350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
LOCAL AREA ENVIRONMENTAL COMMITTEE For ELOOR – EDAYAR AREA
(LAEC) (CONSTITUTED AS PER THE ORDER No PCB/HO/HWM/SCMC/503/2004 DATED 15.10.2004)
Office: 2nd floor, Kaloor Towers, Kaloor, Kochi-17. Ph: 04843952393
www.scmc.info, www.keralapcb.org e-mail: laecperiyar@yahoo.co.in
366
LOCAL AREA ENVIRONMENTAL COMMITTEE For ELOOR – EDAYAR AREA (LAEC)
(CONSTITUTED AS PER THE ORDER No PCB/HO/HWM/SCMC/503/2004 DATED 15.10.2004)
Office: 2nd floor, Kaloor Towers, Kaloor, Kochi-17. Ph: 04843952393
www.scmc.info, www.keralapcb.org e-mail: laecperiyar@yahoo.co.in
REPORT
Witnessing the alarming situation created by generation of hazardous waste, its dumping and
serious irreversible damage as a result thereof to the environment, flora and fauna, health of
animals and human beings, the Research Foundation for Science and Technology approached
the Hon’ble Supreme Court under Article 32 of the Constitution of India complaining
violation of fundamental rights under Articles 14 and 21.
Considering the magnitude of the problem and the volume of hazardous wastes generated, the
Hon’ble Supreme Court issued notices to all the State Governments, Central Pollution Control
Board and the State Pollution Control Boards to identify the problems caused by the
hazardous wastes and allied matters including aspects relevant to minimize its generation with
a view to protect the environment.
In view of the magnitude of the problem and its impact, the State Governments were directed
to show cause why an order be not made directing closure of units generating hazardous
wastes where provision is not made for requisite safe disposal. It was further ordered to show
cause as to why immediate order is not made for closure of all unauthorized hazardous wastes
handling units.
The Hon’ble Supreme Court in its Order dated 4th August 1997 observed that the State
Governments have not taken steps required under the applicable law and have failed to place
before the Court all material facts in spite of considerable time being given to them.
It is in this background, the Hon’ble Supreme Court found appropriate to constitute a
committee to arrest the growth of the problem caused by Hazardous wastes and oversee the
improvement in the quality of environment. The Hon’ble Supreme Court constituted a High
Power Committee (HPC) under the Chairmanship of Prof. MGK Menon to examine all
matters in depth relating to hazardous waste. The committee filed its report on 20th April
1998, on consideration whereof; the Hon’ble Supreme Court on 10/10/1999 issued certain
directions.
The Hon’ble Supreme Court appointed a Monitoring Committee to ensure that the generation
of hazardous wastes is brought to minimum and it is properly handled in every state .The
committee has been entrusted with the duty to oversee the compliance of law, rules and
regulations and directions of the Hon’ble Supreme Court. The committee constituted by the
Hon’ble Supreme Court consists of the following members:
1.
Dr. G. Thayagrajan, Senior Secretary
COSTED, Chennai
Chairman
2.
Mr. V. Rajagopalan, Chairman,CPCB
Member
3.
Director, NEERI, Nagpur
Member
367
4.
Director, NML
Member
5.
Director, IIP, Dehradun
Member
6.
Director, NCL, Pune
Member
7.
Dr. Claude Alvares, NGO
Member
8.
Dr. D.B. Boratkar
Member
9.
Dr. N.H. Hosabettu
Director, HSM Div., MOEF
Member-Secretary
Director, IICT
Co-opted Member
10.
Visit of SCMC in Kerala
The Supreme Court Monitoring Committee (SCMC) visited Kerala on 14-8-2004. The
committee visited several units generating Hazardous waste. The committee found to its
shock that the authorities in Kerala have allowed widespread disregard of the Court order
dated 14-10-2003. It found several units operating without authorization as required by
Hazardous Waste (Management and Handling) Rules 1989 and in defiance of the order dated
14-10-2003. In addition SCMC found the provisions of Air (Prevention and Control of
Pollution) Act and Water (Prevention and Control of Pollution) Act being openly flouted. The
committee was particularly alarmed and distressed at the state of Periyar River which is the
lifeline of Kerala. The committee found the river itself has been converted into a vast illegal
treatment storage and disposal facility (TSDF) for receiving large quantity of hazardous
waste. The Supreme Court Monitoring Committee issued the following directions among
others;
1.
The KSPCB is directed to close forthwith all units that have no authorization to
operate under the Hazardous Waste (Management and Handling) Rules 1989.
These units will not be allowed to reopen until they have the proper facilities to
dispose of their hazardous wastes as required under the Rules.
2.
The committee directed the Kerala State Pollution Control Board to set up a Local
Area Environmental Committee with the following terms of reference to assist the
Supreme Court Monitoring Committee.
a) It will commence an environmental audit of all the 247 industries located in the
area and that are affecting the ecology and environment and the local health of
the population along the Periyar River and in the Udyogamandal industrial
estate. This environmental audit will be completed in six months.
b) The LAEC will visit each of the industrial units and ensure that the units are
complying with environment laws including the provisions of the Hazardous
Waste (Management and Handling) Rules 1989.It will ensure that there are
no illegal discharges into the Periyar River either in the form of solid
waste or liquid effluent containing hazardous wastes.
c) It will ensure that proper material balance is maintained of the various
368
chemicals and wastes used and generated in the premises of each unit.
d) It will also ensure that all industrial units covered by the order dated 14-102003 will have display boards in Malayalam and English at the main gate
accessible to all members of the public in the vicinity.
The Supreme Court Monitoring committee directed the Kerala State Pollution Control Board
to notify the formation of LAEC to all industrial units. The Board was directed to handover to
the LAEC copies of all consents granted to the various units under Air (Prevention and
Control of Pollution) Act and Water (Prevention and Control of Pollution) Act and
authorization granted under the Hazardous Waste (Management and Handling) Rules 1989, if
any and other environment information related to the protection of the Periyar River if
requested by LAEC as if it were being requested by the SCMC.
The Supreme Court Monitoring Committee warned all concerned that should the SCMC find
that these actions do not turn the situation around and reverse the pollution of the Periyar river
within the stipulated period of six months, it will have no hesitation in directing the closure of
the entire Udyogamandal industrial estate and that units will be allowed to re-open one by one
thereafter only if they are able to convince that all measures have been installed to discharge
as per EPA standards and HW Rules.
The Kerala State Pollution Control Board reconstituted the present Local Area Environmental
Committee for Eloor –Edayar Industrial belt on 15-10-2004 with the following terms of
reference.
1. Carry out an environmental audit of all the 247 industries located in the area and that
are affecting the ecology and environment and the local health of populations along
the Periyar and in Udyogamandal Industrial Estate. The environmental audit should
cover the study of raw materials, products, production process, waste generation,
compliance with environmental laws, unauthorized disposal of wastes, present status
etc.
2. Environment audit shall be completed in six months.
3. The LAEC is to visit each of the industrial units and ensure that the units are
complying with environment laws including the provisions of the Hazardous Waste
Rules.
4. Ensure that there are no illegal discharges of hazardous wastes into Periyar either in
the form of solid waste or liquid effluent containing hazardous wastes.
5. Ensure that a proper material balance is maintained of the various chemicals and waste
used and generated in the premises of each unit.
6. Identification and sealing unauthorized outlets.
7. Identification of site in Eloor for a common TSDF.
369
8. Ensure that all industrial unit covered by the order dated 14-10-2003 will have display
boards in Malayalam and English at the main gate visible to all member of the public
in the vicinity.
The committee started its inspections of the industries in Eloor –Edayar belt on 2nd November
2004. The Committee during its inspection associated one Environmental Engineer, one Asst.
Environmental Engineer and one Scientist deputed from the Kerala State Pollution Control
Board to assist in environmental audit. The committee initially conducted inspections with
notice to the units and subsequently realizing the clandestine manner in which the units have
been discharging untreated trade effluent into the environment, it resorted to surprise visits.
The committee constituted a panel of scientists to seek advice for combating the
environmental threat and related issues including steps to protect the river Periyar which is a
major source of drinking water catering the needs of 47 Panchayat , 3 Municipalities and One
Corporation in Ernakulam districts
LAEC asked the industries to make available copies of the statutory orders issued to them
under various environmental laws such as Environmental Protection Act, Manufacture,
Storage and import of Hazardous Chemical Rules, 1989, Hazardous Waste (Managing and
Handling) Rules 1989; Water (Prevention and Control of Pollution) Act, The Air (Prevention
and Control of Pollution) Act etc. and laboratory reports of the accredited agencies to satisfy
itself that the industrial units are functioning with required consents and are complying the
conditions.
The Committee also held public hearings on every first Saturday and third Saturdays in the
office of the. State Pollution Control Board at Eloor and collected the complaints from the
local residents as a part of identifying their problems in the industrial belt. One of the major
complaints from the local residents was that the presence of the Board in the industrial belt is
not felt, as there is no regular monitoring by the regulatory body notwithstanding the fact that
the industries posed serious environmental problems.
LAEC therefore felt necessary, to begin with, examine the veracity of this allegation. On 211-04, LAEC visited the site office of Pollution Control Board at Eloor. To its shock the
office was found closed. On enquiry it is found that the office has been non functional for a
pretty long time. There was absolutely no infrastructure such as lab facilities, lab technicians
and other competent personnel’s for conducting inspections and monitoring the units at
regular intervals in this industrial belt. There was no arrangement even to attend emergency
situations. The complaint of the public was thus stand vindicated and the committee found the
genesis of the environmental problem in the failure of the Board in maintaining a functional
office at Eloor-Edayar industrial belt.
LAEC expressed its concern over the manner in which the site office at the industrial belt is
maintained by the PCB .It resolved in its meeting held on 12-11-2004 to request PCB to make
its site office at Eloor-Edayar functional with necessary infrastructure such as telephone, fax,
lab, vehicle, lab technicians and other staffs for periodic and surprise inspections and
collection of samples for analyzing for ensuring compliance of environmental laws. LAEC
demanded that the office at Eloor be made functional with necessary infra- structure. LAEC
noticed with pain that no steps have been taken by the Board to ensure round the clock
effective functioning of the Site office at Eloor by providing sufficient staff and infrastructure
370
including Lab facilities and vehicle for inspection even after elapse of nine months. LAEC
has passed several resolutions on the subject since 12/11/2004. The constant follow up by the
committee has not yielded any result. Follow-up Resolutions of the 18th meeting held on
21/12/2004,and 14/03/2005and the assurance by Chairman, PCB are yet to be materialized.
The only action reportedly taken by the Pollution Control Board is to appoint a peon and an
Asst. Engineer and a typist. There was no Telephone connection. Not even a facility of a
urinal for woman staff to work. No vehicle has been provided for inspection. Considering all
these aspects LAEC requested to first to relocate its office in any of staff quarters of FACT,
which remains vacant.LAEC took initiative to get a quarter allotted and now PCB has a
building to house a full-fledged office at Eloor. But no steps are taken to provide laboratory
facilities and to collect samples. The office has no typewriter. The office remains closed after
5 PM. The posting of staffs serves no purpose except incurring additional expenditure. The
recommendation of LAEC for 24 hours functional office is to monitor the industries round the
clock to keep a check on the polluters. KSPCB has not been sincere to comply by this
demand. The conduct is strongly disapproved.
The LAEC detected colour change in the river Periyar on 21-11-2004 from the portion
starting from M/s CMRL to downstream up to Eloor ferry. The committee discussed the
report appeared in the press on the large-scale fish kill in river Periyar. The cause for fish kill
was attributable to the discharge of industrial wastes. The Industries situated in the banks of
the river were suspected to be the culprits of the fish kill. LAEC has taken strong exception to
such disposal of waste into Periyar River and condemned such act in strongest terms. The
committee decided to take strong action against persons resorting to such disposal of waste in
future causing damage to the marine life. All the industries were advised not to resort to such
short cut methods of disposal of waste The public was also requested to raise voice against
such indiscriminate discharge of effluent into the river Periyar and help LAEC to capture the
culprits red handed. The local people of the area handed over a sample taken by them from
the final outlet of CMRL. The committee analysed the sample (green coloured effluent) and
found pH 4.4, SS 1410 mg/l, Iron 12238 mg/l, Lead 4.29 mg/l, Chlorides 33500 mg/l and
Manganese 11.2 mg/l. The committee decided to watch CMRL closely as the result indicated
discharge of raw effluent in to Periyar.
The committee during its inspection found the parameters fixed in many consent orders
falling short of important parameters. The Board while issuing consent order seems to
have not considered various aspects such as the nature of the product, various chemicals
used for the manufacturing the product, the composition of the effluent etc with the result
the parameters fixed failed to content pollution. The Board while issuing consent has
unfortunately not applied its mind with specific reference to these fundamental aspects. It
is observed that the Cochin Mineral Rutiles ltd is producing Synthetic Rutiles and by
product Ferric Chloride using raw material such as Ilmenite, Coke, Hydrochloric Acid,
Fuel Oil, Chlorine. The effluent generated in the manufacturing processes therefore would
necessarily contain high Iron, Chlorides, Copper and TDS. The consent issued by the
Pollution Control Board therefore necessarily ought to have prescribed the parameter for
Iron, Chloride, Copper, TDS etc in the treated effluent. Unfortunately these important
parameters are not seen included in the consent. Similarly Merchem Limited, Eloor is
producing Accelerators, Antioxidant, Sodium Sulphate by utilizing raw materials. Their
effluent necessarily contain COD, Mercaptans, Sulphates, TDS, Chlorides along with
other parameters. Similar is the case with Merchem Ltd., Edayar. The unit is
manufacturing the products such as F, ZDC, ZDBC, ZBEC using raw materials such as
371
Carbon disulphide, Zinc Oxide, Zinc Chloride, Di Ethyl Amine, Di n Butyl Amine, Di
Benzyl Amine, Caustic Soda, Hexamine, DPG, MBTS and the effluent necessarily contain
COD. Binani Zinc Limited is producing Zinc, Sulphuric Acid, and Cadmium by using raw
materials such as Zinc Concentrate and Fuel. The effluent necessarily contains Iron and
Nickel. Another Industry namely Minar Chemicals is manufacturing Precipitated Silica
and Sodium Silicate by using raw materials Sodium Silicate, Hydrochloric Acid,
electricity, Caustic Soda, Quartz Powder, Firewood. The effluent would contain Chloride
and therefore parameter should be fixed for Chloride.
The consent issued by the Pollution Control Board ought to have prescribed limits for these
parameters in the consent order to the aforesaid companies. However these necessary
parameters have not been fixed to these units, which is a serious lapse on the Board. In the
above circumstance LAEC resolved demanding PCB to undertake the exercise of revising the
parameters issued to each chemical industries in Eloor – Edayar area case by case and include
the parameters, which are necessary, having regard to the nature of effluent generated by the
units. This exercise is yet to begin.
The committee also resolved to undertake river monitoring periodically and took samples
from the outlets open to Periyar for discharge by the industries. It is noticed that many of the
industries have direct access to Periyar and do not have compound wall. The wild bushes kept
these outlets open to River Periyar unvisible. The committee directed the industries situate on
the bank of the River Periyar to clear bushes and other wild growth from their boundaries to
the river mouth in order to make the outlets visible. LAEC conducted a river survey through
Periyar in Boat and also Eloor- Edayar industrial belt with the officials of DIC to assess the
damage caused to the Periyar and in the areas of the industrial belt by the indiscriminate
discharge of effluent and solid waste to the river and land by the industrial units. During this
joint inspection, the team found industrial waste dumped in open land behind Arjuna Natural
Aromatics and illegal sand mining at different points namely Chirayamkadavu in Alangadu
panchayat; Methanam in Eloor Panchayat; point near to V.R Woods; point near to Yeoman
Bone Industries and Binani Zinc Ltd. The inspecting team suggested that the officials of the
DIC should either block the road by fixing post across the road at four locations, viz., near
Sud Chemie, Arjuna Natural Extracts, Neptune Readymix Concrete (P) Ltd; across the road
between Binani Zinc and Sud Chemie or in the alternative to permit the PCB to fix the poles
and block the road in order to stop transportation of sand illegally and to protect river from the
discharge of trade effluent from outside. The inspecting team appraised the DIC officials of
the need for having a setback of minimum 20 m from the factory building to the river bank to
protect the river from dumping waste both solid and liquid effluents. The officials have
agreed to take up the matter with higher officials. But actions are yet to be taken.
LAEC also during its inspection found an internal industrial road being blocked near to the
Cochin Fertilizers. This road is the only one, which gives uninterrupted access to various
industrial units. By blocking the road the regulatory agencies often face problems for
inspecting industrial units and are compelled to take diversion. There is absolutely no
justification in blocking public road for the exclusive use of one or two units. The space
372
occupied by the road if allotted to any unit has to be resumed and the road should be opened
forthwith for public use. If any private person for the use of their unit has blocked the road
illegally that unit should be directed to remove the obstruction forthwith. It is also brought to
the notice of the LAEC that similar road blocking can be seen at the road leading Merchem,
Edayar. LAEC resolved that all illegal blocking of internal roads obstructing the traffic
have to be removed.
The LAEC found it necessary to monitor the water quality in river Periyar round the clock. It
noticed that the Board has no facility for monitoring the water quality of river Periyar when it
has indiscriminately allowed the industrial units to discharge the effluent to river Periyar.
Having regard to the complaints of polluting the river water by the discharge of untreated
effluent from industries, the committee resolved to request PCB to setup a permanent lab unit
to monitor water quality in river Periyar .The committee decided to take initiative in the
matter and decided to approach the Dist collector Ernakulam, Pollution control board, District
Industries Center and concerned local bodies for materializing the proposal. By the efforts of
LAEC, an extent of 11.250 cents of land has been earmarked in Eloor Ferry and the
concerned Tahsildar & Village Officer have submitted their recommendations for the
assignment of this land in favour of PCB. The process is now almost in the final stage. What
remains is only an order from the District Collector allotting the land accepting the
recommendations of the Tahsildar & Village Officer for allotment of the said land in favour
of PCB. A letter addressed to the District Collector enclosing copies of the recommendations
of the Village officer & Tahsildar has been sent.PCB should take follow up action for
getting the land allotted.
The committee found all units in Eloor Edayar belt depending Periyar for meeting its water
requirement. The water intake of these industries however has no relation with their actual
requirement. Water balance of each unit will show their consumption at exceedingly high
side. There seems to be no control over this consumption. The levy of water cess and its
collection needs to be calibrated and effective measure to be taken to control over
consumption. All the units taking water from river Periyar should be asked to install sealed
water meter at the intake point and the Board officials should take meter reading bimonthly
and cess should be collected on the basis of the meter reading. Each units should be given a
minimum allotment and consumption in excess of that should be assessed at high tariff. The
present practice of collecting cess should be revamped as that causes sever loss to public
exchequer. A strict cess collection on the basis of its consumption will be a check on over
consumption.
LAEC found to its shock that the Pollution Control Board has not carried out air monitoring
for over three years. According to the Board the staffs that conducted air monitoring are now
in the early period 50’s and cannot climb the stacks owing to health problems. The Board
admitted that it has not taken samples for last 2 years and more and that they relay on the
reports furnished by the companies from the accredited labs. LAEC disapproved this
practice which to say the least is blatant breach of its statutory function.
Eloor-Edayar area being an industrial belt with medium and large scale industries having a
minimum of at least 50 stacks ranging at the height from 15 – 75 m, the air monitoring,, noise
level monitoring and ambient air quality monitoring etc are necessary especially in view of
serious complaint from public. The Committee being concerned about the frequent incidents
of fugitive emission in Eloor, Edayar belt, requested PCB to move its Mobile Ambient Air
Monitoring system to Eloor, Edayar Area. It is noted with great pain that this mobile unit has
373
not been utilized in spite of huge investments being made for procuring the unit. The Board’s
plea that the unit requires calibration and that there is no Annual Maintenance Contract
existing etc are not genuine to justify its non-use. The cost of Ambient Air Monitoring can be
met from the factories, who have failed to make adequate arrangements for stack monitoring
by the PCB and who have failed to adhere to the parameters under the consent orders. The
Board also can raise necessary fund from the Units having stacks, which are found to be
causing environmental pollution. In any case, PCB being a regulatory body to monitor the
industries cannot be justified for their inaction on the plea of lack of funds. It is to be noted
that the system is capable to monitor Sulphor dioxide (SO2) Hydrogen sulphide (H2S), Carbon
monoxide (CO), Hydrocarbons, Methane, Particulate matter, Mercaptans etc. In fact these are
all the common gases / substances found in the ambient air in the area, raising significant
complaints from the public.
Fugitive emission from various industries in Eloor Edayar caused serious air pollution to the
people living on the southern side of Pathalam Bridge.. The smoke prevalent in the air was
thick even blocking the vision. The residents felt discomfort in breathing. They described the
smell as those of burned hair. Some people point towards FACT and some against Merchem
Edayar and some under total confusion. The smell was of combination of smokes from
various factories and for that reason no one could specifically accuse any particular industry
by name. But the fact is that the emission of smoke was beyond all parameters. The incidents
of fugitive emissions have caused health hazard to people of the locality and many were
admitted in hospital for primary treatments. The failure to Monitor Air Quality by the PCB is
a serious lapse deserved to be condemned. LAEC therefore resolved to request the Board to
take immediate action to bring under control the alarming Air Pollution in Eloor Edayar Belt.
The practical difficulty highlighted by the Board is not a matter irresolvable. M/s Accurate
Instrumentations and control engineers Pvt Ltd, Valanjambalam is a competent institution
locally available that can attend to any complaints of mobile unit. The committee request the
Board to ensure this mobile unit made operational and is taken to Eloor Edayar belt.
During the inspection of various industries it is noticed that the conditions of the employees
working in various industrial units particularly industries engaged in bone meal, hoofs, tallow
etc. are very pathetic. There was total lack of facility for their basic requirements including
facilities for drinking water. Appreciating the pathetic state of affair of the working class
LAEC decided to take up the matter with the Dist. Medical officer, inspectors and boilers and
other labour officers for ensuring better working amenities. The units have now started caring
the employees.The action taken by the committee was a great relief to the working class.
Bone meal industries in Eloor –Edayar was causing serious odour nuisance. On inspection of
these units, the scene was very horrifying. The inspection team could not go near to these
units due to unbearable foul smell caused by the decay of bone / flesh. The officers of the
PCB accompanying the team some how managed to enter into all these units and found
accumulation of worms and flies inside the units at many places caused by decaying raw
material for want of proper storage and house keeping. There is a huge backlog of raw bones,
collected over a period of 15 days or more lying in these units without proper confined
storage. This heap of raw bones is causing health hazards and great odour nuisance in the
entire area giving rise to consistent complaints from the adjacent units / local community.
The nuisance from these units has to be taken serious note of. It is being caused on account of
their failure to de-grease and process the raw bones on the same day of its arrival. The de-
374
greasing process takes place not on first come first basis. The consent conditions though
stipulate that the raw bones brought to the Units should be processed on the same day itself, it
has been found observed in breach. The violation of this consent condition makes the ambient
air unfit for human habitation. In order to ensure the compliance of the condition in the
Consent such as de-greasing and processing of the raw bones on the same day of its arrival
and to avoid odour nuisance caused by these units, it is necessary to have a stringent measure
requiring the units to provide a Bank Guarantee ranging from Rs. 2.00 – Rs. 5.00 lacs
depending on the size / turnover of the Units for strict compliance of consent conditions
imposed to control odour nuisance .The Bank Guarantee shall be forfeited, if the Unit is found
violating the consent conditions. LAEC have unequally told these units that they cannot be
allowed to function in the manner as it is now being done and that whichever unit fail to
content air pollution will be closed. A meeting was convened to discuss the odour nuisance of
Bone meal units in Eloor-Edayar belt. Dr.Claude Alvaris , Member ,Supreme Court
Monitoring Committee was the special invitee to the said meeting.. Dr.Claude Alvaris
stressed the need for modernizing the bone meal units in the context of changes taking in all
fields of human activity. He promised all assistance including expert advise to the units ready
for change. He stressed the need to arrest the odour nuisance within the outer limit of three
months failing which he cautioned that the defaulting units would have to face closure order.
The Bone meal units agreed to bear the expenses for getting the assistance from expert and
requested LAEC to take initiative for arranging experts for technical advice. The industries
collectively requested for time to implement certain measures to control the odour nuisance
.The bone meal industries have submitted a statement disclosing the details of the
improvements made by the units and undertaking that in case of any failure to content
pollution, agreeing to forfeit the bank guarantee that may be required to be furnished.
The committee deliberated on the proposed common TSDF at Ambalamedu. Members
expressed their unhappiness on furnishing Rapid EIA and DPR late to the committee by the
Pollution Control Board despite being aware of the fact that TSDF matter is one of the
references of the LAEC. Owing to lack of time to study the project report and its suitability,
members resolved to request to PCB 15 days time to offer LAEC’s comments in response to
the notification. Accordingly Chairman addressed a letter to Pollution Control Board and also
will appraise Supreme Court Monitoring Committee these aspects. The committee deliberated
on the rapid EIA and DPR on common TSDF proposed to be established at the premises of
FACT at Ambalamedu. The panel of Scientists assisting LAEC expressed that a local
inspection of the site is necessary to evaluate the feasibility of the project. The committee
resolved to have a local inspection of the proposed site with notice to KSIDC on 25th April
2005 at 3 pm. Accordingly the site was inspected and discussed its feasibility with the
scientists panel. LAEC submitted the following comment to SCMC and PCB and KSIDC,the
nodal agency of the project.
1. One major complaint against the site was regarding the population in and around the
proposed site. The Committee could not find any appreciable population residing
within a radius of 600 metres.
2. The proposed site comprises an area reclaimed by Gypsum dumped by FACT and
adjacent laterite land.
3. Down the site there is a vast extent of wetland with no cultivation. The lake and
adjacent forest in the FACT premises are not affected by the setting up of TSDF since
both these are at a safe distance of 500 metres.
375
4. The lie of the land is in a zig-zag manner. Having regard to the nature of land, the cost
of land development is likely to be very high, which may result in escalation of the
project cost.
5. The test of soil conducted by the KSDIC is through taking samples from a small pit.
For a project like this, the sample ought to have been taken by boring.
6. A two-tier dyke to protect the area from the impact of fugitive loss of hazardous waste
is essential. This is to be constructed with earth removed from the site and selected
vegetation should be raised therein.
7. The monsoon in Kerala stretches for more than half of the year. There must be
temporary storage facility to store the hazardous waste before transferring to the TSDF
after laboratory tests. The quantum of the hazardous waste for one year therefore, has
to be initially assessed to decide the area required for temporary storage and its design.
8. The concept of covering the TSDF by tarpaulin or any such other material during
rainy season seems to be very theoretical and difficult to be executed. Detailed study
has to be made and more sophisticated and practical solutions have to be found out to
protect the site from heavy rains.
9. Kerala State Pollution Control Board being a regulatory body empowered under
various statutes to enforce law should not be a party to the project which is essentially
floated by a company i.e., Kerala Enviro Infrastructure Ltd. Involvement of PCB
officials with the administration / constitution of the company either as a Director or in
any other capacity will erode the confidence of the general public and also would
create a situation of having no regulatory body to be made accountable for
implementing control measures.
10. Air and Water Risk Assessment and Management have not been made in respect of
the proposed site. The flow of water is towards the down stream reaching the creek,
which is affected by tidal waves. A detailed Environmental Risk Assessment (ERA)
should be conducted on Water and Air pollution.
11. The project has not discussed the dust control facility. The quantity of waste to be
incinerated is 3000 tonnes per month. Such a huge quantity is bound to cause serious
air pollution. Wind direction, its speed etc., are therefore matters to be studied in great
depth before finalizing the project.
12. The compatible hazardous waste has to be identified with transit storage.
13. The laboratory proposed should have NABL accreditation.
14. The waste being hazardous at every stage of its handling great care has to exercise.
15. To monitor the functioning of the TSDF, a committee of stakeholders like prominent
non-political person from local area; non-political NGOs; representatives from local
bodies; scientists & experts from reputed institutions like CUSAT etc. have to be
376
essentially involved by way of a participatory monitoring mechanism and effective
implementation.
16. The concern of the community is that in the event of any unforeseen calamities and
untoward incidents, which would compensate the loss suffered on account of the
operation of TSDF. A corpus fund therefore, has to be created which should be made
at the disposal of the KSPCB for immediate utilization for relief and other contingent
uses to cope up with all such situations. A fund of Rs. 5.00 crores to be earmarked for
this purpose and it should be deposited in a nationalized bank. A portion of this fund
has to be utilized to provide community facilities and awareness on disaster
preparedness.
17. The Rapid EIA falls short of many important aspects such Risk Assessment &
Management, Soil tests, Air and Water pollution, zigzag nature of land, temporary
storage of hazardous waste, risks during transportation, laboratory requirements,
laboratory waste, inventory of hazardous waste, its density, compatibility of various
hazardous waste, down stream contamination, drinking water contamination, strategies
for combating heavy monsoon, dust and emissions etc. Cochin University of Science
and Technology (CUSAT) is one such institution, which can be entrusted to prepare a
detailed Environmental Impact Assessment & Environmental Risk Management study.
18. The best practices and best available technology in other places especially the Naroda
Eco Park facility should be studied in detail before finalizing the project and its
design.
In the matter of providing water to the affected community in Eloor Panchayath viz.,
Ward nos. 1, 2, 3, 4 & 17, the Committee conducted a survey of these wards and prepared a
list of affected community, for whom the drinking water is to be provided by the defaulting
companies. The committee found the affected families as 2143 in ward number 1 to 4 and 17
of Eloor Panchayath. There were 1250 wells out of which 926 were contaminated by the
industrial pollution. . The residents now wholly depend the public tap facility to meet their
water requirement. In veiw of the fact that the people had to depend tap water owing to the
contamination of their wells owing to the industrial pollution, the committee unanimously
resolve to request the Board to initiate appropriate action directing the companies, namely
Merchem, HIL, IRE, and FACT to provide drinking water to these families at the rate of 500
litres/day free of cost as has been done in the case of Binani Zinc Ltd to supply water to
people of ward number 15 of kadungaloor Panchayath. Each family should be provided with
separate meter connections and consumption of water in excess of 500 litres should be
directed to be born from the respective families. SCMC has directed that the aforesaid
companies should be asked to provide water to the affected families. In compliance of the said
direction, LAEC has completed the survey and identified the affected families. Further action
from the Board is now awaited. LAEC request the Board to call a joint meeting of the
companies, LAEC and Board to finalize the modalities for providing drinking water including
the estimation of the cost and raising of the fund to be contributed by the companies namely
IRE, Merchem, HIL and FACT. The survey report forwarded to the Board for further
follow up actions which LAEC expects the Board to finish on war footing having regard
to the urgency.
377
The committee has resolved that the Board should revise the accreditation given
to labs and insist them to obtain NABL accreditation.
The Board should also be beware of Environmental consultants who have more
concern to the pockets of the industrialists than the environment. There are environmental
consultants who misguide even those units who want to implement adequate pollution control
measures but ill advice them with deceptive technologies pretending as their saviors. These
consultants can be well identified by checking the efficiency of the pollution control measures
of each units and their track record of violations with reference to seeking the details of the
consultant whom the companies have engaged. The Board should display its wisdom to
expose such quakes and hoaxes, in the best interest of the public and in the interest of
the innocent people in the industry from being cheated.
The other concern of LAEC is the radiation from Indian Rare Earth. The radiation
effect from this unit range between 24 to 82 msV at the points starting from Gypsm yard of
FACT and along the route at FACT junction, HIL, North gate of FACT, reaching at IRE
southern closed gate. The maximum reading of the radiation was recorded at the southern
closed gate of IRE itself. The radiation exceeds the limit and pose great health hazard. This is
matter call for immediate attention. The committee recommends relocation of the thorium
waste stored in huge quantity, which is the source of radiation.
LAEC could only be a barking watch dog .It had no teeth to bite. But that is not the
case of PCB. It has teeth and could be very effective. But alas! the Board has been a silent
onlooker. The committee hope, the situation would change and PCB will come to life like a
phoenix and state government will make the Board functional providing infrastructures to
cope up with the growing demand for modernization to keep pace with time.
LAEC during its surprise inspections could identify major culprits in the industrial belt
that caused environmental pollution detrimental to the land, water and air. The inspection
reports of these units will give an insight how these industries caused damage to the
environment and the efforts taken by the committee to enforce the law. The following are the
reports of the companies inspected by the committee.
BINANI ZINC LIMITED, EDAYAR.
Name of Industry
:Binani Zinc Limited, Edayar
Date of inspection
:02/12/04; 23/01/05; 23/03/05;
29/03/05; 01/04/05; 20/04/05;
11/05/05; 08/06/05; 20/06/05;
08/07/05; 03/08/05
Products:
Name
Quantity (metric tonne/yr)
Zinc
30000
378
Sulphuric Acid
51000
Cadmium
65
Raw materials:
Zinc Concentrate (imported) : 66000 MT/YR
Fuel
: 5.1 KL/day.
Process:
Zinc Concentrate is roasted in a roaster in presence of air to form zinc oxide and sulphur dioxide.
Calcine and hot dust laden gases are the roaster products . The hot gas is passed through a series of
equipments like waste heat boiler, cyclone, hot gas precipitator , scrubber, star cooler and wet gas
precipitator for cleaning the gas . Then cleaned gas is fed to DCDA plant where sulphur dioxide is
converted to sulphur trioxide and sulphur trioxide is absorbed in absorbing acid to produce 98.4 %
sulphuric acid.
The calcine comes out of the furnace as overflow and is cooled , powdered and pneumatically
conveyed to storage silos. Calcine contains easily soluble oxide form (ZnO) and zinc ferrite form
(ZnO.Fe2O3). Leaching of Calcine is carried out to dissolve maximum of zinc and valuable elements
such as cadmium. The impurities in the calcine are sulphates of lead, silver, calcium, barium, iron,
aluminium, arsenic, antimony, gellenium etc and soluble elements such as copper, cadmium, nickel,
cobalt, tellurium. During leaching ZnO gets converted as Zinc sulphate . Leaching is carried out in
neutral condition. During leaching hydrolysable impurities such as iron, aluminium, arsenic, antimony,
gellenium get hydrolyzed and removed. After leaching the slurry goes to a thickener where Zn SO4
solution is separated from the residue. Impurities like insoluble sulphates and hydrolyzed elements are
removed through underflow of thickener and overflow is Zn SO4 solution with soluble impurities like
copper, cadmium, nickel, cobalt, tellurium etc.
Impure Zinc sulphate is purified in purification section.
The underflow of the thickener containing Zinc Ferrite and the excess Calcine is taken to residue
treatment plant where the residue is leached using 50 gm / liter sulphuric acid. Zinc Ferrite breaks
forming Zinc Sulphate and Ferric Sulphate. This Ferric Sulphate is precipitated as sodium Jarosite
using Sodium Sulphate at controlled acidity. Jarosite slurry is settled in a thickener and the underflow
of the Jarosite slurry is filtered in a drum filter and stored in a storage pond.
The recovered ZnSO4 solution is neutralized to hydrolyze remaining iron and to precipitate other
hydrolysable impurities. After hydrolyzing the solution goes to leaching and joins main stream.
Purification:
In purification elements like copper , cadmium, nickel, cobalt, thallium which are more electro
positive than zinc are displaced from the solution by the addition of zinc dust. Purification is carried
out in two stages – cold purification and hot purification. Cold purification is carried out at 55- 60o C
by using cold zinc dust. Here copper, Cadmium, Tl are removed by the solution filtering using a filter
press. The cake is treated in the releach section to dissolve out cadmium. The cadmium solution is
purified for copper, nickel, Tl etc. and sponging out with zinc metal produces cadmium. The cake
generated ( primary cake leach residue) is stored. Cadmium sponge is fed to cadmium furnace and
cast into pencils and plates. The filtrate after called purification is passed through a heat exchanger at
75 0 C. In hot purification Zinc dust is added to sponge out cobalt , nickel etc and filtered in a filter
press. The hot filtrate is sent to Electrolytic cooling and gypsum control plant for gypsum removal
using a clarifier. The hot purification cake is leached at controlled acidity to recover excess zinc dust
379
present and filtered. The filtrate joins main stream in leaching and the residue – cobalt cake
(Secondary cake leach residue) is stored.
Electrolytic Plant: –
Zinc deposited on both sides of the pure aluminium cathode in electrolytic
cell is stripped off and melted in an induction furnace of 30 MT holding capacity. Zinc ash is
generated in this plant. Molten zinc is pumped from furnace to casting moulds.
Waste:
Liquid : The liquid effluent of 550 m3 /day generated from process plant utility services, DM plant and
Supernatent solution from Jarosite pond is discharged into periyar river after treatment.
For treating the effluent an effluent treatment plant consisting of equalization tanks, neutralization
tank, Clariflocculator and collection tank are provided.
Solid:
I. Dry Jarosite from leaching and purification plant containing iron, Zinc, Lead, Cadmium,
Copper, Nickel pumped to Jarosite pond.
II. ETP sludge for disposal in Jarosite pond.
III. Gypsum and anode used from cell house – Jarosite pond.
IV. Primary and secondary cake leach residue.
V. Zinc ash from Zinc melting furnace.
VI. Nickel cake from leaching and purification plant.
VII. Thallium cake from leaching and purification plant.
VIII. Spent V2O5 catalyst
from roaster and acid plant.
IX. Lead dross from cell house.
X. Spent oil from captive power plant.
Findings:
1. Source of water is Periyar River and the water consumption is 2156 m3/ day. The
water utilized for cooling purpose is recirculated .The quantity of discharge is 550n3 /
day .The company authorities reported that a part of the supernatant from Jarosite
pond is used for slurrying the Jarosite cake.
2. Sources of trade effluent are Roaster acid plant utility services. For treating the
effluent and supernatant from Jarosite, an effluent treatment plant consisting of
equalization tank, neutralization tanks (where lime slurry is added through auto
control valve) clarifloccelator/tube settler, and final collection tank are provided. In
the final collection tank pH is brought down to the range of 6.0 to 8.5 by dilute
sulphuric acid .The effluent after treatment is discharged into the river Periyar in the
downstream of Pathalam bund, through v-notch for flow measurement.
3. The hazardous waste of Jarosite residue is made into a slurry and pumped to the
Jarosite ponds for settling. Jarosite ponds are HDPE lined impervious tanks. The
supernatant liquid is pumped back to the equalization tank for treatment in Effluent
Treatment Plant. There are three Jarosite ponds capped. The pond no:4 is being used
now.
4. Waste oil is stored in shed for disposal to the registered recycler.
5. Hazardous wastes for disposal to recyclers/sale as per authorization are stored in
roofed shed.
6. The company has obtained boards consent under the water act upto
31-12-04 for
discharging 5,50,000 litre/day effluent into Periyar river. The production rates are
specified as Zinc –2500 t/month, sulphuric acid- 4250 t/months (by product) and
cadmium-5-6 t/month.
7. The source of emissions are chimneys in sulphuric acid plant, zinc melting complex,
furnace of cadmium section two boilers, two captive power plants.
380
8. The company has obtained Board’s consent under the air act upto 31-12-2005.
9. On line monitors are provided .air pollution control equipments are provided in
chimneys.
10. Obtained authorization dated 16-3-01 under HW rules to operate a facility for
collection, storage and disposed of hazardous wastes
11. During inspection an 02-12-04 an unauthorized outlet discharging trade effluent into
land at a distance of about 10m from the river Periyar, in the premises of the factory at
the rear side of the bungalow was detected. Effluent is seen stagnated near the end of
the pipe. The land was found reddish in colour. Vegetation around the area was seen
damaged.
The origin of the outlet was traced back and found open drain adjacent to the capped
Jarosite ponds. Photographs were taken and samples of effluent and soil were
collected for analysis. The open channel originating near capped pond leads to
underground pipe line with deep manholes. Reddish sludge was seen in manholes.
12. Reddish material was seen on land near the culvert in parur-pathalam road. The storm
water flowing to paddy field, Edayattuchal, now being transformed into a waste
dumping yard. Reddish coloured material and reddish coloured effluent was noticed in
vast area of edayattuchal. Soil samples were collected for analysis. For tracing the
source of discharge in to the culvert, the inspection team again inspected the premises
of capped ponds. Indication of effluent pumping into land was noticeable.
13. The company have constructed a storm water drain for carrying the storm water from
vacant land near capped ponds, jarosite pond no.IV and domestic effluent from staff
quarters into the river directly.
14. Delay pond is not provided in the storm water drain.
15. Water sample was collected from this storm water drain for analysis. The report of
analysis indicates that the storm water is highly acidic with pH-3.5, Zinc 25mg/l and
iron-20 mg/l .No treatment is provided to the storm before discharging into the river.
Recommendations:
1. A water meter shall be installed at the inlet lines for measuring the total water
consumption for industrial purpose, supply to quarters and processing requirement.
2. For measuring the total intake from Periyar River sealed water meter shall be provided
at the pump house.
3. The actual quantity of effluent generation and discharge are to be assessd. Flow
measuring and recording devices are to be provided at the inlet and outlet points of
effluent treatment plant and at the authorized outlet
4. Delay ponds shall be provided in all storm water drains and monitored.
5. All the storm water drain shall be included in the consent order specifying basins
limits for all the pollutants present in the industrial effluent generated by the company
6. Delay ponds are not provided in the drain constructed for discharging storm water
from jarosite pond areas and quarters. Contaminated storm water and domestic
effluents from quarters reaching the drain are flushed out immediately into the river.
The report of analysis of storm water collected from the drain indicates that the pH is
very low high concentration of Zinc (25 mg/l) and Iron (20 mg/l). Hence the direct
discharge of this storm water into the river shall not be permitted, without treatment.
7. The whole quantity of supernatant liquid from jarosite pond is reportedly returned to
the e-t-p by pumping for treatment .A log book shall be maintained at the pump house
of pond no. IV for recording the quality of effluent pumped back during each shift.
381
The quantity of supernatant liquid returned to the process plant and raw effluent
collection tank shall be recorded.
8. Chances of overflow of supernatant liquid from pond no:IV during monsoon is
stopped temporarily to some extent by increasing the height of the side walls .As the
ponds are getting filled, chances of overflow of jarosite pond cannot be ruled out
during heavy rains. The company may seek alternate options viz treatment of overflow
using full fledged Effluent Treatment Plant near the premises of jarosite ponds or
transporting the jarosite cake as solid residue to the disposal pond etc.
2nd report on Binanai Zinc Limited, Edayar
(The minutes of 12th meeting held on 3-12-2004)
Local Area Environmental Committee conducted a surprise inspection at Binani Zinc Ltd in
Edayar industrial belt on 2nd December 2004 from 10.00 am. The inspection team during its
combing operation in and around jarosite pond, discovered an illegal effluent outlet
approximately at a distance of 10 metres from the bank of Periyar river in the premises of
Binani Zinc Ltd.. The effluent from the said illegal outlet was seen discharged into an open
land. The land was found reddish in colour and a water channel carrying the effluent from the
land to the river was clearly visible. On dipping a stick into the said land, slushy material at a
depth of 30 cm could be seen accumulated. Deposit of red particles was seen in the
surrounding areas of Periyar close to the outlet. The vegetation in the water channel and in
and around the land was seen damaged presumably on account of the toxicity of the liquid
discharged in to the land.
The team made an endeavor to trace the origin of the outlet by back tracing .The origin of the
outlet was found at land adjacent to the capped pond .The silt in the water channel at its
source was found red in color. The open channel after taking some diversion and at the point
of pond no 4 continued further down underground through a concrete pipe providing 8
manholes at different places having depth at the range of 7 to 12 feet approximately. The
water and silt collected in these manholes were also seen red in color. The land/sand color in
the area as a whole was not red. However the color of the silt seen in the drain was reddish.
The inspecting team collected samples from various points. The lab report of the collected
samples is awaited.
The inspection was conducted in the presence of senior officials of the company namely Dr.
K Sasi , Mr. Roy Kurian, Mr. Sudheer, Mr. Roshan . They admitted that the outlet detected by
the team is unauthorized. The company has not provided the sketch and plan of the drainage
and the purpose for which it was being used to the pollution control board.
The outlet provided in their premises leading its effluent to Periyar River is undoubtedly
illegal and unauthorized. The company officials could not explain the reasons for the red color
of the effluent seen in the manholes and at the dead end of the outlet. According to them it is a
storm water drainage constructed to prevent flow of rain water in to adjacent land and outside
their premises. Only two outlets are permitted by the Pollution Control Board, one for
discharging treated effluent and other for storm water through ETP.
The outlet detected by the inspecting team was found carrying effluent. The inspecting team
has directed the company official to stop using this drainage for any purpose and furnish a
382
sketch and plan marking the location of ponds and distance from Periyar River to the outlet
etc. The company officials also directed not to disturb the land or meddle with the present
character of the land.
The team found an open land close to Popular Industries with wet red color mud accumulated
with clear water channel indicating carrying of effluent into the adjacent plots. The opening to
this land was through an underground culvert across the Paravur-Pathalam Road. On the other
end of the culvert is the compound of the Binani Zinc. The inspecting team could find the area
wet with red color mud. The inspecting team accompanied the company officials went to the
premises and inspected that particular area. There were clearly visible signs of effluent being
discharged into the land where huge quantity of semi-dried sludge was seen. The vegetation
there was also seen damaged.
According to the company officials, there is possibility of pumping of effluent into their
premises from outside. The explanation was not satisfactory. The inspection team found the
company using open land for discharging effluent and making its run of through low lying
areas.
It is also found that there are few other water channels here and there in the premises of the
Binani Zinc Company containing sludge carry off in reddish color up to the bank of river
Periyar. There is no compound wall in the river side all along the company boundary facing
river.
M/s. Binani Zinc Ltd is found causing damage to the land and river by discharging untreated
effluent indiscriminately and causing irreversible damage. The untreated effluent with solids
carry of hazardous waste has caused extensive damage done to the land and water.
LAEC resolved therefore to place this report before KSPCB and request to take following
action forthwith.
To conduct random excavation in the company premises as to ascertain the quantum
of hazardous waste dumped in to the land and locations where it is dumped.
To direct the company to dismantle the illegal outlet provided under the ground.
To direct the company to remove the sludge collected at the points of outlets and got
accumulated at other various points.
To direct the company to construct a compound wall to prevent any discharge from
their premises accidental or otherwise to River Periyar.
To initiate all legal action including prosecution against the company after fully
complying with the procedure.
The company should be directed to clear the wild undergrowth all along the boundary
of the company facing the river.
383
Consented Parameters and limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
7
8
9
10
Characteristic
pH
Suspended Solids
Total Dissolved Solids
Sulphide
Fluoride
Sulphate
Cadmium (as Cd)
Zinc (as Zn)
Mercury(as Hg)
Copper(as Cu)
Unit
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
Tolerance
limit
6-8.5
30
2100
2
2
1000
0.2
5
0.01
2
Analysis Reports of the Effluent/ Sludge.
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No
1
2
3
4
pH
SS
TDS
Zinc
Unit
mg/l
: Binani Zinc Limited, Edayar
: 2-12-04.
