPORT DT. 16.03.2020 OF THE CENTRAL POLLUTION CONTROL BOARD The 6th Respondent (M/s. Bharat Petroleum Corporation Ltd -BPCL) humbly submits as follows:
Pursuant to the Order dt. 18.09.2019 of this Hon'ble Tribunal, the 12 th Respondent (Central Pollution Control Board -CPCB) filed the Status Report dt.16.03.2020 providing details of the progress of the ICMR Health Study, 4 CPCB's Study on Groundwater Quality and Status of on-going Remediation of Oil contaminated site at Tondiarpet, Chennai. his Reply is filed by BPCL to address certain inaccurate and/orerroneous contents of the Status Report dt. 16.03.2020 and provide the present status of the remediation activities undertaken by BPCL and its consultant namely M/s. Stratus Environmental Inc (Stratus). BPCL reserves its right to file detailed pleadings, if warranted by circumstances. Before addressing the contents of the Status Report dt. 16.03.2020, BPCL provides below the status of the remediation activities from its commencement till date.
In 2015, Stratus carried out a subsurface investigation that included advancement of exploratory soil borings, completion of these borings for either groundwater monitoring or remediation wells, and collection of soil and groundwater samples. A report documenting the findings of this work was prepared and submitted by Stratus on 21.10.2015. Based on the analytical data of soil and groundwater samples, Stratus estimated a contaminant mass of 32,799.12 Kilogram to be present beneath the subsurface. Subsequently, a Corrective Action Plan (CAP) document was submitted on 10.02.2016 comparing viable remedial alternatives and recommending a specific remedial approach. Following approval of the CAP, a catalytic oxidizer and an air compressor were installed at a pre- determined location.
5 Subgrade piping was then connected to the network of vapor extraction and sparging wells and also monitoring wells. SVE remediation was started for continuous operation from 25.05.2016 after the remediation system was connected to the local power grid.
In 2017, CMRL started construction activity (Excavation of soil & Extraction of groundwater) for the construction of metro railway network, which compromised the pipeline network used for remediation. In October 2018, after many months of negotiation with CMRL, BPCL/Stratuswas able to relocate the SVE unit and restart the SVE unit operations. Between February 2018 and October 2018, SVE System operated while extracting only from three wells instead of 14 SVE Extraction wells. In October 2018, only a limited number of wells were connected to the SVE system along T.H Road.
A second SVE system was installed in November 2019 after importing it from USA in August 2019. A great deal of difficulty was faced to operate the large system rated at 500 cfm, since this is the first of its kind in India. Currently, the following wells are connected to the SVE systems: SVE-1, SVE-2A, SVE-3A, SVE-8, SVE-9, SVE-4, SVE-5,SVE-7, MW-16A, AS-4, AS- 5, AS-7, AS-3A andMW 4A. Additional wells need to be installed and connected to the SVE systems to enable operation to full capacity. However, CMRL work still restrict this activity.
Chennai Metro Rail Limited (CMRL) Construction Activity: 6 • In 2017, CMRL started their construction activity (excavation of soil and extraction of groundwater) for building a metro railway network involving a combination of above and below ground railway track. • CMRL has excavated and removed 16,461.80-meter cube of soil as of 30.06.2019.
• CMRL has extracted 5,450 KL of water from excavations and transported to BPCL, Tondiarpet as of October 2018. • Mass removed by CMRL activity in the contaminated zone is estimated by two soil borings was 4833.45kgs (Till June 2019). The total mass removed to date is estimated to be 18,418.86 Kgs (SVE- 13,516.41 kg, socs- 69 kg and remediated soil- 4833.45) from the sub- surface. The reduction is calculated to be 56.15% of the total mass estimated in 2015.
Given the constraints at this site associated with residential housing, narrow streets and further complicated by CMRL construction activity, it is submitted that diligent operation of the systems at the site has resulted in significant mass reduction by SVE systems. The SVE systems are operating as designed and expected.
7 Figure: Concentration vs Time 8 Therefore, with regard to the remediation activities, it is submitted as follows:
a) SVE systems are designed and operating per expectations.
b) Operation of the SVE system has been significantly limited due to the lack of extraction wells that were destroyed during CMRL construction activity.
c) Even with the operations limited, nearly 56.15% of the mass has been extracted by SVE systems.
d) The second bigger SVE system has been operational for only two months. With continuous operation of this system, we anticipate the mass removal rates will increase significantly.
e) Most wells available for sampling, indicate greater than 90% reduction in concentrations due to remedial activity by SVE.

Hence, it is submitted that significant progress has been made in reduction of mass in the subsurface by SVE systems, and additional time is required to further reduce the residual mass in the subsurface. Now reverting to the contents of the Status Report dt. 16.03.2020 which has been broadly divided into four points/parts. With regard to Point No. 1 of the Status Report dt. 16.03.2020 (i.e) BPCL awarding the work of conducting the health study to ICMR, it is submitted that BPCL had obtained approval from its management to float the tender. Further, by email dt. 24.04.2020 and 06.05.2020, BPCL has requested for 9 detailed specifications, scope of work, job description, estimate cost item wise, timelines, vendor registration by ICMR and other details from CPCB in order to float the tender. The details are awaited from CPCB.BPCL is awaiting for the reply form CPCB on the details sought for floating the tender.

With regard to Point No. 2 of the Status Report Reportdt. 16.03.2020 (i.e) the findings of the ground water quality study conducted by CPCB and TNPCB, it is submitted that the remedial activity at the site has resulted in reduction of groundwater concentrations. The concentration of chemicals of concern although above laboratory detection limits, are reducing in the wells sampled. Chemicals of concern at this site are DRO, GRO and BTEX. It is important to note that CPCB has not established permissible limits for the chemicals of concern at this site.

With regard to the statement that there is presence of TOC, TPH and DRO in the 4 deep bore wells, it is stated that these wells historically have detectable concentrations of petroleum hydrocarbons. Similar to the shallow wells, the concentration of chemicals of concern are declining. For example concentration of DRO in well MW-5B was initially reported to be 19.81 mg/l in December 2015, but the current concentration as reported by CPCB is 0.193 mg/l. Further, with regard to the statement that the concentration of mineral oil was found within permissible limit in all monitored wells except in one location (MW-5B), it is stated that the initial concentration of mineral oil in MW-5B was reported to be 9.44 mg/l in 10 December 2016 and the current concentration reported by CPCB is 0.82, indicating a significant reduction in concentration. In addition, presented below is the comparison of analytical data for the two shallow wells with concentration excedences. The analytical data from this data set indicated that there is significant reduction in concentrations.

The statement "The ongoing remediation works have little effect in improving groundwater quality in the area along the abandoned pipelined towards north direction" is unsustainable since the analytical data collected by CPCB has not been made available for examination by BPCL and Stratus. Further, such an interpretation by CPCB of the overall groundwater quality with data from only 3 monitoring well in the shallow zone, out of 22 wells originally used to characterize the lateral extent of impact to groundwater is also unsustainable.Given that groundwater samples have not been collected from the vicinity of the pipeline, it is not clear as to how CPCB is able to make this determination. In addition, presented below is the concentrations in well MW-1A located at the point of 11 release. The analytical data from this data set indicated that there is significant reduction in concentrations.

With regard to Point No. 3 of the Status Report Reportdt. 16.03.2020 (i.e) the status of the remediation activities, CPCB states that the extracted vapors only have GRO. In addition, CPCB states that the SVE system is not effective for reduction of DRO, TPH and TOC from soil or groundwater. The methodology in which CPCB collects the air samples are erroneous. However, this is the best available technology in India. The methodology does not easily allow for analysis of heavier end hydrocarbons and therefore the analytical data from the air samples is not representative. In order to allow for a more consistent and reliable analytical data for heavier end hydrocarbons air samples should be collected using Summa Canisters and analyzed by EPA method 8015 using a gas chromatography- mass spectrometry (GCMS). Analytical data from groundwater monitoring wells in the source area show reduction in heavier end hydrocarbons and therefore the SVE system is effective in removing mass from the subsurface. In addition, soil samples collected from areas where SVE system has remediated the site, (in the vicinity of MW-17A), the concentrations of DRO is low to non-detectable compared to the initial 12 concentrations, indicating that the SVE system has been successful in reducing the concentrations of heavier end hydrocarbons in soil. With regard to the statement that the SVE System was operating at 85.5 cfm against the designated capacity of 250cfm, it is submitted that the SVE system is operating at a lower capacity than the design capacity due a number of factors such as, site geology and hydrogeology, distance of extraction from the SVE system and power and voltage fluctuations. The SVE system operation has not changed since its start up. Similar to the first SVE system, the second SVE system might not operate at max manufacturer identified capacity, due the same reasons identified above. It is pertinent to state that we are concerned with the destruction efficiency of both systems. Both systems are expected to operate at 95% or above destruction efficiency. Over the last 4 years, through CPCB sampling, the fist SVE system has shown to operate at 95% or greater destruction efficiency. The analytical data set for this event, that exhibits a lower destruction efficiency, could be erroneous and might not be representative. Stratus will collect additional air samples to verify the destruction efficiency of both systems.