:LAEC 45(Raw effluent tank)
LAEC 44(Authorized outlet)
LAEC 48(Unauthorized outlet).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Raw
Authorized
Unauthorized Tolerance
effluent
Outlet
outlet
limit as
tank
per
consent
3.4
6.8
4.2
6-8.5
180
8
17
30
13588
784
268
2100
550
0.19
11.0
5
384
5
Iron
6
Mercury
7
Cadmium
8
Copper
9
Fluorides
10 Sulphates
11 Sulphides
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No
Determinant
1
2
3
4
5
6
7
8
9
10
11
12
13
14
pH
Zinc
Iron
Lead
Mercury
Cadmium
Copper
Nickel
Arsenic
Flouride
Chlorides
Sulphate
Sulphide
Manganese
170
ND
8.4
--0.1
ND
ND
0.01
4.88
ND
ND
0.2
13.1
ND
0.01
2
3.27
0.57
ND
2
5000
600
125
1000
ND
ND
ND
2
: Binani Zinc Limited, Edayar
: 30-12-04.
: LAEC 39(River sludge near unauthorized outlet of Binani
Zinc Limited)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
River sludge near
unauthorized outlet
of Binani zinc
Limited
4.43
mg/kg 581.3
440.4
195
0.102
14.7
72.9
41.9
ND
ND
2000
245
ND
436.5
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No
Determinant
Unit
1
2
3
pH
Zinc
Iron
mg/kg
: Binani Zinc Limited, Edayar
: 2-12-04.
:LAEC 16(Jerosite - Drum cake)
LAEC 17(Copper cake)
LAEC 18(Cobalt cake)
LAEC 19( Sludge from Jerosite pond No. IV)
LAEC 20(Soil near Unauthorized outlet)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Jerosite Drum cake
(Hazardous
waste)
Copper cake
(Hazardous
waste )
Cobalt cake
(Hazardous
waste )
Sludge from
Jerosite pond No.
IV (Hazardous
waste)
Soil near
Unauthorized
outlet
3.5
573.5
56880
5.1
585.1
3505
5.7
609.4
1090
6.3
587.5
89400
3.8
486
110985
385
4
5
6
7
8
Lead
Mercury
Cadmium
Copper
Nickel
3616
0.05
373.9
212.9
8.7
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
Determinant
pH
Zinc
Iron
Lead
Mercury
Cadmium
Copper
Nickel
Name of the Lab
Sl.
No.
Determinant
1
2
3
4
5
6
7
pH
Zinc
Iron
Lead
Mercury
Cadmium
Copper
3820
0.08
723.6
196.4
809.6
2950
0.02
355.3
114.1
22.4
196
0.02
70.3
60.8
53.7
: Binani Zinc Limited ,Edayar
: 2-12-04.
:LAEC 21(Soil from the drain near security quarters)
LAEC 22(Sludge from jarosite pond no IV)
LAEC 23(Dry soil near pond no IV)
LAEC 24(Sludge near compound wall outside the company,
near culvert)
LAEC 25(Sludge near compound wall inside the company,
near culvert.)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/kg
Source
Date of sample collection
Sample Identification No
3400
0.06
662
165.8
269.7
LAEC
21
4.2
304
31920
57
ND
6.6
25
12.7
LAEC
22
9.1
597.3
37140
1063
0.04
405.5
202.8
58.4
LAEC
23
8.7
399
56430
233
0.03
9.3
60.3
64.4
LAEC
24
5.1
439.1
131050
443
0.05
23.7
90.8
36.2
LAEC
25
5.1
5000
49350
430
0.16
8.6
4.5
39.7
: Binani Zinc Limited .Edayar
: 2-12-04.
:LAEC 26(Near bamboo forest, inside the compound wall)
LAEC 27(Soil inside the compound, southern side of bamboo
forest near the motor shed).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Near bamboo
forest inside the
compound wall
5.5
mg/kg 321.8
18750
120
0.02
5.1
2.7
Soil inside the compound,
southern side of bamboo
forest near the motor shed
5.3
597.5
18050
90
0.06
3.5
274.7
386
8
Nickel
13.3
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
Determinant
pH
SS
TDS
Zinc(as zn)
Iron
Mercury(as Hg)
Cadmium
Copper(as cu)
Fluorides
Sulphates
Sulphides
14.2
: Binani Zinc Limited .Edayar
:3-8-05
:LAEC 261(Storm water drain outlet)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Storm water drain outlet
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
3.5
223
736
25
20
ND
ND
ND
0.3
625
ND
Tolerance
limit
6-8.5
30
2100
5
0.01
0.2
2
2
1000
2
387
388
389
390
MERCHEM LIMITED, ELOOR
391
Products :
Name
Quantity
1. Accelerators
: 3.8 TPD
2. Antioxidant
: 2.0 TPD
3. Sodium Sulphide
: 0.67 TPD
Raw materials :
Name
Quantity
1. Aniline
2. Acetone
3. Carbon disulphide
4. Industrial Methylated Spirit
5. Caustic Soda Lye
6. Sulphuric Acid
7. Hydrochloric Acid
8. Toluene
9. Soda Ash
10. Trichloroethylene
11. Chlorine
12. Hydrogen peroxide
13. Hexachlorobenzene
14. Sodium Sulphide
15. Sulphur
16. Elasto 245 oil
17. Sodium Sulphite
18. Ferric Chloride
19. Mixed Sulphate Salt
: 385 MT/Yr
: 176 ,,
:275 ,,
:83 KL
: 385 MT/Yr
: 110 ,,
: 20 ,,
: 22 ,,
: 10 ,,
: 25 ,,
: 66 ,,
: 40 ,,
: 45 ,,
: 35 ,,
: 110 ,,
: 2
,,
: 6
,,
: 4
,,
: 6
,,
1st report on Merchem Limited,Eloor, Dated: 14-12-2004.
1
LAEC team along with officials of PCB conducted a surprise inspection of
M/s.
Merchem Limited, Eloor on 9.12.2004 at 3.30 pm. The company was represented by Mr. Mariya Das,
a manager of the company. He took the team to the effluent treatment plant and explained the
operation of the effluent treatment system. He informed that the overflow from the secondary settling
tank would lead to the final polishing tank from where it is discharged into the authorized outlet. One
of the members of the inspection team Mr. Purushan Eloor climbed to the top of the secondary settling
tank to verify the statement. He found no overflow from secondary settling tank to justify the flow of
water to the polishing tank. He asked Mr. Mariya Das to explain as to how there is water flowing from
the outlet pipe of the secondary settling tank when there is no overflow from the secondary settling
tank, if the explanation of the operation of the system is true. Sri. Mariya Das could not offer any
explanation to this. The Environmental Engineer of the PCB, Smt. Chitra Kumari.D accompanying the
team told him that the system is working in a highly suspicious manner and the failure to explain water
flowing from secondary settling tank line to the final polishing tank without overflow from secondary
settling tank is a serious lapse on the part of the company in explaining the operation of the effluent
treatment system. The inlet water to the final polishing tank was showing a pH of 7.9. The tap water
pH was also showing 7.9. The team returned for a full-fledged inspection to another date.
392
2.
The visit of the LAEC members on 9.12.04 was only a pilot visit to get familiarized
with the system of effluent treatment plant of the company. The LAEC team was given a blue
print of the actual operation of the treatment plant and discharge of untreated effluent into the
authorized outlet during nights and other holidays bypassing the line by an informant. The
name and address of the informant for safety reasons is withheld. According to the
information provided to the LAEC, the company staff on seeing any inspection team from
PCB or other bodies would immediately open a valve of the tap water line at the Tea Center,
which will flow into the final polishing tank through the inlet pipe, which is meant for
conveying the overflow from the secondary settling tank to the polishing tank. The treatment
plant will be switched on simultaneously to give an impression that the treated effluent from
the secondary settling tank passes to the Polishing Tank and discharges to the Outlet.
3.
According to the informant there is another connection to the outlet for bypassing the raw
effluent from Effluent Collection tank before entering the mixing channel. According to the informant,
the PVC pipeline-carrying effluent from collection tank to the mixing channel has joints which is
easily detachable and during night and holidays the connection is detached at the point of mixing
channel directly diverting the untreated effluent to the outlet. This pipeline fixed at the authorized
outlet is unauthorized since it bypasses the polishing tank.
4.
The LAEC team conducted another surprise visit on 13-12-2004 in the presence of
Mr.Vishwanathan Works Manager, Dr.Jayapalan, Mr.Mariyadas and Mr.Kuriakose. On surprise
inspection of the Company by the LAEC team on 13.12.2004, the team observed flow of water into
the polishing tank. However, there was no overflow from the Secondary settling tank justifying the
inflow of treated effluent into the polishing tank from the secondary settling tank. The officials were
asked to explain this phenomenon of water flowing through the PVC pipe into the polishing tank
without any overflow from the secondary settling tank. There was no proper explanation to this. The
drain area around the secondary settling tank was found dry. After sometime the flow of water from
the PVC pipe of the Secondary settling tank to the polishing tank stopped.
5.
The team further found another pipeline leading to the outlet. The origin of this
pipeline was found adjacent to a tank, which according to the company officials was the old
final settling tank, which is not in use now. The team found that the PVC pipes carrying
untreated effluent from the raw effluent collection tank to the mixing channel is in a state of
detachable condition and that the untreated effluent on being pumped from collection tanks
could directly reach the authorized outlet without treatment. Thus, escaping and bypassing
the Effluent Treatment system.
6.
This information was passed to the Chairman of the LAEC who was not
accompanying the inspecting team. The Chief Environmental Engineer of PCB Sri. S.D.
Jayaprasad was also informed of these findings of the inspecting team, corroborating the
information of the informant.
7.
The Chairman arrived at about 1.45 pm and assessed the findings. The Chairman also
found that the detachable nature of the aforesaid PVC pipe. Under instructions of the
Chairman, the raw effluent pump was operated and upon detaching the PVC pipe, the effluent
was found directly going to the outlet bypassing the effluent treatment plant. Two
photographs were taken from this point one showing the PVC pipe and the other showing the
PVC pipe after being detached at the connecting points. The company officials objected for
photograph being taken. It was decided to record their objections.
8.
The Chairman and the members of the LAEC along with the other officials of the PCB
proceeded to the Tea Centre as per the confidential information details where they found a water
connection. A valve was seen in this water connection. Upon opening the valve, there was inflow
393
into the polishing tank through the PVC pipeline of the secondary settling tank, meant to carry the
overflow from the secondary settling tank. The officials of the company suddenly dispersed at this
point and the team had to wait sometime to get them back. Mr.Viswanath, Mr. Mariya Das, and other
officials could not explain this phenomenon and they pleaded total ignorance at to how this was
happening. Immediately the Chairman asked to get the Person-in-charge of the pipeline. After half an
hour, one Mr. M.P. Joseph, Asst. Manager-Maintenance came. By this time the water flow to aforesaid
pipeline had stopped. Mr. M.P. Joseph was asked to restore the flow of water through the pipe. He
refused to do stating that he does not know the whereabouts of the valve to be operated. When he was
asked to operate the pump taking water to the pipeline, he expressed his inability on the plea that the
pump is not working due to electrical problem. The company officials showed indifference thereafter
to cooperate with further inspection.
9.
The inspecting team found 19 domestic cylinders of Indane LPG kept near the flare
stack. According to the company these cylinders are meant to be used for maintaining flare
stack for 24 hours. When asked for the register of purchase of the cylinders, Mr. Viswanathan
sought time to produce the register as it is not presently available in the office.
10. The company is allowed to produce 1.10 MT of MBTS per day only. According to the
Company, an expert committee appointed at the instance of Water Appellate Authority has
recommended suggesting that subject to the permission from the PCB, the Company may be
permitted to run their plant at full capacity for testing the adequacy of the treatment system.
On this recommendation, the PCB has issued order dated 30.01.2004 permitting the company
to test the adequacy of the treatment plant at its full production capacity. The said order
however stipulated no time limit for production in full capacity. According to the company, it
is now producing 6.47 TPD accelerators, anti oxidants and sodium sulphide.
11.
According to the company the water requirement is 270 m3 per day of which 1 lakh
litre per day is discharged. The remaining is used for gardening, boiler feed, cooling plant and
for domestic use. It is beyond comprehension to imagine the use of such huge quantity of
water for gardening and other purposes while using only 1 lakh litre for production purposes.
12.
The Company is having a valid authorization under the Hazardous Waste
(Management and Handling Rules) 1989. The authorization is valid upto 24.05.2006.The
Hazardous waste is presently stored in a roofed temporary storage tank, the quantity of which
has to be assessed.
13.
The Chairman expressed his displeasure to the indifference on the part of the
company officials. The inspection team asked for their conference hall to discuss and prepare
report of inspection on the spot. The team was provided with the conference hall, where after
noting down the main points of inspections the team left the company around 6.30 pm
completing the inspection.
14.
The following observations and recommendations are made and the PCB is requested
to take appropriate legal action against the company, which is operating with an illegal outlet
to discharge untreated effluent containing hazardous waste:
1. The authorized outlet is having two pipelines, one from the polishing tank and the
other originating from the platform of mixing channel. The latter pipeline is
unauthorized.
2. The PVC pipeline connecting the pipeline to carry the overflow from the secondary
settling tank to the polishing tank is connected to tap water line at some point through
underground to ensure required pH in the alleged treated effluent discharged to the
394
polishing tank or to deceive the inspecting team that the treated effluent is perfectly
within the parameters by letting out the tap water to the polishing tank by operating
the valve at the Tea Centre.
3. The effluent pumped from collection tank to the mixing channel is through a PVC
pipe, which is easily detachable near the mixing channel point. The PVC pipeline
connecting the mixing channel and the authorized outlet is illegal and unauthorized.
That pipeline is being used for discharging untreated effluent directly to the authorized
outlet, which is reaching Kuzhikandam Thodu, a creek of the Periyar River.
4. The company is using domestic LPG cylinders for industrial use for operating the flare
stack.
5. The concentrated effluent coming from ‘MBTS and TQCBS’ production process is
seen collected in a pit close by an open drainage directly leading to Kuzhikandam
Thodu. The leakage from this pit is seen in the drain. A new stopper made of concrete
in the drain connecting this pit itself was leaking. The very same drain at a distance on
the way to Kuzhikandam Thodu is again connected with another effluent pit. This
drainage is unauthorized. Similarly, other small drainage capable to carry effluent is
seen in and around the flare stack.
6. The Merchem Ltd, Eloor is a company against which lots of complaints have been
received during the public hearing conducted by LAEC on 4-12-2004. regarding
discharge of untreated effluent. The PCB itself has issued as revealed from the records
many closure orders for violating the consent issued under the Water, Air Acts and
HW Rules. The device to let off untreated effluent clandestinely which is detected by
the inspecting team could not have been exposed but for the information given to the
LAEC by the informer.
7. The company is having a total production of 6.47 MT of accelerators, anti-oxidants
and sodium sulphide per day. Anti-oxidants and sodium sulphide are by-products.
The quantity of untreated effluent and the sludge are to be assessed vis-à-vis the
capacity & adequacy of the effluent treatment plant. There is no such study before
allowing the company to take production of its full capacity. And there has been no
review of the order studying the plant and its efficiency to treat the effluent.
8. The order of the PCB dated 30.01.04 permitting the company to take production in full
capacity relying on the Expert Committee Report without ascertaining the capacity,
adequacy and efficiency of the ETP is a clear example of dereliction of duty by the
PCB, being an order overlooking the statutory obligations of the PCB to contain
pollution. The company which is having in fact the consent to produce only 1.10
Metric Tonne of MBTS is allowed to take production in full capacity for nearly one
year under the guise of testing the adequacy of the treatment system. Such an order to
say the least, to a company which is handling hazardous chemicals and wastes is
totally unjustified and beyond the conduct of a normal person instructed in law
touching the Environment and Pollution.
9. M/s Merchem Ltd. Eloor is a industry manufacturing Organic Chemicals . The
compulsory parameters and the additional parameters stipulated in the Environmental
Protection Rules 1986 has to be scrupulously followed. Though there is no limit for
COD(Chemical Oxygen Demand)is prescribed, it is required to be monitored to find
out whether COD in a treated effluent is persistently greater than 250 mg/l. In the
395
event of such industry showing persistently greater than 250 mg/l COD, that unit
should identify the chemicals causing the same and in case which is found to be toxic
as defined in Hazardous Chemical Rule, the Board in such case has to direct the
industry to install tertiary treatment system, stipulating time limit. BOD (Biological
Oxygen Demand)shall be made stringent upto 30mg/l if the recipient fresh water body
is a source for drinking water supply. In the case of Merchem Ltd. being a chemical
industry dealing with Organic Chemicals, COD has to be tested in the effluent
persistently and if found exceeding 250mg/l the chemical causing the same is to be
identified. The KSPCB is directed to monitor COD and take further action as
stipulated in the parameter prescribed for such units.
10. M/s Merchem Ltd. Eloor is an industry dealing with Hazardous Chemicals and
generating Hazardous Wastes. It is required to satisfy environmentally sound
management of Hazardous Waste facilities as required under the provisions of the
Hazardous Waste (Management and Handling) Rules 1989. The limit of BOD
(Biological Oxygen Demand)in the treated effluent should be strictly limited upto
30mg/l since the recipient water body is the River Periyar which is a source of
drinking water supply. KSPCB has an obligation to ensure the treatment of effluent
facility of the company as fool proof before the company can be allowed to take full
capacity as it is now been permitted. Unfortunately this exercise has not been
undertaken .
11. The company for the aforesaid reasons cannot be allowed to function without
satisfying the LAEC and PCB that its operation and the devices in the company
including the ETP is capable of containing pollution in accordance with law. The
company may be allowed to re-start only after satisfying all these conditions.
This report is forwarded to the Chairman and Member Secretary, PCB with copy to the Chief
Environmental Engineer, PCB Regional Office, Ernakulam for immediate action in
accordance with the law.
2nd report on Merchem Limited, Eloor
(The minutes of the 23rd meeting held on 13-1-2005)
Mr.Jayathilakan and Mr.Jacob Lazar representing LAEC and Mr. Shanavas, Asst.
Scientist deputed to LAEC were present during the inspection conducted by Chief
Environmental Engineer Mr.Jayaprasad with A.Farook Sait, Environmental Engineer of
PCB as directed by the Hon’ble High Court. LAEC members reported to the committee that
they have found proposal submitted by the industry on 5-1-05 to recover products from the
non-biodegradable fraction being implemented. It is informed that the system will be ready
for trail run today itself.
A new compressor has been installed and pipeline installed on the wall of the aeration tank
with dip tubes extended to the bottom. Abundant frothing is found through out the surface of
the aeration tank.
Water line earlier used to dilute the effluent from a line near the tea center which was
disconnected earlier has been dismantled by the employees in our presence .
The company officials informed that all remedies suggested will be carried out within the
timeframe indicated by PCB.
396
It is shocking to note that the unit has not disclosed even to the Board in its consent application the
names of various Sulphanamides products, Thiazole products and anti-oxidants. The unit should be
directed to produce the name of products and the quantity of production item wise under the general
headings Sulphanamides, Thiazole and anti-oxidants. The Board should specify only those items in the
consent order which is found cleared in the trial run and not any other products.
3rd report on Merchem Limited. Eloor
(The minutes of the 24th meeting held on 17-1-2005)
Resolved that the request from Merchem Ltd, Eloor for trial run cannot be entertained since
the matter is sub-judice. The meeting took serious note of the notice published by the BMS
union of Merchem Ltd. and resolved to address a letter to the union leaders affording an
opportunity to regret for the uncharitable comments made against the LAEC and PCB . The
meeting expressed that the contents of the notice is distasteful and amount to interfere with
the enforcement of the order of the Hon’ble Supreme Court. Chairman will address a letter to
the union leaders and call on them to regret. The matter can be brought to the notice of the
SCMC and Supreme Court after the replay if any from the union leaders are received.
4th report on Merchem Limited. Eloor
(The minutes of the 26th meeting held on 23-1-2005)
Considered the request of the M/s Merchem Ltd, Eloor in their letter dated 14/01/2005 and
21/05/2005. The committee is totally unhappy with the various comments contained in the letter
dated: 14-01-2005 distorting the findings of the LAEC to create an impression that the findings of the
LAEC are either on apprehensions or insignificant. Notwithstanding this distorted comments in the
aforesaid letter, the committee resolved unanimously to permit the unit to take a trial run for One
Month under the supervision of NEERI, Nagpur or the Centre for Environment Education (CEE),
Ahmedabad and monitored by PCB and LAEC, considering the modifications made in the ETP and
introduction of a new plant to treat toxic effluent pursuant to the inspection of the LAEC. The
company may be permit to take trial run for one month under the supervision of the NEERI and
subject to the following conditions to assess the efficiency of the modified system.
1. A fine of Rs. 5.00 lacs shall be imposed for violating the consent conditions and Hazardous
Waste (Management and Handling) Rules 1989, which will be credited into the fund of the
Periyar Revival programme. The fine imposed shall be without prejudice to the recovery of
further sum/s that may be quantified later on ‘Polluter Pays’ principle.
2. The track record of Merchem Ltd., Eloor indicates that the COD is very high. During trial
run, COD has to be ascertained and if found consistently above 250 as limited by the statutes,
the company should be directed to set up a tertiary treatment plant before permitting the
unit to start commercial production. If necessary Bio-assay test should be insisted.
3. The complaints of the public and nearby residents against the company by and large is the
odor coming out of the company during its operation especially during nights. The odor is
caused by the discharge of Hydrogen sulphide which is a toxic substance polluting the
environment. Flare in the stack has to be continuously maintained. The scrubbing process
using caustic soda should be insisted to control the air pollution.
397
4. The polishing tank now in operation has to be emptied and inspected to make sure that there is
no clandestine pipe connection carrying raw water to dilute the effluent in the polishing tank
before starting the trial and discharge of the outflow from the secondary settling tank.
5. The old settling tank near the mixing channel, which is claimed to be not in use, must be
dismantled.
6. The PVC pipeline carrying untreated effluent to the mixing channel should be insulated with
metal pipe.
7. Before allowing the trial run, the PCB should revise the consent order incorporating
parameters for COD, Mercaptans, Sulphates, TDS, Chlorides etc. and the quantity of the
effluent per day to be discharged.
8. The trial run should be permitted only to produce 1.1 tonne per day as per the original consent.
The PCB in the meanwhile shall assess the mass balance of the Unit based on this production
rate during the period of one month.
9. The effectiveness of treatment for toxic effluent should be separately documented and the
damage to the air by the process of evaporation has to be assessed.
10. The company should be directed to prepare a blue print of the drainage system of the company
including the authorized outlet, storm water drain and such other drain in their premises. All
drains other than the authorized outlet and the authorized storm water drain should be
dismantled and routed either through the ETP or the authorized storm water drain.
11. The raw water line from the Tea Centre to dilute the effluent in the final polishing tank should
be fully dismantled to the satisfaction of PCB. The by pass line from mixing channel to the
outlet carrying untreated effluent and the PVC pipeline from the old settling tank near the
mixing channel to the final polishing pond should be dismantled. All such similar lines and by
pass lines should also be dismantled. The company shall forfeit its right to operate forthwith
if any such unauthorized pipeline is detected in future.
12. In addition to these conditions, the PCB may impose such other conditions that is warranted
on the facts and in the circumstances of the case for trial run.
13. The Company may be permitted to commence commercial production subject to the result of
the trial run to be submitted by NEERI / CEE to the satisfaction of the PCB and LAEC and
complying the following directions.
a) All hazardous waste scattered in the premises should be excavated and deposited in a
secured landfill.
b) The entire factory premises especially the kuzhikandam thodu side should be cleared
of all wild bushes and undergrowth and the area should be leveled and kept clean.
c) The side of the kuzhikandam thodu adjoining the factory premises shall be lined with
rubble masonry.
d) The company shall undertake to provide water to the affected community in nearby
areas. The quantity of water to be supplied, the affected community, the companies
responsible for contaminating the areas etc., shall be independently assessed in due
course.
398
e) The company shall submit a mass balance report supported by the records of raw
materials used, production records and such other documents substantiating the mass
balance report within a period of 1 month.
f) The company should not use domestic LPG cylinders for flaring up the stack.
g) To ensure the compliance of points (a) to (f) above, the company shall furnish a bank
guarantee from a nationalized bank for
Rs.5.00 lacs. This will be in addition to
the fine imposed vide para 1 above.
h) The PCB should ensure that the company has obtained license under the Manufacture,
storage and import of hazardous chemicals rules, 1989,if applicable.
i) In addition to these conditions, the PCB may impose such other conditions that
are warranted on the facts and in circumstances of the case before permitting
commercial production.
5th report on Merchem Limited, Eloor
(The minutes of the 32nd meeting held on 8-2-2005)
Considered the issues of Merchem Limited Eloor Ltd. The company started its trial run on 42-2005 from early morning. No prior intimation was given to LAEC regarding the starting of
trial run. A letter from Merchem Ltd was delivered at LAEC office at about 3 pm on 5-22005. It is not known whether the company has informed PCB about the trial run. The
regional office PCB at Ernakulam if had information about the trial run it ought to have
informed the LAEC .
The trial run by Merchem was started without arranging anybody from Central Pollution
Control Board for supervise the trial run. The joint inspection prior to trial run could not be
arranged in the aforesaid circumstances. The trial run of the unit has started without emptying
settling and polishing tank. These tanks ought to have been emptied before starting the trial
run. The polishing tank have to be emptied and inspected to ensure that no clandestine
pipeline connected to this tank for diluting the effluent. The company has to give water and
other mass balance consumed at different stages of its manufacturing process. The mass
balance should be ascertained during the trial run to enable PCB and LAEC, the nature of
waste, the quantity generated and make the company accountable for the wastes so far
accumulated. Pollution Control Board will instruct the officers to have details of raw
materials and water used at different stages on every day production and a copy will be made
available to LAEC every other day to have independent assessment by the LAEC. Pollution
Control Board will also take samples of the raw effluent and analyze it at different levels of
treatment to assess the progress of the treatment at each step. Copy of the lab test of the
samples shall be forwarded to LAEC. The regional office may brief the progress of the trial
run to the members of LAEC in the meeting scheduled to be held on Friday at 5 pm at LAEC
office.
6th report on Merchem Limited, Eloor
(The minutes of the 33rd meeting held on 10-2-2005)
399
The Trial run of Merchem Limited, Eloor has started from 4-2-2005. The Pollution Control Board has
filed two reports before the Hon’ble High Court on 5-1-05 and 13-1-2005 respectively . The said two
reports recommended trial run subject to remedying the following among other measures.
1. Chemical dosage has to be determined by jar test in each shift and pH adjustment
has to be done with the aid of a portable pH meter.
2. Na MBT slurry is to be continuously dewatered and the solids taken back into the
process . Facility for that is to be put up within two months.
3. All solid waste scattered in the premises are to be collected and deposited in to the
temporary hazardous wastes holding facility and then be shifted to secure landfill
agreed to be provided by the industry by 15-3-2005.
4. Treated trade effluent shall be discharged only through the single outlet consented by
the Board. There should not be any bypass arrangement to deliver any untreated
effluent to that outlet.
5. Effluent generation shall be at the minimum possible level. No dilution with water is
to be done to achieve compliance with tolerance limits laid down by the Board.
6. Tolerance limit shall be introduced for the following additional parameters in the
effluent discharge from the industry.
a. Chemical Oxygen Demand : 250 mg/litre, max.
b. Bioassay
: 90% survival (min) of fish after 96 hours.
Formal order introducing these parameters shall be issued by the Board separately
later.
7. The two storm water drains towards the HIL side shall be combined. The only other storm
water drain permissible is that on the IRE side. Both storm water drains shall be well- lined
open drains (to keep the inside visible) and should have delay ponds prior to discharge into
Kuzhikandom thodu. This work shall be done within there months.
8. The side of the Kuzhikandom thodu adjoining the Petitioner’s premises shall be lined with
rubble masonry within four months.
9. The factory premises on the Kuzhikandom thodu side shall be cleared of all wild bushes and
undergrowth within a week. The area shall be leveled within a month and shall be kept clean.
10. The petitioner shall conduct and submit to the Board a material balance after one month of
operation, accounting for difference, if any.
7th report on Merchem Limited, Eloor
(The minutes of the 34th meeting held on 17-2-2005)
Pursuant to the directions of the Hon’ble High Court, members of LAEC alongwith the
officials of the Kerala State Pollution Control Board viz., Smt.Chitrakumari.D and
Mr.
Shanavas have conducted several round of inspections during the on-going trial run at M/s.
Merchem Ltd, Eloor.
The following aspects noted by the LAEC are brought to your notice to ensure that the trial
run is not made a farce. Appropriate orders may be issued to the company.
400
1. During our inspection, the company is not found producing all products. The unit has
consent to produce Sulphanamides, Thiazoles, Anti-oxidants @ 1.1 tonnes each per
day. During the trial run, the unit should be strictly directed to produce these items. In
Sulphanamides the unit has been producing CBS, MBS and DCBS. Similarly, the
Thiazole products of the unit are MBT, MBTS, and NaMBT. The product of antioxidants of the units is TQ. Primarily, the Board has to limit the quantity of each
Sulphanamides, Thiazole and anti-oxidants and should specify that no other products
should be taken. The unit may be directed to produce the list of products and the
quantity of production daily taken as per the consent order. It is to be borne in mind
that the unit has got an effluent treatment plant for the treatment of combined effluent
of all these products. Therefore to assess the efficiency of ETP, the unit should be
directed to produce Sulphanamides, Thiazole and anti-oxidants as per the consent
order in equal proportion for the remaining days. It is observed that the unit has
produced only very small quantity of those items, which has got more toxic effluent.
2. During the trial run the sample of effluent of the product item-wise have to be
separately tested. This would help to identify the toxicity of the effluent of each items.
Presently the unit is producing those items, which has less toxic effluent. The samples
taken by the Pollution Control Board has been tested in the lab and results are with the
Board. Kindly send copies of the lab reports of all the samples taken so far including
the result of the Bio-assay 90 % survival of fish after 96 hours (minimum) test.
3. The Company may be directed to furnish water balance and process-wise water
consumption details. Water balance must be properly verified during the trial run.
4. At present, the unit has no device for measuring the total water requirement /
individual requirement at the factory premises. However, the unit has been submitting
water consumption details without fixing meter for reading the individual water
consumption though they have been producing separate readings. This conduct of the
unit is highly reprehensible since the unit has been misleading the Board by showing
fake readings in the returns. In the circumstances, the unit may be directed to fix
water meter at the intake point in the factory premises and at all points of water
delivery for the purpose such as cooling, boiler, domestic and processing .
5. There is no arrangement for measuring the effluent discharge rate through the outlet.
The company should provide flow measuring devices and pH indicator recorder both
at the inlet and outlet of the Effluent Treatment Plant.
6. Hazardous waste is lying scattered in the premises of the factory. Board may direct
the company to excavate all hazardous waste lying scattered in their premises and
deposit it into the secured landfill.
7. The entire factory premises especially the Kuzhikandam thodu side should be cleared
of all wild bushes and undergrowth. The Board may direct the company to
immediately clear all the wild bushes. This would help the Board to ascertain whether
the hazardous wastes are dumped in that area and also that whether there is any illegal
outlet to Kuzhikandam thodu covered under bushes and undergrowth.
401
8. The side of the Kuzhikandam thodu adjoining the factory premises shall be lined with
rubble masonry. The company may be directed to complete this work .
9. Direct the company to submit a mass balance report supported by the records of raw
materials used, production records waste generated and such other documents
substantiating the mass balance report within a period of one month.
10. Air pollution problems are immensely noticed by the committee on several occasions.
Hence, monitoring of Stacks of the company and Ambient Air quality are essential.
Necessary action should be initiated immediately to start the monitoring of the stack
and ambient air quality. The mobile lab (air) may be sent to the unit for monitoring air
quality during the remaining period of trial run since there are large number of
complaints of air pollution which has compelled the members of LAEC to rush to the
unit at odd hours of night.
11. The quantity of high COD effluent taken to the recovery system is to be assessed.
12. The treated effluent before reaching the final polishing tank if need to be further
treated, it should be done elsewhere and not near to the mixing channel where the raw
effluent from equalization tank is taken for primary treatment. It is necessary to
ensure that the raw effluent is not by-passed and/or mixed with treated effluent due to
the proximity of both the mixing channels. The treated effluent should not be allowed
to bring for further treatment near to the raw effluent mixing channel, as such
arrangement would give chance for contaminating the treated effluent.
13. The total quantity of sludge generated per day by taking production as per the consent
order may also be assessed during trial run.
14. The trial run is supervised by temporary apprentices on behalf of the Kerala State
Pollution Control Board. LAEC disapproves the supervision by the apprentices
especially of a unit which has a high potential of toxic effluent having regard to the
nature of various chemicals and types of products and rapidly changing quality of
effluent and coupled with poor track record of the unit.
The Board may ensure that senior officers of the Pollution control board be posted at
the factory during trial run especially when the unit is directed to take trial run of all
the products proportionately as per the consent. This trial may be initiated without
further delay since there is hardly 10 days more to complete the 30 days trial.
15. The representatives of Central Pollution Control Board have not yet reached M/s.
Merchem Ltd., to monitor the trial run. The Board may direct the company to ensure
that CPCB officials are available during the trial run. The Board may also take up the
matter with the CPCB.
16. The Unit may be directed to produce a project report of the new toxic treatment plant
with specifications of equipments, quantity of effluent proposed to be treated, the
quantity of products to be recovered and the quantity of effluent recycled and the
nature of emissions. This detailed project is very important for the reason that the
effluent is divided into toxic and non-toxic, toxic being taken for treatment in the
402
proposed project and non-toxic in the ETP. Presently, the attention is more given only
for the ETP.
Many of the aspects mentioned above were discussed in the LAEC meeting held on
17-2-2005 which was attended by you and Mr. Farook Sait. We hope you have
already issued appropriate directions to the unit based on the discussions in the said
meeting.
Kindly ensure that the above aspects of the trial run is taken care of by issuing appropriate
directions to the unit immediately. LAEC looks forward to receive an action taken report in
this matter
8th report on Merchem Limited. Eloor
(The minutes of the 35th meeting held on 24-02-2005)
LAEC has been inspecting Merchem Ltd., Eloor now under trial. On 20th February, 2005,
LAEC members viz., Mr.Asokan, Mr.Purushan, Mr.Jacob V. Lazar and Mr. Anand inspected
the unit at 6.45 am. The staff of the unit, Mr Martin was found pumping water into the
secondary settling tank.. On questioning this act, Mr Martin and Mr. Suresh, Asst. Plant
Engineer explained that the pumping is done to suppress the froth. The explanation was not
found satisfactory. The pumping of water by using approx. 1 ½ to 2 inch diameter flexible
white hose will disturb the equation of the effluent and will dilute the effluent. Thereafter, one
of the employees of the unit confronted Mr. Purushan and Mr. Jacob V. Lazer and questioned
their authority. The employee also warned the members that in future if the unit is closed,
they would face the consequences. This incident was reported to Mr. Suresh, Asst Plant
Engineer and asked him to take action for misbehavior with the members. Though this matter
was reported to the Chairman the issue was given a quietus considering that it was only a
stray incident.
However, to the surprise and shock to the members of LAEC viz., Mr. Anand, Mr. Purushan
and Mr. Jacob V. Lazer, who went to conduct a surprise inspection of Merchem Ltd., on 23 rd
February, 2005 at 9.00 pm on the instructions of the Chairman to verify the information
received by him over phone from a local resident that unbearable odour causing breathing
problems is felt by the residents near the Kuzhikandam thodu. The members after inspecting
the thodu reached the gate of the unit. The members were refused entry by the security staff
stating that he has instruction from higher officials not to let any LAEC members inside the
unit without prior permission of the work supervisor or other senior officers. The members
were made to wait for more than 10 minutes. When they were about to return, Mr. Suresh,
Asst. Plant Engineer came and opened the gate. This incident has not only embarrassed the
members of LAEC but this incident is an affront to the monitoring committee and is therefore
to be viewed seriously. This committee takes strong exception to the behaviour of Merchem
Ltd., towards members of LAEC. Their conduct is highly reprehensible and cannot be
tolerated for that would not only affect the morale of the committee but also would affect its
further smooth functioning.
LAEC therefore requests the SCMC and the Kerala State Pollution Control Board to issue
appropriate orders forthwith. The Kerala State Pollution Control Board may issue
appropriate directions within 24 hours from the date of receipt of this letter, failing
which LAEC will be forced to suspend its inspection at Merchem Ltd., Eloor.
9th report on Merchem Limited, Eloor
403
(The minutes of the 38th meeting held on 2-03-2005)
The recommendation of the CPCB and PCB submitted before the Hon’ble High Court in the
Merchem case on deliberation at the meeting was finally passed expressing the helplessness
of the committee not to agree for a trial run. Dr. Sharma of the Central Pollution Control
Board advised LAEC not to press for closure despite the finding that the present ETP system
is a total failure. The committee expressed consent with great reluctance bearing in mind that
it is nothing but permitting the industry to continue the breach of mandate under Sec 7 of the
Environment protection Act. The committee unanimously resolved to request to Pollution
Control Board to assess the damage caused to the Environment by discharging pollutants all
these years and recover from the company the loss caused to the Environment. It is also
decided to file a additional Affidavit before the Hon'ble High Court reporting the observations
of the committee independently . The additional Affidavit contains the following aspects.
1.
Merchem Limited Eloor commenced its trial run on 4th February 2005 at 50%
production level (3.3 tonne per day). During the manufacturing process a portion of the
stream containing high TDS and COD were diverted to an evaporator system and the
remaining so called non toxic stream were diverted to existing effluent treatment plant. The
toxic stream so diverted to the evaporator system are MBS Aq layer, CBS filtrate, CBS
column bottom and TQ Aq layer. The so called non toxic stream constitute MBT filtrate and
MBTS filtrates. The result of the treated effluent of the so called non toxic stream found high
COD and sudden death of fish in Bio-assay test. It is observed during the trial run that the
treatment of high COD and high TDS effluent through conventional biological treatment
system is rather difficult especially when domestic effluents are not being mixed with
industrial effluent. Mixing of domestic effluent with industrial effluent will not be feasible in
the existing treatment system to achieve a successful compliance. The present ETP system
existing for several years have thus been proved a total failure and the complaint of the local
community stands vindicated. The recommendation of the LAEC for closure of unit is thus
justified.
2.
It was observed that the unit had completed and commissioned the evaporator system to
handle toxic stream upto 20 cubic metre per day, although the system was receiving effluents to the
tune of 15 cubic metre per day only (Generally the effluent from these streams shall be of the order of
35 cubic metre per day at peak production levels.) In order to introduce a fool proof system of treating
various streams generated during the manufacturing process the representative of the Central Pollution
Control Board, Dr.D.C.Sharma enquired with the company its willingness to go for zero discharge.
The company after consultation agreed to go for zero discharge concept. Accordingly, all agreed to the
following suggestion.
a)
The company agreed to install membrane systems (Rochem brand) to treat a
total of 70 cubic metre per day of highly polluting streams at peak production level of 7 tonne
per day, using a disc type which shall deliver almost 70% recovery of treated water
(permeate)leaving behind only 30% of concentrated pollutants to be force evaporated in a
multiple effect evaporator system. The membrane system shall also be useful in reducing the
quantities of effluent to be evaporated to a significant extent. Thus a combination of
membrane systems and evaporated systems shall be installed to achieve the zero discharge
from the industrial Unit.
b)
The emission control systems were cross verified. It was observed that the
scrubbed left over gases were being emitted after a flare system at the top of a 30 metre
high stack. In order to safeguard against any upset conditions and/or malfunctions in the
404
existing scrubbing system, a secondary scrubbing system using ferrous chloride as the
scrubbing medium is agreed to be installed so as to contain even the traces of Hydrogen
Sulphide which is thereafter subjected to flaring to avoid odour nuisance.
c)The non-polluting streams such as condensate water, boiler blow down and pump
gland cooling waters etc. can be successfully recycled in the boiler house and the
processes.
d)The existing effluent treatment plant shall be used to treat a total of 40 cubic metre
per day of effluent generating from floor washings, boiler blow down and domestic
effluent. The treated effluents from the ETP shall have to be completely recycled within
the plant premises for gardening and other purposes.
e) As the unit is going for creating a secured land fill of 100 cubic metre capacity, it
was recommended to increase its size upto 150 cubic metre in order to find place for
transfer of the sludge from temporary storage and the sludge generated in the next two
years.
f) The company agreed to clear all wild bushes in its premises. The land (left after
construction of secure landfill) however shall be cleared of all wild bushes and levelled.
The Central Pollution Control Board and the State Pollution Control Board has made the
following recommendations which has been agreed to by all the parties not withstanding the
fact that the extension of trial run, after being convinced that the treated effluent is of high
COD and the failure in the Bio-assay test, will result in discharging pollutant into
Kuzhikandam thodu which is a creek of Periyar river. This Hon'ble Court may therefore pass
appropriate orders bearing the mandate of sec. 7 of the Environment (Protection Act) 1986.
Sec. 7 of the Environment (Protection Act) 1986 reads thus:
“ No person carrying on any industry, operation or process shall discharge or
emit or permit to be discharged or emitted any environmental pollutant in excess
of such standards as may be prescribed.”
1. The industry must complete installation and stabilization of the additional
evaporator system within two months from 5th March 2005. The installation of
membrane system and all other actions related to achieving zero discharge
shall be completed within 5 months.
2. The additional scrubbing system as proposed shall also be completed within
two months. The installation of hydrogen sulphide sensor cum data logger
shall be completed within a time span of six months.
3. The Hon’ble Court may be pleased to consider extension of the on going trial
run by another two months at the current production level of 3.3 tonne per day
under the continued monitoring by the State Pollution Control Board and the
Local Area Environmental Committee shall continue to associate with the
inspections.
4. On the additional evaporator system being successfully completed and
commissioned in two months time, the existing ETP shall have to treat only the
weak waste arising from floor washing and domestic effluents. At this point of
time, yet another joint inspection is recommended to review the progress and
recommend further course of action.
405
10th report on Merchem Limited, Eloor
(The minutes of 43rd meeting held on 14-3-05 on the complaint of Fugitive emission
from Merchem Ltd, Eloor.)
Fugitive emission in Merchem Ltd Eloor on 13-3-2005 between 9 pm to 11 pm had raised alarm and
serious apprehension of danger to life of the people residing nearby the unit in Eloor. Few local
people were rushed to a nearby hospital and were given emergency treatment.
On getting information about the fugitive emission causing severe headache, chest pain, nausea and
abdominal congestion to the people, the members of LAEC rushed to Merchem Ltd at about 10.45 pm.
A huge gathering of local residents were seen agitated raising slogans in front of the company. The
local residents blocked the vehicle of LAEC members. One member of LAEC was about to be
assaulted by the agitated group. Somehow the situation was managed and the agitated crowd was
assured immediate action to contain the fugitive emission. LAEC members entered inside the factory
and experienced (around the NaMBT plant) severe piercing odour, similar to the one experienced
outside. The entire company premises and outside was having a misty look. The plant in charge,
Mr.Paul Raj, however insisted that the odour is one from HIL, and that Merchem Ltd has nothing to
do with fugitive emission / other emission.
Members of LAEC went to inspect HIL to ascertain whether there is any emission from HIL. Of the
four plants in HIL, three were idle and only one plant viz., Dicofol was found working. No emission
or odour was felt inside the HIL. The team returned to Merchem Ltd.
On account of public upsurge, the Sub Inspector of Police, Cheranallore, who was in charge of Eloor
came to Merchem Ltd, Eloor along with other police personnel and the District Panchayat Member,
Mr Sajan Malayil. The police officials and Mr. Sajan Malayil could feel the smell and asked the
company either to stop the plant or do mitigating measures.
The smell initially experienced was a burnt smell which gradually transformed into severe piercing
odour of the kind, which according to local people were experienced in the early periods of trial run in
1997. Unfortunately, the attitude of the company was not only indifferent but also very negative. The
incident was reported to the Regional Office of the Kerala State Pollution Control Board, Ernakulam.
Mr. Jayprasad, CEE accompanied by Mr.Sateeshan Thampuran, Convenor of LAEC and Mr. Farook
Sait, EE reached Merchem Ltd. around 2.00 a.m. They collected information from Mr. Sudheer, the
apprentice posted at Merchem Ltd. during the trial run.
Mr. Sateeshan Thampuran reported to the committee that there was fugitive emission in the
unit and some remedial measures have to be taken to avoid any such recurrence in future.
Merchem Ltd is a company now under trial run by an extented time of one month. The unit
was found not having adequate effluent treatment system. The Effluent treatment system of
the so-called non toxic effluent after its bifurcation was found inadequate and the treated
effluent was found toxic in the laboratory analysis. During the joint inspection, the complaint
regarding fugitive emission was brought to the notice of the company officials and were
directed to take measures to contain fugitive emission. The unit is now found negligent in
taking adequate measures to contain fugitive emission .
The continued trial of this unit causing serious apprehension to the life of people and
nuisance by negligence of Merchem Ltd., is tending to question even the credibility of the
LAEC, which is supposed to act as a catalyst and help the authority to take action against the
406
unit found violating environmental laws. The very fact that the LAEC members were
restrained by the local people demonstrates the erosion of public confidence in LAEC.
The complaint of the people that the LAEC has failed to appraise the court about the
seriousness of this aspect, though has no basis, in the present context is hard to impress them.
In the circumstances, LAEC has resolved to report this matter to the Hon'ble High Court and
seek review of the trial run and a direction to install efficient control measures before
allowing any kind of production under whatever name it may be called.
During the crisis management in addressing fugitive emission in the Unit, LAEC members except
Shri.RV.Sateeshan Thampuran felt the following deficiencies which need to be addressed
immediately:
1. The site office at Eloor, though revived, is not functioning effectively and there is no
arrangement to address such contingencies / emergencies.
2. The trial run in Merchem Ltd. monitored by PCB through apprentice is found not effective.
Senior and experienced officers of the Board has to be posted so that such incidents could
have been avoided and the source of fugitive emission could have been identified.
3. Stack monitoring and the ambient air quality have not been taken even once during the entire
period of trial run to test the efficiency of the stack and emissions at Merchem Ltd.
The company may be directed to show cause for the fugitive emission causing apprehension to the life
of the people and for causing nuisance and take such action, as may be warranted in the facts and
circumstance of the case.
11th report on Merchem Limited, Eloor
(The minutes of the 48th meeting held on 04-04-2005)
On the complaint of the local residents of Eloor about the fugitive emission from
M/s
Merchem Ltd. on 13 3-2005, LAEC members rushed to the spot. The Pollution Control Board
issued show cause notice seeking explanation. The company replied refuting the allegation.
The LAEC brought to the notice of the Hon'ble High Court, the incident of fugitive emission
through an interlocutory application. M/s Merchem Ltd in the counter affidavit contended
that no such Fugitive emission had occurred on
13-3-2005 between 9 pm to 11 pm.
During the course of hearing the counsel for the Pollution Control Board made a submission
contrary to the stand of Pollution Control Board that the emission was from HIL. Member of
LAEC Mr. Purushan, Eloor When asked about such submission of the counsel of Board, Mr.
Sateeshan Thampuran, CEE, KSPCB, Ernakulam himself at lost explain the reason.
The committee on enquiry with the regional office of the Pollution Control Board was
informed that further action pursuant to the show cause notice has been dropped against the
company.
It is seen from the records that all show cause notices issued by the Pollution Control Board
are closed after obtaining reply from the company. This practice has set a bad trend among the
companies to go scot-free after committing the damage to the environment and nuisance to
the public and residents. LAEC strongly condemn such practice as that would forfeit the
confidence of the people in the law enforcing agency which will lead to anarchy .