The statement "Therefore, present system SVE system is not effective for reduction of DRO, TPH and TOC from soil or groundwater" is unsustainable since the analytical data collected by CPCB has not been made available for examination by BPCL and Stratus.In the Status Report dt. 16.03.2020, it is stated that the systems are not running at full 13 capacity and/or connected to all wells and limitation with operational flow rates versus design flow rates. BPCL's consultant Stratus has stated that most of these systems do not operate at the prescribed flow rates. If the blowers were pulling on ambient air only, they would operate at design flow rates. The flow rates from the subsurface are a function of subsurface geology and hydrogeology and usually do not follow laboratory design factors, unlike in an above ground factory operational setting. The flow rates of SVE-1 has not changed since its startup and been very consistent and resulted in significant reduction in groundwater concentrations and removal of petroleum hydrocarbon mass in the subsurface. Therefore, SVE- 1 is performing well. With regard to the SVE-2 system, if the same was connected to the wells in V.P. Koil Street, it would perform better (mass removal) also.

With regard to Point No. 4 of the Status Report dt. 16.03.2020 (i.e) recommendations of CPCB, it is first necessary to state about the compliance of BPCL with regard to the Further Action Plan for Remediation of the Contaminated Site determined by CPCB, TNPCB and BPCL. Pursuant to the Order dt. 08.02.2019 of this Hon'ble Tribunal, a meeting to review the status of the remediation activities and decide on the further action plan for remediation was convened under the chairmanship of Chairman, CPCB. Executives of TNPCB and BPCL attended the said review meeting held on 01.03.2019. During the said review meeting, the Further Action Plan for Remediation of the Contaminated Site determined 14 by CPCB, TNPCB and BPCL which involved 13 action points. The compliance of BPCL with regard to the 13 action points is listed below. This has also been confirmed in the Compliance Status Report dt. 16.09.2019 filed by CPCB.


     13 Action Points of the Time          Frame/

     Further Action Plan as Agency

Sl. No determined    in     the                     Status as on 05.06.2020

     Review     Meeting      dt.

     01.03.2019

1    BPCL      to    connect       1 month.
                                                    Complied.
     remaining 7 wells to

     existing SVE system to        BPCL
                                                    Installed 2 new wells (SVE2a&
     increase current rate of
                                                    SVE 3a) at TH Road adjacent to
     extraction. They shall
                                                    CMRL site.The pipeline laying
     work out right way to
                                                    work completedand reconnected
     install   pipelines     of
                                                    the     2         new     wells
     about 70m length in
                                                    (SVE2a&SVE3a) with existing 7
     consultation          with
                                                    wells   (SVE-1,    SVE-4,SVE-5,
     TNPCB.         Statutory
                                                    SVE-7, SVE-8, SVE-9 and SVE-
     Permissions shall be
                                                    16A).
     taken.

2    After          obtaining      30 days after    Complied.



                                          15
     statutory      permission      obtaining     local

    from            concerned      permission.           Now the pipeline are connected.

    departments,            the

    pipelines       to       be    BPCL

    connected      within    30

    working days

3                                  1 month               Complied.



                                   BPCL                  Identified new site at VP koil

                                                         street,     Tondiarpet     and

    BPCL to find alternate                               executed agreement with the

place to install new land lord on 01-06-2019. The SVE system in 2nd SVE unit is installed on consultation with 31.08.2019. The 2nd SVE TNPCB to speed up the commissioned. The 2ndSVE is remediation activity. connected to well no MW-4A (dual purpose well ) and now in operation also. Air sparge well AS6 is also connected with the same.

4 Local authority shall BPCL to submit Complied. provide a space of 20 x proposal 16 20 sq. ft. government immediately Second unit is already placed land temporarily for at the private land on VP Koil relocating SVE system street. Therefore additional from current location. space may not required now.


5   Upon     completion      of

    structure, if required,        CMRL
                                                       As BPCL have already obtained
    CMRL      shall     provide
                                                       site and installed 2nd SVE unit,
    temporary      space     of
                                                       BPCL doesn't need additional
    20ft x 20ft on roof top
                                                       space for SVE unit.
    of its structure.

6   A     qualitative    health Time      given:   3

    impact study on the months.

    population in affected

    area be conducted by TNPCB

    obtaining     information                          This is further to BPCL letter

    from local government                              ref:    TNP:REMD:19-20         dated

hospitals, primary 09.05.2019. We request you to health centers defer the qualitative health etc.TNPCB may engage impact study on population in any expert or an affected areas the locality is agency who can commercial in nature and the conduct such studies. residents are on tenement 17 The study to be funded basis. Till now no health by BPCL. complications were reported and the affected applicants were suitably compensated, conducting the study may lead to further unknown complications.

                              A     meeting           convened         on

                              19.11.2020         at     TNPCB,        HO,

                              Chennai,          wherein        it     was

                              concluded                that         Indian

                              Counsel of Medical Research

                              (ICMR) may undertake field

                              visit to understand the ground

                              reality of Oil contaminated site

                              at Tondiarpet and to submit

                              detailed       proposal          including

                              scope of study, methodology,

                              procedure         for     quantification

                              including          cost         and     time

                              frame to complete the study on

                              health     hazards         in     the    oil




                         18
      contaminated               site         at

     Tondairpet. As agreed in the

     meeting, ICMR submitted the

     detailed proposal including cost

     estimates     to     carry    out      the

     study vide ICMR mail to CPCB

     dated 28.02.2020.

     Further TNPCB advised BPCL

     (Vide   their       mail     letter)    on

     10.03.2020to make necessary

     agreement with ICMR to conduct

     the study.         BPCL received the

     necessary                  management

     approval for awarding the job

     on single tender basis with

     ICMR as advised by TNPCB

     vide       their      email         dated

     10.03.2020.          BPCL requested

     CPCBon 24.04.2020 to arrange

     detailed      specifications           and

     scope of work and necessary

     documents          from      ICMR       to




19
                                                            register as vendor also to float

                                                           single tender.



7   BPCL to install Soil Gas Time            given:   2

    Probes to monitor VOCs months,                post

    in vadose zone of sub- completion                 of

    soil at 3 locations in CMRL works.

    affected   area,        which

    shall become part of BPCL

    revised       remediation
                                                           Action   will    be   initiated   on
    scheme post completion
                                                           completion of CMRL works.
    of CMRL works.

8   Identify          applicable CPCB

    standards in monitoring

    /assessing remediation                                 Action by CPCB.

    works        in        similar

    contamination matrices.

9   Upon completion of soil          Time    given:   3

    excavation        works,   a     Weeks        upon

    revised      Remediation         completion       of

    scheme            to       be    soil   excavation

    implemented.                     by CMRL.



                                             20
                                           BPCL

     BPCL       to        submit     a                        Already this scope of work is

     Detailed Project Report                                  available in the Tender. Vendor

     (DPR)       for         revised                          has been informed and aware

     remediation             scheme                           of the study. Will be done on

     based re-assessment of                                   completion of soil excavation by

     site    along        with     site                       CMRL.

     specific    target          levels

     (SSTLs) for remediation

     based on human health

     risk    assessment.             It

     shall specify committed

     duration        to    complete

     the     Remediation.            A

     scope of work for DPR

     be submitted to TNPCB

     Within 3 weeks.

10   To     ensure        adequate        Time   given:   3

     storage         capacity       to    Months.

     store      the       extracted



                                                 21
 water from CMRL site

till   finalization      of   TNPCB

Treatment             plan.