407
The complaint of the local residents on the fugitive emission from the Merchem Ltd cannot
be closed based on the reply refuting the allegation. Such practice will certainly leave the
civilian community without any remedy. In the light of the reply refuting the allegation the
Board ought to have conducted an enquiry into the incident alleged and ought to have come to
definite finding on the merits of the complaint. Closing the file obtaining reply denying the
incident is not a good practice as that would seriously prejudice the public.
LAEC in the aforesaid circumstance, has decided to conduct a public hearing on the
complaint of fugitive emission and take evidence in the matter so that appropriate action can
be recommended against the company redressing the grievance of the residents. The
committee resolved to hold a public enquiry on 16th April, 2005 at Yuvajanavayanashala,
Eloor North at 10 am and collect evidence from the public. Chairman, Pollution Control
Board may be requested to attend the public hearing. Notice of public hearing shall be issued
to the company and also to the local residents through press release.
12th report on Merchem Limited, Eloor
(The minutes of the 65th meeting held on 10-06-2005)
The committee discussed the lab report of the samples taken from Merchem Ltd, Eloor on 01.06.2005.
The samples taken from the pit near Hazardous Storage Place, from the rear side of Canteen, Polishing
pond (the tank to store treated effluent) and of Raw Effluent Tank A, show the parameters of
BOD,COD,SS,TDS,Iron,Chlorides, Sulphate etc all beyond the tolerable limits. Lab Report is
attached.
According to the reliable source of information, the unit is not taking the entire trade effluent
into evaporator for treatment. It takes raw effluent in to the polishing tank and under the guise
of reusing the treated effluent of the polishing tank; the effluent from the polishing tank is
discharged into the open land. The zero discharge clamed by the unit is thus made a mockery.
The lab reports of the sample collected from pit and polishing tanks substantiate this
information.
It may be recalled that the unit was issued with a closure order after having caught red-handed
for discharging untreated effluent into Kuzhikandom thodu by deceptive operation of effluent
treatment system. Right from the trial of the company, there is complaint from public against
the unit for discharging untreated effluent. The unit has successfully managed to overcome all
the action against it by taking some actions to make it appear that it has rectified irregularities.
All such measures taken by the unit has been proved without any earnestness. There is total
lack of bonafides.
The claim of zero discharge has now relieved the company from obtaining consent under the
Water (Prevention and Control of Pollution) Act 1974. The company is now discharging a
major quantity of raw effluent into the open land maintaining the effluent treatment system
for zero discharge for a minimum quantity of effluent only so as to make it appear that the
company is observing zero discharge .The officer deputed in the company for monitoring by
the PCB is found to be ineffective.
The new system introduced by the company needs to be closely monitored continuously
round the clock at least for two months. By such monitoring alone, one can assess the total
physical quantity of the product, the total quantity of the effluent generated each day, the total
capacity of the Effluent treatment system of zero discharge and the total quantity of sludge
408
generated each day in order to assess whether the Zero discharge system is functional and
financially feasible so as to avoid clandestine discharge of untreated effluents.
To undertake this exercise, one must admit that the PCB has no sufficient staff strength on its
roll. LAEC is of the opinion that 6 persons (at the rate of 2 persons per 8 hours) have to be
engaged for supervising and monitoring the unit for two months under its supervision. This
should be in addition to the monitoring of the Board. Appropriate order can be issued in the
light of the monitoring report of this unit by LAEC.
The company, having adopted ETP of zero discharge as claimed by it, simultaneously should
be asked to execute a bank guarantee of Rs 10 lakhs for being forfeited in the event of
resorting to any illegal discharge of untreated effluent into open land. It appears that
companies claiming zero discharge resort to discharge of raw effluent with impunity. The
instances of M/s.Sree Sakthi Paper Mills and Merchem Ltd. are pointer to this fact. From the
experience of LAEC, it is felt that companies claiming zero discharge must be bound by bank
guarantee for observing zero discharge failing which they will make the regulatory machinery
a mockery.
LAEC requests for immediate action against Merchem Ltd, Eloor taking into account the
track record of this unit.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
Determinant
pH
BOD
COD
SS
TDS
Zinc
Iron
Chlorides
Sulphates
Manganese
Phenolic
Compounds
Unit
mg/l
: Merchem Limited ,Eloor.
:1-6-05
:LAEC 195(Effluent from the premises near the new TSDF
(Seen discharged on grassy land))
LAEC 196(Effluent drain from FACT and IRE compound,
before joining the outlets of Merchem and HIL)
LAEC 197(Polishing pond)
LAEC 198(Raw effluent tank No.A)
LAEC 199(Stagnant effluent seen near canteen outlet.)
:Central Laboratory, Gandhi Nagar.
LAEC
195
LAEC
196
LAEC
197
LAEC
198
6.5
90
960
977
9872
ND
174
300
4000
165
1.2
5.6
12
96
196
792
ND
11.8
140
550
39
ND
9.3
108
1232
132
1896
ND
1.4
120
750
ND
2.3
12.8
568
7120
664
9970
ND
18.7
1400
700
ND
2.5
LAEC Tolerance
199
limit as per
consent
8.6
5.5 – 9.0
198
30
2400
-825
100
4690
-ND
5.0
42.6
-2000
-450
-ND
-1.5
1.0
409
12
Colour
hazen
640
20
40
3200
2000
--
Consented Parameters and Limits.
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
7
Characteristic
pH
Suspended Solids
BOD(3Days at 270 C)
Oil and Grease
Zinc
Phenolic Compounds
Sulphides(as S)
Unit
mg/l
,,
,,
,,
,,
,,
Tolerance
limit
5.5-9
100
30
10
5.0
1.0
2.0
Colour Code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
Determinant
No
1
2
3
4
5
6
7
8
9
Zinc
Iron
Lead
Cadmium
Copper
Nickel
Arsenic
Total Chromium
Manganese
Source
: Merchem Limited, Eloor.
: 9-12-04.
:LAEC 35(Sludge from hazardous waste storage tank)
LAEC 36(Dyke of MBTS Storage tank).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Sludge from
Dyke of
hazardous
MBTS
waste storage
Storage tank.
tank
mg/kg 578.5
82.3
57750
1300
128
6
8.2
3.9
99.1
7.4
46.6
30.9
ND
ND
173.3
ND
457
12.9
: Merchem Limited, Eloor
410
Date of sample collection
Sample Identification No
: 9-12-04.
:LAEC 72(Raw effluent collection tank)
LAEC 73(Retention tank)
LAEC 74(Authorized outlet.)
Name of the Lab
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.
Determinant
Unit Raw effluent Retentio Authori
No
Collection
n tank
zed
tank
outlet
H
1
p
8.8
7.7
7.9
2
BOD
mg/l 410
0.2
2
3
COD
3600
4
8
4
SS
15
12
7
5
TDS
7704
68
64
6
Zinc
ND
ND
ND
7
Chlorides
1100
20
8
8
Sulphate
3000
12
ND
9
Phenolic Compounds
0.4
ND
ND
10
Oil & grease
ND
ND
ND
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No
Determinant
Unit
: Merchem Limited, Eloor
: 13-12-04
:LAEC 76(Authorized Outlet)
LAEC 77(By pass line to outlet)
LAEC 78(Storm water drain)
LAEC 80(Flare stack water seal sample).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Authorized
Outlet
By pass
line to
outlet
9.4
210
7640
48
13840
1630
10000
ND
1
Storm
water
drain
6.6
12.4
64
62
494
40
200
ND
0.1
Flare stack
water seal
sample
11.2
200
10800
20
8808
5000
375
2000
250
pH
7.1
BOD
mg/l 2.0
COD
24
SS
8
TDS
398
Chlorides
80
Sulphates
12
Sulphides
ND
Phenolic
ND
compounds
10
Oil & grease
ND
ND
ND
2.2
Source
: Merchem Limited, Eloor
Date of sample collection : 3-1-05
Sample Identification No :LAEC 40(Sludge near storm water drain)
LAEC 41(NAMBT process sludge)
LAEC 42(Sludge western side of polishing pond)
LAEC 43(Sludge near collection tank)
LAEC 44(Sludge near creek(stagnant ))
Name of the Lab
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
1
2
3
4
5
6
7
8
9
Tolerance
limit as per
consent
5.5 - 9
30
-100
-5.0
--1.0
10
Tole-rance limit
5.5-9
30
-100
---2.0
1.0
10
411
Sl.
No
Determinant
1
2
pH
Zinc
3
4
5
6
7
8
9.
10
11
12
13
Iron
Lead
Cadmium
Copper
Nickel
Arsenic
Chloride
Sulphates
Sulphides
Magnesium
Total
Chromium
Manganese
14
Unit
Mg
/kg
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
Determinant
1
2
3
4
5
6
7
8
pH
BOD
COD
SS
TDS
Chlorides
Sulphates
Phenolic Compounds
Source
Sludge
near
storm
water
drain
3
40
NAMBT
process
sludge
Sludge near
collection
tank
Sludge near
creek (stagnant)
6.1
265
Sludge
western
side of
polishing
pond
5
640.8
5.8
590.8
7.1
1024.8
21780
82
4.8
7.2
596.6
ND
40000
21400
ND
2000
13.8
6235
84
4.6
10.3
18.2
ND
2000
127
ND
ND
9.2
463.5
168
6.2
86.8
32.6
ND
2500
2000
ND
2000
286.8
218.5
198
22.8
200
63.7
ND
3000
2300
ND
3000
95.4
6080
252
43.2
24
66.6
ND
837.5
69.8
352
948.5
593
16500
ND
3000
13.8
: Merchem Limited, Eloor
: 7-2-05.
:LAEC 18(Recycling water- sample pumped from the sump
near NMBTS pumped to equalization tank)
LAEC 29(Treated effluent from secondary settling tank)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
Recycling watersample pumped
from the sump near
NMBTS pumped
to equalization tank
7.6
130
3440
35
1740
400
120
1
Treated
effluent
from
secondary
settling
tank
4.4
180
8160
196
3700
1350
400
200
: Merchem Limited, Eloor -Sludge
Tolera
nce
Limit
5.5-9
30
-100
---1.0
412
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No
1
2
3
4
Determinant
Unit
Name of the Lab
Sl. Determinant
No.
9
pH
BOD
COD
SS
TDS
Chlorides
Sulphate
Phenolic
Compounds
Oil & grease
Kuzhikandam
Thodu Downstream
of HIL outlet
6.5
mg/l 160
800
2983
836
300
375
ND
10
Name of the Lab
Determinant
: Merchem Limited, Eloor
:10-2-05
:LAEC 81 (Kuzhikandam Thodu - Downstream of HIL outlet)
LAEC 84 (Outlet)
LAEC 85 (Bio tower outlet)
LAEC 86 (Raw effluent)
LAEC 87 (Effluent after chemical Treatment)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Source
Date of sample collection
Sample Identification No
Sl.
No.
Inside plant-New
Recovery plant
6.22
mg/kg 300000
66470
55.76
pH
Chlorides
Sulphate
Organo Chlorine
compounds
Source
Date of sample collection
Sample Identification No
1
2
3
4
5
6
7
8
:10-2-05
:LAEC 52(Inside plant-New Recovery plant)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Outlet Raw
Effluent
effluent after
chemical
Treatment
6.6
10
6.3
90
205
200
480
2960
2720
72
112
121
3012 4700
4528
1380 1250
3200
1125 750
450
9.6
16
8
Bio
tower
outlet
Toleran
ce limit
6.8
190
1680
153
6888
3380
1375
5.6
5.5 - 9
30
-100
---1.0
ND
ND
10
ND
ND
: Merchem Limited, Eloor
:10-2-05
:LAEC 88(Effluent after primary settling)
LAEC 89(Secondary settling tank outlet.)
LAEC 90(Outlet of final settling tank)
LAEC 91(Inlet water from the sump NAMBT).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Effluent
Secondary
after primary settling
Outlet
of final
Inlet
water
Tolerance
limit
413
1
2
3
4
5
6
7
8
9
pH
BOD
COD
SS
TDS
Chlorides
Sulphate
Phenolic
Compounds
Oil & Grease
mg/l
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
Determinant
1
pH
2
3
4
5
6
7
8
BOD
COD
SS
TDS
Chlorides
Sulphide
Phenolic
Compounds
Oil & grease
9
Unit
mg/l
Source
Date of sample collection
Sample Identification No
Name of the Lab
settling
tank outlet
settling
tank
5
-
from the
sump
NAMBT
5.1
168
880
31
1944
500
500
16
7.2
240
3120
-
5.1
120
800
99
5544
4000
575
12
5.5-9
30
-100
---1.0
-
ND
-
ND
10
: Merchem Limited, Eloor.
:11-2-05
:LAEC 92(Mixing water from the sump near the main plant to
the second sump)
LAEC 93(Flare stack water seal sample)
LAEC 94(Sample from the final sump)
LAEC 95(Sample from the equalization tank inlet (sample 1))
LAEC 96(Sample from the equalization tank inlet (sample 2)).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Mixing
water
from the
sump near
the main
plant to
the second
sump
8.4
Flare
stack
water
seal
sample
Sample
from the
final
sump
Sample
from the
equalizati
on tank
inlet
(sample 1)
10.9
9.1
9.1
Sample
from the
equaliza
tion
tank
inlet
(sample
2)
9.1
500
5360
329
6310
650
ND
1.25
2800
25280
285
8540
250
1248
2.5
244
2880
272
3500
1600
ND
0.8
560
8720
29
3390
1300
ND
0.88
440
5440
61
3460
750
ND
0.6
5.59
30
-100
--2.0
1.0
ND
10
ND
ND
ND
10
: Merchem Limited, Eloor.
:11-2-05
:LAEC 53(Sludge-Final pumping sump).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Tole
ranc
e
limit
414
Sl.
No.
1
2
3
Determinant
Unit
Cyanides
Phenolic Compounds
Organo Chlorine
Compounds
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
Determinant
No.
pH
BOD
COD
SS
TDS
Chlorides
Sulphate
Sulphide
Phenolic
compounds
10
Zinc
Source
Date of sample collection
Sample Identification No
1
2
3
4
5
6
7
8
9
Name of the Lab
Sl.
Determinant
No.
1
PH
2
BOD
3
COD
4
SS
5
TDS
6
Zinc
7
Iron
Sludge-Final
pumping sump
mg/kg BDL
BDL
62.25
: Merchem Limited, Eloor.
:14-2-05
:LAEC 97(Aeration tank outlet)
LAEC 98(Bio tower inlet)
LAEC 99(Bio tower outlet)
LAEC 100(Raw effluent)
LAEC 101(Final Outlet).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Aeration Bio
Bio
Raw
Final
tank
tower tower effluent Outlet
outlet
inlet
outlet
7
3.9
6.5
11.3
5.8
mg/l
108
436
330
996
52
880
1600
960
2720
240
2256
983
81
304
46
5548
5120
5784
7760
1968
2900
1200
2000
1400
600
600
900
900
750
1250
ND
ND
ND
ND
ND
0.93
0.22
0.2
1.1
ND
ND
ND
ND
ND
ND
: Merchem Limited, Eloor.
:19-2-05
:LAEC 32(Raw effluent)
LAEC 37(Sump near Caustic Scrubber).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit Raw effluent Sump near Caustic
Scrubber
6.0
5.5
mg/l 108
200
1920
2400
444
120
3608
5444
ND
ND
100
250
Toleran
ce Limit
5.5-9
30
-100
---2.0
1.0
5.0
Tolerance
limit
5.5-9
30
-100
-5.0
--
415
8
9
10
11
12
13
14
15
16
17
18
Lead
Cadmium
Copper
Nickel
Arsenic
Chlorides
Sulphate
Cyanide
Sulphide
Phenolic Compounds
Titanium
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
pH
BOD
SS
COD
TDS
Free Chlorine
Zinc
Iron
Nickel
Chlorides
Sulphate
Sulphide
Magnesium
Phenolic Compounds
Hexa chromium
Total Chromium
Manganese
Oil & grease
Name of the Lab
Determinant
pH
ND
ND
ND
ND
ND
2000
1100
ND
ND
.410
ND
--------2.0
1.0
--
: Merchem Limited, Eloor.
: 23-2-05
:LAEC 153(outlet)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Determinant
Source
Date of sample collection
Sample Identification No
Sl.
No.
1
ND
ND
ND
ND
ND
1000
2300
ND
ND
1.22
ND
Unit
mg/l
Outlet
5.6
50
61
480
6008
ND
ND
ND
ND
800
1375
ND
30.49
ND
ND
ND
ND
ND
Tolerance
limit
5.5-9
30
100
---5.0
----2.0
-1.0
---10
: Merchem Limited, Eloor.
:25-4-05
:LAEC 183(Kuzhikandam thodu)
LAEC 184(Raw effluent)
LAEC 185(Treated effluent).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Kuzhikandam Raw
Treated Tolerance
thodu
effluent effluent limit
6.4
10.9
6.7
5.5-9
416
2
3
4
5
6
7
8
9
10
BOD
COD
SS
TDS
Iron
Chlorides
Sulphide
Phenolic Compounds
Colour
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
Determinant
pH
BOD
COD
SS
TDS
Zinc
Iron
Chlorides
Sulphates
Manganese
Phenolic
Compounds
Colour
Unit
mg/l
Hazen
Source
Date of sample collection
Sample Identification No
Name of the Lab
mg/l
30
368
480
1396
378
400
ND
0.14
hazen 40
280
3360
628
12536
468
700
ND
1.32
480
128
1184
98
9304
9.4
900
ND
0.4
200
30
-100
---2.0
1.0
--
: Merchem Limited ,Eloor.
:1-6-05
:LAEC 195(Effluent from the premises near the new TSDF
(Seen discharged on grassy land))
LAEC 196(Effluent drain from FACT and IRE compound,
before joining the outlets of Merchem and HIL)
LAEC 197(Polishing pond)
LAEC 198(Raw effluent tank No.A)
LAEC 199(Stagnant effluent seen near canteen outlet.)
:Central Laboratory, Gandhi Nagar.
LAEC
195
6.5
90
960
977
9872
ND
174
300
4000
165
1.2
LAEC
196
5.6
12
96
196
792
ND
11.8
140
550
39
ND
LAEC
197
9.3
108
1232
132
1896
ND
1.4
120
750
ND
2.3
LAEC
198
12.8
568
7120
664
9970
ND
18.7
1400
700
ND
2.5
LAEC
199
8.6
198
2400
825
4690
ND
42.6
2000
450
ND
1.5
Tolerance
limit
5.5 – 9
30
-100
-5.0
----1.0
640
20
40
3200
2000
--
: Merchem Limited, Eloor.
:30-7-05
: LAEC 13(Raw water tank –B(from line)).
LAEC 96(Feed water to RO)
LAEC 95(After RO before degassing from the RO unit)
LAEC 18(Permeate after RO & De- gassing)
LAEC 41(Reject from RO)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
417
Sl.
No.
1
2
4
5
6
7
8
9
10
11
12
13
14
15
Determinant
pH
BOD
COD
SS
TDS
Zinc
Iron
Lead
Chlorides
Nitrates
Phospates
Sulphates
Sulphides
Phenolic
compound
Hexa
Chromium
Unit
mg/kg
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
LAEC
13
8.5
266
8320
15
9889
ND
15.4
ND
1200
ND
ND
7184
ND
1.9
LAEC
96
8.3
20
800
68
10334
ND
14.7
ND
1000
ND
ND
8220
ND
0.08
LAEC
95
7.1
1.0
80
10
100
ND
0.07
ND
4
ND
ND
30
ND
0.035
LAEC
18
6.5
1.2
80
210
143
ND
0.16
ND
5
ND
ND
25
ND
0.02
LAEC
41
8.3
508
11920
38
15824
ND
36
ND
2600
ND
ND
10524
ND
0.93
,,
ND
ND
ND
ND
ND
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl. Determinant
Unit
No.
1
pH
2
BOD
mg/kg
COD
,,
4
SS
,,
5
TDS
,,
6
Zinc
,,
7
Iron
,,
8
Lead
,,
9
Chlorides
,,
10
Nitrates as N ,,
11
Phospates
,,
12
Sulphates
,,
13
Sulphides
,,
14
Phenolic
,,
compound
: Merchem Limited, Eloor.
:30-7-05
: LAEC 98(Raw effluent tank No:A)
LAEC 27(Raw effluent tank-A (from- line)Evaporator)
LAEC 92(Raw effluent tank No:B)
LAEC 235(Effluent after neutralization from Settling tank)
LAEC 342(Effluent from storage Tank. (Old Aeration tank));
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
LAEC
98
8.7
548
15040
268
16987
ND
25.6
ND
5200
ND
ND
6255
232
0.25
LAEC
27
12.5
490
13800
35
26246
0.1
22.8
ND
5400
ND
ND
15224
ND
1.9
LAEC
92
8.2
286
9040
48
16613
ND
1.3
ND
1200
ND
ND
8112
ND
2.7
LAEC
235
12.6
526
12630
126
26990
0.11
14.15
ND
10600
ND
ND
5575
ND
2.5
LAEC
342
9.4
502
12800
76
20050
ND
20.7
ND
7000
ND
ND
5958
ND
1.14
418
15
Hexa
Chromium
,,
ND
ND
ND
ND
ND
Source
Date of sample collection
Sample Identification No
Name of the Lab
: Merchem Limited, Eloor.
: 30-7-05
:LAEC EV(Effluent before entering RO)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.
No.
1
2
3
4
5
6
7
8
9
10
Effluent before entering RO
11
12
13
14
15
Determinant
pH
BOD
COD
SS
TDS
Zinc
Iron
Lead
Chlorides
Nitrates as
N
Phospates
Sulphates
Sulphides
Phenolic
compound
Hexa
Chromium
Unit
mg/kg
,,
,,
,,
,,
,,
,,
,,
,,
8.2
272
10240
296
8303
ND
1.5
ND
1100
ND
,,
,,
,,
,,
ND
6003
ND
1.79
,,
ND
419
420
421
422
COCHIN MINERALS AND RUTILE LTD, EDAYAR
423
Name of the Industry
: Cochin Minerals and Rutile Ltd
Date of Inspection
:26-11-2004 & 28-12-2004
Avg.in t/day Max t/day
Name of the Product
: Synthetic Rutile
FerricChloride
Ferrous Chloride
71
42
43
88
92
91
Avg. t/day
Raw materials
:Ilmenite
Coke
Hydrochloric Acid
FuelOil
Chlorine
125
13
175
10 KL
3.5
Process:
The production capacity of the factory is 71 t/day Synthetic Rutile from the raw materials of
Ilmenite, coke, hydrochloric acid, and chlorine. The production process involves roasting of
purified ilmenite to reduce the ferric oxide to ferrous oxide, leaching of reduced ilmenite with
hydrochloric acid, filtration and calcinations. According to the company 43t/day ferrous
chloride and 42 t/day ferric chloride are produced as byproducts.
Waste:
In the effluent treatment plant, recovery tanks are provided for the recovery of titanium from ferrous
chloride solution. The raw effluent after the recovery of titanium is taken to equalization tank and
treated with lime in flash mixer. After chemical treatment the effluent is taken to slurry collection tank
from where it is pumped to high rate thickener for solid separation. The overflow from the high rate
thickener is settled in ageing tanks and taken to final polishing tank after pH correction. From the
final polishing tank effluent is pumped into River Periyar through underground pipeline
The sludge from the high rate thickener is taken to Solids Collection Yard from where the
supernatent is returned to the ageing tank.
34000 kg/day of sludge generated from the thickener and ageing tanks of ETP constitute the
hazardous solid waste coming under the category 22 BIS and is disposed in solids collection
yard as slurry. Spent/reused oil from roaster, boiler, compressor, calciner plants (category no
44)comes to 2.2kg/day and is disposed to authorized dealers. Lime sludge generated from the
lime preparation unit comes to 658 kg/day and is disposed in sludge drying beds near ageing
tanks of ETP.
Findings:
The company holds valid consent under the Air(Prevention and Control of Pollution)Act 1981 up to
31-12-2005. The consent order specifies the effluent characteristics of certain pollutants, its tolerance
424
limits and mandate that “ the effluent should not contain any other pollutant” other than specified. The
following are the characteristics specified in the consent.
pH
- 6 – 8.5
Suspended Solids
- 30
Oil and grease
-10
Hexavalent Chromium (as cr) - 0.1
Total Chromium (as cr)
-2
Lead
- 0.1
Manganese
- 2.
Nickel
-2
Titanium (as Ti)
-5
Copper
-2
Zinc
-5
Cadmium
- 0.2
Mercury
- 0.01
Cyanides
- 0.2
The validity of consent under the Water (Prevention and Control of Pollution)Act 1974 expired on 3112-2004 and the application for consent renewal is pending with the Board.
The company has obtained authorization under the Hazardous Waste (Management and Handling)
Rules 1989 valid up to 17-09-2006 subject to the condition that the company shall comply the
provisions of Environment (protection )1986 and rules made there under and that the company shall
not rent , lend , sell, transfer or other wise transport the hazardous waste without obtaining prior
permission to state Pollution Control Board. The authorization issued is for the handling and disposal
of 602 tonne/year lime sludge (waste category 22.1 BIS) by secured landfill, 12775 tonne/year ETP
sludge (waste category 22.2 BIS),by securely storing in impervious lined tanks and 2 tonne/year
spent lubricating and system oil (category 44 of schedule I)by securely storing in roofed, impervious
tank to actual user.
During the inspection of LAEC with the officials of Pollution Control Board on 26-11-2004, the
treatment plant was found working. On inspection the committee found bypass lines for pumping the
raw effluent from equalization tank and from flash mixer to hazardous waste dumping yard(Solid
Collection Yard). According to the company the supernatant liquid from the solids collection yard is
pumped back to ageing tank from where it is discharged into the river after pH correction. As no
treatments other than pH correction in the ageing tank is provided for the supernatent liquid from
solids collection yard, untreated effluent is discharged into the outlet. The committee took samples of
the supernatant from solids collection yard which shows the following contents.
low pH (acidic)
high concentration of Iron
Lead
Manganese
-3.9
- 2005 mg/l
-1.14 mg/l
-16.46 mg/l
The method of pH correction adopted by the company in ageing tanks is scientifically not convincing.
The Asst. scientist of the PCB Mr. K.V.M.V.Shanavas who accompanied the team took two samples,
one - the effluent entering the final polishing tank from T3 series of ageing tank and the other from
the authorized outlet discharging from the polishing tank and analyzed the same in the laboratory of
the company itself. The Blue coloured effluent collected from T3 series of ageing tank for lab analysis
showed chloride content of 30823 mg/l and the effluent collected from the authorized outlet showed
chloride concentration of 2332 mg/l. The effluent discharged through the authorized outlet was
however colourless .
425
All the four tanks of T3 series were almost filled with bluish green coloured effluent. The officials of
the PCB and LAEC members sought explanation as to how chloride content of the effluent entering
polishing tank from 30823 mg/l is reduced to 2332 mg/l without any treatment in the final polishing
tank. They had no satisfactory explanation to render. The only inference therefore is that there is
dilution in final polishing tank by using water.
The effluent treatment plant is totally inadequate to treat the pollutant and the effluent discharged from
the outlet contain high chloride which is a pollutant not permitted to be let in to the Periyar under the
consent.
The LAEC found the lime sludge storage near the ageing tank being used for dumping the hazardous
waste. Lime sludge yard used for solid collection is not one built as per the specifications for
dumping hazardous waste. Further it is not an authorized solid collection yard and that it is not
disclosed to PCB as hazardous waste collection yard. This yard is found completely filled and a small
rain fall would lead overflow from this yard to nearby ageing tanks. The sludge collected in this yard
being hazardous waste should be directed to be shifted to hazardous waste dumping yard. The lime
sludge should be used only for lime sludge and not for other sludge.
The hazardous waste dumping yard of the company is almost full. The yard is in a vast area of nearly
1.5 acres of land . A small rain fall would cause overflow from this yard leading the effluent directly
to river Periyar. The company claims that lining of 375 micron LDPE sheet is provided for solid
collection yard.
The analysis of the unused open well near the hazardous waste dumping yard at a distance of 7 m
showed very low pH 3.3 with high iron (13.79 mg/l) and manganese (0.6 mg/l ) content. The water
also contain Zinc( 0.6 mg/l), Copper (0.04 mg/l) Nickel (0.11 mg/l) and Lead (0.1 mg/l).
The test well near the solids collection yard shows Zinc (0.77 mg/l) and iron( 1.28 mg/l)
contents.
The observations reveal contamination of open well and test well due to pollutants from
solids collection yard. The laxity on the part of the company in curbing chances of
percolation of pollutants from hazardous wastes in the solid collection yard is to be viewed
seriously.
The reports of analysis of the solid wastes collected from the Solids Collection Yard reveal the
presence of the Zinc(424.2 mg/kg), Iron (2425.1 mg/kg), Lead(206 mg/kg), Mercury (0.02 mg/kg),
Cadmium(6.4 mg/kg), Copper(22.3 mg/kg), Nickel(67.0 mg/kg), Total Chromium(208.3 mg/kg) and
Manganese(877.6 mg/kg).
The soil sample from the ETP premises show Zinc(130.9 mg/kg), Iron (2494.7), Lead(70.0),
Mercury(0.01), Cadmium(2.8), Copper (21.5) Nickel(60.4),Total Chromium(74.9) and
Manganese (560.9 mg/kg).
A block of soil collected from the river bank near the pump house owned by the CMRL was
found containing Iron(2587 mg/kg ), Zinc (137.8 ),lead (93.0), Mercury (0.03),
Cadmium(4.9), Copper (14.7), Nickel(24.9),Total Chromium(173.7) and
Manganese
(124.5mg/kg).
Also the analysis of the soil sample collected from the new earthern storm water
drain(unauthorized), in the premises of CMRL and the sludge accumulated on land near the
426
Solid Collection Yard indicate the presence of pollutants characteristic of hazardous waste
stored in the solids collection yard viz. Zinc(70.2 mg/kg & 322.5 mg/kg) Iron (2336.1 &
2895.5), Lead (67.0 & 133.0), Cadmium (1.5 & 1.8),Copper (10.0 & 124.0), Nickel (24.3 &
53.6), Total Chromium (408.6 & 94.9) and Manganese (62.2 mg/kg & 71.4 mg/kg).
The concentration of Hexavalant Chromium in the soil sample collected from the storm water
drain(unauthorized) near river side and solid collection yard were found to be 80.5 mg/kg and
185.60 mg/kg. respectively exceeding the concentration limit of 50 mg/kg specified in class
A, schedule 2 of the Hazardous Waste(Management and Handling) Rules 1989.
The hazardous solid wastes are strewn into open land of the factory premises and is illegal
violating the provisions of the Hazardous Waste (Management and Handling) Rules 1989 and
amendments thereof.
The LAEC on inspection on 28th December 2004 noticed that hazardous waste from solid
collection yard was being removed manually for making bricks by mixing with clay. A
temporary kiln was also seen. This activity was not seen during the previous inspection of the
committee. The method of disposal of hazardous waste by making bricks is not an authorized
activity under the Hazardous Waste Rules. The company could not produce any authorization
for carrying out such activity. The company has violated the condition of authorization under
the Hazardous Waste (Management and Handling) Rules 1989.
A flow meter is provided in the PVC pipeline carrying treated effluent from polishing tank
through vertical pump pit into river. A bypass line was seen provided to this pipeline before
the flow meter, which according to the company authority is for pumping the effluent in case
of flow meter failure. A valve and flange opening of 4 inch dia was also seen provided before
the flow meter near the T 4 (b) ageing tank. The company officials reported that the provision
is for testing effluent flow into the river through the effluent discharge pump installed in
vertical pump pit. However the explanations were not satisfactory as it is hard to believe a
sampling point with a 3 inch dia valve and flange on the effluent discharge line to river. The
valve arrangement provided can be utilized for pumping untreated effluent from solids
collection yard and ageing tanks into the river through the authorized outlet. This arrangement
should be dismantled.
The committee took samples from the man hole no 1 in the effluent discharge pipeline
carrying treated effluent from authorized outlet to the final outlet in River Periyar. It was
found containing highly acidic effluent, Iron 225mg/l and Chlorides 1750mg/l indicating the
discharge of untreated effluent through the authorized outlet into the river.
The total length of the effluent discharge pipeline would be more than 1 ½ kms and
throughout the entire length of this pipeline, there are several connection points at intervals of
4 to 6 feet length (on an average). The effluent discharge pipeline is not visible throughout its
entire length. The presence of several connection points and “T” joints is highly suspicious
and there is possibility of unauthorized connections of pipeline / hose into the authorized
effluent discharge pipeline.
The pipe line conveying effluent from the factory through the first manhole passes through
the adjacent land underground and slightly exposed at points, crosses the road and passes
through the bank of Chakkalathodu to reach the final manhole and river. Yellow colour
effluent was seen in Chakkalathodu from the point of “T” joint of effluent pipeline laid along
427
the thodu . The lab analysis report of the sample taken from chakalathodu indicates Iron 12.1
mg/l, Chloride 620 mg/l, Magnesium 57.8 mg/l and colour 45 hazen units.
On 28-11-04 at about 7 am the members of LAEC including its Chairman, Mr. P.K. Ibrahim
went to the final outlet of the company provided in the river near Pathalam bund on getting
information that untreated effluent is being discharged into the river. The team found red
coloured effluent coming out of the authorized outlet. Samples and photographs were taken.
The pH and concentration of Lead were beyond the limits. Also the Iron content was 18.9
mg/l. It is pertinent to mention that after one hour of the inspection of the outlet by the LAEC,
the reddish colour of the effluent got reduced and ultimately colourless effluent started
flowing through this outlet. LAEC members have observed this phenomenon on many
subsequent days intermittently. The company was thus found untreated effluent through this
outlet. The results of analysis of this sample show pH 8.3, Lead 0.57 mg/l and Iron 2.8 mg/l.
On several occasions, the members of LAEC on being informed by the local citizens have
rushed to the Pathalam bund and nearby places adjacent to the River Periyar. There is
widespread
complaint
of
fish
killing
in
Periyar
river.
There is also widespread complaint of Periyar running in red colour. The committee have
observed in several occasions have seen untreated effluent being discharge into Periyar river.
The local people including NGOs have reported the discharge of untreated effluent by the
company. In one occasion one of the NGO working in Eloor – Edayar area namely
SOLIDARITY collected green coloured effluent from the final outlet of the company and
handed over to the LAEC members requesting action for discharging untreated effluent.
LAEC got the sample analyzed at the central laboratory PCB and found the following
characteristics .
pH
Suspended Solids
Zinc
Iron
Lead
Chlorides
Manganese
-4.4
-1410 mg/l
-2.01 mg/l
-12238mg/l
-4.29 mg/l
-33500 mg/l
-11.2 mg/l
The company consumes 1.84 lakhs litres of water from Periyar River per day and discharges
1.50 lakh litre of effluent per day into the River Periyar. According to the effluent monitoring
reports submitted by the company the effluent discharged through the outlet does not contain
any pollutant which can cause danger to the river. However the lab reports of the samples
taken by the LAEC with the assistance of the officials of the PCB shows the effluent
containing high concentration of pollutants characteristics of the hazardous waste in the
sludge collection yard. The effluent discharged through the outlet is in utter violation of the
consent order under Water(Prevention and Control of Pollution)Act 1974.
LAEC met on 26th January 2005 for finalizing the inspection report of this company. The
report was being finalized. The meeting adjourned for today for finalisation of the report. In
the meanwhile yesterday at 8.00 pm a member of the LAEC Mr. Anand who is a
428
representative of Confederation of Indian Industry was alerted by a phone call from Edayar
that he could not get the Chairman LAEC on phone and that there is a discharge of untreated
effluent througth the outlet of CMRL and that if he rushes to the spot sample can be collected.
Immediately Mr. Anand contacted Mr. Jayathilakan a member in the LAEC representing
Kerala Management Association and Mr. Asokan member in LAEC representing Edayar
Small Scale Industrial Association and Mr. Jacob.V.Lazer, member, LAEC representing
Peoples Union for Civil Liberties proceeded to CMRL outlet near pathalam bund. The
LAEC team reached there around 8.30 pm and requested one of the local resident Mr. Saffar
to take samples climbing the walk way provided at the CMRL outlet and collect samples. By
this time a number of local people also gathered. Mr.Shamsudin President of the
Pourasamithi was also present. Photographs were taken.
The green effluents collected from the outlet is sent for lab analysis to Central laboratory,
PCB. On request by the LAEC The Central Laboratory PCB gave an emergent report of the
sample which shows pH – 6.0, Iron 1881, Chloride – 6500.
The colour of the effluent seen discharged from the outlet of the company at times is bluish,
greenish or reddish. The change of colour from blue to green to red shows different stages of
hydrolysis of iron from ferrous to ferric states in different pH ranges. The Iron salts get
hydrolyzed absorbing dissolved oxygen from river water and thereby depleting the dissolved
oxygen level in water. When the dissolved oxygen falls below 4 mg/l fish kill is likely to
occur. When the dissolved oxygen approaches or becomes zero an anaerobic or septic
condition sets in which render aquatic life in water impossible and causes formation of
obnoxious gases.
The committee today met and resolved to forward the report of the company to the State
Pollution Control Board recommending immediate action against the company. A copy is also
marked to Supreme court monitoring committee for information and report to the Hon’ble
Supreme Court.
The committee places on record the service and co-operation of the local residents who have
out of their civic concern alerted the committee and brought to its notice an activity that is
detrimental to the environment and river Periyar which is the main source of drinking water of
the people for nearly four districts of the state.
The committee makes the following recommendations:
By discharging polluted effluent containing hazardous chemicals into the river, the company
has caused irreparable damage to the river and surrounding environment .The company is
seen discharging untreated effluent to river Periyar violating the provisions of the Hazardous
Waste(Management and Handling) Rules 1989 and Water (Prevention and Control of
Pollution)Act 1974 by violating the conditions of authorization and the consent issued under
the aforesaid Acts. The company should be therefore be directed to close down until it satisfy
PCB and LAEC of the efficiency of the effluent treatment plant and adequacy of storing
sludge in the hazardous waste dumping yard which qualify the specification of the Board.
The company should be directed to dismantle the bypass lines provided from the raw effluent
pipe to equalization tank and lime treated effluent tank and at flash mixer point to divert the
raw effluent to hazardous waste dumping yard.
429
The supernatant from hazardous waste dumping yard should be directed to be taken for
treatment separately than bringing it to ageing tank where there is no scientific treatment is
made.
Though the company is producing Synthetic Rutiles, its byproducts contains Iron and
Chloride namely Ferrous Chloride and Ferric Chloride. The company is virtually dumping its
by products directly into the river. The entire river bed and through out the downstream of
the Pathalam bund, Ferric Iron is visibly seen and is accumulated at the bottom of the river.
The LAEC team during its river inspection conducted on 4-12-2004 could observe this . It is
shocking that the company is discharging iron and chloride to the river when the consent
specifically mandate that the effluent permitted for discharge to river Periyar shall not
contain any other pollutant.
The company should be directed to shift the hazardous waste stored in lime sludge yard to a
secured land fill established as per the specification of the Board.
The Hazardous waste disposal yard covering approximately an area of 1.5 acres is open and
cannot contain the rain water of a small rain fall and therefore they have no capacity to hold
water for diverting the same for treatment.
The hazardous waste strewn in the premises of the company should be directed to collected
and stored in hazardous waste dumping yard.
The hazardous waste dumping yard is found leaching and the lab report of the samples taken
from the open well and test wells demonstrates this fact. The company should be directed to
stop leaching failing which the river water will be contaminated having regard to the volume
of the waste being accumulated in the hazardous waste dumping yard, which is hardly 20
meters from Periyar.
The company is found violating the provision of the environmental protection Act and have
caused damage to the environment by dumping hazardous waste to land and river, The
company should be directed to pay a fine of Rs. 10.00 lakhs, which amount shall form part of
the compensation which will be determined on Polluter Pays Principle.
The company should be directed to give a mass balance statement with a documentary proof
regarding the total quantity of raw material used, the total production, the quantity of the solid
waste generated etc. over these years. Details regarding water balance should also be
furnished.
Admittedly the validity of the consent issued under the Water (Prevention and Control of
Pollution) Act, 1974 has been expired in December 2004. The company is found violating the
parameters stipulated in the consent order. The renewal of consent only be granted after the
company is satisfy the efficiency of the effluent treatment plant to the satisfaction of PCB and
LAEC.
The company should be directed to provide sampling point at the river side under lock and
key and accessible to the inspecting team for surprise inspections. The sampling point must
have pH indicator and recorder.
430
The action on this report may be expedited, as delay would cause serious prejudice to the public
interest. PCB may also intimate Supreme Court Monitoring Committee on the actions taken on this
report with a copy to LAEC for information.
Consented Parameters and Limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Characteristic
Unit
pH
Suspended Solids
Oil and Grease
Hexavalant Chromium (asCr)
Total Chromium (asCr)
Manganese
Nickel
Titanium (asTi)
Copper
Zinc
Cadmium
Mercury
Lead
Cyanides
Total Heavy metals
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
Tolerance
limit
6-8.5
30
10
0.1
2
2
2
5
2
5
0.2
0.01
0.1
0.2
7
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
Determinant
Un
it
:Cochin Minerals and Rutile Ltd., Edayar
:26-11-04
:LAEC 1(Soil near equalization tank)
LAEC 2(Lime slurry collection tank)
LAEC 3(Solid collection yard)
LAEC 4(Block of soil from riverside (near pump house))
LAEC 5(Soil from the storm water drain)
LAEC 6(Sludge from the CMRL premises (backyard of cochin
fertilizers)).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Soil near
equalizat
Lime
slurry
Solid
collec-
Block of
soil from
Soil
from the
Sludge
from the
431
1
Zinc
2
3
4
5
6
7
8
Iron
Lead
Mercury
Cadmium
Copper
Nickel
Total
Chromium
Manganese
Hexavalant
chromium
9
10
ion tank
collection tank
tion yard
riverside
(near
pump
house)
storm
water
drain
CMRL
premises
(backyard
of cochin
fertilizers)
mg
/kg
,,
,,
,,
,,
,,
,,
,,
130.9
415.0
424.2
135.8
70.2
322.5
2494.7
70.0
0.01
2.8
21.5
60.4
74.9
2696.3
127.0
0.02
6.4
22.3
67.0
208.3
2425.1
206.0
0.02
6.5
63.8
69.6
830.0
2587.0
93.0
0.03
4.9
14.7
24.9
173.7
2336.1
67.0
ND
1.5
10.0
24.3
408.6
2895.5
133.0
ND
1.8
124.0
53.6
94.9
,,
,,
560.9
3.5
877.6
18.1
460.6
185.6
124.5
7.2
62.2
80.5
71.4
3.6
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No
1
2
3
4
5
6
7
8
9
10
11
Determinanat
pH
SS
Zinc
Iron
Lead
Mercury
Cadmium
Copper
Nickel
Cyanides
Hexa.
Chromium
Unit
mg/l
: Cochin Minerals and Rutile Ltd.,Edayar`
: 26-11-04
:LAEC 16(Authorised outlet)
LAEC 17(Storm water delay pond)
LAEC 18(Test well)
LAEC 19(Open well near ETP sludge pond)
LAEC 21(Supernatent from ETP sludge pond( Solid collection
yard)).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Authorised
outlet
Storm
water
delay
pond
Test well
Open well
near ETP
sludge
pond
Supernatent from
ETP sludge
pond(Solid
collection yard)
Tolerance
Limit as per
consent
6.8
8
ND
ND
0.62
ND
ND
0.07
0.17
ND
ND
9.6
20
ND
ND
ND
ND
ND
ND
0.02
ND
ND
7.5
22
0.77
1.28
ND
ND
ND
ND
ND
ND
ND
3.3
15
0.6
13.79
0.1
ND
ND
0.04
0.11
ND
ND
3.9
35
0.15
2005
1.14
ND
0.03
0.07
0.35
ND
ND
6-8.5
30
5
-0.1
0.01
0.2
2
2
0.2
0.1
432
12
13
14
15
Total
Chromium
Manganese
Oil and Grease
Titanium
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
ND
ND
0.04
2
0.072
ND
ND
ND
ND
ND
ND
ND
ND
0.6
ND
ND
16.46
ND
ND
2
10
5
: Cochin Minerals and Rutile Ltd., Edayar
: 21-12-04
:LAEC 37(Hazardous waste from CMRL used for brick
making)
LAEC 38(Hazardous waste mixed with clay for making
brick).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Hazardous waste
from CMRL used
for brick
Making
5.1
mg/kg 493.1
352250
190
0.03
8.3
56.4
61.1
277.9
714
pH
Zinc
Iron
Lead
Mercury
Cadmium
Copper
Nickel
Total chromium
Manganese
Name of the Lab
1
2
3
4
ND
Determinant
Source
Date of sample collection
Sample Identification No
Sl.
No.
ND
Determinant
pH
BOD
COD
SS
Unit
mg/l
Hazardous waste mixed
with clay for making
brick
4.1
176
548.1
142
0.02
5.6
48.1
48.9
152
328
: Cochin Minerals and Rutile Ltd., Edayar
: 28-12-04
:LAEC 22(Outlet)
LAEC 28(Polishing tank)
LAEC 12(Manhole no 1 is treated effluent pumping line to the
river)
LAEC 13(Outlet sample preserved for metals)
LAEC 15(Final outlet into river),
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Outlet
Polishing
tank
Manhole
no 1 is
treated
effluent
pumping
line to the
river
Outlet
sample
preserved
for metals
Final
outlet
into
river
Tolerance
limit
6.5
6
26
8
4.7
10.0
560
215
2.1
20
480
460
1.9
16.0
64
8
6.5
2.0
17.2
8
6-8.5
--30
433
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Chlorides
Cynide
Sulphide
Phenolic
Compounds
Total
residual
Chlorine
Oil & grease
Hexa
chromium
Zinc
Iron
Lead
Mercury
Cadmium
Copper
Nickel
Manganese
Titanium
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
Determinant
pH
SS
TDS
Chlorides
Cyanides
Oil & Grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
Determinant
Zinc
Iron
Cadmium
Copper
Nickel
2600
ND
ND
0.1
18800
ND
ND
1.4
1750
ND
ND
0.08
31200
ND
ND
0.5
2750
ND
ND
0.08
-0.2
---
ND
ND
ND
ND
ND
--
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
10
0.1
ND
ND
ND
ND
0.023
0.171
ND
ND
ND
ND
106.5
0.4
ND
0.321
0.85
ND
ND
ND
ND
225
0.03
ND
0.052
0.028
ND
8.2
ND
ND
280.8
0.45
ND
0.243
0.906
ND
ND
ND
ND
ND
ND
ND
0.03
0.053
ND
2.1
ND
5
-0.1
0.01
0.2
2
2
2
5
: Cochin Minerals and Rutile Ltd., Edayar
: 26-1-05
: LAEC 19(Final outlet point in Periyar river).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
Final outlet
point in
Periyar river
5.8
2100
12400
6515
ND
ND
Tolerance limit
6-8.5
30
--0.2
10
: Cochin Minerals and Rutile Ltd., Edayar
: 26-1-05
: LAEC 26(Metals).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Metals
mg/l
1.697
1881
2.263
0.235
0.501
Tolerance
Limit
5
-0.2
2
2
434
6
7
8
9
10
11
12
Total Chromium
Manganese
Titanium
Lead
Mercury
Arsenic
Hexa Chromium
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Determinant
pH
SS
Zinc
Iron
Lead
Mercury
Cadmium
Copper
Nickel
Chlorides
Cyanides
Hexa chromium
Total Chromium
Manganese
Oil & grease
Titanium
Source
Date of sample collection
1.087
ND
ND
2.2
ND
ND
ND
2
2
5
0.1
0.01
-0.1
: Cochin Minerals and Rutile Ltd., Edayar
: 1-1-05
:LAEC 81(Sample taken by Solidarity from final discharge
point of CMRL in River)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
Sample taken by
Solidarity from final
discharge point of
CMRL in River
4.4
1410
2.01
12238
4.29
ND
0.192
ND
ND
33500
ND
ND
0.41
11.2
ND
ND
Tolerance
limit
6-8.5
30
5
-0.1
0.01
0.2
2
2
-0.2
0.1
2
2
10
5
: Cochin Minerals and Rutile Ltd., Edayar
: 1-4-05
435
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
Determinant
pH
SS
Zinc
Lead
Cadmium
Copper
Nickel
Cyanides
Hexa chromium
Total Chromium
Manganese
Oil & grease
Titanium
: LAEC 178 (outlet)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
LAEC
178
9.5
8
ND
2.92
ND
0.03
0.08
ND
ND
ND
0.3
ND
ND
Tolerance
limit
6-8.5
30
5
0.1
0.2
2
2
0.2
0.1
2
2
10
5
436
437
438
439
440
INDIAN ALUMINIUM COMPANY LIMITED, ALUPURAM SMELTER
Name of Industry
: Indian Aluminium Company Limited.,
Alupuram Smelter.
Date of inspection
: 7-9-05
Raw materials
:
(a) For pot room and associated facilities. (Plant de energized effective-1-8-03)
1.
2.
3.
4.
5.
6.
Alumina
Cryolite
Aluminium Fluoride
Electricity
Pitch
CP Coke
: 75 t/day
: 0.07 t/day
: 1.1 t/day
: 661830KWh/day
: 5.4t/day
: 15.3 t/day
(b) For casting plant.
1.
2.
3.
4.
Aluminium ingots
Aluminium process and extrusion scrap
Furnace oil
Alloying ingredients
:14 t/day.
:14.5 t/day
: 3860 litres/day
:1 t/day.
Products:
(a) From pot room and associated facilities.
1. Aluminium metal
(smelter de energized effective –1-8-03)
2. Carbon electrode paste
(carbon plant shut down effective1-10-03)
:1143 t/months
: 580 t/months
(b) From casting plant
1. Aluminium billets
:700 t/month
2. Aluminium ingots(shut down since August 2003)
:443 t/month
3. Aluminium Wire Rods (shut down since August 2003)
Process:
Aluminium is produced by electrolysis of alumina .The electrolytic cell consists of a cathode
which is a steel shell lined with refractory and baked carbon black. The carbon anode is
suspended over the cathode. DC power is supplied across the cell. Alumina the main raw
material is charged to pots periodically. Molten aluminium collected on the cathode is tapped
out in vacuum crucibles and sent to casting plant. Aluminum ingot is fed to the melting
furnace of the casting plant. Required alloying elements are added and billets are cast as per
the requirement.
Solid Waste generation:
441
1. There are two main hazardous wastes generated from the electrolytic cells.
a. Gaseous fumes containing fluorides and alumina dust. This is led to wet scrubber
for removal of fluoride and dust. The removed fluoride is neutralized using lime
and filtered. This scrubber sludge is land filled. Quantity of the same is 1000t/year
as per the authorization issued by KSPCB.
b. Another hazardous waste originates is from cathodes. The carbonaceous lining
degenerates after an age of 1500 to 2000 days. Upon this the lining is demolished.
This waste is called spent pot lining. Quantity of waste is 700 t/year and is stored
in building under cover on concrete pits.
c. Lead acid batteries retired from mobile equipments. This comes to 50 numbers per
year. Lead acid batteries are sold to authorized vendors or to the manufacturers.
d. Waste asbestos used as thermal insulation. Quantity of Asbestos waste is 1 t/year
which is land filled.
e. Spent bricks.
Refractory and fire bricks of failed pots are removed as and when required.
Quantity of this waste is 150 t/year as per the authorization issued by KSPCB.
2. Waste generation from casting plant. The following hazardous wastes are generated from
this plant.
a. Aluminium Dross.
b. Oil containing sludge and oil emulsion.
c. Lubricating oil and System oil.
Aluminium dross is oxides of aluminium, generated during the time of melting. Quantity
of the waste is 120 t/year. Generation of oil containing sludge is 1.5 t/year and Lubricating
/system oil is 2 t/year.
All the above wastes are disposed by sale to authorized re- processors.
3. Water Consumption and Liquid waste:
The industry now consumes 1140 KL of water per day. According to the consent
issued by KSPCB the quantity of effluent discharged through outlet No.A is
20,50,000 litres/day and through outlet no B is 6,50,000 litres /day. This quantity
is based on water consumption when the unit was working in full swing. Now the
industry is closed. The outlet A is to Periyar River which discharges effluent
from bath rooms and other washings .The outlet B is over flow from cooling
water tank which is discharged into land for percolation. During inspection there
was some effluent discharge through the outlet A.
Findings/ Recommendations:
1. The industry had de energized the smelter and associated facilities effective 1 st
august 2003.
2. There is no waste generation from the smelter since the above period.
3. The carbon electrode paste plant was shut down effective 1st October 2003.
4. Hazardous waste from the scrubber generated prior to the above period is seen
land filled.
5. Spent pot lining is seen stored carelessly in the industrial building.
6. Spent bricks are also seen stored carelessly inside the industrial building.
7. Oil containing sludge /lubricating oil/system oil are seen stored inside the plant
building. This is disposed by sale to authorized reprocessors.
442
8. The industrial plant was not working and hence there was no effluent
generation.
9. Company has obtained consent under the Water Act (to be renewed), consent
under the Air Act and authorization under the Hazardous Waste (Management
and Handling) Rules 1989.
10. The monitoring well is to be relocated close to the capped pond to ascertain
the leachate. The present inspection well in oversized and wide open which
is totally unreliable to test leachate. These wells should be closed.
11. The company has to renew the consent from KSPCB before restarting
production.
12. The sample taken from inspection well indicates fluoride content 2.26 mg/l
which indicate ground water contamination. Even open wells of nearby
residents indicates fluoride contamination. Therefore the unit must take
necessary measure to prevent leachate from the disposal site.
13. The unit on functioning in full swing , there would be good number of
employees using canteen . There should be Effluent Treatment Plant for
treating canteen waste.
14. This is a unit which should go for zero discharge, since major discharge is
overflow from cooling tower.
Consented Parameters and limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
Characteristic
Unit
Tolerance
limit
Outlet A
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
pH
Suspended Solids
Dissolved solids
Sulphates
Fluoride
Oil and Grease
Free Ammonia
Ammoniacal Nitrogen
Zinc
Bio Chemical Oxygin Demand
Nickel (as Ni)
Chromium
Copper(as Cu)
Lead
Outlet B
PH
Suspended Solids
Bio Chemical Oxygin Demand
Dissolved solids
Oil and Grease
mg/l
,,
,,
,,
,,
,,
,,
-mg/l
5.5-9
100
2100
1000
2
10
5
50
5
30
3
2
3
0.1
5.5-9
200
100
2100
10
443
Indian Aluminium Company- Extrusion division
Name of industry
: Indian Aluminium Company- Extrusion
division
Date of inspection
: 7-9-05
Raw materials.
:Aluminum billet
Electricity
Products
: Aluminum extruded sections :840 t/month.
Aluminum extruded scrap :360t/month
:1200 t/month
: 27356 KW h/day.
Production Process.
Aluminium extrusion is produced by squeezing a pre heated aluminium billet at a high
pressure through an orifice of required shape in a steel die. Aluminum and its alloys are soft
and plastic in temperature between 400oC to 550oC.The material can be easily extruded in the
above temperature range. Aluminium scrap generated in the process is sent to the smelter
section for reprocessing into billets.
Solid waste generation.:
Lead acid battery –5 nos/year. Used battery is stored in shed with roof and concrete floor.
This is disposed by selling back to the suppliers.
Quantity of spent lubricating and system oil comes to 5 t/year as per authorization issued by
KSPCB. There is a facility for storing this in steel drums in shed with roof and concrete floor.
Disposal of the material is by selling to approved reprocessor.
Water consumption and Liquid waste generation
The industry consumes 104 m3of water/day. They have provided facility for reusing cooling
water used in the plant. The overflow from the cooling water tank is discharged into Periyar
River. The quantity of effluent discharged from the plant is 15000 litres /day as per the
consent issued by KSPCB.
Findings/ Recommendation:
1. Used lead acid battery is disposed by selling back to suppliers.
2. Hazardous waste generated (spent lubricating and system oil) is seen stored in steel
drums.
3. There is facility for recycling of cooling water.
4. There is overflow from the cooling water storage tank which is discharged through the
outlet to Periyar River.
5. Industry has obtained consent under the Water (Prevention and Control of Pollution)
Act 1974(to be renewed) and authorization under Hazardous Waste (Management and
Handling) Rules 1989 from KSPCB
444
6. The company has to renew the consent under the Water (Prevention and Control of
Pollution) Act 1974.
7. The unit should obtain zero discharge as its main discharge is from overflow of
Cooling tower.
Consented Parameters and limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1.
2.
3.
4.
5.
Characteristic
Unit
PH
Suspended Solids
Temperature
0
mg/l
C max
,,
,,
Tolerance
limit
5.5-9
100
shall not
exceed 50C
above the
receiving
water
temperature.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
13
Determinant
PH
BOD
SS
TDS
Zinc
Lead
Copper
Nickel
Fluorides
Sulphates
Free Ammonia
Ammoniacal Nitrogen
Hexavalent Chromium
: Indian Aluminium Company Limited.
: 7-9-05
:LAEC 172 (Outlet (Extrusion plant)),
LAEC 147 (Outlet A),
LAEC 197 (Inspection well (storage pit)),
LAEC 199 (From well of Vincent),
LAEC 49 (From well of flory George)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
LAEC
172
6.2
0.18
7
40
ND
ND
ND
ND
ND
ND
Nil
0.44
ND
LAEC
147
5.5
0.2
8
56
ND
ND
ND
ND
1.3
15
Nil
ND
ND
LAEC
197
5.6
0.12
7
112
ND
ND
ND
ND
2.26
44
Nil
ND
ND
LAEC
199
5.6
0.18
8
112
ND
ND
ND
ND
0.36
44
Nil
ND
ND
LAEC
49
5.6
0.12
12
123
3.0
ND
ND
ND
0.9
36
Nil
0.6
ND
445
14
15
Total Chromium
Oil&Grease
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
FACT, UYOGMANDAL. DIVISION
Name of Industry
:FACT, Uyogmandal. Division
Date of inspection
:01/06/05,08/07/05,30/07/05
23/08/05,24/08/05
Raw material
:Naphtha
673 t/day
:Rock Phosphate
325 t/day
:Furnace oil
135 t/day
Sulphur
194 t/day
Products
: Sulphuric Acid - 600t/day Sulphuric acid and
550tonnes/day combined capacity SO2 /acid
: Ammonia
-900t/day
: Phosphoric acid
-100t/day
: Ammonium Sulphate -682t/day
: Ammonium Phosphate - 450 t/day
: Carbon dioxide
-1007t/day
: Gypsum
- 500 t/day
Production Process:
1.Sulphuric Acid.
The process consists of Sulphur melting, Combustion of sulphur-to-sulphur dioxide, Catalytic
conversion of sulphur dioxide to get sulphur trioxide, Intermediate absorption of Sulphur tri
oxide in concentrated Sulphuric acid to produce Sulphuric Acid, Final conversion of
unreacted Sulphur dioxide to Sulphur trioxide and final absorption of Sulphur trioxide in
concentrated Sulphuric Acid.
The converter consists of four beds of vanadium pentoxide catalyst. The gas from the furnace
after passing through the waste heat boilers enters the first bed at 430 oC.In the first layer
about 57% of SO2 is converted and the gas leaving the first bed is cooled from 594oC to
440oC in the waste heat boiler, and then enters the second bed where the conversion reaches
85% and the temperature raises to 520oC which is brought down to 450oC in Intermediate
Heat Exchangers. The gas then goes to 3rd bed where conversion reaches 94% and
temperature to 475oC.The gas goes to the final heat exchanger and then to the Intermediate
Absorption Tower where SO3 is absorbed and gas leaving the absorber at 65oC enters the
fourth bed at 420oC after passing through the Final Heat Exchanger and then the Intermediate
446
Heat Exchanger. The conversion reaches 99.5% and temperature 445oC.The gas then goes to
the final absorption tower through an economizer where the temp is brought down to
180oC.Gas from the final absorption tower is released to the atmosphere through the stack.
Process water is admitted to the tower bottom to maintain the acid concentration at 98.4%.
The acid drawn off from the final absorber is cooled to 40oC and stored.
2.Ammonia
Process involved in the production of ammonia are :
a. Predesulphurisation of the raw naphtha. The bulk part of sulphur is removed in this
section.
b. Final desulphurisation of the hydrocarbon feed in one step: Removal of remaining
sulphur compounds.
c. Reforming of the desulphurised hydrocarbon feed in two steps by steam and air. The
process gas from these steps contains hydrogen and nitrogen as well as carbon
monoxide (CO), carbon dioxide (CO2), methane and argone. The reforming takes
place at pressure of about 35kg/cm2
d. In the gas purification section, CO is first converted to CO2 and H2 yield. CO2
is then removed in the CO2-removal section, and afterwards the remaining CO and
CO2 in the converted gas are removed in the methanator.
e. The purified synthesis gas is compressed to a pressure of about 135kg/cm2 and
converted into ammonia by a catalytic reaction.
f. The plant is designed to a nominal production of 900 MTPD ammonia and 10,800
Nm3/H of synthesis gas. The ammonia produced in the plant is sent to the caprolactam
plant and to atmospheric storage. Synthesis gas is consumed in the caprolactam plant
as well, and in combination with part of the CO2 produced.
3.Phosphoric Acid
Phosphoric acid is manufactured by wet process by the reaction of rock phosphate with
sulphuric acid.
The principal steps in the production of Phosphoric acid by this method are the following:
Grinding of rock phosphate, Reaction of the ground rock with sulphuric acid, and Separation
of phosphoric acid from the gypsum.
(a) Grinding of rock phosphate: The phosphate rock is ground dry in mills after drying if
necessary. There are three grinding mills with a total capacity of 40 tonnes/hr of
ground ore. The rock is ground so that 95 per cent will pass through a 100-mesh
screen.
(b) Reaction of rock phosphate and sulphuric acid: The main aim of this step is to get the
rock reacted with sulphuric acid in such a manner as to (1) produce the highest
possible concentration of phosphoric acid, (2) give good coarse gypsum crystals which
could be easily filtered and washed with minimum of water to give a washed gypsum
almost free of soluble phosphoric acid and (3) give the maximum yield of P 2O5 from
the rock.
The Dorr Oliver single tank reaction system is employed here.
The slurry formed during the reaction is fed to the filter for separation of gypsum from
phosphoric acid.
447
Counter-current washing of the cake is carried out with 10 to 12% acid, secondly 3 to
5% acid and finally with water. Wash acid of strength 19%is returned to the reaction
system. The filtrate of strength 20 to 22% is sent to storage.
The byproduct gypsum is slurried with water and pumped to the Sulphate plant.
4.Ammonium Phosphate
Phosphoric acid, Sulphuric acid and gaseous ammonia are fed to a saturator and
agitated. Further addition of ammonia is done in the second saturator. The neutralized
product is a thick slurry and flows to a blunger where it is mixed with undersized
granules; crashed granules and recovered dust, along with some urea. The granulation
takes place in the blunger.
The liquid ammonia at a pressure of 15 psi (g) and 18 oC is injected to the blunger to
adjust the mole- ratio to 1.8.The amount of dry material recycled to the blunger is
about 6 to 10 tonnes per tonne of dry material produced .The blunger which operates
which on fludisation technique is of a double shat paddle mixer set on a slope .The
granulated wet product from the blunger flows through a chute to rotary co-current
drier when the material is dried by a current air along with combustion products from
a combustion chamber. The material leaving the drier is conveyed to set of vibrating
screens with 8 and 14 mesh screens. The –8 and +14 material is taken out as the
product. The +8 material is crushed and, along with –14-mesh material is fed back into
the blunger .The hot airflow is maintained through the driver by fan. The dust- laden
air leaving the drier fan passes through a multiple cyclone where the bulk of the dust
separates out. The dust coming from the screens and other equipments is driven out by
a dust fan through a cyclone. The air from the drier cyclone and dust cyclone along
with the fumes leaving the reaction tank enter the scrubbers for removal and recovery
of ammonia and dust. The scrubbing is done with phosphoric acid. The scrubber
solution is fed back to the reaction tank. The product is bagged and sent to storage.
5.Ammonium Sulphate
The Ammonium sulphate solution fed to the unit consisting of two separate streams
from the Caprolactum Plant of Petrochemical Division .One feed stream is Lactum
ammonium sulphate solution and the other feed stream is Oxime ammonium sulphate
solution. This plant consists mainly of the following four sections.
1. Concentration and crystallization section
2. Dewatering section
3. Drying and cooling section
4. Storage and bagging section.
1. Concentration and crystallization section:
The quadruple effect crystalliser and evaporator system with one concentrator are used
for this purpose. First effect consists of two evaporators, one for oxime and the other
for Lactum ammonium sulphate solutions. Second and third effects are the oxime
448
ammonium sulphate crystallizers, and fourth effect is lactam ammonium sulfate
crystallizers.
The 40 % Oxime Ammonium sulphate solution is fed into 1st Effect Oxime
Ammonium sulphate Evaporator after preheating at Oxime Ammonium sulphate.S pre
heater and solution is concentrated to approx. 51-wt % of ammonium sulphate.
The concentrated solution is sent to No.1 Oxime Ammonium sulphate crystalliser. A
half of ammonium sulphate contained in Oxime Ammonium sulphate solution is
crystallized in this crystalliser and the slurry (approx.30 wt %) is sent to dewatering
section. The rest mother liquor overflows to No.2 oxime Ammonium sulphate
crystallizer where ammonium sulphate is crystallized and the slurry is sent to be
dewatering section.
To prevent accumulation of impurities mainly composed of ammonium nitrate in the
system and to keep product quality, a portion of mother liquor is purged from No.2
Oxime Ammonium sulphate Crystallizer.(V4) 40% Lactum ammonium sulphate
solution is fed to concentrator Cyclone Underflow tank where lactam Ammonium
sulphate solution dissolves dirty crystals. The mother liquor is fed to 1st Effect Lactum
Ammonium sulphateEvaporator (V-2) be concentrated to approx.46 wt %. The
concentrated solution is sent to Lactum Ammonium Sulphate crystallizer(V-5) and
the slurry containing high impurities is sent to S-3 Concentrator Cyclone.
2. Dewatering section:
There are 5 numbers of continuous pusher type centrifuges used for dewatering of,
ammonium sulphate crystals. Oxime ammonium sulphate slurry is thickened in a
prethickner. In the Centrifuges crystals are washed by vapor condensate and
dewatered simultaneously. Dewatered product crystals are then fed to the next drying
section through two conveyors.
Lactum ammonium sulphate slurry is thickened in cyclone and dewatered in
centrifuge. The crystals are then sent to the dryer.
3. Drying and cooling section:
Both of oxime and lactam sulphate crystals from the centrifuges are fed to Dryer
Cooler through conveyor. One dryer-cooler is in service and an integrated design of
dryer and cooler is applied. Both dryer and cooler are fluidized bed type. The wet
crystals are dried by hot air generated in Hot Air Heater. Then, the hot dried crystals
are cooled down to approx.55oC by direct air-cooling and indirect heat exchanger
installed inside the cooler.
4. Storage and Bagging section:
The crystals are then fed to hopper A or B by Product Conveyor. Dehumidified Air is
fed to the Hoppers to prevent caking of the hygroscopic Ammonium Sulphate
crystals.The crystals are bagged using four bagging machines.
Waste
449
The effluent generated in various plants of the factory are treated in the effluent treatment
plants and discharged through three outlets.
The company has obtained Boards consent under the water act for discharging 12,000-m3/day
effluents through outlet no. A into River Periyar, 5000 m3/day effluent through outlet no. E
into Kuzhikandam thodu, and 4800 m3/day effluent through outlet No.I into Edamula branch
of River Periyar.
An Effluent treatment plant consisting of equalization, neutralization, clariflocculation and
ammonia stripping are provided for treating the effluent from sulphuric acid plant,
Ammoniam Sulphate, Ammonium Phosphate and Phosphoric acid plants. The treated
effluent is discharged through outlet No. A into Periyar river. The new complex Ammonia
plant effluents are collected separately for neutralization and settling before taking to the
guard ponds from where it is discharged through the outlet I in to the Edamula branch of
Periyar river. Outlet carrying storm water and various condensate from ammonium sulphate
plant are discharged into Kuzhikandam thodu through open drain in the premises of M/s
HIL.(Outlet No. E)
The company has obtained Board’s consent under the Air Act for making
emissions through14 stacks from process plants and 2 stacks from captive Power
plant.
Hazardous wastes generated from the factory are spent catalyst from sulphuric acid plant and
ammonia complex, sulphur muck from sulphuric acid plant, gypsum from phosphoric acid,
and sludge from effluent treatment plant. The company has obtained authorization under
Hazardous Waste (Management and Handling) Rules 1989 for the disposal of (a) 40 t/year
spent catalyst by sale or transfer to person possessing valid authorization from Board. (b)
1300 t/year sulphur containing residue in disposal area and 20-t/year waste oil to authorized
recycler.
Findings.
1. Source of water is Periyar River and the treated water from a common water treatment
plant meets the requirement of FACT-UDL, FACT-PD and FACT Township. Treated
water is also supplied by FACT to other neighbouring industries. According to the
company total water consumption in Udyogamandal division is 26522 KL
2. Sulphuric acid plant was inspected on 30-07-05.There are two sulphuric acid plants
600 tpd DCDA plant producing 400-t/day sulphuric acid and 200-t/day oleum, and the
new plant producing 375t/day So2 and 175-tpd sulphuric acid. Both the plants have
DCDA conversion process for converting SO2 to SO3.
3. During the time of inspection 600 tpd sulphuric acid plant called DC DA plant was
under shut down. Online SO2 monitor is installed in the sulphuric acid plant. The So2
Monitor in DCDA acid plant is seen not working since 26/7/05. On July 7th, the date
of occurrence of gas leakage and fugitive emission from DCDA sulphuric acid plant,
the monitor recorded the upper range value of 1000 ppm, the manual stack analysis
data showed 1373 ppm.
4. . The Production capacity of the Ammonium sulphate plant is 682 t/day. The company
authorities informed that 30% ammonium sulphate solution brought from FACT-Petro
chemical Division is concentrated, crystallized, centrifuged, dryed and cooled to
produce ammonium Sulphatevapour condensate is used to produce ammonia in the
450
HYAM plant of FACT-Petro Chemical Division and the purge liquid containing 30%
ammonium sulphate is reused in the plant.
5. Overflow of vapour condensate storage tank and spillage are taken to a collection pit
and pumped to effluent treatment plant. A level controller is provided in the pit. The
storm water drains and vapour condensate from ammonium sulphate plants are found
leading to a marshy land near old ammonia plant and finally discharge into
Kuzhikandam thodu through an open drain ie, outlet no: E through the premises of
HIL.Immense flow was noticed through the outlet, which according to the company
authorities was due to storm water infiltration in cable trenches. The effluent through
the drain is seen contaminated with high pH.
The monitoring data indicates that SO2 levels are often exceeded. The emission from
both the acid plant are let out through one stack.
6. The ladder provided for monitoring SO2 emission through sulphuric acid plant stack
is not being used. The company authorities informed that the manual stack sampling
is done by collecting the air sample through hose connection at ground level.
7. One storm water drain from the factory premises leading to the Northwest corner, after
crossing the road passes through the property of M/S.IRE Ltd (hazardous waste
disposal area) and joins Kuzhikandom thodu before the discharge point of HIL. This
drain of the company is seen carrying Gypsum on many occasions.
8. The effluents from the complex ammonia plant are taken to guard pond after
neutralization and discharged into the Edamula branch of Periyar River through outlet
No.1.A pH meter is installed at the neutralization tank. Arrangement is provided for
returning the effluent back to neutralization tank incase the quality of effluent in the
guard pond is beyond limits. Online pH meter is installed at the guard pond.
9. The phosphoric acid plant ammonia complex and ammonium phosphate plants are the
major sources of liquid effluent. Ammonia complex effluents are treated separately
and discharged. The liquid effluents from sulphuric acid, phosphoric acid ammonium
phosphate and ammonium sulphate plants are taken to the effluent treatment plant
consisting of equalization tank having two compartments, flash mixer, clariflocculator
and ammonia stripper. The effluent generated from various plants are collected in a
collection tank inside the plant before admitting to the equalization tank. The under
flow from the clariflocculator is returned to the equalization tank. Accumulated sludge
from the equalization tank is removed using crane and dumped nearby for dewatering.
The surface run off from the dumping area is taken to the equalization tank. . The
dewatered sludge is taken to LDPE lined Gypsum disposal yard of the factory
approved by the Board, which is away from the factory site.
10. An oil trap provided in the storm water drain in boiler plant near oil handling area is
seen not functioning.
11. The phosphoric acid plant is not working. Imported acid is used for the production
purpose.
12. The company authorities informed that the scrubbed liquid from ammonium
phosphate plant is taken to collection tanks for recirculation. Recirculation
arrangements are provided for reusing the scrubbed liquor from ammonium phosphate
plants.
13. The scrubbed liquid from IV th stage ammonium phosphate plant is seen containing
oil and black particles. The downward dispersal of emissions from scrubber stacks of
the (300tpd) IVth stage ammonium phosphate plant close to TCC boundary is creating
air pollution problems of poor visibility, mist and fog formation and health effects in
the Eloor Edayar industrial area.
451
14. The company has obtained Board’s consent under the Water Act for discharging
12000m3/day effluent through outlet no.A. into Periyar River, 5000m3/day effluent
through outlet E into Kuzhikandom thodu, and 4800 m3/day through outlet no: 1into
Edumula branch of Periyar River.
15. The hazardous wastes generated are spent catalyst, sulphur muck, spent lubricating oil
and system oil, and sludge from effluent treatment plants. Of these spent catalyst such
as zinc and nickel are disposed by sale to authorized dealer and spent vanadium
catalyst as hazardous waste in disposal site. Sulphur muck is stored for disposal in
approved disposal area. Effluent Treatment Plant sludge and filter cakes of phospho
gypsum from gupsum filters are stored in intermediate storage for final disposal in
LPDE lined gypsum yard. As per the Environmental statement furnished by the
company for 2003, the quantity of wastes handled were
sulphur muck-1158t/year
spent catalyst-65t/year
waste oil
-17t/year
ETP sludge -2125.62t/year.
16. Low chromate treatment system is adopted for treating cooling water. It is informed
that the company have programme for changing cooling tower treatment system from
low chromate to non-chromate system in Ammonium Sulphate plant.
17. Raw material Sulphur spilled over during material handling near the unloading area is
reaching the river along with surface run off. The company have already taken some
steps for containing the spillage of sulphur particles escaping through the drain.
18. Effluent samples were collected from various plants ,effluent treatment plant and
outlets for analysis.
19. The company authority informed that they have proposals for improving the quality
of effluent and elimination of storm water contamination.
a. Proposed to modify the effluent treatment during 2005 in a phased manner.
b. Scheme for diversion of vapour condensate from new ammonium sulphate
plant to phosphoric acid plant by 2006. But there is no production of
phosphoric acid.
c. Scheme for diverting storm water from pollution control plant area.
d. Scheme for elimination of E drain, to be commissioned by March 2006.
Recommendation :
1. Effluent treatment plant is to be augmented incorporating measures for reducing
ammoniacal nitrogen content and effective control over the addition of treatment
chemicals, sludge removal, dewatering, and disposal.
2. Delay pond shall be provided in all storm water drains with monitoring facility.
3. Steps shall be taken for reducing the water consumption, effluent generation and
achieving zero effluent discharge system.
4. Adequate steps shall be taken to prevent the escape of gypsum through storm water
drains.
5. Oil traps in storm water drains are to be revamped and made functional.
6. Adequate steps for effective control of S02 emission through Sulphuric acid plant stacks
shall be taken.
452
7. The scrubber stack for IVth ammonium phosphate plant 150 t/day is seen creating
severe air pollution problems. Adequate control measures such as increasing stack
height and emission velocity shall be provided.
8. Stack monitoring facilities should be renovated and sampling should be done by
drawing sample at the sampling point.
9. Arrangement for avoiding the spillage of sulphur into the storm water drain shall be
provided.
10. Sealed Water meters shall be installed at the raw waters intake point in Periyar River
to measure the water consumption by FACT-UDL, township and FACT-PD separately.
11. The Board should direct the company to install sealed water meter at the intake point
and collect water cess according to the reading in the meter . There should be
periodic for reading water meter.
12. Remedial measure to prevent spillage by overflow of sulphuric acid to avoid leading
to periyar.
13. The discgharge from FACT through outlet E be located near the first culvert over the
Kuzhikandam thodu and made visible and accessible.
14. The company should conduct a safety audit with the competent agency periodically.
2nd report on FACT Udyogamandal Division
(Extracts of 70th meeting held on 29-06-2005)
Resolution no. 1
Mr. Purushan Eloor, Member LAEC reported that an incident of fugitive emission on 26-62005 at Eloor Vadakumbagam where a public sector undertaking namely FACT
Udyogamandal situate. Huge white smoke spread around the area caused severe discomfort
for breathing, throat irritation and vomiting sensation to the residents of Kanjirakuzhi and its
northern area of Eloor Panchayat.
The fugitive emission is believed to be from FACT and, by the description of discomfort felt
to the people, the fugitive emission contained sulphur dioxide and sulphuric acid mist. The
smoke burned even the leaves of the trees. Some residents were treated in the Primary Health
Center, Eloor.
The reported fugitive emission was duly informed at the office of the Pollution Control Board
Ernakulam. LAEC members Mr. Purushan Eloor, Jacob.V.Lazar and official of Pollution
Control Board Mr. K.S.Soman AEE inspected the affected area and took statements from the
residents on the incident. The report of the inspection is read over in the meeting and is made
part of this proceeding.
The committee deliberated on various aspects of the incident and expressed its anxiety on the
lack of arrangements for attending to such incidents, which is part of the comprehensive
chemical disaster management. The committee has been alerted on the fact that despite EloorEdayar industrial belt being an area with number of chemical industries dealing in hazardous
chemicals, a program for chemical disaster management is indispensable and the same is yet
to be evolved.
453
The district administration, Factories and Boilers and Pollution Control Board should evolve a
scheme for chemical disaster management for Eloor - Edayar and periodical review is to be
made. The residents of Eloor –Edayar should also be educated and necessary training be
given.
Committee resolved to approach the district collector and seek his indulgence for constitution
of such a body. Mr. Purushan Eloor and Mr.Asokan are authorized to meet the collector and
to follow up the matter.
3rd report on FACT Udyogamandal Division
(Extracts of the 72nd meeting held on 9-7-2005)
Resolution No.1
LAEC members as part of the stack monitoring inspected FACT, Udyogmandal along with
the officials of PCB viz., Mr. K.S. Soman, Asst. Environmental Engineer; Mr. K.V. Shanavas,
Asst. Scientist on 8th July, 2005 at 12:30 p.m.
The inspecting team before arriving at FACT had received complaints from local people
including industrial workers regarding suffocation, chest congestion etc., as a result of serious
fugitive emission, which was found visible in areas near Sud-Chemie, Binani Zinc Ltd.,
Njavallil Latex and other areas in the Edayar industrial belt. A survey conducted by the
inspecting team in these areas revealed that the source of emission is from FACT,
Udyogamandal and people have been suffering such discomforts for the past few days. It may
be recalled that a large scale emission, which caused serious apprehension in the minds of the
people by the fugitive emission happened on 26/06/2005 was taken note of and this
Committee had resolved to request PCB for necessary action against FACT, Udyogamandal,
being the culprit of fugitive emission.
Mr. Baburaj, Asst. Environmental Engineer of PCB joined the inspecting team at 1:30 p.m. at
FACT, Udyogamandal. FACT, Udyogamandal Acid Plant was inspected by the team as the
concern of the team was to find out the source of SO2 & SO3 (Sulphur dioxide and sulphur trioxide) emission. The FACT claims to have on-line recorder for stack monitoring. The said
system for stack no. 15 (Acid plant) was found to be operational. The needle of the recorder
is found remaining at the maximum point viz., 1000 ppm, which is equivalent to 2617
mg/nm3 as against the permissible concentration of 1500 mg/nm3.
The emission through the stack being highly in excess of the permissible limit, which is even
beyond the comprehension of the installed on-line recorder was detected as a serious lapse
causing very grave concern to the environment and local community. The complaints of the
local community and from the nearby industrial community stands vindicated by the above
findings of LAEC. The inspecting team asked the Company to furnish the statement of online recorder for previous 7 days on-line monitoring. The company refused to provide the
same on the plea that they have a Chemical Analysis Report of Manual analysis of checking
concentration of pollutants. The inspecting team then asked as to how a manual analysis is
conducted. The company confessed that the manual analysis is not done from the stack
inspection duct by climbing at the sample point. According to them, the ladder provided for
climbing is rusted and not safe enough to use the same. The sample is therefore collected
from a pipe connected to the duct of the chimney. When confronted by the LAEC, as to how
samples were taken from pipe can give the pressure of the emission, the company admitted
454
the faulty nature of manual analysis. The laboratory reports of the manual analysis furnished
to the LAEC is thus found to be unreliable. Despite insisting for the on-line recorder
statement, the same has not been furnished.
The company is not having adequate system to control the fugitive emission and even the
system provided for recording the emission is found totally inadequate. The Company has not
provided necessary arrangement even to the regulatory machinery to monitor the Stack. The
provisions of the Air Act and the conditions of the Consent issued to the Company is thus
found violated with impunity.
During the inspection, Mr. Dandapani, Plant Manager was present throughout. After the
inspection, the inspecting team also met Mr. Asokan, General Manager and appraised him of
the situation and the concern of the LAEC.
After the inspection, Chairman, LAEC had a telecon with the General Manager, FACT in the
evening to inform him that any future complaints on fugitive emission from the locals would
be seriously viewed and that the company should immediately arrest the emission beyond the
consent parameters.
Mr. Asokan, General Manager, FACT assured that necessary
precautionary steps will be taken up.
Despite these warnings, the Company could not control fugitive emission and as a result at
around 10:30 p.m., Chairman, LAEC was informed by members of LAEC, Mr. Asokan and
Mr. Jacob Lazer that they are patrolling in Eloor / Edayar belt on information that there is
huge smoke in the entire area and some unit is on fire. The workers in the industrial belt was
found panicky. LAEC members, surveilled the entire area and found 3 fire force engines,
police force and the Eloor Panchayath President, Smt. Subaida Hamsa were all moving in the
Industrial area to identify the source of wide spread white smoke. LAEC members, local
community and industrial workers felt suffocation. The major source of this emission was
ultimately found to be from FACT, Udyogamandal.
In the above circumstances, LAEC resolved to recommend that the operation of the Acid
Plant of FACT, Udyogamandal be directed to stop production forthwith and be allowed to restart production only after ensuring that the Unit makes adequate and fool-proof pollution
control measures to the satisfaction of LAEC and PCB.
455
456
Analysis Reports of the Effluent/ Sludge.
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
DARK RED: POLLUTANTS IN HAZARDOUS WASTE /SLUDGE EXCEEDING LIMIT AS PER HW RULES.
BLUE: PRESENCE OF HEAVY METALS/POLLUTANTS IN HAZARDOUS WASTE/SLUDGE.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
: FACT – UD
: 24-8-05
: LAEC 210(Combined Effluent Ammonium Phosphoric Acid
Plant (300 TPD plant)),
LAEC 202 (Ammonium phosphate collection pit 150 TPD
plant),
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Determinant
pH
BOD
COD
SS
TDS
Arsenic
Chlorides
Fluorides
Nitrates as Nitrogen
Phosphates
Sulphates
Cyanides
Free Ammonia
Total kjeldhal Nitrogen
Ammoniacal Nitrogen
Phenolic compounds
Hexa valent Chromium
Total Chromium
Oil & grease
Vanadium
Unit
LAEC 210
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
2.14
1.2
32
22
1329
ND
200
27.2
0.36
560
190
ND
Nil
140.2
137
1.55
ND
ND
ND
ND
LAEC
202
6.7
0.8
32
15
135
ND
80
2.8
0.23
25.4
40
ND
0.098
19.9
19.5
0.84
ND
ND
ND
ND
Tolerance
Limit
6.5-8.0
100
---1.5
20
5
0.2
4
150
75
0.1
2
10
0.2
457
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Determinant
pH
BOD
COD
SS
TDS
Arsenic
Fluorides
Chlorides
Nitrates as
Nitrogen
Phosphates
Sulphates
Cyanides
Free Ammonia
Total kjeldhal
Nitrogen
Ammoniacal
Nitrogen
Phenolic
compounds
Hexa valent
Chromium
Total
Chromium
Oil & grease
Vanadium
Unit Spillage
pit
(New
NH4SO4
plant
8.2
mg/l 0.8
”
14.7
”
8.0
”
255
ND
0.13
30
7.0
Source
Date of sample collection
Sample Identification No
Name of the Lab
: FACT – UD
: 24-8-05
: LAEC 212(Spillage pit (New NH4SO4 plant)),
LAEC 204(Guard pond(Ammonia Complex)),
LAEC 168(Edrain(Collection sump))
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Guard pond
Edrain(Collection
(Ammonia Complex sump
Tolerance
limit
6.7
4.2
48
8.0
1548
ND
0.19
590
4.0
6.5-8
100
--1.5
20
5.8
0.8
8.3
12
240
ND
0.14
50
0.45
ND
90
ND
6.65
96.9
0.2
170
ND
0.31
63.5
150
ND
90
ND
Nil
19.9
95
62.3
75
19.5
2.1
2.4
2.6
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
: FACT – UD
: 30-7-05
: LAEC 248(Final outlet),
LAEC 249(Raw Effluent-1),
LAEC 250(Sludge under flow),
LAEC 251(Raw effluent-2)
LAEC 252(Effluent before Ammonia removal)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
458
Sl.
No.
1
2
Determinant
pH
SS
3
4
5
6
7
8
9
10
11
12
13
14
Arsenic
Fluorides
Nitrates as Nitrogen
Phosphates
Sulphates
Cyanides
TKN
Ammoniacal Nitrogen
Hexa Chromium
Total Chromium
Oil and Grease
Vanadium
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
13
14
Determinant
pH
SS
Arsenic
Fluorides
Nitrates as Nitrogen
Phosphates
Sulphates
Cyanides
TKN
Ammoniacal Nitrogen
Hexa Chromium
Total Chromium
Oil and Grease
Vanadium
Unit
mg/l
LAEC
248
6.9
15
LAEC
249
4.6
52
LAEC
250
8.0
22
LAEC
251
3.2
47
LAEC
252
9.2
8
”
”
”
”
”
”
”
”
”
”
”
”
ND
1.39
0.33
0.8
320
ND
74
71
ND
ND
ND
ND
ND
21
0.369
36O
550
ND
222.4
218
ND
ND
ND
ND
ND
2.42
7.09
1.2
625
ND
61
60
ND
ND
ND
ND
ND
68.2
0.06
1092
1100
ND
513
503
ND
ND
ND
ND
ND
0.76
0.22
ND
750
ND
118
116
ND
ND
ND
ND
: FACT – UD
: 30-7-05
: LAEC 253(Raw effluent After Primary settling),
LAEC 254(Effluent after Ammonia removal),
LAEC 255(Raw Effluent (inside plant))
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
”
”
”
”
”
”
”
”
”
”
”
”
LAEC
253
5.8
8
ND
5.2
0.27
74
425
ND
112
109
ND
ND
ND
ND
LAEC
254
8.8
10
ND
0.87
0.25
ND
450
ND
72
71
ND
ND
ND
ND
LAEC
255
5.2
162
ND
81.6
0.43
4.4
2000
ND
766
751
ND
ND
ND
ND
459
FACT- PETROCHEMICAL DIVISION
Name of the Industry
:FACT- Petrochemical division
Raw materials
: Name
1.
2.
3.
4.
5.
6.
7.
8.
Products:
Benzene
Synthesis gas as Ammonia
Caustic Soda (100 %)
Sulphur Dioxide
Ammonia
Carbon dioxide
Oleum as 100% sulphuric acid
Furnace oil
Name
1.
2.
3.
4.
Quantity(Avg. tones /day)
150
79.5
19
213
236
66.5
210
175
Quantity(Metric tonne /day)
Caprolactum
Ammonium Sulphate (solution)
Soda Ash
55% Nitric Acid
152
672
14
11.5
Process:
The production process consists of
1.
2.
3.
4.
5.
Benzene hydrogenation
Cyclohexane oxidation
Hydroxylamine sulphate preparation
Oximation and Lactum preparation
Lactum flaking and bagging
Hydroxylamine sulphate preparation: Hydroxylamine sulphate is prepared using the
RASCHIG process. In this, first ammonium carbonate solution is prepared by absorbing
carbon di oxide in an aqueous ammonia solution. A mixture of NO and NO2 is prepared by
oxidizing ammonia over platinum catalyst. This mixture is then absorbed in the Ammonia
Carbonate solution to produce a solution of Ammonium Nitrite. Ammonia Nitrite is then
reacted with sulphur di oxide to obtain Hydroxylamine Di sulphonic Ammonia, which is
further hydrolsed with water to produce hydroxylamine sulphate and Ammonium Sulphate.
Oximation and Lactum preparation:Hydroxylamine sulphate is reacted with cyclohexanone,
with simultaneous addition of Ammonia to control the pH. This results in the formation of
cyclohexanone oxime and Ammonium Sulphate. The cyclohexanone oxime separated as an
460
organic layer from the above mixture is then subjected to a reaction called ‘Beckman
Rearrangement.’Chemically, both cyclohexanone oxime and Caprolactam have same
molecular formula; but different molecular structure. This reaction takes place at elevated
temperature in the presence of oleum. The oluem does not take part in the reaction and it is
later converted to Ammonium Sulphate by adding ammonium to the reaction mixture. This
gives a two –phase mixture; one phase containing caprolactam and the other, Ammonium
Sulphate.The crude Caprolactum solution separated from this is then subjected to a series of
purification steps to remove the various impurities. The Ammonium sulphate solution is sent
to the crystallization section.
Lactum flaking and bagging: The final product lactam from the previous step is in the form of
a liquid with a solidification temperature of 69 degree Celsius. This is then falked in a
standard drum flaker cooled with water. The flakes are then bagged.
Waste:
The company have obtained consent under the Water(Prevention and Control of
Pollution)Act 1974 for discharging 5040 m3 /day effluent into the Edamulla branch of Periyar
river. The effluent treatment system consists of holding basins, oil traps, equalization tank,
aeration tank, secondary clarifier and guard ponds. The hot raw effluent generated from
various sources are taken to holding basin consisting of a series of tanks and fed to aerobic
biological treatment system. Treated effluent is taken to two guard ponds, pH concentration
is done , and discharge into Edamula branch of Periyar River.
The gaseous emissions formed during the process in HYAM plant and anone plant are let out
through chimneys after treatment .The Company is having thermal oil furnace, two boiler
stacks, one caustic recovery boiler stack, flare stack and process stack in HYAM plant. In the
HYAM plant oxides of nitrogen is a major pollutant. The oxides of nitrogen formed during
the combustion of ammonia and off gas from the nitrate reactor is passed through an absorber
for the removal of oxides of nitrogen and sent through a mist eliminator. Emission of sulphur
di oxide during the preparation of hydroxy \amine disulphonic ammonia is controlled by
scrubbing with ammonia water where as oxides of nitrogen is removed by selective catalytic
reduction. This reactor is incorporated as an inbuilt pollution control measure in the process.
This off gas with the emissions from nitrate preparation section are emitted through HYAM
plant stack.
In the Anone plant from 70 metres stack has been provided for burning uncondensed
cyclohexane in the off gas from Benzene hydrogenation and cylcohexane preparation section.
The off gas from benzene hydrogenation is used as a fuel in main boiler and fired gas heater
of HYAM plant and remaining quantity, if any is vented to atmosphere after adsorption of
organics in an activated carbon bed.
In the captive power plant boiler a continuous on line SO2 analyzer is provided. Fuel
additives and fire side treatment is provided to reduce SPM level in Capture Power Plant
stack. The ammonia handling and storage area has been provided with a flare stack to burn
any ammonia vented.
461
Soda ash is recovered from the caustic effluents separated during the purification of
cyclohexaanone and is disposed as by-product.
Sources of hazardous waste are spent catalysts, Sludge from effluent treatment plant and
waste oil. The company have obtained authorization as per Hazardous Waste(Management
and Handling)Rules 1989 for the disposal of the hazardous waste generated in the factory.
1. Bio sludge: The excess sludge generated from biological treatment are stored in brick
and plastic lined, constructed lined storage pits. The quantity is generated is 50 MT/yr.
2. Spent Raney Nickel Catalyst: The Spent Raney Nickel Catalyst generated from the
hydrogenation section of lactam plant is sold to registered re processing agencies. The
quantity is generated is 1.3 to 1.5 MT per year.
3. Spent Copper Zinc Oxide Catalyst: 10 t/yr of Spent Copper Zinc Oxide Catalyst
generated from the dehydrogenation section of Anone plant is sold to registered
reprocessing agencies.
4. Spent Zinc Oxide Catalyst: The Spent Zinc Oxide Catalyst generated from the
hydrogenation section of Anone plant is sold to registered reprocessing agencies. The
quantity generated is 3.6 MT/year.
5. Waste oil: Waste oil is generated from the plant machineries and transformers and oil
circuit breakers in the entire plants. The quantity generated is 35000 l/yr. This is
reportedly burned in the boilers along with fuel oil.
Findings:
1. The company has obtained Board’s consent under the Water(Prevention and Control
of Pollution)Act 1974t, Air(Prevention and Control of Pollution)Act 1981 and
authorization under Hazardous Waste(Management and Handling)Rules 1989 for the
disposal of hazardous waste.
2. The source of water is Periyar River .The water consumption according to the
company is 8762.59 M3/day and average discharge is 3556kl/day. The consented
quantity of discharge is 5040 m3/day into Edamula branch of Periyar River.
3. The sources of effluent are process effluent, DM plant regeneration effluent and plant
drains. An effluent treatment plant is provided for treating the effluent. The Effluent
Treatment Plant was working during the time of inspection.
The effluent treatment system consists of holding basins, oil traps, equalization tank,
aeration tank, secondary clarifier and guard ponds. The hot raw effluent generated
from various sources are taken to holding basin consisting of a series of tanks and
fed to aerobic biological treatment system. Treated effluent is taken to two guard
ponds, pH concentration is done , and discharge into Edamula branch of Periyar
River.
4. The effluent from the Caprolactum plant is collected in the plant , neutralized, aerated
in equalization tanks and after pH correction is sent for biological treatment plant in
the main Effluent Treatment Plant.
Nitrate containing effluent are segregated and taken for denitrification process. After
clarification the effluent is taken to equalization tank to complete the remaining cycle
of operation in activated sludge process along with other effluent streams.
462
5. Oil trap is provided for the removal of oil from raw effluent.
6. The effluent after treatment discharging through the guard pond is mixed with raw
water and let out into the River Periyar. The Company authorities informed that the
dilution activity with raw water and DM Plant effluent are being practiced since long
back.