TNPCB/CPCB               to
                                           Scope      is    included     in    the
identify parameters as
                                           tender, will be initiated for
per         international
                                           treatment and disposal as
standards for disposal
                                           soon as the parameters are
of     treated        water
                                           provided by TNPCB / CPCB.
without          harming
                                           TNPCB           collected         water
environment
                                           samples twice and the test

                                           results           reveals           the

                                           parameters are well "Below

                                           Detection        Level.           BPCL

                                           sought TNPCB's approval to

                                           dispose within the plant for

                                           internal        maintenance        use.

                                           TNPCB is yet to respond.

                                           CPCB collected the samples

                                           third time on 13 Feb 2020

                                           and     the     results     are    also

                                           Below detection level/ Below

                                           limit   of      qualification.     Lab



                                      22
                                                        report      enclosed.         CPCB

                                                       permission        awaited        for

                                                       dispose      of   water      within

                                                       plant      for    internal     use.

                                                       Adequate          storage         is

                                                       available at location.

11   BPCL         to      submit BPCL                  Complied

     proposal to TNPCB for

     disposal of 7,287 litre                           Extracted contaminated water

     of oil & 2, 07,395 litre                          has been disposed through ETP

     of   oil     contaminated                         (Effluent Treatment          Plant)    of

     water presently stored                            Chennai Petroleum Corporation

     in a tank within BPCL                             Ltd Refinery, Manali.

     Storage Depot.


12   Till the time a revised        Time given: Till

     remediation scheme is          completion    of

     finalised,        BPCL    to   CMRL works.

     continue     to    carryout

     assessment               and

     monitoring of existing

     SVE system and CMRL            CPCB/TNPCB/        BPCL agreed to continue to

     works as per earlier           BPCL               monitor.


                                           23
       recommendations       of

      CPCB/TNPCB.

13    BPCL     shall   ensure    BPCL               Complied.

      adequate and quality                          18,000 liters of Chennai Metro

      of   water   supply   to                      Water    is   being    supplied

      affected population in                        through tank lorries on daily

      contaminated area.                            basis. This is substantiated by

                                                    the Water Supply Report of

                                                    Chennai Metro Water.



Now with regard to the recommendations of CPCB contained in the Status Report dt. 16.03.2020, it is submitted that there is a significant reduction in ground water concentration and also improvement in soil condition. SVEs are functioning very consistently. BPCL was unable to start the road cutting works due to permission issues from authorities as a result of one way traffic and rains initially. After which, due to COVID-19 and restrictions, BPCL was unable to arrange the same. BPCL will arrange to get the permissions soon after the lockdown.

Dated at Chennai on this the 8thday of June, 2020 VERIFICATION I, Gururaj Nagappa Sankh, son of Nagappa G Sankh,Territory Manager (Retail) of the 6th Respondent, do hereby declare that what is stated above is true to the best of my knowledge, information and belief. 24 Verified at Chennai on this the 8thday of June, 2020 - 6TH RESPONDENT"

4. Central Pollution Control Board also filed their response to the objections filed by Bharat Petroleum Corporation Ltd., by their reply dated 19.6.2020 which reads as follows:
"Reply affidavit on behalf of Central Pollution Control Board (Respondent No. 12) with regard to Objection filed by Bharat Petroleum Corporation ltd., w.r.t Status report dated 16.03.2020 of the Central Pollution Control Board.
I, S. Suresh, Son of S.R. Sathyanarayana, Hindu, aged about 57 years, having office at the Regional Directorate (South), Central Pollution Control Board, 1st& 2nd Floors, Nisarga Bhavan, A- Block, Thimmaiah Main Road, 7th D Cross, Shivanagar, Bengaluru - 560 079 do hereby solemnly affirm and sincerely state as follows:-
That I am presently working as Scientist 'E' & Regional Director, Regional Directorate (South), Central Pollution Control Board (hereafter called as CPCB), Bengaluru and have been authorized to file the present compliance affidavit. I am fully conversant with the facts of the case and hence, competent and authorized to depose and swear the present compliance affidavit as under:
That in compliance of Hon'ble NGT order dated 18.09.2019, CPCB coordinated with Indian Council for Medical Research (ICMR) and Tamil Nadu Pollution Control Board (TNPCB) and convened meeting on 19.11.2019 at TNPCB, H.O., Chennai to discuss the scope and 25 modalities of health impact study. The meeting was attended by the officials of CPCB, TNPCB, ICMR, BPCL and representative of M/s Environment Stratus (Consultant for remediation of oil contaminated site). IN the said meeting, representatives of ICMR and BPCL were apprised about the requirement of conducting health studies in time bound manner.