7. Separate drains are provided for storm water and oil traps are provided in storm water
drains for removing oil.
8. The indicator installed at the Effluent Treatment Plant showed raw effluent pH of 7.39
and outlet pH 7.8
9. Recorder shall be installed at the outlet for measuring effluent flow rate.
10. The hazardous waste of spent catalyst are disposed in dumping yard or solid to
authorized recyclers. Biosludge is disposed in lined storage pit and waste oil is stored
for sale to recyclers.
11. Soda ash is recovered from the caustic effluents separated during the purification of
cyclohexanone and are disposed as byproduct.
12. The company authority informed that hazardous waste TSDF exclusively for FACT is
under construction at Ambalamedu.
13. House keeping is to be improved by removing wild bush. Scrap is seen dumped in the
premises.
Recommendation :
1. Huge quantity of water is used for diluting the effluent after treatment at the outlet of
the guard pond, before discharging through the authorized outlet into the river periyar.
Dilution activity should be stopped forthwith. The prescribed quality should be
achieved by proper treatment in the Effluent Treatment Plant itself.
2. Effluent treatment plant is to be modified for achieving the prescribed quality
stipulated in the consent order without dilution.
3. Adequate steps shall be taken for reducing the water consumption and also to reuse the
treated effluent for achieving zero discharge system.
4. Oil traps must be provided in all the storm water drains at intervals to curtail
contamination of storm water.
5. Delay ponds shall be provided in storm water drain with monitoring facility. Oil trap
existing in oil handling area near boiler house is to be revamped and made operational.
6. The scrap materials in the premises of the factory shall be disposed to registered
recyclers.
7. House keeping shall be improved by removing wild bushes.
8. The oil trap system being an integral part of the treatment plant unit of raw effluent
holding basin and guard pond, more attention should be provided in maintaining the
oil traps.
9. Safety audit has to be undertaken periodically at regular intervals.
Analysis Reports of the Effluent/ Sludge.
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
463
Name of the Lab
: FACT – PD
: 24-8-05
: LAEC 191(Holding Sump (Raw Effluent),
LAEC 152(Final Outlet),
LAEC 199(Neutralization Pit (Outlet of Guard Pond)),
LAEC 178(Anion Plant- Neutralization tank),
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.
No.
1
2
3
4
5
6
Unit LAEC
191
9.6
mg/l 8.2
96
38
92.3
181.1
Source
Date of sample collection
Sample Identification No
7
8
9
10
Determinant
PH
BOD
COD
SS
Free Ammonia
Total kjeldhal
Nitrogen
Amm:Nitrogen
Phenolic Compounds
Oil and Grease
Nitrates as Nitrogen
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
Determinant
PH
BOD
COD
SS
TDS
Nitrates as N
Sulphate
Cyanide
Free Ammonia
TKN
177.5
2.2
ND
ND
LAEC
152
7.7
1.2
16
18
0.46
18.80
LAEC
199
8.5
1.2
16
20
0.962
7.6
LAEC
178
3.5
132
8880
32
Nil
328
Tolerance
limit
5.5-9.0
30
250
100
5
100
18.5
1.91
ND
5.0
7.4
1.61
ND
2.5
322
4.33
ND
250
50
1
10
20
: FACT – PD
: 2-4-05
: L8A (Outlet)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
L8A
7.8
2
76
100
1040
7
250
ND
1.61
60.4
464
11
12
13
Ammoniacal Nitrogen
Phenolic Compounds
Oil & grease
53.7
ND
ND
Outlet
INDIAN RARE EARTHS, LTD
Name of Industry
:Indian Rare Earths, Ltd
Date of Inspection
:18/08/05 & 19/08/05.
Raw materials :
Monozite
Caustic soda
Hydrochloric acid
Oxalic acid
Sulphuric acid
Soda ash
Sodium hyphochlorite
Hydro Fluric acid
Process water
Magnesium sulphate
Barium carbonate
Sodium sulphide
Furnace oil
Diesel
Kerosene
: 7.94t/day
: 4077t/day
: 4t/day
: 0.6t/day
: 0.13t/day
: 0.25t/day
: 3.55t/day
: 140l/day
: 83kl/day
: 10kg/day
: 19kg/day
: 65kg/day
: 7.0t/day
: 135l/day
: 16l/day
Products :
Rare Earths Chloride(Composite)
Tri Sodium Phosphate
Rare Earths Fluoride
Cerium oxides
Thorium Oxalate
Evaporated Lye
: 11t/day
: 13t/day
: 0.3t/day
: 1.0t/day
: 2.0t/day
: 1.5t/day
Production Process
The industry is engaged in the processing of Monozite sand ,which is a phosphate mineral of Rare
Earths and Thorium.This sand constitutes about 4 to 5% of the beach sands of Kerala and Tamil
Nadu at certain locations towards the tip of peninsula, the other constituents being Ilmenite, Zircon,
Sillimanite, Garnite, Rutile etc.
Monozite contains about 60% of Rare Earths expressed as M2O3, 8-9% Thorium expressed as ThO2,
and 27-29% Phosphate expressed as P2O5. Raw monozite sand after being ground to a very fine size is
mixed with Caustic Soda in the form of Lye, and digested at about 140 to1600 C for a few hours when
insoluble hydroxides of Rare Earths and Thorium and soluble Sodium Phosphate
are formed.
465
The top solution is decanted, clarified by filtration and cooled by adiabatic
evaporation in a vaccum crystalliser. This crystallised slurry is centrifuged and
the crystals are dried in a hot air pneumatic conveyor drier and the dry Tri
sodium Phosphate having a P2O5 content of 17.5% is packed in bags.
The mother liquor from centrifuge is a weak Caustic Soda solution of about 10%
concentrtion. This is concentrated by evaporation and re-used for reaction with
monozite.
The slurry of insoluble hydroxides is filtered and washed in rotary drum vaccum
filter
to free it of soluble Phosphate and Lye. The washed hydroxides are then treated
with commercial Hydrochloric Acid under controlled conditions to dissolve the
Rare Earths preferentially leaving thorium hydroxide undissolved. The slurry is
allowed to settle and clear RE Chloride solution is decanted.
The Crude thorium hydroxide slurry is dissolved in HCL and subjected to a
solvent extraction process to separate and recover Uranium and produce high
purity Thorium Oxalate.
Waste :
The company have obtained Board’s Consent to discharge 3000 KL of effluent
per day into River Periyar. For treating the effluent the company have provided
an effluent treatment plant consisting of
1.
2.
3.
4.
5.
6.
Settling tanks.
Separate pretreatment tanks for acidic and alkaline effluents.
Effluent mixing channels.
Clariflocculator
Treated effluent collection tank and
Sludge filter.
The effluent from the settling tanks inside the main plant is pumped to the pretreatment tanks.
Acidic effluent and alkaline effluent are collected in separate tanks. This is pumped to a
mixing channel where HCl/NaOH is added for neutralization of the effluent. Ca Cl2 and FeCl3
are also added for precipitation of hydroxy apatite of Calcium Phosphate and Calcium
Fluoride. The slurry from flash mixer is sent to the clariflocculator and allowed to settle. The
over flow from the clarifloculator is collected in a storage tank and discharged into the river.
Underflow of the clariflocculator is pumped to an intermediate storage tank from where it is
filtered in a precoat type rotary drum filter. The filter cake is collected in HDPE laminated
bags and disposed in earthern pit in the waste dumping yard of the factory situated in the
western side.
The filtrate is either pumped to post treatment tank or pre treatment tank for further treatment
or disposal depending on the quality. The treated effluent from post treatment tank is
discharged into the River Periyar.
Sources of gaseous emissions are extraction and deactivation plant, Cerium hydrate
precipitation tank, Rotary kiln, solvent extraction plant and acid dilution tank. The company
have got valid consent under the Air Act upto 31-12-05.
466
The company has obtained authorization as per Hazardous Waste(Management and
Handling)Rules 1989 for the disposal of the following hazardous wastes generated in the
factory.
1. 745 kg/day Insoluble waste separated as undigested sand from raw material is
stored and disposed in RCC trenches /silos.
2. 465kg/day Sludge separated while deactivation of rare earth chloride is Stored and
disposed in underground FRP lined RCC trenches.
3. 460kg/day dried sludge generated from the effluent treatment plant is disposed in
trenches in open land at the disposal site.
Three concrete silos containing thorium hydroxide near river side is being removed to
another silo through mechanical retrieval system and pure thorium oxalate is recovered.
Ammonium di uranate recovered is supplied to BARC. The waste generated is disposed in
concrete tank called muck silo.
Findings:
1. Factory rules regulation of M/s IRE is done by the Atomic Energy Regulatory Board
(AERB) and is looking after the health physics aspect of the plant. Dr.P.M.B.Pillai of
AERB informed that radiation level inside the factory is As Low As Reasonably
Achievable and public exposure is also low. Internal dose is taken care of by limiting
the personal doses and direct dose is measured by various methods. AERB is
providing advanced medical check up to the exposed workers.
As part of the environmental protection and abatement programme the company have
also constructed monitoring wells and have been monitoring 20 bore wells inside the
factory, open wells, four open wells outside the factory, Periyar river and back water
stretch.
2. Three concrete silos containing thorium hydroxide near river side is removed to
another silo through mechanical retrieval system and pure thorium oxalate is
recovered. Ammonium di uranate recovered is supplied to BARC. The waste
generated is disposed in concrete tank called muck silo.
3. The source of water is Periyar River. Water consumption as reported by the company
is 1971 M3/day.
4. The company is having one authorized oulet and obtained consent for discharging
30,00,000 litre /day of effluent into the river. According to the company authorities the
daily average discharge is 1500 m3/day.
5. According to the company authorities only deactivated effluent is brought to the
treatment plant. Raw effluent generated are collected and settled at the plant before
taking to the ETP. Activated part is taken to FRP lined concrete tank by pumping
6. Effluent treatment plant consists of acidic and alkaline effluent collection tanks, flash
mixers, clariflocculator and sludge storage tank rotary drum filter. The dried ETP
sludge from the filter is collected in HDPE laminated bags and disposed in trenches in
open land owned by the company.
7. For inplant emission, control filters and scrubbers are provided.
8. The company have obtained Board’s authorization under Hazardous
Waste(Management and Handling)Rules 1989 for the disposal of hazardous waste.
Solid wastes of mixed cake generated during deactivation containing BaSO4, PbS,
Ra228 is taken to trenches of FRP lined underground RCC tanks and capped. The
solids are transferred to the disposal trenches by admitting water and pumping to FRP
467
lined, roofed RCC tanks. The effluent layer is pumped back. Insoluble sand wastes are
also disposed of in RCC trenches.
9. At the dumping site capped hazardous waste tanks, FRP lined concrete tanks under
use, and two FRP lined tanks ready for use are seen. FRP lined concrete tanks at the
dumping site under use and new tanks ready for commissioning are seen protected
from rain by providing roofing.
10. As per condition no.13 of the consent order issued under Air Act dt 3-4-2004
continuous emission monitors for chlorine and its compounds ,and sulphur dioxide in
Mohur Plant Chimneys shall be provided. Also furnish a bank guarantee for an
amount of 10% of the cost of monitors on or before 15-05-04 with the Board.
According to the company authorities order for procuring the monitor were placed
but not executed due to some technical problems raised by the supplier regarding
Chlorine and Chlorine compounds monitor.
11. Emission from Material processing plant(Oxide Plant) are scrubbed with caustic soda
lye and let out through chimney No. 4. The scrubbed liquid is taken to Effluent
Treatment Plant.
12. MOHUR plant is renamed as SEP- I. Process emission through Stack No 3 of
MOHUR Plant is scrubbed and discharged to E-T-P. for treatment.
13. There is no helium recovery and HERO Plant is named as SEP II., Emission from SEP
II are let out through Stack No.6
14. Dust collector is provided for recovering the particulates from the emission of rotary
kiln and vent out through Chimney No. 5.
15. The captive power plant is not operated. There is no emission through Stack No.7
There are two gensets 160 KVA and 330 KVA. Stack No 8, 9
There is one boiler (Now IBR)
16. Coloured effluent from the land property of M/s IRE Ltd. used as disposal trench for
Effluent Treatment Plant sludge is seen entering the storm water drain in the
adjacent property owned by M/s Merchem Limited, Eloor.
17. Effluent samples are collected from various stages of the effluent treatment plant for
analysis.
18. The other concern of LAEC is the radiation from Indian Rare Earth. The radiation
effect from this unit range between 24 to 82 micro Sv at the points starting from
Gypsm yard of FACT and along the route at FACT junction, HIL, North gate of
FACT, reaching at IRE southern closed gate. The maximum reading of the radiation
was recorded at the southern closed gate of IRE itself. The radiation exceeds the limit
and pose great health hazard. This is a matter call for immediate attention.
Recommendation :
1. Steps shall be taken for reducing the water consumption and effluent discharge.
2. Canteen effluent is to be treated before discharging into the river. The storm water
drain is to be included as an authorized outlet in the consent order as there are chances
of contamination of storm water.
3. Delay pond shall be provided in the storm water drain with monitoring facility.
4. Even though the hazardous waste disposal site of FRP lined concrete tanks under use
are roofed properly, rain water is seen entering the tanks through the sides. Hence
precautionary measures are to be taken to prevent the entry of rain water into the
tanks.
5. Take steps for complying with consent conditions under Air(Prevention and Control of
Pollution)Act 1981 by providing online monitors.
468
6. The hazardous waste of Effluent treatment plant sludge is disposed in earthern
trenches at the disposal site. There is leachate from this earthern pit. Therefore
Effluent Treatment Plant sludge should be disposed of any in percolation free
trenches.
7. The committee recommends relocation of the thorium waste stored in huge
quantity, which is the source of radiation.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
: Indian Rare Earths LTD.
: 02-04-05
:LAEC L10 (River Water near IRE outlet),
LAEC L10 A(Effluent through pipe flow),
LAEC L10 B(Effluent through Channel)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.
Determinant
No.
1.
pH
2
BOD
3
COD
4
SS
5
Zinc
6
Lead
7
Fluoride
8
Chlorides
9
Phosphate
10
Sulphate
11
Sulphide
12
Ammoniacal Nitrogen
M/S KEMO GRAVURES , EDAYAR
Unit
mg/l
L10
L10A
L10B
6.4
1.2
24
40
ND
ND
1.66
770
0.9
200
ND
0.72
85
1.2
28
15
ND
ND
1.4
290
0.85
25
ND
9.5
8.6
0.8
16
12
ND
ND
1.89
340
0.9
44
ND
2
Name of Industry
:M/s Kemo Gravures , Edayar
Date of inspection
:05/03/05 and 25/05/05
Raw Material
: M.S.Pipes , Copper plates,
Rochellte salt solution, Chromic acid.
Products
: Rotograver printing rollers
Process:
Manufactures Rotograver printing rollers by electroplating operation .MS Pipes after
fabrication and turning is subjected to conditioning by both alkali copper plating and acid
copper plating by dipping in Rochelle salt solution. After polishing, the materials are exposed
to photochemical action and etching, is done using ferric chloride solution. The material is
then taken for chrome plating. Polishing is done before and after chrome plating.
469
Waste:
Sources of wastewater are batch solution from vats and rinse water, acidic and alkaline
solutions, rinse water, chromate waste after cyanide dipping , chromium plating, anodizing,
electroplating solutions, and floor washings. The quality of effluent is reported as 100 liter/
day.
Findings:
1. An underground tank is provided for collecting the effluent. The company authorities
are not sure about the conditions of the tank whether the floor of the tank is plastered
or not.
2. The effluent is found to be highly acidic. The factory authorities reported that
neutralization of the effluent using sodium bi Sulphate Solution is regularly done.
But no provision for treatment is seen provided at the time of inspection.
3. The wastewater generated due to the floor washing is allowed to flow to the storm
water drain. The sample collected from the storm water drain was found to be
acidic.(pH 2.5).
4. Well in the premises is the source of water. Water consumption is 1000 l / day.
Quantity of effluent is reported as 100 l/day.
5. A chimney of 3 meter high is attached to the Chromium plating reactor. An exhaust
fan is provided inside the Chimney.
6. Fugitive emission of acid fumes is felt around the reactor.
7. A D.G set of 63 KVA is installed in the unit.
8. The factory is working without the Board’s consent under the Air(Prevention and
Control of Pollution)Act 1981, & Water(Prevention and Control of Pollution)Act
1974 .
9. Open burning of the solid waste is noticed in one corner of the compound.
10. A proposal for efficient effluent treatment is reportedly submitted to the Board.
Recommendations:
1. Should obtain consent under Water(Prevention and Control of Pollution)Act 1974,
Air(Prevention and Control of Pollution)Act 1981, and Authorisation under Hazardous
Waste(Management and Handling)Rules 1989.
2. Should provide an effluent treatment plant of adequate capacity to treat the effluent
generated.
3. The unit is functioning without any consent / authorization. It has not even applied for
obtaining necessary consent. The committee hence recommend closure and should be
allowed to start only after providing adequate pollution control measures and
obtaining necessary consent.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
Determinant
: Kemo Gravures
: 5.3.05
:LAEC 30
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
LAEC
30
470
1.
2
3
4
5
6
7
8
9
10
11
pH
COD
SS
TDS
Zinc
Iron
Lead
Cadmium
Copper
Hexa chromium
Total Chromium
mg/l
3.2
496
1442
2000
2.0
100
1.78
ND
ND
50
115
MERCHEM INDIA PVT.LTD.,EDAYAR
Name of Industry
:Merchem India Pvt.Ltd.,Edayar
Date of Inspection
:29/11/04,08/06/05;04/10/05
Products
: Name
Average.
TMT
ZMBT/Mertard
Mertiser
SDMDC/PDMDC
SP
TBBS
Raw materials
1300
800
250
350
100
---
Quantity(kg/day)
Maximum
1700
1500
700
1500
400
---
: Name
Quantity (Avg. t/day)
Di methyl lamine (40 %)
2.35
Caustic Soda lye,
0.81
Carbon disulphide,
1.53
Chlorine .
0.77
Process oil
0.03
Sodium bicarbonate
0.036
NaMBT
1.006
Zinc Chloride
0.463
Teritary Butyl Amine
0.077
Sulphuric Acid
0.123
Sodium hypochlorite
0.061
Sodium sulphite
0.095
Hexa Chloro benzene
0.217
Sodium sulphide
0.179
Methylated spirit
0.158
China clay
0.256
Stearic acid
0.035
Phenol
0.050
471
Styrene
Fatty acid
Caustic potash
Boroquat
Ammonium Chloride
Iso Propyl Alcohol
Di Ethanol Amine
Styrenated Phenol
Sulphur
Xylene
Iron P. Cyanine
0.117
0.030
0.013
0.036
0.009
0.0006
0.0001
0.031
0.024
0.002
0.006
Process:
1. Mercure TMT: Di methylamine, caustic soda lye and carbon disulphide are reacted
in the first reactor to give sodium salt solution. The solution is then oxidized with the
mixture of Chlorine & Air in the second reactor and gives the slurry of product and
water. The resultant slurry is filtered and washed in a centrifuge to give wet
product. This wet product is then dried in a drier and milled in a pulveriser to get dry
and powered product. This product is then weighed and packed in specified packing
bags.
2. Mercure ZMBT
NaMBT solution is taken in the reactor . the zinc chloride solution is used for the
precipitation of product in this reactor. The required product will be in slurry from
with water, which is then is filtered and washed in a centrifuge to give wet product.
This wet product is then dried and milled in a pulveriser to get dry& powdered
product. This product is then weighed and packed in specified packing bags.
3. Mercure TBBS.
NaMBT solution , TBA, sulphuric acid and hypo are reacted in the reactor. After the
addition of caustic solution, the product containing slurry is filtered in a centrifuge to
get wet product. This wet product is then dried in drier and milled in a pulveriser to
get dry & powdered product. This product is then weighed and packed in specified
packing bags.
4. Mertiser
Hexa Chloro benzene and sodium sulphide is reacted in first reactor to give sodium
salt of PCT solution. This solution is then oxidized with Chlorine in the second
reactor and gives the slurry of product and water. The resultant slurry is filtered and
washed in a centrifuge to give wet powder. This wet powder is then dried in a drier
and milled in a mill to get dry & powdered PCTS. This product is then mixed in Nauta
mixer along with China clay, Stearic acid and iron Pthalao cyanine to get a mixer.
This mixed powder is then milled in a pulveriser and this product is weighed and
packed in specific packing bags.
5. Mernox SP
Styrene monomer is reacted with phenol in a reactor at controlled temperature under
stirring for around eight hours. This liquid product is cooled and filled / packed in
suitable containers.
6. Mernox SP(E)
472
Styrenated Phenol and hot water is agitated in an emulsifier at controlled temperature.
This liquid product is then cooled and filled / packed in suitable containers.
7. Merstabfs
Ammonium chloride and Boroquat is reacted in a reactor at room temperature by
stirring for around 5 hours. This liquid product is filled / packed in suitable containers.
8. Antitack Agent VC
Fatty acid and caustic soda lye is reacted in a reactor at controlled temperature by
stirring for 8 hours. This liquid product is filled / packed in suitable containers.
9. SDMDC
Raw materials are; Di methylamine, Caustic soda lye , Carbon disulphide.
Di methylamine, Caustic soda lye , Carbon disulphide are reacted in the reactor to
give SDMDC solution. This liquid product is filled / packed in suitable containers.
Waste:
The company have obtained Board’s consent under the Water(Prevention and Control of
Pollution)Act 1974 for discharging 10000 l/day effluent into periyar river. The effluent
generated in the factory is taken to the Effluent treatment plant in the premises of
M/s
Merchem Limited , Edayar for treatment . The combined effluent after treatment is discharged
into periyar river.
A temporary facility of concrete tank with lining of HDPE provided in the premises of
Merchem Limited Edayar is used for storing the hazardous waste of Effluent treatment plant
sludge generated from sludge drying beds.
The Effluent treatment system comprises of Primary & Secondary treatments . Liquid
effluent from the plants is collected in a sump in the premises of the factory and taken to the
raw effluent collection tank of ETP for equalization .The effluent is then pumped to the
mixing channel where it is treated with chemicals such as lime, alum to coagulate the
dissolved & suspended solids. This is allowed to settle in a primary settling tank and the
overflow is subjected to secondary treatment of activated sludge process.
After secondary treatment the effluent is allowed to settle in the secondary settling tank.
The overflow is discharged through a V-notch chamber into periyar river through an open
channel. The sludge generated is pumped to the sludge drying bed and then it is stored in
temporary TSDF .
Findings:
1. The factory is producing Rubber accelerators , liquid type antioxidants, peptiser ,
Form Stabilizer, Anti tack agents and the production rate specified in the consent
order is
Mercure TMT
40 t/month
ZMBT/Mertard
25
,,
Mertiser
15
,,
473
2.
3.
4.
5.
Mercure TBBS
5
,,
Mernox SP
5
,,
SDMDC/PDMDC
30
,,
Obtained consent under the Water(Prevention and Control of Pollution)Act 1974 for
discharging 10,000 litre /day effluent into Periyar river.
Effluent Treatment Plant constructed in the premises of Merchem Limited, Edayar is
used for treating the effluent generated from both the factories.
The effluent generated in the factory is collected in an effluent sump and taken to the
Effluent Treatment Plant of Merchem Limited., Edayar in the adjacent plot by
gravity flow. The treatment facility provided at Merchem limited comprises of
Chemical treatment followed by, Activated Sludge Premises .
The effluent treatment plant was not working at the time of inspection on 29-11-04.
There was no overflow from the secondary settling tank. But there was considerable
discharge from the outlet from the overflow channel of the secondary settling tank.
Effluent samples were collected for analysis.
The quality of supernatant effluent sample collected from the secondary settling tank
and effluent in the overflow channel indicate that the effluent quality is varying to a
great extent, instead of being similar. The overflow sample discharged through outlet
is well within the limits whereas the effluent in the secondary settling tank is highly
contaminated as noted below.
No
Determinants
Unit
1
2
3
4
5
6
7
8
pH
Suspended Solids
TDS (inorganic)
Zinc
Chlorides
Sulphates
Phenolic Compounds
Oil and grease
mg/l
,,
,,
,,
,,
,,
,,
Effluent from
Secondary
Settling tank.
5.9
647
6900
1.60
4000
800
30
ND
Effluent from overflow channel
of Secondary
Settling tank
7.0
15
382
ND
68
25
0.2
ND
6. The result reveal that bypass line is provided for admitting fresh water to the outlet
for diluting the effluent and achieving the prescribed quality.
7. On seeing the inspection team the effluent treatment plant was started by pumping raw
effluent from the collection tank to the mixing channel for chemical treatment.
8. According to the company about 3kg/day sludge is generated from the effluent
treatment plant which is dewatered in the sludge drying beds and disposed in the
recently constructed temporary storage facility for hazardous wastes.
9. Both the units namely M/s Merchem Limited, Edayar and M/s Merchem (India ) Pvt.
Ltd have not obtained authorization under the Hazardous Waste(Management and
Handling)Rules 1989 for the disposal of hazardous wastes.
10. No Hazardous waste was seen stored in the temporary storage facility during the
inspection on 29-11-04. The company authority informed that solid wastes and sludge
generated so far from the effluent treatment plant ,since its inception were land
disposed after drying in sludge drying beds.
474
11. During the subsequent inspection on 08/06/05 hazardous waste disposal in temporary
facility is seen started.
12. The report of analysis of effluent collected on 29-11-04 and 08/06/05 show that the
raw effluent contains high BOD,COD,TDS,Chlorides, Sulphates and high COD/BOD
ratio.
Date of Sampling 29-11-04
No Determinants Unit Raw
Effluent
Tank
Raw
Effluent
ZDC tank
Primary
Settling
Tank
1
2
7.4
mg/l 30
8.6
788
,,
16632
,,
,,
,,
,,
,,
3
4
5
6
7
8
pH
Suspended
Solids
TDS
(inorganic)
Zinc
Chlorides
Sulphates
Phenolic
Compounds
Oil
and
grease
6.5
18
Effluent
from
secondary
Settling
tank
5.9
647
Overflow
channel of
Secondary
Settling
tank
7.0
15
9542
8748
6900
382
0.35
11400
280
0.24
0.1
3700
2000
31
3.5
6000
400
10
1.6
4000
800
30
ND
68
25
0.2
ND
ND
ND
ND
ND
Date of Sampling 08/06/05.
Sl. Determinant Unit Merchem,
No.
India
Raw
effluent I
(from
ETP)
1.
pH
6.5
2
BOD
mg/l 920
3
COD
,, 2560
4
SS
,, 486
5
TDS
,, 34518
6
Zinc
,, 12.5
7
Iron
,, 2.94
8
Fluoride
,, ND
9
Chlorides
,, 13700
10 Phosphates
,, ND
11 Phenolic
,, ND
Merchem
India
Over flow
Raw
effluent II
Merchem
India
collection
sump
Merchem Merchem, Tolerance
India raw Edayar
limit
effluent
from line
6.6
152
1432
596
26578
15
2.04
ND
14800
ND
ND
6.9
120
1416
673
32414
11.5
1.37
ND
15100
ND
1.51
5.9
212
2400
172
3754
17.5
1.46
ND
14300
ND
1.51
9.6
50
552
87
1420
ND
0.84
ND
100
ND
ND
6-8.5
30
2100
5
1000
1
475
12
13
14
15
16
Compounds
Manganese
,,
Oil
and
,,
Grease
Sulphates
,,
Cyanide
,,
Sulphides
,,
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
10
1200
ND
ND
1500
ND
ND
750
ND
ND
500
ND
ND
110
ND
ND
1000
ND
ND
13. A boiler is operating in the unit. The company have obtained Board’s consent
under the Air(Prevention and Control of Pollution)Act 1981
14. During the inspection on 04/10/05 raw effluent from both the factories are seen taken
to the equalization tank for mixing. But the treatment plant was not working.
Recommendation:
1. The effluent generated from the factory contains high Chlorides,TDS and high
COD/BOD ratio. The existing biological treatment system is ineffective for achieving
the prescribed quality. Hence the company shall be directed to provide alternate
treatment techniques such as evaporation system for eliminating pollution problems
and achieving zero discharge system. The unit despite notice , have not taken any
initiative to treat the inorganic toxic effluent generated . The discharge of toxic
effluent by employing dilution technology after the biological treatment system is
violation of Water(Prevention and Control of Pollution)Act 1974. A sister concern of
this unit generating similar toxic effluent had to go for other non-biological
treatment system. Until such system is installed the unit must be asked to stop
production as the present ETP is found inadequate and ineffective.
2. The actual production rate, water consumption and quantity of effluent generation
are to be assessed.
3. Water meter shall be provided at the intake point for measuring the actual water
consumption.
4. The actual quantity of effluent generated shall be assessed.
MERCHEM LIMITED ,EDAYAR
Name of the Industry
:Merchem Limited ,Edayar
Date of Inspection
:29/11/04,30/12/04,23/03/05,08/06/05
Name of the Products :
Name
Quantity(kg /day)
Average
Maximum
F
ZDC
ZDBC
ZBEC
400 kg
600 kg
200 kg
30 kg
900 kg
1500 kg
700 kg
500kg
476
Raw materials
:
Name
Carbon di sulphide
Zinc Oxide
Zinc Chloride
Di ethyl Amine
Di n Butyl Amine
Di Benzyl Amine
Caustic Soda
Hexamine
DPG
MBTS
Quantity(kg/day)
-
345
143
62
256
113
19
38
56
56
288
Process:
1. F is manufactured by formulation of MBTS with DPG and hexamine. The raw
materials are pulverized, mixed and again pulverized.
2. ZDC is manufactured by reacting diethylamine and zin oxide with carbon
disulphide with C1 as catalyst .the resultant solution is filtered, washed dried and
pulverized to get ZDC.
3. ZDBC is manufactured in two steps.In step-1 SBDC is manufactured by reacting
Di-n- butylamine and caustic with carbon disulphide.In step-2, ZDBC is
manufactured by precipitation with SBDC and Zinc chloride along with dispersalF.The resultant solution is filtered,washed,dried and pulverized.
4. ZBEC.sodium dibenzyle dithio carbonate(SDBC) is manufactured by reacting
DBEA (di benzyl amine)and caustic with carbon disulphide.The SDBC formed is
reacted with Zinc chloride along with dispersal F to Precipitae ZBEC.
Waste:
Sources of liquid waste are centrifuge washings during the process of manufacture of
ZDC, ZDBC and ZBEC. For storing the hazardous waste of effluent treatment plant
sludge removed from sludge dying bed, a roofed temporary storage tank is constructed.
Findings:
1. The factory is engaged in the production of Rubber and accelerators
(ZDC,ZDBC,ZBECF). The raw material used are Carbon Di sulphide, Di ethyl
Amine, MBTS, Di Benzyl Amine, Di n Butyl Amine , Hexamine, DPG,MBTS,Zinc
Oxides and Zinc chloride. The board has issued consent for manufacturing 53 t/m of
accelerators where as the max production rate reported by the firm is
83 t/m.
2. The source of water is an open well near the bank of the river Periyar.The total
quantity of water consumed by the company is reported as 6000 litre /day. The
production process reveals that the actual water consumption is much higher than the
quantity reported by the company.
3. An effluent treatment plant is provided in the factory premises which is used for
treating the effluent generated from Merchem Limited and a mother unit functioning
in the adjacent property namely Merchem (India)Pvt.Ltd. . The quantity of effluent
discharge as per the consent issued to the unit is 13900 litre/day.
477
4. The effluent treatment plant consists of two raw effluent collection tanks, mixing
channel, primary settling tank, aeration tank, secondary settling tank, and sludge dying
beds. The effluent generated from both the units are collected in two collection tanks
and treated with lime and alum. The effluent after settling is taken to aeration tank for
aerobic biological treatment, and settled in secondary settling tank. The overflow from
secondary settling tank is discharged into the River Periyar through an open drain.
5. The effluent treatment plant was not working at the time of inspection on 29-11-04.
There was no overflow from the secondary settling tank. But there was considerable
discharge from the outlet from the overflow channel of the secondary settling tank.
Effluent samples of supernatant from the Secondary settling tank and effluent in the
overflow channel of secondary settling tank were collected. Water sample was
collected for analysis from the well in the factory premises which was found reddish
in colour. Solid wastes accumulated and effluent stagnated as a pond just outside the
factory boundary in the adjacent land owned by M/s Kunnath Chemicals was also
collected for analysis.
Source : Sludge from the premises of Kunnath Chemicls near compound of Merchem Edayar
Date of sampling : 29-11-2004
Sl.
No.
2
3
4
5
6
Determinant
Iron
Lead
Cadmium
Total Chromium
Manganese
Unit
15
448.4
86535.0
337.4
9.3
1344.0
1098.7
This lab report indicates the presence of effluent and ETP sludge in the adjacent
premises.
6. Effluent treatment plant was started on seeing the inspection team(08/06/05) by
pumping raw effluent from the collection tank to the mixing channel for chemical
treatment.
7. According to the company about 3kg/day effluent treatment plant sludge is generated
which is dewatered in the sludge drying beds and disposed in the recently constructed
temporary storage tank for hazardous wastes. The unit has not obtained authorization
under Hazardous Waste(Management and Handling)Rules 1989 for the disposal of
hazardous wastes.
8. No Hazardous waste was seen stored in the temporary storage facility during the
inspection on 29-11-04. The company authority informed that solid wastes and sludge
generated so far from the effluent treatment plant ,since its inception were land
disposed after drying in sludge drying beds. During the inspection on 8-6-05 sludge
disposal in the temporary facility was seen started . But during the inspection
conducted on several occasions effluent is seen discharged into the Periyar River
violating the consent condition.
478
9. The company have obtained Boards consent under the water act upto 31-12-04 for
discharging 13,900-l/day effluents.
10. The quality of supernatant effluent sample collected from the secondary settling tank
and
overflow channel indicate that the effluent quality is varying to a great extent,
instead of being similar. The overflow sample discharged through outlet is well
within the limits whereas the effluent in the secondary settling tank is highly
contaminated as noted below. The result reveal that bypass line is provided for
admitting fresh water to the outlet for diluting the effluent.
No
Determinants
Unit
1
2
3
4
5
6
7
8
pH
Suspended Solids
TDS (inorganic)
Zinc
Chlorides
Sulphates
Phenolic Compounds
Oil and grease
mg/l
,,
,,
,,
,,
,,
,,
Effluent from
Secondary
Settling tank.
5.9
647
6900
1.60
4000
800
30
ND
Effluent from overflow channel
of Secondary
Settling tank
7.0
15
382
ND
68
25
0.2
ND
11. The report of analysis of effluent collected on 29-11-04 show that the raw effluent
contains high Chlorides(11400 mg/l), Sulphates(2000 mg/l) and Phenolic compounds.
Date of Sampling 29-11-04
No Determinants Unit Overflow
channel of
Secondary
Settling
tank
1
pH
7.0
2
Suspended
mg/l 15
Solids
3
TDS
,,
382
(inorganic)
4
Zinc
,,
ND
5
Chlorides
,,
68
6
Sulphates
,,
25
7
Phenolic
,,
0.2
Compounds
8
Oil
and ,,
ND
grease
Primary Raw
Raw
Well
Settling Effluent Effluent Water
Tank
Tank
ZDC
Merchem
tank
6.5
18
7.4
30
8.6
788
6.1
8
Effluent
from
secondary
Settling
tank
5.9
647
8748
16632
9542
688
6900
3.5
6000
400
10
0.35
11400
280
0.24
0.1
3700
2000
31
ND
190
250
ND
1.6
4000
800
30
ND
ND
ND
ND
ND
479
Sl.
No.
Determinant
1.
2
3
4
5
6
7
8
9
10
11
pH
BOD
COD
SS
TDS
Zinc
Iron
Fluoride
Chlorides
Phosphates
Phenolic
Compounds
Manganese
Oil and Grease
12
13
Unit
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
Merchem, Merchem, Merchem
Edayar
India
India
Raw from Over flow
ETP
Raw II
9.6
6.5
6.6
50
920
152
552
2560
1432
87
486
596
1420
34518
26578
ND
12.5
15
0.84
2.94
2.04
ND
ND
ND
100
13700
14800
ND
ND
ND
ND
ND
ND
Final
outlet
Well
Merchem
6.6
3.2
48
48
1158
0.1
1.602
ND
440
3.5
0.96
6.7
0.2
16
45
1788
0.27
6.29
ND
510
ND
0.18
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
12. During the enquiry of a complaint received from M/s Kunnath Chemicals Pvt. Ltd
regarding the escape of Chlorine gas through the exhaust fan of Merchem Ltd, Edayar on
23-3-05 the company authorities reported that chlorine is one of the raw materials used for
production purpose. But it is noted that chlorine is not shown among the list of raw materials
and name of the product manufactured using chlorine are not mentioned in the Proforma
submitted to LAEC.
Recommendations:
1. The effluent generated from the factory contains high Chlorides,TDS and high
COD/BOD ratio. The existing biological treatment system is ineffective for achieving
the prescribed quality. Hence the company shall be directed to provide alternate
treatment techniques such as evaporation system for eliminating pollution problems
and achieving zero discharge system. The unit despite notice , have not taken any
initiative to treat the inorganic toxic effluent generated . The discharge of toxic
effluent by employing dilution technology after the biological treatment system is
violation of Water(Prevention and Control of Pollution)Act 1974. A sister concern of
this unit generating similar toxic effluent had to go for other non-biological
treatment system. Until such system is installed the unit must be asked to stop
production as the present ETP is found inadequate and ineffective.
2. The actual quantity of effluent discharge should be assessed for the maximum
production rate.
3. Maximum production rate reported in the proforma is found to exceed the quantity
specified in the consent order.
4. Chlorine gas is admittedly used in the factory for processing purpose. But Chlorine
gas is not included among the list of raw materials furnished to the committee. It is
noticed from the proforma submitted by Merchem (India) Pvt. Ltd. Chlorine gas is
480
5.
6.
7.
8.
used for producing MBTS/MBS. It should be ascertained whether M/s Merchem
Limited, Edayar is manufacturing these products, which are not disclosed in the
application submitted to the committee /PCB.
Products manufactured and Production rate shall be verified.
During the inspection of the factory it was noticed that fresh water dilution is
employed at the discharge point of Effluent treatment plant for achieving the
prescribed effluent quality. This should be stopped forthwith. The company should go
for zero effluent discharge system by providing other treatment techniques such as
evaporation.
The premises of the effluent treatment plant near the well found containing effluent
and slurry from Effluent treatment plant
House keeping is to be improved.
SUD CHEMIE INDIA PVT LTD
Name of the Industry
: Sud Chemie India Pvt Ltd
Date of Inspection
Name of the Products
:20-11-2004.
:HT shift catalyst- 60 t/ month
LT shift catalyst- 20t/ month
Zinc oxide catalyst- 25 t/month
Dechlorination catalyst or
Hydrodesulphurization catalyst—20 t
Raw Materials:
Name of materials
Process where used
Consumption
in t/day(Max)
1. Ferrous Sulphate
2. Sulphuric Acid
3. Caustic soda
4. Sodium bicarbonate
5. Zinc
6. Copper
7. Alumina
8. Ammonia
9. Carbon dioxide
10. Magnesium oxide
11. Soda ash
12. Commercial Zinc oxide
13. Ammonium molybdate
14. China Clay
15. Lime Powder
HT Shift catalyst
HT Shift catalyst and ETP
HT Shift catalyst
HT Shift catalyst
LT Shift+zinc oxide catalyst
HT+ LT Shift catalyst
LT Shift catalyst
LT Shift catalyst
LT Shift catalyst
LT Shift catalyst
Zinc oxide catalyst
Zinc oxide catalyst
Hydro desulphurisation catalyst
Zinc oxide / dechlorination catalyst
Dechlorination catalyst
8.0 MT
4.8 MT
2.5 MT
0.5 MT
1.5 MT
1.5 MT
0.5 MT
1.0 MT
2.5 MT
0.1 MT
1.6 MT
1.6 MT
1.0 MT
0.1 MT
0.2 MT
481
16. Graphite
HT+ LT Shift catalyst
17. Ammonium bicarbonate Dechlorination catalyst
18. Barium Hydroxide
Dechlorination catalyst
19. Furnace oil
HT+ LT Shift catalyst
20. MTO
HT+ LT Shift catalyst
0.2 MT
0.2 MT
0.08 MT
3000 litre/day
2800 litre/day
Process.
Metal carbonates and hydroxides on support like alumina are made through metal amine
carbonate complex .These metal carbonates are calcined to form oxides ,which are formed
into extrudates or tablets
C12 Catalyst (Iron and Chromium catalyst) manufacturing process.
Ferrous Sulphate solution and sodium bichromate are mixed and dilute sodium
hydroxide is added. After precipitation the slurry is transferred to precipitator
after adding required quantity of proper solution and graphite. The slurry is
washed, filtered and dried in band drier or box drier. Wastewater from C18
filtrate is used for washing.
C18 Catalyst
Zinc Amine solution is prepared by reacting Zinc, Ammonia, and carbon dioxide
in water or scrubber solution and stored. Copper ammine solution is prepared by
reacting Copper, Ammonia, and Carbon dioxide in water or scrubber solution in
Copper reactor. Zinc solution and Copper solution are blended in C18 premix to
get the specified ratio. DM water or scrubber solution is filled in decomposer I
and required quantity of alumina is charged into it. Carbon dioxide is bubble
through the solution and steam heated. Premix solution is pumped. The boiling is
continued when the metal concentration in the slurry reaches the desired level of
0.01 %, the slurry is quenched in decomposer II. It is settled, decanted and
graphite is added. The slurry is filtered, dried and fed to granulating / tabletting
machine.
C7 (intermediate) and G1 Catalyst
Commercial Zinc oxide is activated in decomposer with ammonium bicarbonate and
water. It is heated to about 70 0 C and maintained for about 4 hours and soluble metal
boiled down. This solution is filtered to get the cake and the cake is washed. The cake is
dried in the box drier and the dried lump is stored as HSA zinc oxide(C7). For G1 the
specified quantity of HSA zinc oxide is mix mulled with ammonium molybdate,
Copper solution and graphite to get the required zinc oxide in the finished product. The
feed so made is fed to the pelletizer to form pellets.These pellets are collected in drums
and kept for steam curing. After curing the pellets are loaded into racks and dried in
box drier to reduce the LOI below 5%.
C11-18
Zinc amine solution and copper amine solution are made using the process
similar to C18.Zinc and cuprous free copper solution are blended in C18 premix
to get the specified ratio. DM water or scrubber solution is filled in decomposer I.
482
Steam is admitted into the coils. When boiling starts the scrubber system is
switched on. Premix solution is pumped continuously. When the predetermined
batch size of total metal is pumped from premix tank, pumping is stopped.
Boiling is continued and soluble metal in the slurry is brought down to less than
0.01%. When the soluble metal is below 0.01% the slurry is transferred to
decomposer II or C18 hold tank. The slurry from the hold tank is filtered in filter
press and the cake is collected in racks for drying. The cake is dried in box drier.
C18 G.
C18 powder (rework), barium hydroxide and ammonium bicarbonate is charged to the
decomposer already filled with DM water. It is heated to about 50-550 C and start injecting
CO2. Check for turbidity at regular intervals. Once turbidity is ok, the solution is filtered to
get the cake. This cake is washed and collected in racks for drying. The cake is dried in box
drier.
Waste:
The company generates 150 to 200 m3 per day of effluent which is discharged in to the
Periyar River after treatment.
The sludge generated from the effluent treatment plant containing Chromium, Zinc, Iron,
Copper, and Aluminium etc is the hazardous waste (category – 34.3 ETP sludge). Waste
generation per 100 tonne product is 600 kg and the maximum waste generation is 50 kg /day.
A roofed concrete tank is used for storing the hazardous waste. Before constructing this new
tank, sludge was being disposed in open pits in the premises of effluent treatment plant by the
riverside.
Findings
1. The factory situates by the river side at about 60m away from the river. There is no
direct intake from Periyar River. The Water requirement of 200 to 250 m3 /day is met
by M/s FACT (80%) and three nos ground wells in the factory premises
2. The company authorities reported that the hazardous waste generated since 1997 is
stored in the roofed concrete storage tank (without lining) and the quantity of waste
stored till date is 169 tonne. The capacity of the tank is 225 m3. The unit has got valid
consent under the Water (Prevention and Control of Pollution) Act 1974, Air
(Prevention and Control of Pollution) Act 1981 and authorization under Hazardous
Waste (Management and Handling) Rules 1989. The company authorities have
informed that they have requested for Board’s permission to use the newly constructed
R.C.C tank of 10.5 x 21 x 2.4 m after providing polythene lining.
The sources of emissions are Boilers (2nos) band driers (2nos) ammonia scrubber
stack (30 m high), box driers (2nos), tableting machines (2nos), generator (2nos, 500
KVA and 100 KVA)
Effluent and emission monitoring reports as stipulated in the consent order and
environmental audit report are submitted to the Board periodically.
483
The company authorities informed that there is a proposal for installing sulphuric acid
catalyst manufacturing plant.
3.
4.
The effluent treatment plant was working during the inspection. The effluent
generated from the factory are passed through oil taps for removing oil and collected
in equalization tank. The wastewater from the canteen is taken to the equalization tank
after removing the suspended solids.
The effluent is then taken to the flash mixer for chemical treatment, settled and passed
through sand filters. The treated effluent is discharged into the river Periyar. The
underflow from the settling tank is fed through a plate and frame filter press and the
dewatered sludge is disposed in the hazardous waste storage tank. The filtrate from the
filter press is taken to sand filter after pH correction. The pH of the effluent from the
filter press was noted as 6.5 during inspection.
The sludge pump used for pumping the sludge to the filter press is kept in a roofed tank.
Solid wastes from the canteen are collected in a roofed tank provided with a grilled
cover.
5. The spillage from furnace oil storage tanks are collected inside the dyke wall, passed
through oil traps and recovered. Considerable spillage was noticed near the storage
tanks.
The waste water discharged from the oil trap is taken to the ETP.Used oil is collected
in
drums for final disposal to authorized dealers. The quantity of used oil as reported by
the
company is 150 litre in 90 days. Scrap is stored separately.
6. A Delay pond is provided in storm water drain.
7. During the inspection of the factory the surrounding areas of effluent treatment tanks
were seen covered with crushed metals. Over all housekeeping is satisfactory.
The cooling water (20m3/day) after passing through cooling towers (2nos) is recirculated
8. The raw material FeSo4 is stacked in a partially roofed yard. An underground cement
plastered pit with tin sheet roofing is provided for collecting the leakage from old wooden
pit, which was used for collecting the spillage from FeSo4 storage area.
9.Greenbelt provided is inadequate. During the subsequent inspection conducted it is noticed
that the company have taken positive steps for planting more trees and more trees and
developing greenbelt .
10. Effluent and water samples are collected for analysis.
The report of analysis of the effluent collected from the authorized outlet of the factory
on 20-11-04 and 15-7-05 are noted below.
Parameters Analyzed
1.
2.
3.
4.
5.
6.
PH
BOD
COD
SS
Zinc
Iron
Parameters Tolerance limits in the
consent book
7.1
0.9 mg/l
3.2 ,,
6.0 ,,
0.04 ,,
0.11 ,,
pH
-
6.70
5.5-9.0
SS
Zinc
-
9.0
0.12
100
5
484
7. Lead
8. Mercury
9. Cadmium
10. Copper
11. Nickel
12. Chlorides
13. Cyanides
14. Phenolic compounds
15. Hexavalent Chromium
16. Total Chromium
17. Manganese
18. Oil and grease
19. Titanium
20. Free available Chlorine
0.88 ,,
ND
0.07 ,,
0.068 ,,
0.03 ,,
34.0 ,,
ND ,,
ND ,,
ND ,,
0.03 ,,
0.15 ,,
ND ,,
ND ,,
ND ,,
copper Nickel -
ND
ND
3
3
Hexavalent Chromium- 0.1 mg/l
Total Chromium- 2mg/l
Oil and grease -10 mg/l
The analysis report of the hazardous waste collected from the waste storage tank
on 12-1-05 is given below. A/R no;1131 The report shows the presence of copper,
Chromium compounds II exceeding the limits specified in class B schedule II and
also high content of Zinc.
Recommendation:
1. A decision is to be taken by the Board on the company’s proposal to use the newly
constructed hazardous waste storage tanks after providing required lining.
2. Effluent treatment plant should be augmented for complete recycling of treated effluent.
3.Chromium bearing effluent should be segregated and treated separately.
4. Chromium recovery plant should be installed.
5. Test wells are to be provided near the effluent treatment plant and hazardous waste
storage tank.
6. Greenbelt is to be improved.
Consented Parameters and limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
7
8
Characteristic
PH
Suspended Solids
Oil and Grease
Hexavalant Choromium
Total Chromium
Copper(as Cu)
Nickel (as Ni)
Zinc (as Zn)
Unit
mg/l
,,
,,
,,
,,
,,
,,
Analysis Reports of the Effluent/ Sludge.
Tolerance
limit
5.5-9
100
10
0.1
2.0
3.0
3.0
5.0
485
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Determinant
PH
Zinc
Lead
Mercury
Cadmium
Copper
Nickel
Arsenic
Chlorides
Nitrates (as N)
Sulphate
Cynide
Sulphide
Free ammonia
Ammoniacal Nitrogen
Phenolic Compounds
Total Chromium
Manganese
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
Determinant
pH
SS
Zinc
Copper
Nickel
Free Ammonia
Ammoniacal Nitrogen
Hexa Chromium
: Sud Chemie India Pvt. Ltd.
: 12-01-05
:LAEC 45(Sludge pond)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
LAEC
45
6.7
mg/kg 14812.5
180
BDL
6.8
6460
201
BDL
800
1000
6390
BDL
BDL
0.36
45
BDL
9812
1030
: Sud Chemie India Pvt. Ltd.
: 15-07-05
:LAEC 240(Raw Effluent Incoming line),
LAEC 242(Effluent +Canteen Effluent after Oil trap),
LAEC 241(Effluent Composite Tank),
LAEC 243(Flash mixer Outlet),
LAEC 244(SettlingTank)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
,,
,,
,,
,,
,,
,,
LAEC
240
12.3
898
0.1
1.1
ND
86.23
ND
ND
LAEC
242
12.3
132
0.2
ND
ND
267.38
267.38
ND
LAEC
241
10.3
296
0.08
ND
ND
249.48
297
ND
LAEC
243
5.8
284
0.1
ND
ND
ND
409.4
ND
LAEC
244
5.3
35
0.1
ND
ND
ND
159.4
ND
486
9
10
Total Chromium
Oil and Grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
Determinant
pH
SS
Zinc
Copper
Nickel
Free Ammonia
Ammoniacal Nitrogen
Hexa Chromium
Total Chromium
Oil and Grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
13
Determinand
pH
BOD
COD
SS
Zinc
Iron
Lead
Mercury
Cadmium
Copper
Nickel
Chlorides
Cyanides
,,
,,
ND
ND
ND
ND
ND
ND
ND
ND
: Sud Chemie India Pvt. Ltd.
: 15-07-05
:LAEC 245(Filter Pin Outlet),
LAEC 246(Fixed Outlet),
LAEC 247(Sand Filter),
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
LAEC
245
6.6
12
0.14
ND
0.53
ND
105
ND
ND
ND
LAEC
246
6.7
9
0.12
ND
1.12
ND
224
ND
ND
ND
LAEC
247
6.5
8
ND
ND
1.3
ND
260
ND
ND
ND
: Sud Chemie India Pvt. Ltd.
: 20-11-04
:LAEC 1(Outlet)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
LAEC1
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
7.1
0.9
3.2
6.0
0.04
0.11
0.88
ND
0.07
0.068
0.03
34.0
ND
ND
ND
487
14
15
Phenolic Compounds
Hexa Chromium
,,
,,
ND
ND
Hindustan Insecticides Limited, Eloor
Name of the Industry
: Hindustan Insecticides Limited, Eloor
Date of Inspection
: 12-03-05,24-5-05, 28-7-05
Name of the Product/s
: DDT(Tech)
- 3.73 MT/day
DDT 50%WDP
- 7.47 MT/day
Endosulfan (Tech)
- 4.43 MT/day
Hildan 35 EC
- 5.33 KL/day
Dicofol (Tech)
- 0.417 MT/day
Hilfol 18.5 EC
- 2 KL/day
Mancozeb 75 WP
- 3.15 MT/day
Recovered Sulphuric Acid - 5 MT/day
Recovered Hydrochloric Acid - 4.42 MT/day
Raw materials
: Name
Consumption in MT/day
-------------------------------------------------MCB
4.1
Chloral
1.85
Alcohol
1.4
Oleum
7
Chlorine
4.7
CTC
0.75
Na OH Flakes
0.075
HCCP
3.5
BD
1.15
Toluene
0.45
Thionyl Chloride
1.55
EPH
0.07
Ivamol
0.07
Tech.DDT
3.8
China Clay
2.7
Hydrated Calcium Silicate 0.38
Soda Ash
0.2
Surfactants
0.63
Tech.Endosulfan
2
Emulsifier
0.28
Stabilizer
0.075
Solvent
3.5
Carbon di Sulfide
1.9
Ethylene Diamine
0.7
Caustic Soda lye
0.92
Manganese sulphate
1.9
Zinc Sulphate
0.35
Hexamine
0.065
488
Furnace oil
HDO
4.0
0.2
Production Process:
1. DDT
DDT is a insecticide used to control agricultural pests and Malaria Vectors such as mosquitoes.
Alcohol is chlorinated to produce Chloral alcoholate which is then distilled in presence of oleum to
produce Chloral. Chloral and monochlorobenzene are condensed in the presence of oleum to produce
DDT. The Technical grade DDT is further processed into water dispersible powder by particle size
reduction after mixing with materials like chinaclay and wetting and dispersing agents.
2.Endosulfan
The company is not producing Endosulfan at present after the fire accident occurred in July
6th 2004. Endosulfan is an insecticide/acaricide used against all kinds of pests. Production
started in 1980’s.
Manufacturing process consists of two stages. In the first step an intermediate
product Het diol is produced by the condensation of Hexachlorocyclopentadiene (HCCP) with
Butenediol in the presence of solvent toluene and an acid scavenger Epichlorohydrin. The
slurry is centrifuged to separate Het diol powder.Excess Hexachlorocyclopentadiene and
toluene are recovered by distillation and reused.
In the second step Het diol is condensed with thionyl chloride in presence of solvent
toluene to get endosulfan. The Hydrochloric acid formed during the reaction is absorbed in
water to get 30% Hydrochloric acid as a byproduct.
The brand name of Endosulfan EC produced in HIL is Hildan.
3.Dicofol
Dicofol is an insecticide used in controlling mites and lices and is widely used as an acaricide
in tea plantation and vegetable garden. Production started in 1996.Dichloro Diphenyl
Dichloro Ethylene (DDE) is produced by hydro chlorination of DDT.
DDT is converted into DDE with the elimination of one molecule of HCl by Sodium
hydroxide in Ethanol medium at 900 C. In the second step DDE is chlorinated to produce
Tetrachloro compound (Tetramer). The tetramer is hydrolysed using sulphuric acid at 130 0 C
to produce Dicofol. Technical product is formulated as 18.5%EC for use in agriculture.
4.Mancozeb
Mancozeb is a fungicide introduced in the production list of HIL recently. This has an
inorganic base of MgSO4 and ZnSO4 complex. Mancozeb is manufactured from Carbon
disulfide, ethylene diamine, manganese and zinc salts.
489
Manufacturing process consists of the following steps.
1. Naham is produced by reacting ethylene diamine and Carbon disulphide with
sodiumhydroxide.
2. Naham is reacted with manganese sulphate to produce Maneb.
3. Maneb slurry is reacted with zinc sulphate to form mancozeb.
4. Mancozeb slurry is dried in a spray drier to get Technical grade mancozeb.
1800 tpa mancozeb formulation is also made . Different liquid formulations are made
by dissolving the technical grade product in suitable solvent and adding emulsifier and
stabilizer. Active ingredient content is made to adjust the requirement.
Waste:
Sources of hazardous waste are ETP sludge, pesticide residue from settling tanks, floor
sweepings, HCCP residue , Off gases from the Hazardous waste incinerator and spent /used
oil generated in the factory.
The company is operating an incinerator with stack height of 30m provided with
fume scrubbing arrangement for incinerating the hazardous waste.
The liquid effluent generated from individual process plants are collected and settled. The
settled effluent is then pumped to the centralized effluent treatment plant for combined
effluent treatment. The treatment system consists of equalization, neutralization using lime,
setting in clarifiers and cascade aeration . The quantity of effluent generated is 1020 m3 per
day. The sludge from ETP is taken to a lagoon. Dewatered sludge from the lagoon is
excavated and stored in impervious hazardous waste storage tank. According to the company
85t of ETP sludge were recovered last year and the accumulated sludge is approximately 400t
at present.
Sources of emissions are fugitive emissions from fume scrubbers, ETP, and Hazardous
waste incinerator. The emission from the incinerator by incinerating floor sweepings of the
plants, muck from settling tanks, HCCP residue from endosulphan plant etc is water scrubbed,
settled and taken to ETP for treatment.
The company has got valid authorization under the Hazardous Waste (Management and
Handling) Rules 1989
(i) For storing 100t/year ETP sludge (containing CaCo3 and CaSo4 ) in concrete
yard securely.
(ii) Incinerating 132t/year pesticide residue highly polymerized material and solid
residue from endosulfan plant
(iii) Incinerating 1.6t/year spent oil /used oil and
(iv) Disposal of 65t/year old drums and containers of raw materials after
decontamination and deformation
Findings:
490
1. The factory produces DDT (Technical and Formulations), Endosulphan (Technical
and Formulations), Mancozeb (Technical grade and Formulations) and Dicofol
(Technical grade and Formulations).
2. Endosulphan plant is under shut down due to a fire accident in 2004. Commercial
production of DDT is reportedly restricted to the requirement of the Govt. for
programs like Malaria eradication and for the production of Dicofol.
3. Source of water is Periyar River and the company is having a water treatment plant
near the intake point.
4. The company has obtained consent under the Water (Prevention and Control of
Pollution)Act 1974 upto 31.12.2004 for discharging 1,00,000L/day effluent from
Endosulphan plant and 9,20,000 L/day effluent from DDT plant into Unthithodu.
Reported water consumption is 1530000L/day.
5. Manholes in the effluent drain of Mancozeb plant is found chocked. Also the effluent
drain is not properly maintained. Effluent generated from Mancozeb plant after
settling is pumped to another collection tank and then to settling tank after mixing
with effluent from Dicofol plant. The settled effluent is then pumped to the centralized
effluent treatment plant.
6. Raw effluent from Dicofol plant consisting of dicofol wash water and HCL gas
scrubbed liquid are settled in a series of compartments of settling tank and the
overflow is pumped to mancozeb settling tank.
7. The DDT plant was not working at the time of inspection. BHC production is
reportedly stopped from 1997.
8. Effluent after settling in individual settling tanks are pumped to the centralized
effluent treatment plant consisting of settling, equalization, lime treatment and
clarification. The over flow from the clarifier after cascade aeration is discharged into
Kuzhikandom thodu. Underflow sludge from the clarifiers and overflow from lime
preparation tank are taken to earthern lagoons. According to the company authorities
the accumulated sludge from the lagoon is removed periodically to hazardous waste
storage tank.
9. It is reported that 100MT of sludge is removed from the lagoon per year and stored in
impervious roofed tank. The company authorities informed that 85t were recovered
last year and the accumulated sludge is approximately 400t at present. The effluent in
the sludge is percolated on land. The analysis of the sludge collected from the lagoon
on 12-3-05 shows zinc (4560 mg/kg), iron (30720mg/kg), lead (1500 mg/kg), copper
(65.4 mg/kg), Nickel (160.2 mg/kg), Magnesium (13000 mg/kg).
10. Two CS2 storage tanks are installed in the factory.
11. Got valid authorization under the Hazardous Waste (Management and Handling)
Rules 1989 upto 22-5-06
491
i.
For storing 100t/year ETP sludge(containing CaCO3 and CaSO4)
in concrete yard securely.
ii.
Incinerating 132t/year pesticide residue highly polymerized
material and solid residue from endosulfan plant
iii.
Incinerating 1.6t/year spent oil /used oil and,
iv.
Disposal of 65t/year old drums and containers of raw materials
after decontamination and deformation.
12. The company is operating an incinerator with stack height of 30m provided with fume
scrubbing arrangement for incinerating pesticide residue. The waste is collected in
open bunker, and mixed with sawdust and charged into the incinerator. The fumes are
water scrubbed. The scrubbed water is collected in settling tanks and sent to the final
effluent treatment plant for treatment.
13. Drums used for storing HCCP are decontaminated .The drums are cut into sheet and
heated to burn the contents. The scrap is then disposed to recyclers. Plastic drums are
washed and disposed to recyclers.
14. No treatment is given to the canteen effluent.
15. The company has got consent under the Air (Prevention and Control of Pollution) Act
1981 valid upto 31-12-05.
16. Excess Chlorine gas in chlorinator and Hydrolyser in Dicofole plant is scrubbed with
caustic solution and marketed as Hypo.
17. Hydrogen Chloride gas from alcohol chlorination is scrubbed with water and
hydrochloric acid produced is marketed.
18. House keeping is very poor. Wild growth of bushes and scrap scattered in the premises
are noticed.
19. There are many effluent drains and storm water drains scattered in the premises of the
production plants. Most of the drains are seen ruined and manholes are chocked with
sold residue of raw materials/products.
20. Effluent from the premises of FACT- Udyogmandal is seen reaching the storm water
drain of HIL and finally joining the outlet Kuzhikandom Thodu. As per the analysis
report, the effluent in the drain is found to contain 0.314 microgram per litre BHC and
0.694 microgram per liter Endosulphan.
21. The analysis report of the effluent collected from the factory oulet on 24-5-05 show
BHC content11.2 microgram/litre endosulphan 4.94 /micrograms/litre, and iron –0.32
mg/litre. All other parameters are within the limits.
22. The water sample from nallah inside the factory premises show pH -6.2,COD-136
mg/litre, TDS-820 microgram/l, Chlorides- 85 mg/l and colour-50 Hazen units.
23. Analysis report of the effluent sample collected from the outlet on 12-03-05-show
pH –6.3, SS-30 mg/l, TDS-404mg/l, Chlorides-90mg/l, and DDT-0.434 microgram/l.
492
24. The raw effluent from Mancozeb and Dicofole plants contain TDS concentration of
6732 mg/litre and 8880 mg/l respectively. Corresponding Chlorides concentration are
100 mg/l and 6200mg/l. Sulphates in raw effluent of mancozeb is 4800 microgram/l
and in dicofole plant effluent is 260mg/l. DDT content in settled effluent of Dicofole
plant is 15.02 microgram/litre. BHC level in raw effluent of Mancozeb plant is 55.9
microgram/litre.
25. The analysis of effluent collected from the settling tank for Dicofole and Mancozeb
effluent on 12.03.05 show pH 3.4, DDT -8.319 microgram/litre and BHC -1017.68
microgram/litre.
26. The sludge collected on 12.3.05 from the lagoon contains 4560-mg/kg zinc, 30720mg/kg iron, 1500 mg/kg lead, and other metals such as Copper, Cadmium, and
Nickel.
27. Pesticides are noticed in the storm water drains, which are discharged into the
Kuzhikandom thodu without any treatment.
28. Analysis Report of the water sample (No: LAEC, 10) collected on 28-7-05 from
Kuzhikandom Thodu (opposite Sebastian’s shop) Very high levels of DDT, BHC, and
Endosulphan are noticed in the water sample
The company authorities informed that they have got manufacturing license for 25 products.
The Company authorities informed that the company has joined TSDF and Rs 5 lakh is
invested and they have plan for developing a secured landfill in the company premises for
disposing the hazardous waste incase the HWTSDF is not materialized. It is informed that
technical discussions are over and are waiting for the site approval by the Board. For
incinerating the hazardous waste, the company is proposing to install a hazardous waste
incinerator as prescribed under the HW rules. It is informed that tenders are being finalized. It
is informed that the company proposes to commission Hazardous waste incinerator as per HW
Rules before August 2005. Lean acid fumes from the proposed hazardous waste incinerator
would be used for scrubbing the off gases and the acid of 25 – 30 % concentration would be
sold as waste acid. Also informed that an online monitor would be installed in the incinerator
and the work order for the same is to be issued.
Organo Chlorinated Pesticide
BHC
29.82 Micro gram/litre
Alpha BHC
Beta BHC
Gamma BHC
Delta BHC
15.39 Microgram/litre
4.74 Microgram/litre
2.99 Microgram/litre
6.7 Microgram/litre
Endosulphan
220.98 Micro gram/litre
Alpha Endosulphan
Beta Endosulphan
147.97 Microgram/litre
73.01 Microgram/litre
Limit - 10 microgram/litre
Limit - 10 microgram/litre
493
DDT
73.77 microgram/litre
Para Para DDT
73.77 Microgram/litre
Limit - 10 microgram/litre
Recommendations:
1. Effluent treatment plant is to be revamped.
2. Treatment facility for canteen effluent is to be provided.
3. Stop dumping of ETP Sludge in earthern lagoons as seepage is found. ETP sludge
should be mechanically dewatered and disposed in secured landfill as per HW Rules.
4. Effluent drains in the premises are to be reconstructed.
5. Arrangement shall be provided for the removal and recovery of solid pesticide residue
from the effluent at the source of generation.
6. Manholes of the drains are to be cleaned periodically.
7. Storm water drains are to be combined as far as possible and segregated to avoid
mixing of trade effluent.
8. The storm water drain should be included in the consent order as authorized storm
water outlet. Delay pond is to be provided in the storm water drain before leaving the
premises.
9. Water consumption reported by the company is 1530 m3 per day and consented
discharge is 1020 m3 per day. Steps should be taken for reducing the water
consumption as well as the discharge. Cooling water is to be recirculated. Treated
effluent recirculation arrangements are to be provided
10. Water meter should be provided at the inlets of processing line, domestic
consumption, cooling etc.
11. The quantity of discharge through the outlet should be metered by installing suitable
measuring devices. An indicator recorder should be provided for the purpose.
12. Inplant control measures are to be provided for good house keeping and efficient
management practices.
13. Also the scrap dumped in the premises must be safely stored in storage area specified
for the purpose and disposed.
14. Steps are to be taken for storm water harvesting.
494
15. Proposed SLF site is not fit. The committee has serious concern about old
Endosulphane waste and the old stockpiles. They should be handled as per the
standard stipulated by FAO.
16. Leachate from SLF of HIL premises into Kuzhikandam creek should be stopped.
17. Conduct H/W inventory and make a comprehensive environmental impact assessment
with the help of competent agency.
18. The company should achieve zero discharge within a reasonable time frame.
19. HIL, which produce DDT, comes under the purview of the Stockholm Convention and
hence need to be incorporated in the National Implementation Plan for a
comprehensive impact assessment for remediation.
20. It is seen from the records that HIL got valid Hazardous Waste Authorisation from
1989.Available data produced by HIL itself admit settling tank sludge 5 metric ton
/annum, ETP sludge around 100 metric ton /annum and the sludge containing carbon
particles from Endosulphan plant 3.6 ton per annum. The company should be asked to
account for the total quantity of waste generated over these years, and a fine as
contemplated under Rule 16 of Hazardous Waste (Management and Handling) Rules
1989 be imposed.
Periyar Malineekarana Virudha Samathi (PMVS) placed before LAEC the result of
analysis of air sample taken from the premises of HIL Eloor which according to the
said NGO is a report obtained by Global Community Monitor (GCM), a Chennai
based organization working in the field of environment related issues in association
with them. According to said NGO, GCM has trained few members of the PMVS for
taking air samples from industrial belt which is commonly known by the name
“Bucket Brigaders”. The “Bucket Brigaders” are volunteers of GCM.They took the air
sample on 20-8-05 and the same was sent to Columbia Analytical Service, INC
California. According to the result produced by the said NGO, air pollutant such as
Carbon Disulfide, Chloroform, Carbon Tetrachloride, Toluene, Hexa chlorobutadiene
are present in the air beyond all permissible limit. The result is shocking that way. It is
a health hazard in so far as pollutants causing cancer and other incurable diseases are
seen present in the air. According to the said NGO, their study of health hazard in
Eloor belt leads to presence of toxic substances such as dioxin. This is a matter that
requires detail study. LAEC hope that the study of environmental assessment also will
cover these aspects.
HIL is a unit already under closure order by the Pollution Control Board (PCB) on the
directions of the Supreme Court Monitoring Committee (SCMC). The committee has
also come to know that Central Pollution Control Board (CPCB) has suggested
various remedial measures. However, the company seems to have taken some
initiative on the remedial measures suggested by CPCB.
The company being a public sector undertaking, for all the negligence leading to
environmental hazard, the responsibility of Government cannot be ignored. This sets a
bad example for other units.
495
Consented Parameters and Limits.
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1.
2.
3.
4.
5.
6.
7.
Characteristic
Unit
Tolerance limit
H
p
SS
TDS
Oil and Grease
Sulphates
Chlorides
Phenlic
compounds
8. Endosulphan
9. BHC
10. DDT
11. Bio-assay test
6.5-8.5
100
2100
10
1000
1000
1
mg/l
,,
,,
,,
,,
,,
microgram/l
,,
,,
---
10
10
10
90% survival of fish after 96 hours in 100%
effluent concentration
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No
1
Determinant
BHC
2
3
DDT
Endosulphan
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.No
1
Zinc
Determinant
: Hindustan Insecticides Limited.
: 24-5-05
:LAEC HIL-1(Outlet)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Outlet
micro 11.2
gram/l
BDL
4.94
: Hindustan Insecticides Limited.
: 12.3.05
:LAEC 60(Sludge from Lagoon)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Sludge from Lagoon
mg/kg 4560
496
2
3
4
5
6
7
8
Iron
Lead
Cadmium
Copper
Nickel
Arsenic
Magnesium
30720
1500
8.0
65.4
160.2
BDL
13000
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No
1
2
3
4
5
6
7
8
9
10
Determinant
pH
SS
TDS
Chlorides
Sulphate
Phenolic
Compounds
Oil & grease
DDT
BHC
Endo Sulfan
: Hindustan Insecticides Limited.
: 12.3.05
:LAEC 70(Settling tank meant for Dicofol and Mancozeb
effluent.)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
,,
,,
,,
,,
Settling tank
meant for Dicofol
and Mancozeb
effluent.
3.4
136
5540
3300
1250
0.04
,,
microgram/l
,,
,,
ND
8.319
1017.68
ND
Source
Date of sample collection
Sample Identification No
: Hindustan Insecticides Limited.
: 12.3.05
:LAEC 31(Outlet)
LAEC 33(Mancozeb Raw Effluent)
LAEC 175(Dicofol inlet to settling tank)
LAEC 36(Dicofol plant outflow from settling tank)
LAEC 14(Drain from FACT before mixing HIL effluent in
HIL premises)
497
Name of the Lab
Sl.
No
1
2
3
4
5
6
7
8
9
10
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Determinant
Date of sample collection
Sample Identification No
Name of the Lab
12
13
LAEC
31
6.3
mg/l
30
,,
404
,,
90
,,
28
,,
0.04
,,
ND
microgrm/l 0.434
,,
ND
,,
ND
pH
SS
TDS
Chlorides
Sulphate
Phenolic Compounds
Oil & grease
DDT
BHC
Endo Sulfan
Source
Sl.
No
1
2
3
4
5
6
7
8
9
10
11
Unit
Determinant
PH
COD
SS
TDS
Zinc
Iron
Lead
Chlorides
Phosphates
Sulphates
Phenolic
Compounds
Manganese
Colour
LAEC
33
8.3
1648
6732
100
4800
0.02
ND
ND
55.09
0.193
LAEC
175
2.7
18
4620
3455
42
0.12
ND
1.0
ND
ND
LAEC
36
2.5
51
8880
6200
260
0.1
ND
15.02
ND
ND
: Hindustan Insecticides Limited and Merchem Limited
Eloor
: 24-5-05.
:LAEC 188(Kuzhikandam thodu near Merchem )
LAEC 192(FACT effluent before mixing HIL effluent)
LAEC 191(HIL ETP sludge)
LAEC 190(Nallah before mixing Merchem effluent (inside
HIL))
LAEC 193(1:1 mixture HIL outlet & FACT through IRE
compound)
LAEC 194(Effluent near Merchem outlet coming from
FACT through IRE compound)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
LAEC
188
9.2
200
150
948
ND
113.2
ND
76
1.4
ND
ND
ND
hazen 80
LAEC
192
6.8
48
25
292
ND
2.2
ND
16
1.1
ND
ND
LAEC
191
7.5
16
10
40
ND
0.32
ND
6
ND
ND
ND
LAEC
190
6.2
136
55
820
ND
28.5
ND
85
ND
ND
ND
LAEC
193
9.8
96
40
1416
ND
21.3
ND
100
ND
ND
ND
LAEC
194
9.8
56
18
2072
ND
1.3
ND
50
ND
ND
ND
ND
30
ND
30
ND
50
ND
30
ND
30
TRAVANCORE COCHIN CHEMICALS LIMITED, ELOOR
LAEC
14
6.8
40
704
70
220
ND
ND
ND
0.314
0.694
498
Name of industry
: Travancore Cochin Chemicals Limited, Eloor
Date of Inspection
: 22-3-05
Name of the Product/s
: Name
Raw Materials
Quantity (tonne/day)
Caustic Soda (Lye & Flakes)
Chlorine
Hydrochloric Acid (commercial)
Soda Bleach
125
72
290
45
:Name
Quantity
Raw Salt
L.S.H.S
212.5t/day
7.00 kl/day
Process:
Electrolysis of brine by Membrane cell technology produces Chlorine and Caustic Soda. Part
of Chlorine is converted to Hydrochloric acid, remaining is liquefied and sold in cylinders.
Waste:
Slurry of chemical sludge formed during the precipitation of impurities in brine is disposed in earthern
sludge yard near to the riverbed. The quantity of brine sludge is reported as 25 kg/tonne of NaOH
produced. Hazardous waste containing mercury is reportedly disposed in capped hazardous waste
storage yard. The treated effluent is discharged into the down stream of Pathalam Bund in Periyar
River. In waste chlorine deposit plant, waste chlorine gas is passed through caustic soda to produce
sodium hypochlorite and sold as by product.
Findings:
1. The company has fully changed over to diaphragm cell process for the manufacture of
Caustic soda. Mercury cell plants are stopped with effect from 31-7-2004. The
building materials of scraped plants are disposed in the solid waste dumping area and
also on the riverbank. The committee instructed the company to stop disposing the
wastes on riverbank, which may affect the natural flow path of river.
2. Wet brine sludge containing impurities such as chlorides and sulphates of Calcium,
Magnesium etc is pumped to an earthern pit near the capped hazardous waste storage
tank, close to the river bank at about 30 meter from river bed. Sludge sample from this
pit is collected for analysis .The waste generation is 25 kg sludge per tonne of NaOH
produced. As the dumping pit is not lined there are chances of leaching chlorides into
ground water, which may finally lead to the river.
3. Water source is of the company is Edamula branch of River Periyar and treated water
from the water treatment plant of the company is used for meeting the various
requirements of the factory and company quarters. Total intake reported by the
company is 420 m3 per hour from which 60 m3 per hour is supplied to TCC colony
for domestic purpose. The balance quantity of 360 m3 per hour is used by the
company for meeting domestic, processing and cooling purposes. A part of the cooling
water is supplied to Merchem Ltd, Eloor and the average supply is 300 m3 per day as
499
per the records maintained by TCC. The water consumption of 360 m3 per hour
reported by the company is abnormally high.
According to the company authorities the high water consumption is due to the over
capacity of the pump installed at the intake point and the replacement cost is high.
However the authorities have agreed to consider the issue.
4. The effluent generated from brine purification process is collected in settling tanks,
aerated to remove dissolved chlorine gas and clear overflow is pumped to ETP
through baffled drain where pH correction and sodium bi sulphite addition for
removing residual chlorine are done. A sensor and automatic dosing pump are
provided for the lagoon purpose. The effluent is allowed to stand and settled effluent is
discharged into the river through outlet No:IV after adding sodium bi sulphite and pH
correction, if required. Cooling tower overflow and rectifier cooling water from
membrane cell plant are discharged into the river through outlet No.IV.
5. The factory is discharging the canteen effluent and storm water through outlet 3 into
the river. Food particles are seen discharged through the outlet into the river. The
company authorities informed that they propose to divert outlet No.III to outlet No. IV
after minimizing cooling water overflow from membrane cell plant.
6. Outlet No II previously carrying cooling tower overflow and rectifier cooling water
from membrane cell plant has been reportedly stopped w.ef. August 2004. The drain
is now kept as storm water drain.
The company authorities reported that the Outlet no.1 formerly discharging storm
water, cooling tower overflow and rectifier cooling water is diverted to outlet
No.IV.No discharge is noticed through this outlet during the time of inspection.
7. There are about 1000 employees including management staff. The company is
operating a canteen for employees. No treatment is given to the canteen effluent
except a tiny screening chamber. The company authorities informed that they propose
to install a bio gas plant for the canteen effluent.
8. The company authorities reported that they have discontinued discharging through the
two outlets, outlets No: I and outlet No:II. The committee during the inspection
noticed meagre discharge through the discontinued outlet No:II.
9. The company is having consent under the water act upto 31-12-2004 for discharging
3000 m3/day through outlet No. I, 1600 m3/day each through outlet No.II & III and
1300 m3 /day through outlet No.IV. The company authorities reported that they have
stopped discharging through outlet No. II and I.
10. The company hasn’t taken effective steps for completely reusing cooling water,
rectifier cooling water and Cooling tower over flow which are discharged in to the
river.
11. Hold consent under the Air act valid upto 31-12-2005. The three stacks in HCl
synthesis unit is not having the stack height specified in the consent order.
12. Waste Chlorine gas is collected through network of collection points and absorbed in
Caustic Soda to produce bleach liquor. The company authorities informed that they
have stopped using lime and hence there is no solid waste of spent lime slurry. The
operation of calcium bleach plant stopped with effect from 7-1-2005
13. Obtained authorization under Hazardous Waste (Management and Handling) Rules
1989 for disposing the hazardous waste in secured landfill.
14. Source of liquid effluent are brine purification plants, DM water unit, floor washings,
domestic effluent, boiler blow down, gland cooling water etc. The effluent is taken to
500
lined brine sludge pit and aerated to remove free chlorine. The overflow is taken to
lagoon for settling. The sludge settled in the lagoon is disposed in the sludge pit.
15. The premises are not maintained properly. Scrap metals, remains of demolished plant
and equipments, lime sludge is seen disposed in a haphazard manner in the premises.
16. Common salt is also seen disposed on land in between the brine sludge pit and river.
17. Four tests well are seen provided near the capped hazardous waste pit for periodical
sampling. Depth of the wells less than one meter. Water samples are collected for
analysis.
18. Water samples are collected from test well in the northern side of the capped
hazardous waste pit. The sampled test well is at a distance of four meter from the brine
sludge pond and five meter from the capped hazardous waste storage tank.
19. There is a natural drainage-carrying surface run off from the roadside through the
premises of the company near final effluent pond leading to river Periyar. A sample
from the drain is collected for analysis.
Source
Date of sample collection
Sample Identification No
: Travancore Cochin Chemicals Limited, Eloor
: 19-8-05
: LAEC 216(Inspection well between capped pit and sludge
pond)
LAEC 193(Final outlet No.4),
LAEC 221(CanteenEffluent No.3)
LAEC 211(Outlet No.1 Storm Water)
Name of the Lab
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.
Determinant
Unit LAEC
LAEC LAEC
LAEC
No.
216
193
221
211
1.
pH
7.6
7.9
6.8
6.7
2
BOD
mg/l 0.6
0.6
1.2
0.8
3
SS
12
10
45
20
4
TDS
2180
3400
36
3312
5
Chlorides
760
1940
16
1700
6
Total Residue Chlorine
ND
ND
ND
ND
Source
Date of sample collection
Sample Identification No
: Travancore Cochin Chemicals Limited, Eloor
: 22.3.05
: LAEC169 (Authorised outlet)
LAEC 168(Drain near landfill)
LAEC 166(Monitoring Well No:2)
LAEC 167(Monitoring Well no:1)
LAEC 170(Canteen and cooling water reservoir overflow)
Name of the Lab
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.
Determinant
Unit LAEC LAEC LAEC LAEC LAEC
No.
169
168
166
167
170
H
1.
p
7.6
7.1
8.2
8.9
6.3
2
BOD
mg/l 1.0
4.0
4.0
1.4
2.0
3
SS
8
54
48
8
15
501
4
5
6
7
8
9
10
TDS
Chlorides
Sulphate
Cyanide
Magnesium
Total residual chlorine
Oil & grease
956
520
36
ND
2.43
ND
ND
7630
4800
80
ND
19.93
ND
ND
5120
3300
90
ND
8.26
ND
ND
4470
3300
70
ND
1.94
ND
ND
780
20
ND
ND
0.97
ND
ND
Source
Date of sample collection
Sample Identification No
: Travancore Cochin Chemicals Limited, Eloor
: 22.3.05
: LAEC171 (Discharge to river)
LAEC 172(Raw effluent)
Name of the Lab
:Central Laboratory, K.S.P.C.B, Gandhi Nagar
Sl.
Determinant
Unit LAEC LAEC
No.
171
172
H
1.
p
9.7
3.5
2
BOD
mg/l 4.2
2
3
SS
67
8
4
TDS
2410
2950
5
Chlorides
900
1900
6
Sulphate
44
30
7
Cyanide
ND
ND
8
Magnesium
0.49
1.94
9
Total residual chlorine
ND
ND
10
Oil & grease
ND
ND
Source
: Travancore Cochin Chemicals Limited, Eloor
Date of sample collection : 22.3.05
Sample Identification No : LAEC 81 (Sludge Dumping yard.)
Name of the Lab
:Central Laboratory, K.S.P.C.B, Gandhi Nagar
Sl.
No.
1.
2
3
4
5
6
7
8
9
Determinant
pH
Lead
Chlorides
Sulphate
Cyanide
Manganesium
Hexa chromium
Total Chromium
Manganese
Source
Date of sample collection
Sample Identification No
Name of the Lab
Unit
Sludge Dumping
yard
9.27
mg/kg 46
150000
1769
BDL
1215
BDL
BDL
121.2
: Travancore Cochin Chemicals Limited, Eloor
: 19-8-2005
: Sample 211(Outlet No 1)
:STIC (Sophisticated Test& Instrumentation Centre)
Cochin University of Science and Technology P.O. Cochin.
502
Sl.
No.
1
Determinant
Unit
Hg
ppm
Outlet
No 1
0.01
20. The report of analysis of effluent sample collected on 22-3-05 show that the
concentration of TDS, Chlorides in the monitoring wells are very high . The sludge
dumping yard containing slurry of brine sludge and ETP sludge show high pH 9.27
and Chloride contain of 150000 mg/l
21. During the inspection on 29-8-05 , outlet 1 is seen reaching the river directing instead
of joining the final pond and outlet no 4 . Mercury content of 0.01 mg/l is noticed in
the effluent (Report of analysis from Sophisticated Test& Instrumentation Centre,
Cochin University of Science and Technology P.O, Cochin)
Recommendations:
1. The water consumption of the company is exorbitantly high. Should reduce the water
consumption by reducing the pumping rate, reusing the cooling tower overflow,
rectifier cooling water and gland cooling water of pumps.
2. Also water-pumping rate to Merchem Ltd, Eloor be controlled.
3. Canteen effluent is to be treated separately to achieve the prescribed quality before
discharging into the river.
4. There are chances of leachate reaching the river from the brine sludge disposal pit.
This is to be ascertained by providing test wells in the direction of river flow. Also
chances of overflow during rain are to be checked.
5. Better house keeping is to be maintained.
6. Should not discharge cool water. The company should take all precautionary measures
to curtail the discharge of cooling tower overflow /rectifier cooling water / gland
cooling water.
7. Scrap materials dumped in the premises are to be disposed to recyclers.
8. Unauthorized outlet should be closed forthwith.
9. Salt disposed on land near the river should be removed and disposed in dump pit
safely to prevent salt intrusion.
10. Should take effective steps for improving house keeping. In plant control measures are
to be improved.
11. Should grow green belt of fast growing trees all along the factory boundary.
12. Brine sludge storage pit shall be percolation free.
13. BOD, Chlorides, and TDS should be incorporated in the consent order.
14. The company should be directed to achieve Zero discharge within a time frame.
Travancore Cochin Chemicals Limited, Eloor
Consented Parameters and limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
Characteristic
pH
Suspended Solids
Sulfides, as S
Unit
mg/l
Tolerance
limit
6.0- 8.5
30
2.0
503
4
5
6
Mercury
Oil and Grease
Total Residual Chlorine
,,
,,
,,
0.01
10
1.0
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
BSES KERALA POWER LIMITED, UDYOGMANDAL.
Name of the Industry
Date of Inspection
Raw materials
Product
: BSES Kerala Power Limited, Udyogmandal.
: 26-7-05.
:Naptha-650 t/day
HSO-start up fuel
:Electricity 3.196 mu/day
Production process:
The naphtha fuel required for the station is received in 2 nos.bulk storage tanks of
capacity 5000 Cu.M.each. The naphtha is pumped from IOCL Irumpanam terminal through
a branch pipeline connecting between IOC and FACT. The naphtha required for firing GTG is
centrifuged and stored in a clean tank of capacity cu.M and a day tank of capacity 1250
cu.M.The above tanks are protected against fire with on line foam system and hydrant and
spray system. Tanks are heavily earthed. There are 4 nos of Medium velocity firewater spray
pumps.
The clean naphtha is pumped to gas turbine generators and burned in the combustion
chamber while admitting air compressed at a ratio of 1.30.The high pressure and high
temperature product will drive 2 stage HP turbines and then 5-stage LP turbines .The exit gas
of LP turbine at @450 degC is fed into HRSG’s and will leave at 120 degC at stack outlet.The
heat recovered is used to generate steam in HRSG’s o run 36MW steam Turbine Generator.
DM water is injected to the gas turbine combustor for Nox suppression and Sox level is
reduced by using low sulphor fuel.
Findings:
1. During the time of inspection the factory was not working .It was informed that the
company is not functioning due to non-availability of raw material Naphtha.
2. 165 MW Power plant comprises of 3gas turbines of 43.2MW each, 3 nos HRSG
and 1 no. Steam Turbine of 36 MW. Obtained consent under the Air Act valid up
to 31-12-05 to operate 150 MW thermal power plants.
3. Source of water is Periyar and intake quality is 3560 m/day. Water is used for
processing, fire fighting and equipment cooling. Water is treated in the water
treatment plant. Obtained valid consent under the Water Act for discharging
504
50,000 litres of generated from the water treatment plant effluent into public drain
leading to Periyar River.
4. Cemented tank is provided for the collection of sludge from treatment plant.
5. Obtained authorization under HW Rules for the disposal of 950 kg/yr sludge and
filters contaminated with oil, and1300 kg/yr used oil to authorized recycler
reprocessor, and chemical sludge from wastewater treatment plant in temporary
storage facility.
6. Residue from Naphtha filter is stored in drums for disposal to authorized recycler.
7. Green belt is provided.
8. Oil trap provided in storm water drain.
Neutralization system is provided for the wastewater generated from DM plant.
Neutralized effluent
from DM plant, effluent from HRSG through flash and sump pit,
cooling tower blow down, and outflow from the clarifloculater are collected in Guard pond. A
portion of water from guard pond is used for horticulture purpose and balance is let out into
storm water drain through sand filter.
Recommendation:
1. Steps for water conservation shall be taken.
2. Adequate oil traps shall be provided in storm drains.
Njavallil Latex Pvt.Ltd.
1st report on Njavallil Latex Pvt.Ltd.
(Extracts of the minutes of 20th meeting held on 4-1-2005)
Members of the Local Area Environmental Committee along with officials of the
Pollution Control Board Shri. R.V Sateeshan Thampuran (Senior Environmental Engineer),
Shri. Farook Sait A. (Environmental Engineer), Smt.Chitrakumari D. (Environmental
Engineer), Shri. Shanavas (Asst Environmental Scientist) conducted a surprise inspection at
M/s Njavallil latex Ltd, Binanipuram, Edayar today (4-1-2005).
Mr. Sridharavydiar
Accountant of the unit and Managing Partner Sri. Antony Kurian were present during the
inspection. The inspecting team found untreated effluent being discharged into an open pit
near the Periyar River approximately at a distance of 5 metres . Waste oil is seen discharged
into an open drain in the premises of the unit leading to Periyar River. Further a portable
generator-cum-pump set is seen near the composite tank from where a water hose having
length of 49.5 metres with 5 inch diameter was seen connected to Periyar River and a pond
near river side.
The hose was found full of untreated effluent which was pumped from composite pond for
discharge to the river Periyar. The effluent contains high BOD, COD and suspended solids.
The discharge of waste oil through its drain into Periyar is illegal and an objectionable act of
the unit. The liquid effluent and sludge require careful handling. The unit is seen indulged in
discharging untreated effluent and waste oil into the River Periyar. It has violated the
505
conditions of the consent order issued under the Water (Prevention and Control of Pollution)
Act 1974.
The unit is not having an efficient ETP to treat the untreated effluent containing chemicals.
There are no adequate provisions for handling the effluent and the waste oil. The industry is
situated on the banks of the River Periyar. This unit is in operation for several years and
shockingly the efficiency of the ETP has not been verified by the PCB while renewing the
consent under the Water (Prevention and Control of Pollution) Act 1974 from time to time.
The ETP is totally out dated and is of no use. The unit could not account the sludge generated
from the ETP over these years showing its storage in its premises.
Having regard to the above facts and detection of the illegal activity of the unit, the LAEC
resolved to request the PCB to direct the closure of the unit immediately. The unit shall be
permitted to function only after satisfying the efficiency of the ETP. PCB shall make sure that
the unit is having sufficient facility to dispose of the waste oil from washing empty drums,
which are being used as containers for filling Rubber Latex.
PCB shall also ensure removal of sludge dumped in the premises to a secured place. The
report of the inspection is hereby forwarded for immediate action to the Chief Environmental
Engineer of PCB. A copy of this report is also is forwarded to the SCMC, Chairman and
Member Secretary of the Pollution Control Board
2nd report on Njavallil Latex Pvt. Ltd.
Name of the Industry
: Njavallil Latex Pvt. Ltd.
Date of Inspection
: 5-3-05
Name of the Product/s
: Centrifuged latex (3 t /day of 60 %)
Raw materials
: Ammoniated natural rubber latex
Process
Ammoniated natural rubber latex after desludging is centrifuged in a centrifuged machine
where the latex is separated to 60% centrifuged latex and skim. After standardization the 60
% latex is packed in drum and marketed. The skim is coagulated with sulphuric acid and dried
and marketed.
Findings/ Recommendations:
This is one unit inspected by the LAEC and recommended closure order as per report dated
4th day of January 2005 in its 20th meeting. The unit was subsequently given trial order
@ 1/3 capacity , suspending the closure order issued by the PCB on the recommendation of
LAEC.
1. Water is consumed for processing purpose viz; vessel washings, floor washings and
domestic purposes. Source of water is well and water consumption is reported to
506
15000 l/ day . The factory is situated by the river side and the total land area available
is 2.5 acre.
2. The production capacity of the plant is increased by installing three more centrifuge
machine.
3. The water consumption after expansion comes to 30000 l / day.
4. The waste water generated from the factory is 30,000 l /day. For treating the waste
water, the company has constructed a few treatment tanks. According to the company
the capacity of the treatment plant is 50000 l /day and the scheme for effluent
treatment is different from the project report furnished earlier
5. Regarding the sludge disposal, Effluent Treatment Plant sludge is not seen stored in
the premises.
6. It is reported that 50kg/day sludge containing magnesium ammonium phosphate is
produced from desludging tank.
7. The company is having valid water consent under the Water (Prevention and Control
of Pollution )Act up to 31-12-2004.
8. Sludge generated from ETP should be disposed of as per Hazardous Waste (M&H)
rules and authorization should be obtained.
9. House keeping is to be improved.
10. The unit should be directed to grow fast growing and long lasting trees all along the
boundary.
11. Water meter should be provided at the intake point.
12. The Board may insist the unit to execute a bank guarantee of Rs.2 lakhs which would
ensure that the unit shall not repeat discharge of untreated effluent either into the open
land or percolation or to the river .
Consented Parameters and Limits.
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
7
8
9
Characteristic
pH
Suspended Solids
Total Dissolved Solids(inorganic)
BOD(3Days at 270 C)
COD
Oil and Grease
Total Kjeldhal Nitrogen(as N)
Ammoniacal Nitrogen (as N)
Sulfides, as S
Unit
mg/l
,,
,,
,,
,,
,,
,,
,,
Tolerance
limit
6-8
100
2100
50
250
10
100
50
2.0
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
507
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Method of Analysis
Sl.
No.
1
2
3
4
5
6
7
8
9
10
Determinant
pH
SS
TDS
BOD
COD
Oil & grease
T.K.N
Ammoniacal
Nitrogen
Sulphide
Sulphate
: Njavallil Latex Pvt.Ltd, Edayar.
: 4-1-05
:LAEC 90(Unauthorised outlet discharging effluent into a pond
on land)
LAEC 91(Unauthorised outlet discharging effluent through
flexible hose into land).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
: IS 3025
Unit
mg/l
Source
Date of sample collection
Sample Identification No
Name of the Lab
Tolerance limit
5.52
107
5600
3212
3616
BDL
2016
1668
5.08
566
5208
3802
4160
BDL
1512
1185
6-8
100
2100
50
250
10
100
50
24
2571
36
2130
2.0
--
Unit
pH
BOD
COD
SS
TDS
Sulphide
T.K.N
Ammoniacal Nitrogen
Oil & grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Unauthorised outlet
discharging effluent
through flexible
hose into land
: Njavallil Latex Pvt. Ltd, Edayar.
: 4-1-05
:LAEC 27(Unauthorised outlet (hose pipe))
LAEC 3( Raw effluent)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.No Determinant
1
2
3
4
5
6
7
8
9
Unauthorised outlet
discharging effluent into a
pond on land
mg/l
LAEC27
5.15
2080
3760
259
4900
15.6
592
500
ND
LAEC
3
8.05
700
1808
150
950
ND
38
30
ND
Tolerance
limit
6-8
50
250
100
2100
2.0
100
50
10
: Njavallil Latex Pvt.Ltd, Edayar.