Subsequently, ICMR prepared a detailed proposal comprising scope of work, methodology, procedure for quantification of health impacts including project cost and timelines to complete the study. ICMR submitted the proposal to TNPCB and CPCB on 28.02.2020. Thereafter, CPCB, forwarded the ICMR proposal to BPCL and TNPCB vide letter dated 28.02.2020 with request to expedite award of project to ICMR.

Further,as per the directions of Hon'ble NGT,CPCB and TNPCB have carried out groundwater monitoring as well as performance of Soil Vapour Extraction System installed by BPCL for remediation of oil contaminated site at Tondiarpet. The report was submitted before Hon'ble NGT on 16.03.2020.

That Hon'ble Tribunal heard the matter on March18, 2020, and on the request of Respondent No. 6 (M/s BPCL), adjourned the matter for allowing filing the objections by them. M/s BPCL has filed the objections on June 09, 2020 the same was received through CPCB counsel.

26 That para wise reply from CPCB on the said objections are as below:

Para 1 to 14:
1. It is submitted that with respect to averments made is para 1 to 14 are about General information, on-going remediation work and its status, hence no comments to offer from this Respondent No. 12.
2. Para 15: "With regard to Point No. 1 of the Status Report dt. 16.03.2020 (i.e.) BPCL awarding the work of conducting the Health study to ICMR, it is submitted that BPCL had obtained approval from its management to float the tender. Further, by email dt. 24.04.2020 and 06.05.2020, BPCL has requested for detailed specifications, scope of work, job description, estimate cost item wise, timelines, vendor registration by ICMR and other details from CPCB in order to float the tender. The details are awaited from CPCB. BPCL is awaiting for the reply from CPCB on the details sought for floating the tender."

CPCB Reply:

That as per the direction of Hon'ble NGT, as a committee member CPCB taken lead role to convene the meeting with ICMR and follow-up with ICMR to obtain the detailed proposal comprising scope of work, methodology, procedure for quantification of health impacts including project cost and timeline to complete the study and the same was sent to BPCL vide letter dated February 28, 2020(Annexure -1,2,3) with request to expedite award of project to ICMR. However, no official communication has been received 27 from BPCL, after lapse of fifty-six days CPCB received mail from BPCL, the matter of mail is as below:
"Please help us with following details to float the single tender to ICMR.
1. Detailed specifications of tender
2. Scope of work, job description and estimate cost item wise, time lines for the job, LD clause etc.
3. Vendor registration template in the format (enclosed) duly filled and submit by vendor (ICMR) to register them. (ICMR need to provide their registration / incorporation certificate, GSTN copy and other details as per the format enclosed)"

That it is the responsibility of BPCL to justify placing single tender on ICMR. Since ICMR has submitted the detailed technical and financial proposal, BPCL might have sought required clarifications from ICMR and request CPCB/TNPCB to convene a meeting with ICMR. Further, it is humbly submitted that CPCB may not justify or recommend tendering terms, which may be finalised between ICMR and BPCL following the established procedures of respective agencies.

3. Para 16: "With regard to Pont no 2 of Status Report dated 16.03.2020 (i.e.) the findings of the ground water quality study conducted by CPCB and TNPCB, it is submitted the remedial activity at the site has resulted in reduction of ground water concentrations. The concentration of chemicals of concern although above laboratory detection limits, are reducing in the wells sampled. Chemicals of 28 concern at this site are DRO,GRO and BTEX. It is important to note that CPCB has not established permissible limits for the chemicals of concern at this site."