: 5-4-05
:LAEC 180(Raw effluent)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
508
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
Determinant
pH
BOD
COD
SS
TDS
Phosphate
Sulphate
Cynide
Sulphide
TKN
Amm. Nitrogen
Oil & grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
Determinant
pH
BOD
COD
SS
TDS
Phosphate
Sulphates
Cyanides
Sulphides
TKN
Ammo.Nitrogen
Phenolic Compounds
Oil & grease
Unit
mg/l
Raw
effluent
5.3
1800
9040
1988
9990
120
6000
ND
40
898
800
4.8
Tolerance
limit
6-8
50
250
100
2100
---2.0
100
50
10
: Njavallil Latex Pvt.Ltd, Edayar.
: 6-5-05
: LAEC 186(Outlet)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
Outlet
7.9
16.4
64
225
736
2.2
350
ND
ND
115
112.0
0.108
ND
Tolerance
limit
6-8
50
250
100
2100
---2.0
100
50
-10
509
510
511
KAIRALI LEATHER INDUSTRIES, EDAYAR.
Name of the Industry
: Kairali Leather Industries.
Date of Inspection
: 4-11-2004.
Name of the Product/s
: Wet blue leather 4 ton /day
Raw materials
: Raw hides -6 ton /day.
Process:
Soaking –Liming –Chroming.
Waste:
Chromium bearing ETP sludge-500 kg/month(item no 30.1 and 30.2 of schedule 1 )
Findings / Recommendations:
The unit was not working at the time of inspection. The unit has ETP using activated sludge.
This unit also has a chromium removal system in the ETP.
The stack/chimney height of the generator is not adequate and should be as per the norms.
The hide soaking effluent should be pre treated and introduced in the solar pond.
The Unit does not have authorization under the HW (M&H) Rules, 1989. The Unit claims to
have applied for it.
Chromium bearing effluent should be treated separately and sludge recovered which should
comply with the HW(M&H)Rules.
The unit is now permitted to discharge 90,000 liters of waste water to River Periyar after
treatment from ETP. The unit is situated on the banks of the river Periyar. It depends River
Periyar for water maximum reuse of effluent should be provided.
Old chromium bearing sludge is dumped on the land which should be recovered and
transferred to the temporary storage facility.
The unit should ensure confined storm water drain and if pollutants are mixed in the storm
water, it should be treated properly.
The Unit should implement good house keeping systems.
Green belt of fast growing and long lasting pollutant resistant plants should be planted where
ever possible.
Proper hygienic house keeping should be practiced in and out of the plant strictly.
512
The Pollution control Board will take samples from the Unit ie., from Effluent outlet,
hazardous wastes etc. and will mark a copy of the Laboratory Result to the LAEC.
The unit depends on the River Periyar for its water requirements and it is situated in the banks
of the River.
The unit should adopt best available technology with a view to reduce consumption of raw
materials ie., water, chromium etc.; waste minimization, odour control, waste reuse and
recycling .
2nd report on Kairali Leather Industries, Edayar
( Extracts of the minutes of the 41st meeting held on 10-03-2005)
Local Area Environmental Committee members accompanied by officials of Kerala State Pollution
Control Board namely, R.V.Sateeshan Thampuran, SEE, Smt. Chitrakumari.D, EE, Shri.Farook
Sait,EE and Mr. Shanavas, Asst.Scientists conducted a surprise inspection on 22-2-2005 on getting
information that the unit is discharging untreated effluent into Periyar River.
On inspection of the outlet of the unit, the colour of the river water was found dark. Foul odour of
tannery waste in the downstream of the bund was experienced by the team. The team on inspection of
the unit found effluent treatment idle. All the treatment units were almost filled with effluent. The
tanks were found filled with red coloured effluent generated from soaking tanks. A pump was seen
placed near the aeration tank with suction line from aeration tank and discharge line with hose
connection. The inspecting team observed by this arrangement that the functioning of the aeration tank
was not properly utilized and that the odour in the river bank and discolour seen in the river water near
outlet was the result of directing pumping of effluent by using pump and hose through the authorized
outlet.
The unit is handling raw hides and processing the same using Chromium. It has a Chromium effluent
separating system but the same has not been put to use. The unit is depending on River Periyar for its
water requirement. It is discharging 90000 litres of wastewater per day into river Periyar. Discharging
effluent without recovering the Chromium is causing severe harm to the River Periyar. Old Chromium
bearing sludge is seen dumped in the premises. The house keeping of this unit is very poor. The
conventional effluent treatment system is to be modified and upgraded by using the best available
technology. Considering depletion of water in the river, the unit should come forward with resource
saving concept and minimize water consumption by reusing the water, which is discharged into the
river for other purposes.
Considering the conduct of this unit (discharging untreated effluent with impunity) the unit
should be asked to show cause why stringent action including closure should not be taken for
its failure to comply by the provision of Environment Protection Act, Water (Prevention and
Control of Pollution) Act 1974, and Hazardous Waste (Management and Handling) Rules
1989.
LAEC recommends the following measures:
1. The unit being a tannery unit, the use of Chromium for its process, if at all insisted, the best
available technology for recovering the Chromium should be directed to be adopted. It is
advisable to go for a non-Chromium based process.
2. The effluent treatment should be modified and the treated water should be directed to be reused.
513
3. Minimize the water consumption. Direct the unit to install water meter for measuring water
consumption.
4. Direct to provide V-notch at the statutory outlet to measure the quantity of effluent discharged.
5. The unit may be directed to remove the Chromium sludge dumped in its premises and store it
in a temporary hazardous storage facility.
6. The unit may be directed to give a mass balance statement of the Chromium sludge and
account for its disposal/storage.
7. Greenbelt of fast growing and long lasting pollutant resistant plants should be planted in its
premises.
8. The undergrowth and wild bushes all along the boundary of the unit near the banks of the
Periyar River should be directed to be cleared.
9. The unit should be directed to go for Zero discharge in a phased manner and a proposal with a
time schedule may be obtained which should from part of the condition in the consent order.
Consented Parameters and limits.
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
7
8
9
Characteristic
PH
BOD(3Days at 270 C)
Oil and Grease
Chloride (as Cl)
Hexavalent Chromium as (Cr +6)
Total Chromium (as Cr)
Sulphides (as S)
Boron
Suspended Solids
Unit
mg/l
,,
,,
,,
,,
Tolerance
limit
6-9
30
10
1000
0.1
2
2
2
100
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
: Kairali Leathers Industries, Edayar
: 18-2-05
: LAEC 38(Primary settling tank)
LAEC 78(Equalisation Tank).
514
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Determinant
Determinant
PH
Zinc
Iron
Lead
Cadmium
Copper
Nickel
Arsenic
Total Chromium
Sulphide
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
Unit
PH
COD
Chlorides
Sulphate
Sulphide
Total Residual Chlorine
Total Chromium
BOD
SS
Nitrates
Phenolic Compounds
Hexa Chromium
Oil & Grease
Boron
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
LAEC 60(Solar pond 1)
LAEC 77(Solar pond 2)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Determinant
mg/l
Primary
settling
tank
Equalisation
tank
Solar
pond 1
Solar
pond 2
Tolerance
limit
7.8
5120
4500
1350
100
ND
3.04
520
112
ND
0.032
ND
ND
ND
7.5
3040
4700
2000
72
ND
3.34
428
448
ND
0.05
ND
ND
ND
9.1
3600
4000
1250
58.4
ND
0.089
680
463
ND
0.07
ND
ND
ND
11.2
6000
4000
1100
472
ND
0.139
1050
98
ND
0.15
ND
ND
ND
6-9
-1000
-2
-2
30
100
--0.1
10
2
: Kairali Leathers Industries, Edayar.
:18-2-05
:LAEC 54(Hazardous waste storage yard)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Hazardous waste storage yard
7.22
mg/kg 201.8
7254
348
2.4
23
16.8
BDL
BDL
177300
:River water near the outlet of Kairali Leathers Industries,
Edayar
:22-2-05
:LAEC 151(River water near Kairali Leathers outlet)
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
River water near Kairali Leathers outlet
515
1
2
3
4
5
PH
BOD
COD
SS
TDS
mg/l
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
Determinant
Zinc
Lead
Iron
Mercury
Cadmium
Nickel
Hexa chromium
Total Chromium
6.4
1.2
8
23
1120
: Kairali Leathers Industries, Edayar - Sludge
: 22-2-05
: LAEC 58.
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
LAEC
58
mg/kg 189.6
150
129100
BDL
3.8
72.4
1.18
195.6
516
517
518
M/S SREE SAKTHI PAPER MILLS LIMITED, EDAYAR.
Report on M/s Sree Sakthi Paper Mills Limited, Edayar.
(Extracts of the minutes of the 67th meeting held on 16-06-2005)
The LAEC members Mr. Asokan and Mr. Purushan Eloor along with the officials of
Pollution Control Board Smt.Chitrakumarri.D,EE, Mr.K.S.Soman. AEE, Mr.Shanvas, AES,
and Mr.Baburaj .P.K, AEE and Smt.Vandana Babu, AE inspected M/s Sree Sakthi Paper
Mills on 9-6-2005.
During the inspection the team found a person pumping hot raw effluent into the pits seen
dugged in its premises. The ETP was not functional. The untreated effluent was pumped
using flexible hose. Simultaneously, through different PVC pipeline effluent was being
discharged in to the open land from where it flowed through a concealed pipe into the drain of
a public road ultimately reaching in Periyar.
The pumping was abruptly stopped seeing the inspecting team. The scene was photographed
for recording the state of affair noted by the team. The inspecting team has collected samples
from various pits and is given for lab analysis. The report is awaited. The inspecting team
prepared a mahazar of the scene noted by them at the time of inspection that is signed by the
Works Manager of the unit Mr.Jayakumar. The incinerator found in the unit is totally
inadequate and seems to be not complying the norms of the PCB. The house keeping is
thoroughly poor. Paper pulp is seen scattered everywhere, inhibiting one to walk through.
The concealed PVC pipes laid across the premises which is said to be for draining storm
water is suspicious. . It is believed that these pipeline is used for discharging trade effluent.
The unit is not having consent under Water(Prevention and Control of Pollution)Act 1974 .
The boiler ash is kept openly and is likely to carry by the wind or through water .
It may be recalled that in the previous two inspections by the LAEC in this unit on 22-112004 and 17-4-2005, the unit was found indulging in the similar illegal activity and the unit
was warned with dire consequences if such activity is found repeated.
Sree Sakthi Paper mill is a unit that claims to have zero discharge effluent treatment system.
Under the pretext of the said claim the unit has not obtained any consent under the Water
(Prevention and Control of Pollution)Act 1974.The unit has forfeited the confidence of the
committee for the reason of having violated its promises made at the time of detecting such
illegal activity.
The unit is a medium scale industry. It consumes huge quantity of water. The effluent is also
in huge quantities. The Effluent treatment system that claims to attain zero discharge is
found not operating at all occasions of LAEC’s inspection. By discharging untreated effluent,
the unit has violated Environmental Protection Act and Water (Prevention and Control of
Pollution) Act 1974.
The letter dated 10.06.05 addressed to the chairman, the unit has tacitly admitted that the zero
discharge system of the unit is not functional and the unit must be given two months time “to eliminate
the irregularities” and that the unit has “appointed a consultant namely M/s. Enviro cum Laboratories,
Kalamassery”. And that “they are preparing a detailed scheme to overcome the irregularities noted I
the zero discharge system and to make the same more effective”.
519
Having regard to the repeated instances of illegal discharges by the unit and found violating the
provisions of the Environmental Protection Act and the fact that the unit is not having an adequate
system to treat the effluent, the unit should be directed to bring down its production forthwith and be
permitted to function in a phased manner only subject to following conditions.
Assess the capacity and efficiency of the ETP now available in the unit and depending on its efficiency
allow the unit to run to take such quantity of production that generate effluent proportionate to the
capacity of the existing ETP.
The unit should be asked to execute a Bank Guaranty of Rs 5 lakhs and an undertaking that it shall
not discharge untreated effluent in to the open land.
The unit should be directed to make zero discharge system functional within 45 days.
The unit should be allowed to take full production only after it establishes effective zero discharge
system.
The unit should be asked to furnish bank guarantee of Rs.5 lakhs which shall be forfeited in the event
of illegal discharge after the operation of ETP of zero discharge.
The unit should install an incinerator conforming the norms of the Pollution Control Board.
The unit should be directed to dismantle the PVC pipe used for rain water drainage and asked to
provide an open drainage.
The Unit should keep boiler ash in a confined area protecting it from wind and rain.
The ash generated by the burning of plastic waste in the incinerator should be removed to secured
landfill.
At present the plastic waste are kept in open land near Periyar without confining to any particular
room with a roof, protecting it from being escaped into the river Periyar .
The Unit has to improve its house keeping.
Green belt not seen provided. The units should be directed to grow fast growing and long lasting trees
all along its boundary.
2nd Report on M/s Sree Sakthi Paper Mills Limited, Edayar.
Name of Industry
: Sree Sakthi Paper Mills Limited, Edayar
Date of inspection
:22-11-04, 07-04-05, 09-06-05 &03-08-05
Raw materials: Waste paper,
Fuel for Boiler (saw dust, firewood, paddy husk, coconut)
520
Product:
Kraft Paper - 60 t/ day- Avg. (Installed capacity- 75 t/day).
Waste:
According to the company 1200 m3 /day wastewater generated from paper machine, high-pressure
shower and pulper cleaning is taken to the saveall process for removing the fibers and recycled in
process. Plastic materials removed are disposed by burning in an ordinary incinerator. Metallic items
such as pins are disposed by sale.
Process:
1. Pulping: Raw materials, viz Waste paper are sorted for removal of foreign materials like wax,
plastic, rubber bands, metal pins etc before feeding into conveyor. The conveyor takes the waste paper
to a hydro-pulper, where the waste paper is slushed with required quantity of water. This process is
called pulping. This pulp is allowed to flow through the sand trap for removal of sand and heavier
impurities and screened in a perforated vibrating screen to remove rejects. The screened pulp is a
further refined and sizing chemical like Rosin and Alum are added.
2. Paper Formation: The pulp is diluted and is made into 0.8% consistency. The diluted
pulp is sprayed through a head box with a series of sprayers into paper machine wire
where paper is formed. The wire with formed paper is passed in between presses to
allow water to drain. After passing through the first press, the moisture content in the
paper is brought down to about 55%. The second press reduces moisture to 52%. The
paper is then transferred to felt which takes the paper over a stainless steel M.G.
Machine, which has a 14 ft diameter. It is heated by Boiler steam. On passing through
this M.G. Machine, the moisture content in paper is reduced. The paper is wound into
the parent rolls and made into reels.
Findings:
1. The factory is commissioned in 1993. The installed capacity is 75 t/day of Kraft paper
and the present average production is 60 t/day.
2. According to the company about 220 m3 /day water is required for boiler feed,
domestic and processing. Source of water is well in the insulator incinerator yard of
the company, near river Periyar at about 200metres. The wastewater generated from
process plant is passed through screening chamber where plastic particles are removed
and then taken to save all system for removing the fibre. The fibre recovered is
reused and the whole quantity of effluent generated ie, 100M3/day is reportedly reused
in process.
3. The unit has obtained Boards consent under Water (Prevention and Control of
Pollution) Act 1974 upto 31-12-04. The production rate is 900-950 t/m of Kraft paper,
and consented quantity of effluent discharge is 100 m3/day into Periyar River.
4. The effluent treatment system comprises of a series of collection tanks. Pumping
arrangement for recycling the effluent is provided at the treatment plant. The sludge
recovered from the settling tanks is reportedly recycled to process.
5. There is one storm water drain leading to the southeastern side of the factory. During
the time of inspection on 7-4-05 the storm water drain is seen carrying effluent under
anaerobic condition. PVC pipe with valve and hose connection is seen provided for
521
conveying the effluent. There are indications of black coloured effluent percolated on
vacant land on eastern side of the factory.
6. Delay pond is provided for the storm water drain and provision is also made for
discharging the storm water from the delay pond into the drain outside the company
premises. The delay pond is seen completely filled with black coloured wastewater.
7. Canteen facility is not provided in the factory. The kitchen and toilets used by the
workers are not maintained properly and are found to create an unhygienic situation
in the premises. General house keeping is also poor.
8. There are two boilers (one stand by) of 4t/hr and 3-t/hr capacity (one stand by) fired
by fuels like saw dust, firewood, rice husk and coconut shell. For controlling the
emission of particulates through the chimney a dust collector is provided. Manual
shaking of the sac for the removal of dust collected is found to cause dust emanation.
The boiler ash accumulated in open area between the boiler house and factory gate is
likely to create dust nuisance to the neighbouring units. Also the adjacent unit
regarding the dust nuisance raises complaints verbally. There is chance of carry over
of ash particles during heavy rain into the river.
9. Raw material waste paper is stacked in open land.
10. Waste plastic materials are brought to another compound in the rear yard of the
factory in open area near river and incinerated. A Chimney of 30 M is provided to the
incinerator.
11. Ash generated from the incinerator is disposed on land in open area and there are
chances of wash out during rain.
12. The company authorities informed that they propose to install a new incinerator as per
rule for burning the plastic waste.
13. A Genset of 600 KVA is installed in the factory.
14. The unit has got Board’s consent under the Air (Prevention and Control of Pollution)
Act 1981.
15. The quantity of used oil generated is reported as 70 litres. The company has applied
for authorization under Hazardous Waste (Management and Handling) Rules 1989.
16. The members of LAEC Shri Purushan Eloor and Shri Ashokan along with board
officials Chithrakumari D (EE), K.S Soman (AEE), Shri Shanavas. (AS), Shri Baburaj
PK, (AEE) and Smt. VandanaBabu, inspected factory on 9-6-05.
During the inspection of the factory it was noticed that hot untreated effluent
from one of the effluent collection tank is pumped into a pit in the eastern side
of the factory using flexible hose. Effluent is also seen discharged into open
land at various points through PVC pipelines, reaching the storm water drain of
the company and finally leading to the public drain near the south-east corner
of the factory. Effluent samples were collected for analysis. Site mahazar was
also prepared.
The treatment plant was not working during the time of inspection. Plastic
materials are seen accumulated in the insulator. Civil construction works for
installing another incinerator is seen started. Arrangements are not provided for
preventing the escape of boiler ash from the open ash dumping area.
The report of analysis of effluent sample collected during the inspection while
pumping raw effluent from the treatment plant and stagnant effluent collected
from open land are shown below. The analysis report shows that the effluent is
highly polluted with low pH, high BOD, COD, Suspended Solids, TDS and
Sulphates.
522
Source
Date of sample collection
Sample Identification No
illegally into open land)
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
Determinant
pH
BOD
COD
SS
TDS
Fluorides
Chlorides
Phosphates
Sulphates
Oil and Grease
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
Source
Date of sample collection
Sample Identification No
land)
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
13.
: Sree Sakthi Paper Mills Limited.
: 7-6-05
: LAEC 208 (Raw Effluent Collected while pumping
Raw Effluent Collected while pumping illegally
into open land
4.9
3100
6240
6165
14730
ND
500
ND
3000
ND
: Sree Sakthi Paper Mills
: 9-6-05
: LAEC 207 (Stagnant effluent collected from open
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Determinant
Unit
pH
BOD
COD
SS
TDS
Zinc
Iron
Lead
Mercury
Chlorides
Phosphates
Sulphates
Phenolic compounds
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
Stagnant effluent collected from
open land
5.0
2040
4800
258
8612
0.5
148
ND
ND
460
ND
1750
1.4
17. For verifying the reported complaints by the company, the factory was again inspected on 3-82005. House keeping is seen improved and arrangement for segregating pulp from effluent is
provided. The pulp removed is collected in one of the old sludge drying beds for reuse and the
effluent is recycled to process plant.
Recommendation:
523
1. Even though the company is reportedly recycling the whole quantity of effluent, 100
% recycling can be successfully effected only after implementing a full fledged
effluent treatment plant
2. Storm water drains and effluent drains are to be segregated.
3. Steps must be taken for rainwater harvesting and green belt development.
4. Intake water from the well and process requirements are to be metered.
5. Steps must be taken for controlling dust emanation and escape of boiler ash by wind
and rain from ash dumping area.
6. House keeping is to be improved.
Consented Parameters and Limits.
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No Characteristic
Unit
1
2
3
mg/l
,,
PH
Suspended Solids
BOD(5Days at 200 C)
Tolerance
limit
5.5 -9
100
30
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
Determinant
PH
BOD
COD
SS
TDS
: M/s Sree Sakthi Paper Mills, Edayar.
: 7-6-05
: LAEC 208(Raw Effluent Collected while illegal pumping)
:Central Laboratory, Gandhi Nagar.
Unit
mg/l
,,
,,
,,
Raw Effluent Collected
while illegal pumping
4.9
3100
6240
6165
14730
Tolerance limit
5.5 – 9
30
-100
--
524
6
7
8
9
10
Fluorides
Chlorides
Phosphates
Sulphates
Oil and Grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
Determinant
PH
BOD
COD
SS
TDS
Zinc
Iron
Lead
Mercury
Chlorides
Phosphates
Sulphates
Phenolic compounds
,,
,,
,,
,,
,,
ND
500
ND
3000
ND
------
: M/s Sree Sakthi Paper Mills, Edayar.
: 9-6-05
: LAEC 207(Stagnant Effluent)
:Central Laboratory, Gandhi Nagar.
Unit
Stagnant Effluent
Tolerance limit
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
5.0
2040
4800
258
8612
0.5
148
ND
ND
460
ND
1750
1.4
5.5-9
30
-100
----------
525
526
527
M/S SIGMA FERTILIZERS, EDAYAR
Name of the Industry
: Sigma Fertilizers.
Date of Inspection
: 4-11-2004.
Name of the Product/s :
:Bone Meal, Tallow and organic rich water
Raw materials
: Raw bone
Process:
After boiling the raw bones are crushed, sieved and packed.
Findings:
Kerala State Pollution Control Board issued consent to establish this fertilizer industry for
production of bone powder by order dated 1-3-2000. Among the conditions imposed the
Board specifically directed this unit to obtain consent from the Board under the
Air(Prevention and Control of Pollution)Act 1981 before commissioning the industry.
The consent to establish the industry directed the unit to plant and maintain trees within the
factory premises to improve the environment.
The Board also specifically directed the unit that it shall not produce tallow.
The unit started without obtained consent under the Air Act and it is continuing its
production. The unit has no consent under the Water (Prevention and Control of Pollution)Act
1974. There is no green belt in and around the industry and no effort has been made to comply
with the directions of the Board contained in the consent to establish the industry even after
four years.
The Factory and premises are kept untidy and unhygienic. The raw bones are stocked
unhygienically in the premises. Storm water drain with blood drippings are a disturbing scene.
Effluent and storm water in anaerobic condition is seen stagnated in the adjoining land.
Unbearable foul odour emanating from the factory and premises keep a normal person at least
a distance of 50 meters away from the factory. House keeping is pathetic. The labourers
mostly from other states were found seen taking meals just by the side of putrefied pond
wherein countless worms crawling one over the other, a scene cannot be imagine in any
situation of human habitation. Labour officers have not checked the implementation of
welfare laws.
528
Recommendations:
The unit is functioning without obtaining the consent under the Air(Prevention and Control of
Pollution)Act 1981 and Water(Prevention and Control of Pollution)Act 1974 and found
operating against the mandate of Air Act and Water Act and Environmental Protection Act.
The unit is found producing tallow against the directive in the consent to establish.
Green belt is not provided
Air and Water pollution is a cause of nuisance to the near by units and public.
House keeping is pathetic and absolutely no proper drainage system is maintained.
For the aforesaid reasons LAEC is of the opinion that the unit should be given a closure order
forthwith and can be allowed to restart only subject to complying with the following
stipulations:1. The unit should obtain consent of the Board under Water Act and Air Act
2. Raw material should be stored in a confined area hygienically.
3. Unit should provide stack /chimney of 15 m above ground level with draft /use of
bio-filter to expel foul smell.
4.
Only dried bones should be allowed to process.
5. Storm water drain should not contain any pollutants carried over.
6. Greenbelt of fast growing and long lasting pollutant resistant plant should be planted
wherever possible.
7. Proper hygienic house keeping should be practiced in and around the factory.
8. The unit should install sophisticated equipments for odour control.
529
530
COCHIN ALLOY PRODUCTS (P) LTD
531
Report on Cochin Alloy Products Pvt. Ltd
(Extracts of the minutes of the 42nd meeting held on 12-03-2005)
The Unit was inspected by the Local Area Environmental Committee accompanied by
officials of the Pollution Control Board, Mr Shanavas, Asst. Scientist. The company is
producing Ferrous Silicon and Calcium carbide. The raw materials used are sea shell, Wood
Charcoal, Carbon paste etc.
The furnace area near chimney is found not properly covered. Fugitive emission is a problem noticed
in the unit. The Pollution Control Board refused consent under Air (Prevention and Control of
Pollution) Act 1981 on 10-3-1997 for want of adequate air pollution control measures. The unit was
given a closure order by the Pollution Control Board for operating without consent under the Air Act.
Subject to the condition that all air pollution control measures will be provided, the unit was allowed
to operate by a Court order.
The unit claims to have complied with all pollution control measures and applied for renewal of
consent on 14-6-2002. Pollution Control Board refused consent on 1-10-2002 stating inadequacy of
the pollution control measures and failure to furnish information on capital investment etc. The unit
having failed to adhere to the pollution control measures Pollution Control Board filed a complaint
before the Judicial First Class Magistrate Court, N. Parur on 6-11-2003 for prosecuting the unit.
Findings:
The Pollution control measures are found inadequate . Fugitive emission is a problem. The height of
the chimney is not adequate. In spite of declining consent under the Air Act for want of proper system,
the unit is functioning with impunity. It has not cared to satisfy the regulatory Board on the adequacy
of the system. The information furnished by the unit to the LAEC that their application for consent is
pending is false. In the above circumstances, LAEC is of the opinion that the unit should be directed to
be closed down and be permitted to re-start only after providing adequate air pollution control
measures to the satisfaction of the Board.
The unit should be allowed to operate subject to satisfying the following conditions:
1. The unit should obtain the consent under Air (Prevention and Control of Pollution) Act 1981.
2. The unit should provide adequate air pollution control measures to contain fugitive emission.
3. The units should be directed to grow fast growing and long lasting trees all along the
boundary.
4. Grow curtain plants (jaiva veli or bio-fencing) all along the boundary at a height of 20 feet and
start maintaining the plant.
RAMANAND ELECTROCOATS, EDAYAR.
Name of the Industry
: Ramanand Electrocoats, Edayar.
Date of Inspection
: 16-11-2004.
Name of the Product/s
: Job Work of Powder coating, Electrical gadgets,
switch covers, metal articles etc.
532
Raw materials
: Pre-treatment Chemicals 10-12 L/day.
: Powder coating paints (Powder) 10- 20
kg/day
Process:
The production process involves pre-treatment of metal articles such as degreasing, de-rusting, rinsing
and phosphating by dipping in series of tanks followed by powder coating in Cyclone booth and
curing in Electric oven.
Waste:
About 1000 litres of water is consumed per day for processing purpose. The waste water
generated from degreasing, derusting, rinsing, and phosphating operations are discharged
without any treatment. The sludge removed from phosphating tank (10 – 20 kg/month) is
stored in a partially covered underground tank.
The phosphating sludge (waste category 12.5) and acid/alkali residue from metal surface
treatment (category 12.1, 12.2 ), ETP sludge of metal surface treatment (12.9), spent bath
(12.3) comes under The Hazardous Waste (M&H) Rules.
Findings:
1. The pickling liquor and rinse water generated from the processing is highly acidic containing
iron, Chlorides etc. This is discharged into the river without any treatment.
2. The unit has not obtained Board’s consent under the Water (Prevention and Control of
Pollution) Act 1974 for discharging effluent.
3. The well water near to the Pre treatment and phosphating tanks is seen acidic with a
pH 2.0, indicating contamination due to effluent from processing area. Washed acid
/ waste water is let into this well.
4. The waste water / acid residue in 7 nos. tanks are directly discharged into the River
Periyar through unauthorized open outlet.
5. The sludge from phosphating tank is seen stored in a partially covered underground
tank. The unit has not obtained authorization under the Hazardous Waste
(Management and Handling) Rules 1989 for the disposal of phosphate sludge.
6. A vent pipe is provided for letting out the emission from powder coating area. The tip
of the vent pipe is immersed in a water tank and the overflow from the tank is seen let
out.
Recommendations:
533
1. Proper treatment facility should be provided for the wastewater generated from the
unit.
2. The phosphating sludge (waste category 12.5) and acid residue from metal surface
treatment (category 12.1) comes under the Hazardous Waste (M&H) Rules.
3. The unit should be directed to be closed down forthwith and be allowed to re-start
only after obtaining the consent under the HW (M& H) Rules, 1989, Air Act and
Water Act.
4. The Unit should be directed to install ETP for treatment of waste water and should go
in for Zero discharge.
5. Two wells one near the process area and the other one near the main gate being
contaminated with acidic substances should be reclaimed.
6. Green belt not seen provided. The unit be directed to grow fast growing and long
lasting trees all along the boundary and report planting of seedlings within one month
to the Pollution Control Board.
7. The damage caused to the environment due to improper dumping of wastes should be
assessed separately and recovered from the Unit.
The unit was subsequently inspected on 3-8-2005 after giving time for improvement. During
the subsequent inspection the following aspects were noticed.
Findings:
1. The treatment unit comprises of an oil trap, neutralization chamber collection sump,
compressed aeration chamber, coagulant addition and settling tank, pr sand filter and
activated carbon filter, and overhead treated effluent storage tank.
2. The treatment system is reportedly designed for 3000l/day.
3. Treatment units constructed are incapable of providing the desired treatment for which
it is constructed due to the improper inlet and outlet location, inadequate capacity of
settling tank and sludge drying bed, inefficient chemical coagulation treatment.
Colour code
Red: Pollutants not conforming to the standards.
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
: Ramanand Electro Coats, Edayar.
: 15-3-05.
:LAEC 160(Effluent collection Sump)
LAEC 161(Unused well).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
534
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
Determinant
PH
COD
SS
TDS
Zinc
Iron
Lead
Chlorides
Phosphate
Sulphate
Acidity
Hexa chromium
Oil & grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Unit Effluent
collection Sump
3.6
mg/l 240
140
1268
ND
80
ND
600
ND
230
250
ND
7.4
Unused
well
4.9
160
54
584
0.2
1.8
ND
40
ND
400
8
ND
22.12
: Ramanand Electro Coats ,Edayar.
: 15-3-05
: LAEC 75(Phosphate sludge)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.
Determinant
Unit
No.
1
PH
2
Zinc
mg/kg
3
Iron
4
Lead
5
Copper
6
Nickel
7
Chlorides
8
Phosphate
9
Cynide
10
Hexa.Chromium
NATIONAL BATTERY INDUSTRIES, EDAYAR.
Phosphate
sludge
5.2
86280
127500
112
13.4
344.2
200
599.4
ND
53.2
Name of the Industry
: National Battery Industries, Edayar.
Date of Inspection
: 18-11-2004
Name of the Product/s
: Battery
Raw materials
: Lead scrap, Sulphuric Acid and water.
Process:
535
Lead is melted in melting furnace and casted to produce Lead grid. Lead oxide coating is
provided and air-dried. Battery containers are brought from outside and filled with Acidic
water (Sulphuric Acid and water) and charged.
Waste:
Lead residue from melting furnace 200 kg/month (category 9.1) and waste plastic containers
are reported to be disposed to re-processing units. The waste water generated is discharged
into land without any treatment. Lead slag contained in polythene bags is kept in the factory
premises.
Findings:
1. Second Lead melting pot is kept open in the shed with small chimney ,which is
inadequate.
2. Waste-water from hand washings and vessel washings are discharged into land
without treatment.
3. Received complaints regarding the illegal dumping of smelter residue from battery
reprocessing.
4. Reprocessing activity is not noticed during inspections.
5. The unit has not obtained Board’s consent under the Air Act and Water Act.
6 The unit has not obtained Board’s permit under The Batteries (Management and
Handling)Rules, 2001.
7 The Unit has not obtained Consent under the Hazardous Waste (Management and
Handling) Rules, 1989.
8 Sulphuric acid is stored in the open in plastic drums. The plastic drums are washed
with lime and let out in the open.
9 House keeping is very pathetic.
Recommendations:
1. Air Pollution control measures are to be provided to the Lead melting furnaces with
adequate chimney heights.
2. The Unit be directed to be closed down forthwith and be allowed to re-start only after
obtaining the consent of the PCB under the Hazardous Waste (Management and
Handling)Rules 1989; Water (Prevention and Control of Pollution)Act 1974 and
Air(Prevention and Control of Pollution) Act, 1981
3. The unit should comply with the provisions of The Batteries(Management and
Handling) Rules,2001.
4. The Unit should be directed to implement good House keeping systems.
5. The Unit has not displayed Board showing the Hazardous Waste generation. The Unit
must be directed to display the board.
6. Green belt not seen provided. The unit be directed to grow fast growing and long
lasting trees all along the boundary and report planting of seedlings within one month
to the Pollution Control Board.
536
7. The damage caused to the environment due to improper dumping of wastes should be
assessed separately and recovered from the Unit.
Colour code
Red: Pollutants not conforming to the standards.
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
Determinant
Zinc
Lead
Cadmium
Nickel
Arsenic
Sulphate
Total Chromium
: Hazardous waste, National Battery Industries, Edayar
: 17-01-05
: LAEC 46.
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
LAEC
46
mg/kg 733
256500
6.2
25.8
BDL
7880
55.2
HI- TECH ELECTRO THERMICS (P) LIMITED, EDAYAR.
Name of the Industry
: Hi- Tech Electro Thermics (P) Limited, Edayar.
Date of Inspection
: 23-11-2004
Name of the Product/s
: Ferro Alloys
Silico Manganese : 4 - 4.5 t/day.
Ferro Silicon :
2 - 2.5 t/day.
Ferro Manganese: 4.5 - 5.0 t/day.
: Calcium Carbide : 5- 5.5 t /day.
Raw materials
:
Products
1.Silico Manganese
Raw Materials
:Manganese ore -10 t/day
:Charcoal - 3.5 t/ day.
:Dolomite - 1.0 t /day.
537
2. Ferro Silcon
:Quartz- 4.5 t/day.
:Charcoal-3.0 t/day.
:M.S.Scrap- 0.7 t/day
3.Ferro Manganese
:Manganese ore – 12.5 t/day
:Charcoal - 3.5 t/day
:Dolomite – 3.5 t/day.
4.Calcium carbide
:Lime shell -10 t/ day
:Charcoal – 6 t/ day.
Process:
The raw materials are mixed in required proportion and charged into the furnace periodically
at regular intervals and the molten mass formed inside is tapped out through a tap hole into a
laddle or sand bed. The solidified metal cake is broken into required sizes and then packed
inside gunny bags for despatch.
Waste:
The slag formed during the process is the hazardous solid waste. About 1.5- 2 t /day slag is
produced which according to the company is disposed to outside parties for land filling.
Findings:
1.
2.
3.
4.
5.
6.
7.
8.
9.
Water is used for cooling and domestic purposes. Cooling water is re-circulated after
passing through a cooling tower.
Waste-water generated from the canteen is let out into the drain after passing through
solid trap.
For letting out the emissions from the furnace two chimneys are provided.
A hood system is provided to the furnace and a chimney of 30 m height is attached to
the hood for venting the emissions from the furnace. Fugitive emissions from the
furnace after passing through a spark arrester is let out through a dust collection
system of air pulse jet air bag filter and a chimney of height
25 m.
A butterfly valve is provided in the chimney of 30 m height. According to the
company authorities, the butterfly valve is closed and the emissions are let out only
through the new chimney of 25 m height to which the dust collection system is
attached. But during the inspection emission was noticed through both the chimneys.
Provision for venting out the emissions through the roof-top of the factory building is
seen provided.
Huge dust emission through the new chimney was noticed during the cleaning of filter
bags. The company authorities reported that the bags require cleaning in 3 hour
interval. The dust collection system is switched off during the cleaning time of 10
minutes and the emissions are let out directly through the old chimney which is not
having dust collection system.
The company is not having valid consent under the Air (Prevention and control of
Pollution) Act.
The company is not having authorization under the Hazardous Waste (Management
and Handling) Rules 1989.
538
Recommendations:
1. The old chimney of 30 m height should be equipped with dust collection system of
adequate capacity.
2. The height of the new chimney with dust collection system should be increased to 30
m above ground level.
3. The capacity of the dust collector attached to the new chimney should be enhanced
with automatic bag cleaning system.
4. The provision for venting the emissions through the roof top of the factory building
should be dismantled.
5. The waste water from the canteen is to be treated properly.
6. The company should obtain the board’s consent under the Air (Prevention and Control
of Pollution ) Act.
7. Green belt is to be developed.
8. House keeping is very poor and is to be improved.
9. The company should obtain the authorization under the Hazardous Waste
(Management and Handling) Rules 1989.
10. The Company should be directed to be closed down forthwith since it does not have
authorization under HW (M&H) Rules & Air Act. The Unit may re-start after strictly
complying with the above conditions.
MINAR CHEMICAL INDUSTRIES, EDAYAR.
Name of the Industry
: Minar Chemical Industries.
Date of Inspection
: 31-12-04.
Name of the Product/s
: Precipitated silica 0.3 t/day
Sodium Silicate 2 t /day
Raw materials :
:
For sodium silicate
: Caustic soda
Quartz powder.
Fire wood.
For Precipitated silica
: Sodium Silicate
Hydrochloric acid.
Process:
a) Sodium silicate : Quartz powder is mixed with caustic soda solution and the solution is
boiled in a closed tank. Sodium silicate formed is stored for despatch.
b) Precipitated silica: Sodium silicate is neutralized with dilute hydrochloric acid under
controlled condition . Then silica is precipitated. The process material is pumped to the
539
centrifuge for washing with water. The product is separated by filtration, dried and powdered
in ball mill. The wastewater containing sodium chloride is the liquid effluent.
Findings:
1. The unit has obtained Board’s consent under the Water Act valid upto 31-12-2004 for
discharging 75,000 litre per day of effluent into Periyar river through underground
pipeline.
An effluent storage tank of about 40,000 litres capacity is existing in the factory. At
the time of inspection the tank is seen used for storing water.
3
The effluent generated from silica gel is acidic with high Sodium Chloride content.
Effluent treatment facilities are not provided.
4
Fugitive smoke emission is noticed from the oven (firewood burning) used for heating
the reactor. Also the height of the chimney is inadequate.
5
Inplant air pollution control measures are to be implemented in silica gel plant for
controlling fugitive emissions.
Recommendations:
1. The Unit should obtain consent under the Water Act.
2. The waste-water containing Sodium chloride is the liquid effluent from the
manufacture of precipitated silica. The effluent generated from Silica gel is acidic
with high sodium chloride content. Effluent treatment facilities for both the products
are not provided. The Unit is therefore, discharging untreated effluent into River
Periyar through under ground pipeline. This is in violation of the Environment
Protection Act and Water Act. The Unit therefore, should be directed to be closed
down until adequate effluent treatment facilities are provided and re-use the treated
water. Zero discharge should be implemented.
3. The height of the chimney is inadequate resulting in fugitive smoke emission. The
height of the chimney is to be increased as per the Rules and measures for containing
fugitive smoke emission should be implemented prior to re-start of the Unit.
4. Green belt not seen provided. The units should be directed to grow fast growing and
long lasting trees all along the boundary.
ABCO ACCUMULATORS, EDAYAR.
540
Name of the Industry
: Abco Accumulators, Edayar.
Two units are functioning under the name Abco accumulators in the same survey number of
Edayar development area.
Unit 1
Date of Inspection
: 18-02-05
Raw materials
:Crumb rubber powder
Used tyres- 800 kg/day
Fire wood – 200 kg/day
Products:
:Reclaimed rubber.
Source of water is well and KWA
Process:
Crumb rubber powder, used tyres etc are put into grinder for reducing the size. The powder is put into
an autoclave machine (2 nos) and cooked with steam. The cooked rubber is put into the mixing mill
for making rubber sheets.
Findings:
There are two storm water drains. The waste water from canteen is disposed into a pit.
There is a boiler and thermic fluid heater. Public complaints exist regarding the
burning of tyre waste.
Cooling water is seen discharged into land.
The unit has obtained Board’s consent under the Air (Prevention and Control of
Pollution)Act 1981 valid upto 31-12-2005.
Least attention given for house keeping.
Green belt is not provided.
Dust pollution control measures are not provided
Recommendations:
1.
2.
3.
4.
Cooling water recirculation arrangement should be provided.
Dust pollution control measures are to be provided.
Should obtain authorization under HW Rules for the disposal of used /spent oil.
Burning of Scrap rubber should be stopped forthwith.
Unit 2
Raw materials
:Scrap battery – 5500 kg /month.
Product
:Lead – 3000 kg/month.
541
Process:
Lead is made from lead plates for lead acid batteries from dry scrap batteries. Process consists of
heating the dry scrap battery plates with charcoal in a furnace. Battery plates consists of free lead and
lead oxide. Lead oxide is reduced with charcoal to form lead. This is fed into the furnace again. The
fumes evolved from this is collected through a duct and passed through water in a closed chamber for
scrubbing the fumes and released through a chimney.
Findings:
1. The unit is not having valid consent under the Air Act. The validity of the consent
issued by the Board expired on 31-12-1999.
2. Two lead melting furnaces are attached to a common chimney. Lead fumes emitted
from both the furnaces are passed through a closed chamber containing water and then
let out through a chimney of 30 metre height.
3. Lead oxide powder is prepared by grinding lead balls and the dust laden air is passed
through three dust collectors in series. Very fine lead oxide powder collected inside
the bags of the dust collector is disposed off. Lead oxide produced is used for making
lead oxide paste.
4. Lead slag, fine lead oxide powder and various scrap materials are seen haphazardly
disposed in open area in the factory premises.
5. Massive fugitive emission of lead fumes is noticed from the open lead melting furnace
used for making grids.
6. Attention is not given on house keeping.
Recommendations:
1. The unit should provide Air pollution control equipments for containing lead fumes
from the furnaces and obtain the Board’s consent under the Air (Prevention and
Control of Pollution)Act 1981.
2. Measures for controlling fugitive emissions during lead oxide preparation should be
provided.
3. Should obtain authorization under HW Rules for the disposal of lead slag / lead
bearing residue (category 9.1) and lead ash / particulate from flue gas ( category 9.2).
4. House keeping is to be improved.
5. Green belt is to be developed.
6. This unit should be directed to be closed down forthwith and permitted to re-start only
after obtaining all consent and authorization under relevant Rules.
ST. GEORGE INDUSTRIES, EDAYAR.
Name of the Industry
:St. George Industries, Edayar.
Date of Inspection
: 16-11-2004.
Name of the Product/s
: Fabrication and Powder coating of
structural items on Job work.
Raw materials
: Epoxy coating powder.
542
Pre-treatment chemicals.
Process:
Fabricated MS items are de-greased in alkali base, rinsed with water, de-rusted using
phosphoric acid and water rinsed. The items are then taken to pre-dip tank containing 1%
alkali, 5% phosphating tank and passivated.
Waste:
The acidic and alkaline effluent (250 litres/day) generated from pre-treatment is mixed and
discharged. The phosphating sludge (waste category 12.5) and acid/alkali residue from metal
surface treatment (category 12.1, 12.2 ), ETP sludge of metal surface treatment (12.9), spent
bath (12.3) comes under The Hazardous Waste (M&H) Rules. The unit is required to obtain
the authorization under the HW Rules.
Findings:
Proper facility is not provided for treating the effluent generated from processing areas of pretreatment and phosphating.
A dust collection system is provided to the powder coating area but was not operational at the
time of inspection.
The unit has not obtained Board’s consent under the Air (Prevention and Control of Pollution) Act
1981 and Water (Prevention and Control of Pollution) Act 1974.
The phosphating sludge (waste category 12.5) and acid/alkali residue from metal surface treatment
(category 12.1, 12.2 ), ETP sludge of metal surface treatment (12.9), spent bath (12.3) comes under
the HW Rules. The unit has not obtained authorization under the Hazardous Waste (Management and
Handling) Rules 1989.
Recommendations:
The unit should provide adequate effluent treatment facilities.
The unit should provide Board’s consent under the Air (Prevention and Control of Pollution)Act 1981
and Water (Prevention and Control of Pollution)Act 1974.
The unit should provide adequate air pollution control measures.
The unit should obtain authorization under the Hazardous Waste (Management and Handling) Rules
1989.
The Unit is given time one month’s time to obtain all required consent and authorization,
failing which the Unit will be directed to stop production.
Colour code
Red: Pollutants not conforming to the standards.
543
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
Determinant
pH
COD
SS
TDS
Zinc
Iron
Lead
Chlorides
Phosphate
Sulphate
Cyanide
Acidity
Hexa chromium
: St.George Industries
: 15.3.05
: LAEC 66(Second rinsing tank)
LAEC 35(Third rinsing tank).
:Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
Second
rinsing tank
4.1
8
48
564
1.0
50
ND
20
ND
220
ND
290
ND
Third
rinsing tank
5.7
4
20
568
ND
4
ND
30
ND
125
ND
2.0
ND
HI- TECH SEALS (P). LTD.
Name of the Industry
:Hi- Tech Seals Pvt. Ltd.
Date of Inspection
: 16-11-2004.
Name of the Products
: Fuel Tank
Wheel Rim
Radiator Cover
Mudguard Plate
Spiral Wound Gasket
15Nos
11 nos
8 ,,
7 ,,
45 nos
Raw materials
: CRCA Sheet
Stainless Steel Strips
Paint
Rings
Graphite Tape.
26.2 kg
10 kg
500 metre
Process:
Engineering works of cutting, drilling, punching, welding, acid treatment, rinsing,
phosphating followed by spray painting in painting booth.
544
Waste:
Waste water generated from Acid treatment, rinsing and phosphating constitute the liquid
effluent and is let out into land without any treatment. The waste material metal scrap (20
kg/day) is disposed by sale.
Findings/ Recommendations:
1. Adequate facility is not provided for treating the waste water generated from the plant.
2. Pollution control measures provided at the paint booth is inadequate.
3. The unit is not having the Board’s consent under the Water Act and Air Act. The
unit should provide adequate air and water pollution control measures and obtain the
Board’s consent.
4. The acidic waste from pre treatment and sludge from phosphating comes under the
hazardous waste category. The unit has no authorization under the Hazardous Waste
(Management and Handling) Rules 1989
5. The Unit operates without any consent viz., Hazardous Waste (Management and
Handling) Rules 1989; Air Act and Water (Prevention and Control of Pollution) Act
1974.
6. The Unit is given time one month’s time to obtain all required consent and
authorization, failing which the Unit will be directed to stop production.
ARJUNA NATURAL EXTRACTS LTD, EDAYAR.
Name of the Industry
: Arjuna Natural Extracts Ltd, Edayar.
Date of Inspection
: 19-02-05.
Name of the Product/s
: Garcenia Cambogia extract powder
max(100 kg/day)
Raw materials
: Sodium Hydroxide , Methanol , Calcium Chloride ,
Ethylene dichloride, Hydrochloric acid.
Waste:
Liquid effluent generated is stored in underground tanks for transporting to the treatment plant
of the company at Keezhmadu. Used oil is stored in barrels and kept in roofed shed for further
disposal.
Findings:
1. The unit has obtained Board’s consent valid upto 31-12-04 under the Water
(Prevention and Control of Pollution)Act 1974 for discharging 1000 L/day effluent
into the ETP of the company at Keezhmadu.