CPCB Reply:

That in reply to points raised by M/s BPCL at para 16, CPCB submitthe following facts before Hon'ble NGT:
On receipt of complaints dated July 14, 2013 regarding Petroleum impact in bore wells located in the public domain on TH road and VP Koil Street at Tondiarpet, Chennai; CPCB/TNPCB inspected and directed BPCL to discontinue the damaged pipelines carrying petroleum products and also directed to take up detailed study to assess the extent of contamination and its remediation. As per the direction of Hon'ble NGT, BPCL engaged the experts from IIT Madras in November, 2013 and conducted initial evaluation and prepared tender documents, scope of work for the remediation work. Accordingly, BPCL engaged the consultant M/s Stratus Environment in December, 2014 to carryout remediation of oil contaminated site under the supervision of IITMadras. In the remedial works initiated under guidance from IIT, Madras, risk assessment studies were not carried out to derive site specific target levels. While hearing the matter on March 17, 2016, the Hon'ble NGT implead the CPCB and passed an order that " till date no remediation measures worthy of speaking has been taken in the interest of the residents in the area, we discharge the experts from IIT-M from any further supervision 29 over the remediation efforts and directed the CPCB to take up the supervision of remediation work of erasing oil contamination in the water aquifer in Tondiarpet taking into consideration all the reports of experts of IIT-M as well as the Board and file its report by next date of hearing. In this exercise the CPCB is permitted to avail the service and /or expertise from any recognised Organisation/Institute located in the Country. The cost involved for the said purpose shall be fully borne by the BPCL (Annexure-4)".
That in compliance to the aforesaid order, CPCB has inspected the oil contaminated site at Tondiarpet along with the officials of TNPCB on April 05, 2016 and reviewed the status of remediation works. The salient observations vis-à-vis recommendations communicated to BPCL vide CPCB letter dated April 27, 2016 (Annexure -5). The major salient observations are as below:
"(4) The remedial measures initiated are not based on any quantifiable risk reduction. There is need to set standards for remediation based on reduction in risk at the receptor rather than just operating a soil vapour extraction system. It is therefore suggested that the scope of work to the consultant should include a quantitative risk assessment. Tier-1 screening of the soil and groundwater may be carried out using Canadian screening standards and Dutch intervention values.
(8) Based on site specific target levels derived from risk assessment, the consultant shall evaluate multiple remedial options that may be required 30 beyond soil vapour extraction system including proposal for long term plan for assessment and monitoring may be submitted to TNPCB and CPCB within a period of 4 months. Short term findings on performance of SVE system may be included in this report.
(10) Target level for remediation shall be set based on quantitative risk assessment and such target level shall be authorised by TNPCB to monitor the remediation works."

CPCB reviewed implementation of above recommendations and the project status including reasons given by BPCL for not implementation of aforesaid suggestions were submitted to Hon'ble NGT vide status report dated November 16, 2016 (Annexure -6). The extracted paragraph of status report of CPCB dated November 16, 2016 is as below;

"(iii) As per the CPCB recommendations, it is required to set Site Specific Target levels (SSTL) to be derived from quantitative risk assessment using any suitable model based on the human health risk associated with both inhalation and incidental ingestion of specific contaminants at the exposure concentration and SPR (Source-Pathway-Receptor) linkage. M/s BPCL has not made any progress in developing SSTL, however, excavation of contaminated soil for the proposed Metro construction may alter the source pathway receptor considerations for developing the SSTL, therefore it may be appropriate to develop SSTL at later stage. "

It is submitted that as per directions of Hon'ble NGT, CPCB has been monitoring ground water quality and performance of soil vapour extraction 31 system and effectiveness of remediation is reported in comparison to previously observed values. Since excavation works of CMRL are nearing completion in impacted area, M/s BPCL may carry out risk assessment studies by engaging a reputed remediation consultant and proposed Site Specific Target levels (SSTL) may be submitted to TNPCB for acceptance or authorization of remediation standards.

4. Para 17: "With regard to the statement that there is presence of TOC, TPH and DRO in the 4 deep bore wells, it is stated that these wells historically have detectable concentrations of petroleum hydrocarbons. Similar to the shallow wells, the concentration of chemicals of concern are declining. For example concentration of DRO in well MW-5B was initially reported to be 19.81 mg/L in December 2015, but the current concentration as reported by CPCB is 0.193 mg/L. Further, with regard to the statement that the concentration of mineral oil was found within permissible limit in all monitored wells except in one location (MW-5B), it is stated that the initial concentration of mineral oil in MW-5B was reported to be 9.44 mg/L in December 2016 and current concentration reported by CPCB is 0.82, indicating a significant reduction in concentration. CPCB Reply:

That as per the directions of Hon'ble NGT, CPCB initiated monitoring of groundwater since June, 2016 by selecting 9 monitoring wells installed in core area as well as in boundary of contaminated site and the status 32 report showing fluctuation of concentrations of chemicals of concern in groundwater was submitted to Hon'ble NGT vide CPCB status report dated January 05, 2018 (Annexure-7). The report revealed that "concentration of Mineral Oil and Gasoline Range of Organics (GRO) found less than 0.01 mg/L and 20 µg/L, respectively in most of monitoring well locations. However, concentration of Diesel Range of Organics (DRO), Total Petroleum Hydrocarbon (TPH) and Total Hydrocarbon (THC) in groundwater indicates that the present system of operation of SVE could not establish the satisfactory reduction".
Due to ongoing Metro excavation and seasonal variation of groundwater, monitoring wells identified by CPCB (except MW-5B) were either closed or dried-up. In contrary to claims of M/s BPCL, comparison of TOC, DRO and THC levels in monitoring well MW-5B, in samples collected on 22 November, 2017and 14 February, 2020 indicates clear increment in concentrations values from 14 mg/L, 0.089mg/L&0.272 mg/L to as high as 64 mg/L, 0.193 mg/L &1.01 mg/L respectively, however such increment may be attributed to movement of groundwater and change in hydro-geological conditions due to CMRL works. CPCB monitoring has also indicates that low concentrations in other wells, however over-all remediation efficiency cannot be decided based on monitoring of few wells. Therefore, based on observed groundwater quality CPCB concluded that the present system of operation of SVE could not establish the satisfactory reduction in groundwater contamination. It is therefore necessary to 33 augment SVE system by connecting as many wells as possible and by operating both the SVE systems simultaneously to optimal extraction rate. The observations of BPCL claiming significant reduction in concentration is not acceptable. PRAYER That it is humbly submitted prayed that Hon'ble NGT may issue suitable direction to BPCL to;
1. Issue suitable direction to M/s BPCL to carry out detailed site investigation and risk assessment study to evolve Site Specific Target Levels (SSTLs) for remediation of oil contaminated site at Tondiarpet, Chennai;
2. Direct M/s BPCL to augment SVE system by connecting as many wells as possible and by operating both the SVE systems simultaneously to optimal extraction rate;

This answering Respondent No. 12 shall abide to any direction passed by the Hon'ble Tribunal. DEPONENT VERIFICATION It is verified that the content of this reply affidavit is based on office records. Nothing has been concealed therein.

Signed and verified on this 19th day of June 2020 at Bengaluru DEPONENT COUNSEL FOR 12th RESPONDENT"

5. When the matter came up for hearing today through Video Conference, Mr. S. Saravanan represented Mr. Yogeswaran, counsel appearing for applicant in O.A.No.176 of 2013, Mr. Kandhan Doraisamy, learned counsel represented applicants in O.A.Nos.34 to 42 of 2014, Mr. Mani Gopi represented second respondent in O.A.No.176 of 2013 and fourth respondent in O.A.Nos.34 to 42 of 2014, Mr. D.S. Ekambaram through Mrs. Jayalakshmi represented 12th respondent in O.A.No.176 of 2013, Mr. Gokul Krishnan, through Mr. S. Saravanan represented MoEF 34 & CC, Mr. S. Saravanan represented IOCL, Mr. Abdul Saleem through S. Saravanan represented Tamil Nadu Pollution Control Board.

6. Since the presence of counsel appearing for BPCL is required for hearing, we feel it appropriate to grant one more opportunity to the parties for hearing on the status report.

For hearing, post on 8.7.2020 ...................................J.M. (Justice K. Ramakrishnan) .............................E.M. (Shri. Saibal Dasgupta) O.A. 176/2013, O.A.34 to 42/2014 22.6. 2020 Kkr 35