545
2. Source of water is bore well, KWA and purchase from outside. It is reported by the
company that the raw bore well water is unsuitable due to high iron content. Reported
water consumption is 3500 L/day. Bore well water is used for cooling requirements
after aeration.
3. Effluent generated are stored in two underground effluent tanks. The solid layer on the
top is reportedly fired after drying.
4. One storm water drain is found reaching the effluent sump.
5. Residue / solid wastes from processing is seen burnt in the open yard near storm water
drain. There are chances of carry over ash through the storm water drain.
The general public has complaints against this unit for discharging effluent into
Edayattuchaal.
The boiler 1.5 t/hr is provided with a chimney of 30 meter high. Two gensets of 125
KVA and 40 KVA are having vent pipes of height 2.5 meter and 1.5 m respectively.
The company has got consent under the Air (Prevention and Control of Pollution)Act
1981 valid upto 31-12-2005 for producing 2.5 t/month Garcenia Cambogia extract
powder.
During inspection it is noticed that the factory is producing extracts of Posweillea
Seraeta, Linseed oil, rice bran oil etc.
Used oil is stored in drums and stored in a roofed shed. It is reported that the unit has
applied for authorization under Hazardous Waste (Management and Handling) Rules
1989, but not obtained.
LAEC verified the register kept for transportation of the effluent to Keezhmadu and
found that the entries are not genuine and do not reflect the correct position. Entries
appear to have been made at a stretch and not properly matching.
Recommendation:
1. Storm water drain leading to effluent sump is to be segregated from trade effluent
drain.
2. Adequate treatment facility for treating the effluent may be provided at the Unit itself
rather than allowing to be transported to Keezhmadu unit for disposal. The Water
consent has expired and should be renewed only after the unit provides proper Effluent
treatment Plant in the premises itself.
3. The quantity of effluent discharge 1000L /day reported by the company seems to be
very less than the actual effluent generation . This needs to be verified.
4. The house keeping is to be improved.
5. The Unit may be given one month’s time to set up an Effluent Treatment Plant (ETP),
failing which the Unit may be directed to be closed down and allowed to re-start only
after obtaining consent under the relevant Rules.
The unit was further inspected on 6-8-05 and the committee finalize the following reports.
Findings:
The factory authorities informed that their sister concern at kunnathunadu stopped production
in May 05 due to labor problems. The effluent generated is reportedly evaporated in the
evaporator. But during inspection indication of land discharge of effluent in the backyard of
the factory is noticed .A sample of sludge from open land is collected for analysis.. An
effluent sample from the final storm water drain leading to Edayathuchal is collected for
analysis.
546
The report of analysis of the top layer solids in the collection sump show Zinc (243mg/kg),
Iron 323.4(mg/kg), Total Chromium (32.2 mg/kg), Manganese 18 mg/kg.
The raw effluent is highly contaminated with BOD, COD SS, Iron, Chlorides, and Phenolic
compounds. The company should provide Pucca treatment plant in the factory premises itself
for achieving the prescribed quality. As the unit is not having an adequate treatment plant, it
should be directed to be closed down as recommended already.
Consented Parameters and Limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
Characteristic
Unit
pH
Suspended Solids
BOD(5Days at 200 C)
Oil and Grease
mg/l
,,
,,
Tolerance
limit
5.5-9.0
100
30
10
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
Determinant
pH
BOD
SS
TDS
Zinc
Iron
Fluoride
Chlorides
: Arjuna Natural Extracts Ltd.
: 19.2.05
: LAEC 41(Borewell in the factory premises).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
Borewell in the
factory premises
4.7
2
72
2830
10
25
0.25
800
Tolerance Limit
5.5-9.0
30
100
547
9
10
11
12
13
Nitrate
Phosphate
Sulphate
Phenolic Compounds
Manganese
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
Determinant
1
2
3
4
5
6
7
: Arjuna Natural Extracts Ltd.
: 19.2.05
: LAEC 65(Effluent sump ( Garcinia Cambogia Processing))
LAEC 62(Effluent Sump near Poswellia Seraeta)).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
pH
BOD
mg/l
COD
SS
TDS
Iron
Chlorides
Nitrate
Phenolic Compounds
Hexa Chromium
Oil and Grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
ND
ND
1500
1.4
ND
Determinant
pH
BOD
COD
SS
TDS
Iron
Chlorides
Effluent
sump(Garcinia
Cambogia
Processing)
4.5
2272
20800
5096
54148
500
5500
ND
3.9
ND
1.6
Effluent Sump
near Poswellia
Seraeta)
Tolerance
Limit
6.9
1040
9520
85
2760
9
1200
ND
1.76
ND
ND
5.5-9.0
30
: Arjuna Natural Extracts Ltd.
: 6-8-05
: LAEC 268(Effluent from the drain)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
Effluent
from
the
drain
6.0
1300
2640
394
2809
307
320
Tolerance
limit
5.5-9
30
100
100
10
548
8
9
10
11
Nitrates as Nitrogen
Phenolic compounds
Hexa chromium
Oil & grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
0.08
0.353
ND
9.6
10
: Arjuna Natural Extracts Ltd. - Sludge
: 6-8-05
: LAEC AQ11(Sludge from soil in the rear side of industry)
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Determinant
Zinc
Iron
Lead
Cadmium
Copper
Nickel
Fluorides
Cyanides
Total Residual chlorine
Manganese
Unit
Sludge from soil in the rear side of
industry
mg/kg 486.8
,,
13150
,,
58
,,
BDL
,,
40
,,
39
,,
18.2
,,
BDL
,,
BDL
,,
42
NELKADIR BONE INDUSTRIES,EDAYAR
Name of the Industry
:Nelkadir Bone Industries
Date of Inspection
: 04-11-2004
Name of the Product/s
: Crushed bones and bone meal – 7.50 Mt/day
Process:
Raw bones are received in a hall of 4100 sqft. Hooves and horns are segregated and bones are
fed to the primary crusher where the bones will be made into pieces . These pieces are dried in
drying yard and the drilled bones are crushed in the disintegrator. Using the conveyer system
the crushed bones are passed to vibrator screens and the products are separated into crushed
bones, bone meal and sinews.
Findings:
The Unit has acquired the consent to establish and the consent to operate under the Air Act,
which is valid upto 31-12-2005. Even though this industry has not shown the use of boiler /
549
reactor, there exists a boiler/ reactor and the tallow is said to be separated and mixed with ash
and sold out as fertilizer. House keeping is satisfactory. They have erected a bio filter near to
the disintegrator and vibrator. The Bio filter is said to have equipped with wood coal and
water.
There is an open yard on the Southern side of the Unit, which according to the Unit Head was earlier
used for storing of bones. The unit should be instructed not to store bones in this open yard and to
store it in an enclosed area with proper roofing.
Recommendations:
1. All conditions stipulated in the consent under the Air Act issued by the KSPCB should
be strictly complied.
2. Chimney of height 15 metres from the ground level has to be provided, with sufficient
draft using blower / fan so as to have the appropriate exit velocity to provide
dispersion and dilution of the nuisance smell in the raw bone storage enclosure or
should provide appropriate bio-filter to contain the nuisance gas coming out from the
storage. The blower/fan should have a separate electricity meter to measure current
used.
3. There should not be any tallow extraction and any liquid effluent.
4. The storage area should not produce any leachate and the leachate should be treated
before discharge.
5. There should be confined rain water drain and no liquid effluent, leachate or
putrefiable matter should be carried by the drain. If such , the discharge from the
drains should be treated.
6. Raw materials should be protected from birds using net coverings.
7. The Unit shall not store bones in the open yard and shall be directed to store bones in
an enclosed area with proper roofing.
8. Raw bones brought to the Unit shall be processed on the same day itself.
9. Crushing of bones, storing, packing, loading and unloading shall be done in enclosed
area.
10. The Unit must be directed to submit ambient air quality analytical reports to the PCB
at least once in three months.
11. The Unit shall be directed to plant suitable species of tress along the periphery of the
factory premises, forming a green belt to improve the environment.
12. Effective Bio-filter should be installed for odour control within one month.
550
551
KAVERI BONE INDUSTRIES, EDAYAR.
Name of the Industry
: Kaveri Bone Industries
Date of Inspection
: 04-11-2004 & 11-04-2005
Raw Material
: Animal bones -6 tonnes / day
Name of the Products
: Crushed bone- 4 t/day
: Bone meal - 1.5 t/day
: Hooves- 0.05 t/day
: Horns- 0.05 t/day
: Sinews -0.25 t/day
Process:
Animal bones received will be stored in a storage area of capacity 100 tonnes. Bone received will be
fed to hammer mill where the bones will be crushed into pieces. Crushed pieces are dried and
introduced to vibrator screen where bone meal and sinews separated as final product. The raw
material is the bones collected from slaughter houses.
Findings:
The Unit has acquired the consent to establish from KSPCB and also the consent to operate under the
Air Act, which is valid upto 31-12-2005. The Unit is situated in a congested area and sufficient space
is not available other than the building where the processing is carried out. Stacked wet bones as raw
material is stacked and smell of volatile amines and putrefying gases originate creating nuisance. The
general house keeping is pathetic and the odour is intolerable. At the time of inspection, it is found
that the Unit has extensively sprayed an Insecticide called Hilfen to control flies. The stinking smell of
the bones coupled with the toxic pesticide made the inspection difficult. The inspecting team
experienced irritation in the eyes during the inspection. In order to avoid the flies, 500 ml of
insecticides after dilution is used for seven days spraying. This unit has erected exhaust fans on two
sides connecting it to the dwarf ducts. The unit is extracting tallow. The Unit is found storing in the
building terrace the solid waste from the process mixed with ash in gunny bags, causing serious air
pollution in the entire area and nauseating foul smell. The process of storing this is unhygienic and
against the consent directions.
Recommendations:
1. All conditions stipulated in the consent under the Air Act issued by the KSPCB should
be strictly complied.
2. Chimney of height 15 metres from the ground level has to be provided, with sufficient
draft using blower/ fan so as to have the appropriate exit velocity to provide dispersion
and dilution of the nuisance smell, in the animal bone storage enclosure or should
provide appropriate bio-filter to contain the nuisance gas coming out from the storage.
The blower/fan should have a separate electricity meter to measure current used.
552
3. There should not be any tallow extraction and any liquid effluent.
4. The storage area should not produce any leachate and such leachate, if any should be
treated before discharge.
5. There should be confined rain water drain and no liquid effluent, leachate or
putrefiable matter should be carried by the drain. If such , the discharge from the
drains should be treated.
6. Raw materials should be protected from birds using nets coverings.
7. Raw bones brought to the Unit shall be processed on the same day itself.
8. The Unit must be directed to stop forthwith spraying of toxic pesticides for controlling
flies and must confine to only bio-control of flies.
9. Effective Bio-filter should be installed for odour control within one month.
10. The Unit must directed to submit ambient air quality analytical reports to the PCB at
least once in three months.
11. The Unit must be directed to implement good house keeping systems.
12. The Unit should be directed to ensure better Occupational health and safety of its
workers.
13. The Unit has absolutely no facility to store waste and its safe disposal. The Unit is a
nuisance for the neighbouring community and the other industries. The Unit should be
directed to ensure total prevention of air pollution, odour control, safe storage and
disposal.
553
554
NATIONAL INDUSTRIES, EDAYAR
Name of the Industry
: National Industries, Edayar
Date of Inspection
: 04-11-2004
Name of the Product/s
: Animal bones- 4 tonnes / day
Products
: Crushed bone- 3 t/day
: Bone meal - 0.75 t/day
: Tallow- 80- 100 kg / day
: Sinews- 40 – 50 kg / day
: Organic fertilizers -100 kg/day
Process:
Raw bones received will be stored in a storage area and are dried by steam and tallow is
separated. Waste water from the boiler is mixed with ash and separated as organic fertilizer.
The bones are crushed into pieces. Crushed pieces are dried and introduced to vibrator screen
where bone meal and sinews are separated as final product.
Findings:
The Unit has obtained Air Consent valid upto 19-05-2005. This unit is situated very near to the river
Periyar and as a special condition no 16 of the consent there should be a buffer area of 20 meters to be
kept free from any construction and this unit has no construction upto approximately 10 mts but 20
mts is not left free. Wet bones as raw material is stacked in a floored and roofed shed with ventilation
around at top. This unit is using a boiler/reactor for steaming and the tallow extraction. General house
keeping is in a pathetic condition. There is no confined drain to tackle the rain run off. There is a drain
outside the unit, which is let into the River Periyar without any treatment. This is an unauthorized
outlet into the River Periyar and should be removed immediately.
Recommendations:
All conditions stipulated in the consent under the Air Act issued by the KSPCB should
be strictly complied.
Chimney of height 15 metres from the ground level has to be provided, with sufficient
draft using blower/ fan so as to have the appropriate exit velocity to provide dispersion
and dilution of the nuisance smell, in the raw bone storage enclosure or should
provide appropriate bio filter to contain the nuisance gas coming out from the storage.
The blower/fan should have a separate electricity meter to measure current used.
There should not be any tallow extraction and any liquid effluent.
The storage area should not produce any leachate and such leachate if any should be
treated before discharge.
555
There should be confined rain water drain and no liquid effluent, leachate or
putrefiable matter should be carried by the drain. If such , the discharge from the
drains should be treated.
Raw materials should be protected from birds using nets coverings.
Effective Bio-filter should be installed for odour control within one month.
Raw bones brought to the Unit shall be processed on the same day itself.
Crushing of bones, storing, packing, loading and unloading shall be done in an
enclosed area.
The Unit must be directed to submit ambient air quality analytical reports to the PCB
at least once in three months.
The Unit shall be directed to plant suitable species of trees along the periphery of the
factory premises, forming a green belt to improve the environment
The Unit must be directed to implement good house keeping systems.
The Unit should be directed to ensure better Occupational health and safety of its
workers.
Sign board showing the name of the Unit shall be displayed at the entrance of the site.
The Unit has not complied with Condition no. 16 viz., maintaining of a buffer of 20
metres wide land in the premises of the Unit in the side of Periyar River. This must be
complied forthwith and structures within this area shall be dismantled.
The unauthorized storm water outlet, which opens directly into the River Periyar, shall
be directed to be sealed forthwith.
556
557
YEOMAN BONE & ALLIED PRODUCTS, EDAYAR.
Name of the Industry
: Yeoman Bone & Allied Products
Date of Inspection
: 04-11-2004
Raw Materials
: Animal bones
Name of the Products
: Crushed bone 3 t/day
: Bone meal 750 kg /day
: Tallow 80- 100 kg / day
: Sinews 40 – 50 kg / day
: Organic fertilizers 100 kg/day
Process:
Raw bones received are stored in a storage area with flexible roofing material. Bones received
are dried by steam using a separate boiler. Crushed pieces are dried and introduced to vibrator
screen where bone meal and sinews are separated as final product.
Findings:
This unit is located very near to the River Periyar in the Edayar Industrial Area. This Unit has
acquired the consent to operate from KSPCB which is valid upto 31-12-2005.
Wet bones as raw material is stacked in a floored and roofed shed with ventilation around at top.
General house keeping is in a pathetic condition.. There is no confined drain to tackle the rain run off.
Insecticides viz., Nuvan is sprayed on the raw material for controlling flies. The intolerable odour of
bones coupled with the toxicity of the insecticides made the inspection next to impossible. The Unit is
alleged to have continuously dumping wastes and worms into the River Periyar. There is continuous
attack by birds due to improper storage of wet bones.
Recommendations:
All conditions stipulated in the consent under the Air Act issued by the KSPCB should
be strictly complied
Chimney of height 15 metres from the ground level has to be provided, with sufficient
draft using blower/ fan so as to have the appropriate exit velocity to provide dispersion
and dilution of the nuisance smell, in the raw bone storage enclosure or should
provide appropriate bio-filter to contain the nuisance gas coming out from the storage.
The blower/fan should have a separate electricity meter to measure current used.
There should not be any tallow extraction and any liquid effluent.
The storage area should not produce any leachate and such leachate, if any should be
treated before discharge.
There should be confined rain water drain and no liquid effluent, leachate or
putrefiable matter should be carried by the drain. If such , the discharge from the
drains should be treated.
558
Raw materials should be protected from birds using nets coverings.
Effective Bio-filter should be installed for odour control within one month.
Raw bones brought to the Unit shall be processed on the same day itself.
Crushing of bones, storing, packing, loading and unloading shall be done in an
enclosed area.
The Unit must be directed to submit ambient air quality analytical reports to the PCB
at least once in three months.
The Unit shall be directed to plant suitable species of trees along the periphery of the
factory premises, forming a green belt to improve the environment.
The Unit must be directed to implement good house keeping systems.
The Unit should be directed to ensure better Occupational health and safety of its
workers.
The Unit should be directed to maintain a buffer of 20 metres wide land in the
premises of the Unit in the side of Periyar River. This must be complied forthwith and
structures within this area shall be dismantled.
The Unit must be directed to stop forthwith spraying of toxic pesticides for controlling
flies and must confine to only bio-control of flies.
The unauthorized storm water outlet, which opens directly into the River Periyar, shall
be directed to be sealed forthwith.
Considering the immediate proximity of this Unit to the River Periyar and the track
record of the Unit in dumping wastes, worms and continuous attack by birds due to
improper storage of wet bones, the Consent to Operate must be reviewed and PCB
must immediately issue fresh directions to ensure that the Unit does not pollute the
River Periyar.
559
560
PANCHAMI AGRO INDUSTRIES, EDAYAR.
Name of the Industry
: Panchami Agro Industries
Date of Inspection
: 04-11-2004
Name of the Product/s
: Bone meal – 1050 tonnes / year
Process:
Raw dry bones brought from Wayanad area is crushed and bone meal is produced. Storage
and processes are in confined roofed area. Crushed pieces are dried and introduced to vibrator
screen were bone meal and sinews are separated as final product.
Findings:
This industry has acquired the consent to establish of the Board under the Air Act which is
valid upto 21-5-2006. General house keeping is seen satisfactory. There is no confined drain
to tackle the rain run off. Tallow operation is not carried out in this unit.
Recommendations:
All conditions stipulated in the consent under the Air Act issued by the KSPCB should
be strictly complied with.
Chimney of height 15 metres from the ground level has to be provided, with sufficient
draft using blower/ fan so as to have the appropriate exit velocity to provide dispersion
and dilution of the nuisance smell, in the raw bone storage enclosure or should
provide appropriate bio filter to contain the nuisance gas coming out from the storage.
The blower/fan should have a separate electricity meter to measure current used.
3
The storage area should not produce any leachate and such leachate, if any should be
treated before discharge.
4
There should be confined rain water drain and no liquid effluent, leachate or
putrefiable matter should be carried by the drain. If such , the discharge from the
drains should be treated.
5
Raw materials should be protected from birds using nets coverings.
6
Effective Bio-filter should be installed for odour control within one month.
7
The Unit must be directed to submit ambient air quality analytical reports to the PCB
at least once in three months.
8
The Unit shall be directed to plant suitable species of trees along the periphery of the
factory premises, forming a green belt to improve the environment.
9
The Unit must be directed to implement good house keeping systems.
561
10 The Unit should be directed to ensure better Occupational health and safety of its
workers.
SOUTH INDIAN FERTILISERS, EDAYAR
Name of the Industry
: South Indian Fertilisers, Edayar
Date of Inspection
: 04-11-2004
Raw Material
: Castor cake -1.675 t/day.
: Neem cake -1.275 t/day.
: Akshaya -1.8 t/day.
: Bone meal- 0.75 t/day.
: M.O.P- 0.2 t/day.
: Leather meal -0.3 t/day.
: Dolomite -1.5 t/day.
Product/s
: Castor Bone complex – 6 t/day
Process:
The raw materials are hand mixed according to the requirement and then powdered with
the help of a pulverizer and packed. There is no water usage and hence no liquid effluent.
Findings:
The Unit has stored large quantities of dolomite and press mud in a temporary shed without proper
roofing and flooring. The storm water drain adjacent to the temporary shed is in a dilapidated
condition. Possibility of dolomite and press mud getting washed away through the drain and
contaminating the ground water. The house keeping should be improved. The storm water drain is
seen not properly maintained and maintenance is required for the same. The front side storage yard is
having only temporary roof which should be made permanent so as not to damp the stored raw
material and products.
Recommendations:
All conditions stipulated in the consent of KSPCB should be strictly complied with.
Product / raw material should not entrain in the storm /rain water drain, and if so it should
be separately treated before discharge to outside.
The Unit must be directed to ensure proper house keeping systems, proper storage of raw
materials in a permanent shed and proper maintenance of drain with adequate treatment
prior to discharge.
AES INDUSTRIES, EDAYAR
Name of the Industry
: AES Industries.
562
Date of Inspection
: 4-11-2004.
Name of the Product/s
: Crushed Bone-3.5 t/day
Raw materials
: Raw Bone -7 tonnes /day.
Process:
Storing of Raw bone in godown, crushing in the machine, grading in different sizes, packing
of finished goods.
Findings:
1. According to the Consent issued to the Unit the raw materials and products should
be stored in a fully enclosed room.
2. No arrangement for venting out the smell from the raw bones.
3. The boiling of bone is carried out inside the unit in a crude method thus, creating
severe odour nuisance.
4. The raw bones brought to the Unit have not been processed on the same day.
Huge quantities of raw bones brought to the Unit on different dates are seen
heaped in a room, which is causing unbearable odour nuisance, which would keep
a normal human being at least 50 yards away. The odour is causing severe
nuisance to the nearby industrial units. The raw bones brought to the Unit are
neither de-greased nor processed on the same day thus resulting in huge backlog,
which is a serious violation of the Consent condition causing severe odour
nuisance.
5. There is no compartmentalization of the raw bones to de-grease the raw materials
on a first come first basis. The open exposure of the raw bones would make the
material wet especially during rainy season and by putrefication, the entire area
would be rendered unhealthy with worms.
Recommendations:
There should be fully confined storage of raw material and products.
Raw bones brought to the unit should be de-greased on the same day itself and
the de-greased bones should be kept in different compartments to ensure process on
first come first basis.
Animal bone raw (wet) or dried should be kept at a totally enclosed chamber,
to avoid bad smell in the air. A chimney of not less than 15 metres from the ground
level should be provided with artificial draft to expel the foul smell to the atmosphere
and a bio filter should be used to control the smell.
563
Tallow production should not be carried out in the unit.
New technology should be adopted for boiling the raw bones and to control odour
nuisance.
No solid waste should be burnt in open air.
The Unit must be directed to set up a treatment facility for waste water generated
during boiling of bones and obtain the necessary Consent under the Water Act.
The Unit should be directed to grow fast growing and long lasting trees in its premises
and all along its boundary and report planting of seedlings within one month to the
Pollution Control Board.
Conditions in the Consent order are being violated with impunity and hence the PCB
should issue directions for ensuring strict compliance of de-greasing and processing
of raw bones brought to the Unit on the same day itself, failing which the Unit must
be directed to be closed down.
564
565
COCHIN FERTILIZERS, EDAYAR
Name of the Industry
: Cochin Fertilizers.
Date of Inspection
: 4-11-2004.
Name of the Product/s
: Bone Meal-1600 kg/day
: Crushed Bone 2350kg/day.
Raw materials
: Raw Bone
Process:
Raw bones are segregated. Bones are steamed in the reactor for fat removal. Heated bone is
stored in godown. It is thereafter crushed and powdered.
Waste:
About -1400 litres effluent is generated per day during bone marrow extraction.
Findings:
Common chimney is provided for two reactors for venting the emission from fire wood firings.
The Unit has a valid consent upto 31-12-2004 for discharge of trade effluent into land for
percolation. The Unit has no treatment facility for the liquid effluent from the boiling of
bones.
A leak is noticed in the brick lining from the reactor to the chimney. Putrified effluent is seen
discharged from the Unit and is stagnant inside the compound of CMRL. The sample results
shows High BOD of 2060 mg/l and SS – 250 mg/l. This is a serious lapse on the part of the
unit and any such discharge should be contained and properly treated.
The Unit has not obtained consent under the Air Act.
There is no compartmentalization of the raw bones to de-grease the raw materials on a first
come first basis. The open exposure of the raw bones would make the material wet especially
during rainy season and by purification, the entire area would be rendered unhealthy with
worms.
Recommendations:
1. The unit should obtain Board’s consent under the Air Act immediately, failing which
it must be directed to be closed down.
566
2. Raw materials should be stored in confined store hygienically and a chimney should
be provided with forced drafts / use bio filter to control odour problems.
3. Raw bones brought to the unit should be de-greased on the same day itself and the degreased bones should be kept in different compartments to ensure process on first
come first basis.
4. New technology should be adopted for boiling the raw bones and to control the odour
nuisance
5. No solid waste should be burnt in open air.
6. The Unit must be directed to set up a treatment facility for waste water generated
during boiling of bones / waste water from the reactor and the Water Consent should
be modified accordingly.
7. The Unit should be directed to grow fast growing and long lasting trees in its premises
and all along its boundary and report planting of seedlings within one month to the
Pollution Control Board & LAEC.
8. Tallow should not be produced in the unit.
9. The leak in the brick lining to the Chimney should be rectified immediately.
567
568
569
COCHIN RUBBER INDUSTRIES, EDAYAR.
Name of the Industry
: Cochin Rubber Industries, Edayar
Date of Inspection
: 15.02.03 & 22.02.03
Name of the Product/s
: Crepe rubber
Raw materials
: Scrap rubber
Waste
7500L/day waste water generated is discharged into land after passing through rubber traps.
Process
Scrap brought to the factory is soaked in water to remove dirt and stones
The scrap is then pressed through a series of rollers with sprinkling of water.
The product is dried in air.
Findings/Recommendations :
1. Effluent under anaerobic condition is seen stagnant in ponds in the premises. There is
no facility for Effluent treatment. Scrap waste solids are dumped in the premises of
collection tanks. Due to putrefaction and open land discharge, the entire area is untidy.
Proper Effluent treatment plant should be set up for treating the effluent.
2. The consent issued by the Board under the Water (Prevention and Control of
Pollution) Act, 1974 has expired w.e.f. 31.12.04. It is shocking to note that in the
said, the KSPCB has allowed the Unit to discharge trade effluent into open land.
The Unit is therefore, discharging the trade effluent into open land including to the
adjacent low-lying areas.
3. Effluent from the premises is seen dumped in the adjacent property through an
underground pipe, where it gets stagnated.
4. The Unit should be directed to set up proper ETP system and obtain the Board’s
consent within one month’s time, failing the Unit shall be directed to be closed down.
The Unit must be directed to re-use the treated effluent and not to discharge it into the
open land.
The Unit must be directed to forthwith stop discharging untreated effluent into open
land and to the nearby low-lying areas.
Unit must be directed to improve the house keeping.
The Unit must provide a green belt, with fast growing and long lasting trees in its
premises.
570
Consented Parameters and Limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
Characteristic
Unit
pH
BOD(3Days at 270 C)
Oil and Grease
Suspended Solids
mg/l
,,
,,
Tolerance
limit
6-8
30
10
100
Colour Code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ sludge
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
Determinant
PH
BOD
COD
SS
TDS
Oil & grease
: Cochin Rubber industries.
: 15-2-05
: LAEC 5(Raw Effluent)
LAEC 102(Stagnant Effluent).
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
mg/l
Raw
Effluent
5.6
330
1456
96
1316
ND
Stagnant
Effluent
6.7
7600
18820
10192
760
ND
Tolerance
Limit
6-8
30
100
10
571
572
COCHIN LEATHER PRIVATE LIMITED
Name of the Industry
: Cochin Leathers Private Ltd
Date of Inspection
: 2-11-2004.
Name of the Product/s
: Wet hides
Raw materials
: Wet salted raw hides,
Lime,
Sodium sulphide,
Enzyme,
Ammonium sulphate,
Bate Enzyme,
Sodium Chloride,
Sulphuric Acid,
Chromium Sulphate,
Magnesium Oxide
Process:
The salted raw hides are soaked in water (to remove salt and dirt). After washing
liming is carried out to remove hair using lime and sodium sulphide solution. Thereafter flesh
in the skin is removed through a peeling process. The peeled skin is then washed and tanned
in drum by adding chromium sulphate. The final product is the semi-finished leather, also
known as wet blue hide, which is allowed to dry in stacks.
Waste:
The Unit generates 500 kg/month of sludge containing chromium. Chromium bearing sludge
is hazardous waste as per item No.30.1and 30.2 of schedule I. The waste is stored in a
temporary shed with roofing . The old stock has been dumped in the compound. The unit
discharges 48,000 liters of effluent per day after treatment. The flesh removed during the
process comes about 8 tones in every 15 days . A portion of the flesh is used in the Biogas
plant and the rest is sold to glue manufacturers.
Findings / Recommendations:
The Unit has a temporary facility for storage of hazardous waste. The unit has obtained
authorization under HW(M&H) Rules. The temporary shed is having roofing but sides are not
fully covered .Chromium Sludge is dumped in to this temporary shed, which would be
approximately 4 to 5 tones only. The old stock has been dumped nearby as landfill. Black
sludge is seen oozing out of the biogas plant. Heaps of soil (landfill) found very near to the
biogas plant and bubbles coming out of black sludge on one side and other side filled with
reddish colour waste water. Some oily substances is seen floating in the waste water. Sludge
has been camouflaged with soil to escape our attention at the time of the inspection. The
reasons could not be properly explained by the Unit officials. But, according to them, this
could be seepage from a nearby factory viz., Cochin Minerals & Rutile Ltd.
573
Mosquitoes are seen breeding in the solar evaporation tanks. One of the tank is seen to have
reddish colour water.
Though ETP was working at the time of our inspection, considering the present state of the
plant, it appears that this has not been functioning regularly and hence suggest further
inspection without notice at a later point in time.
The unit employees 13 permanent and 5 casual labourers .The flesh removed after the fleshing
process is stored inside the units. The general house keeping is pathetic. The waste water is
removed to the solar evaporations tanks /ETP through drains.
Sides of the temporary sheds are to be covered to prevent rain water entering into the shed .
Surprise inspection to be conducted to assess whether the ETP is functioning properly.
The labourers should be provided with gloves, masks, boots, other safety gadgets, common
uniform etc.
Appropriate instructions should be issued to ensure scientific house keeping.
The unit discharges 48,000 liters of water after treatment from ETP into the River Periyar.
This water should be re-used rather than discharging into the River Periyar. There is no device
to measure the quantity discharge from the unit.
The effluent outlet to the Periyar is not visible and hence it should be kept in an elevated
position. The treated effluent, now being discharge to the River Periyar should be let out
through a manhole within the precincts of the Unit.
At present the fleshing waste is removed only once in 15 days. The units should be asked to
remove at lesser intervals to prevent decay and foul smell.
The unit should remove the old stock of chromium bearing sludge, which is presently dumped
as landfill and transfer it to the temporary storage facility within 30 days from 15 th November,
2004.
The unit should be directed to comply with various provisions of labour welfare legislations.
A drain is passing through the boundary of this Unit (adjacent to the ETP outlet). This drain
carries yellowish colour water. The Kerala State Pollution control Board shall ascertain the
source of the drain and stop the effluent from entering the River Periyar forthwith.
The KSPCB will ensure that the unit will comply with all the conditions stipulated in the
consent order.
The unit should ensure confined storm water drain and if pollutants are mixed in the storm
water, it should be treated properly.
The unit should implement good house keeping systems.
574
Green belt of fast growing and long lasting pollutant resistant plants should be planted where
ever possible .A minimum of 15 to 20 plants should be planted, depending on the availability
of space.
We could see plastic bags and other waste burnt in the open yard. This should not be allowed.
This report is forwarded to the Kerala State Pollution Control Board to take necessary action
and issue notice to the unit with a copy marked to the LAEC for compliance within a specific
time frame.
The Pollution control Board will take samples from the Unit ie. from Effluent outlet,
hazardous wastes etc. and will mark a copy of the Laboratory Result to the LAEC.
The unit depends on the River Periyar for its water requirements and it is situated in the banks
of the River.
The unit should adopt best available technology with a view to reduce consumption of raw
materials ie. water, chromium etc.; waste minimization, odour control, waste reuse and
recycling .
Consented Parameters and Limits.
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
7
8
9
Characteristic
PH
Suspended Solids
BOD(3Days at 270 C)
Oil and Grease
Chlorides
Hexavalant Chromium
Total Chromium
Sulphides
Boron
Unit
mg/l
,,
,,
,,
,,
,,
,,
,,
Tolerance
limit
6-9
100
30
10
1000
0.1
2
2
2
Colour Code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
: Cochin Leathers Private Ltd
575
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
5
6
7
8
9
10
: 22-2-05
: LAEC 17 – Raw Effluent
LAEC 150- Treated Effluent
: Central Laboratory, Gandhi Nagar.
Determinant
Unit
PH
BOD
COD
SS
TDS
Chlorides
Sulphate
Hexa chromium
Total Chromium
Oil & grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
mg/l
Raw
Effluent
7.3
1900
4000
4304
8332
5600
1350
ND
5.9
1.1
Determinant
Unit Raw
effluent
Final
effluent
1
2
3
4
5
pH
BOD
SS
Chlorides
Hexa
Chromium
Total
Chromium
Oil &Grease
Boron
Sulphides
7.5
mg/l 1500
,,
1515
,,
5900
,,
ND
7
8
9
100
1000
0.1
2
10
Solar
evaporation
tank
7.0
2500
3540
13800
ND
Tolerance
limit
7.0
140
69
1100
ND
Solar
Evaporation
tank
10.0
2004
966
1400
ND
6-9
30
100
1000
0.1
,,
25.9
1.01
0.09
ND
2
,,
,,
,,
ND
ND
412
ND
ND
2.0
ND
ND
889
ND
ND
440
10
2
2
Source
Date of sample collection
Sample Identification No
Name of the Lab
Tolerance
Limit
6-9
30
: Cochin Leathers Private Ltd
: 27-11-04
: LAEC 22(Raw effluent)
LAEC 24(Final effluent)
LAEC 25(Solar evaporation tank)
LAEC 26(Solar evaporation tank).
:Central Laboratory, Gandhi Nagar.
Sl.
No.
6
Treated
Effluent
7.23
104
320
163
3504
1800
550
ND
ND
ND
: Cochin Leather Industries
: 27-11-04
: 7(Sludge from Soil)
8(Sludge from hazardous waste storage tank).
: Central Laboratory, Gandhi Nagar.
576
Sl.
No.
1
2
3
4
5
6
7
Determinant
Zinc
Iron
Lead
Mercury
Cadmium
Nickel
Total Chromium
Unit
Sludge
from Soil
mg/kg 86.3
4300
189
0.05
6.3
47.9
3200
Sludge from HW
storage tank
87.5
2665
154
0.03
ND
55.8
3300
TMS LEATHERS, EDAYAR
Name of the Industry
: TMS Leathers, Edayar.
Date of Inspection
: 2-11-2004.
Name of the Product/s
: Wet hides
Raw materials
: Wet salted raw hides,
: Pelvit-ISA
: Lime,
: Sodium sulphide liquor
: Lezyme-A
: Ammonium sulphate
: Chromino –XT,
: Sulphuric Acid
: Lunacid –AP
: Basic Chromium sulphate
Process:
The salted raw hides are soaked in water (to remove salt and dirt). After washing liming is
carried out to remove hair using lime and sodium sulphide solution. Thereafter flesh in the
skin is removed through a peeling process. The peeled skin is then washed and tanned in
drum by adding chromium sulphate. The final product is the semi-finished leather, also
known as wet blue hide, which is allowed to dry in stacks.
Waste:
The sludge containing chromium @ 530 kg is generated per month Chromium is hazardous
waste as scheduled 1: Item 30.1 and 30.2.
577
The chromium sludge is stored in gunny bags in a roofed temporary shed. The sides are
covered with plastic sheets.
The waste water from soaking, fleshing and all other process are directed to ETP and solar
evaporation ponds through drains inside the units. There are such five solar evaporation ponds
in functioning condition. The salt recovered from the solar tanks are sold as fertilizer.
The flesh removed after the fleshing process is stored inside the units. According to the unit,
the flesh so removed, once it reaches 10 tonnes is transported to Tamilnadu where the same is
used by glue manufacturers.
Findings / Recommendations:
The unit generates chromium bearing residue and Chromium bearing sludge. It does not have
authorization under HW (M&H) Rules 1989. According to the proprietor he has applied for
the authorization.
The unit has consent under water (P&C of Pollution) Act valid up to 31-12-2004.
The unit has displayed board at the front gate giving details of the hazardous waste.
The unit is now permitted to discharge 1.20 lakh liters of waste water to River Periyar after
treatment from ETP.
There are 25 employees in the unit .They are not covered under ESI and PF Acts.
We could only find very few gunny bags of chromium sludge and it is not known where the
unit had dumped the hazardous waste since its inception. There has been a change in
ownership and hence no satisfactory explanation could be elucidated from the present owner.
The factory roof viz., truss is seen corroded and it requires immediate repair.
The drains inside the unit is not maintained properly and is seen damaged at several places
thereby obstructing the free flow of effluent.
The solar evaporation tank is likely to be flooded during rainy season and the process waste
water will flood and mix with the storm water and drain into the River Periyar.
Almost 1.50 tonnes of sodium formate, which according to the unit was used as raw material
earlier, is lying in the Unit. This is in a damp condition. This should be scientifically
disposed of.
Water is seen accumulated in a pit / pond adjacent to the ETP. This pit / pond should be
utilized for rain water harvesting and to meet the water requirements and not for any other
purpose.
The Pollution control Board will take samples from the Unit ie., from Effluent outlet,
hazardous wastes etc. and will mark a copy of the Laboratory Result to the LAEC.
578
The unit should adopt best available technology with a view to reduce consumption of raw
materials ie, water, chromium etc.; waste minimization, odour control, waste reuse and
recycling .
The Pollution Control Board should dispose of the application for authorization under HW
(M&H) Rules 1989 forthwith and direct the unit to install chromium recovery plant within 90
days from 15th November 2004.
All the sides of the temporary shed used for storing Chromium sludge in gunny bags should
be directed to be covered with plastic sheets to prevent rain water entering into the shed
through sides.
At present the fleshing waste is removed only once in 15 days. The units should be asked to
remove at lesser intervals to prevent decay and foul smell.
The unit should be directed to comply with various provisions of labour welfare legislations.
The KSPCB will ensure that the Unit will comply with all the conditions stipulated in the
consent order.
The unit should ensure confined storm water drain and if pollutants are mixed in the storm
water, it should be treated properly.
Green belt of fast growing and long lasting pollutant resistant plants should be planted where
ever possible. A minimum of 15 to 20 plants should be planted, depending on the availability
of space.
The Unit should implement good house keeping systems.
We could see plastic bags and other waste burnt in the open yard. This should not be allowed.
This report is forwarded to the Kerala State Pollution Control Board to take necessary action
and issue notice to the Unit with a copy marked to the LAEC for compliance within a specific
time frame.
The Pollution control Board will take samples from the Unit ie. from Effluent outlet,
hazardous wastes etc. and will mark a copy of the Laboratory Result to the LAEC.
This unit was further inspected on 9-6-05 and the committee records the following findings.
Findings:
Chromium recovery system is installed and commissioned for the removal and recovery of
Chromium. Chrome tanning effluent is segregated, passed through traps for removing solid
materials and collected in a collection tank of approximately 3 days holding capacity. The
effluent is then treated with Magnesium oxide in a reactor with stirring for 7 hour. The reactor
capacity is 5000-litres. After reaction, the slurry is taken to another vessel and treated with
sulfuric acid to form Chromic acid, which is stored in an overhead tank for reuse. The
579
supernatant from the reactor is taken to equalization tanks for further treatment. According to
the company authorities, about 20% of the raw Chromium the Chromium, recovered from the
effluent, meets requirement.
During inspection one more equalization tank is seen constructed and commissioned.
Aerator in second equalization tank is not seen working .No chemical treatment is given .Bio
towers (2 towers) which were not in line is now under commissioning. All the solar
evaporation ponds are found to contain storm water. For distributing the soaking effluent into
solar ponds inlet-chamber has been constructed. Foul odour existed in the premises of the
outlet point in the river. Effluent samples are collected for checking the efficiency of
chromium recovery system.The result shows no chromium even in raw effluent. The unit is
therefore asked to explain the reason and Board may follow up the matter. The lab report of
the chromium recovery plant is given below.It is to be born in mind that this unit is situate in
the upstream of the Pathalam bund .
Consented Parameters and Limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
Characteristic
Unit
PH
BOD(5Days at 200 C)
Total Suspended Solids
Sulphides(as S)
Hexavalent Chromium as (Cr +6)
Oil and Grease
Mg/l
,,
,,
,,
,,
Tolerance
limit
6.5-9
30
100
2
0.1
10
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
Determinant
: TMS Leathers, Edayar
: 27-11-04
: LAEC 27(Raw effluent)
LAEC28(After alum treatment)
LAEC 29 (Final effluent)
:Central Laboratory, Gandhi Nagar.
Unit
Raw
After
Final
Tolerance
effluent alum
effluent Limit
treatment
580
1
2
3
4
5
6
7
8
9
PH
BOD
SS
Chlorides
Sulphides
Hexa Chromium
Total Chromium
Oil &Grease
Boron
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
PH
BOD
COD
Zinc
Lead
Mercury
Cadmium
Copper
Nickel
Chloride
Cyanide
Hexa Chromium
Total Chromium
Manganese
Titanium
Free available Chlorine
Name of the Lab
Determinant
Zinc
Iron
Lead
Mercury
Cadmium
11.1
2500
1950
600
492
ND
0.18
ND
ND
7.1
560
12
900
51.8
ND
ND
ND
ND
6.6
140
10
550
2.0
ND
ND
ND
ND
: TMS Leathers, Edayar
: 22-11-04
: TMS 2(Outlet)
: Central Laboratory, Gandhi Nagar.
Determinant
Source
Date of sample collection
Sample Identification No
Sl.
No.
1
2
3
4
5
mg/l
,,
,,
,,
,,
,,
,,
,,
Unit
Outlet
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
5.2
1.8
22.4
0.17
ND
ND
ND
0.01
0.064
600
ND
ND
0.014
0.19
ND
ND
Tolerance
Limit
6.5-9
30
0.1
: TMS Leathers, Edayar
: 27-11-04
: 9(Sludge)
10(Ash sample).
: Central Laboratory, Gandhi Nagar.
Unit
Sludge Ash
sample
mg/kg 34.4
487
8515
8975
124
1803
0.02
0.15
4.3
51.6
6.5-9
30
100
2
0.1
10
581
6
7
Nickel
Total Chromium
26.2
2940
45.9
640
PRIMA AGRO LIMITED, EDAYAR.
Name of the Industry
:Prima Agro Limited, Edayar.
Date of Inspection
: 23-11-2004.
Name of the Product/s
: Cattle Feed 200 t/day
Raw materials
: Jowar, Maize, rice bran, deoiled cake,
trace mineral mix and molasses.
Process:
The feed ingredients as per the formulae specification is weighed and fed to the grinder. The
ground batch is charged in to the batch mixer and micro nutrients are added. The product mix
is then passed through molasses blender. The finished products are in pellet or mash form.
The mash is mixed with steam for conditioning . The mix is conveyed in to the pellet press for
getting the product in pellet form. The cooled pellets are sieved to remove the fines and
packed .
Findings:
1. The company is having valid consent up to 31-12-05 to operate baby boiler (fire wood
fuel) and DG set of 250 KVA.
2. The whole processing area is enclosed.
3. A dust collector is provided to the grinder but inplant air pollution control measures
need special attention for worker protection.
4. The height of the vent pipe attached to the DG set is inadequate and is to be increased
to 3.9 m above the roof level of DG room.
Recommendations:
Inplant measures for Air Pollution Control is to be provided.
Height of the vent pipe of DG set is to be raised to 3.9 m above roof level.
Contents of the storage tanks are to be displayed with capacity
The company should be directed to plant fast growing long lasting plants around its
premises and directed to report the compliance to the Pollution Control Board within
one month.
The Unit be directed to grow curtain plants (jaiva veli or bio fencing) all along the
boundary at a height of 20 feet and start maintaining the plant.
582
House keeping is to be improved.
ENGINEERING UNITS.
The following engineering industries/workshops were inspected by Local Area Environmental
Committee. The problems identified in respect of these industries are similar and identical. Therefore
the recommendations are applicable to all these Units and the Board may issue appropriate directions
to these units for ensuring compliance of the provisions of the Environment Protection Act.
Sl No. Name of the Industry Date of Inspection Nature of Production
1.
2.
3.
JMJ Machines and
Equipments, Edayar
16-11-04
Repair work of Rubber
cutting machines
Star Engineers, Edayar
16-11-04
Repairing works.
16-11-04
Production and repair of mild
steel engineering components.
Accurate Components
and Tools, Edayar
4.
Damodar Industries,
Edayar
16-11-04
Production of M.S Bolts,
Wires and Studs
5.
SBN Engineering Works,
Edayar
16-11-04
Welding shop
6.
Rini Engineering Works,
Edayar
16-11-04
Production of furniture
and smokeless oven
7.
Steel Engineering Works,
Edayar
16-11-04
Welding Workshop
8.
Adithya Engineering Co.,
Edayar
16-11-04
Production of Industrial
Machines.
9.
Southern Carbon (P) Ltd.,
Edayar
16-11-04
Construction and
Commissioning of Biomass gasifier
10.
V More Engineering,
Edayar
16-11-04
Welding and grinding
11.
K.K. Engineering, Edayar
16-11-04
Welding and Grinding unit
12.
Manoj Engineering Works,
Edayar
16-11-04
Welding Workshop.
Poduval Industries, Edayar
16-11-04
Assembling of brushless Alternator
and Kirloskar D.G Sets.
13.
583
14.
15.
Southern Engineering Corp.,
Edayar
18-11-04
Fabrication work.
Techs India Company,
Edayar
Fabrication of storage tanks,
Chimneys.
18-11-04
16.
New Tech Company, Edayar. 18-11-04
Transformer body building.
17.
Lakshmi Electricals, Edayar. 18-11-04
Electrical Workshop.
Recommendations:
Used / spent oil generated by the use of oil to lubricate machines and /or from the generator
have to be collected and disposed as per the Hazardous Waste (Management and Handling)
Rules 1989. The small industries having small quantity of such used / spent oil should make a
collective effort to collect such oil at different intervals and sell it to authorized recyclers .
CRUSHER UNITS
The following Crusher units were inspected by Local Area Environmental Committee. The problems
identified in respect of these units are similar and identical. Therefore the recommendation hereby
made apply to all these units and the Board may issue appropriate directions to these units for ensuring
compliance of the provisions of the Environment Protection Act.
Sl No. Name of the Industry
Date of Inspection
Nature of Production
1.
National Granites, Edayar.
18-11-04
Crushing of Granites.
2.
Kummencheriyil Metals,
Edayar
18-11-04
Crushing of Stones.
3.
Hill Rock Metals, Edayar
18-11-04
Crushing of Stones.
4.
Edayar Metals, Edayar
18-11-04
Crushing of Stones.
5.
Vijay Associates, Edayar.
18-11-04
Crushing of Granites
Recommendations:
The units should provide adequate Air
pollution control measures and obtain the
Board’s Consent under the Air Act.
584
Green belt not seen provided. The units
should be directed to grow fast growing
and long lasting trees all along the
boundary and report planting of seedlings
within one month to the Pollution Control
Board.
Grow curtain plants (jaiva veli or bio
fencing) all along the boundary at a
height of 20 feet and start maintaining the
plant.
Provide water storage tank having a
minimum capacity of 12,000 liters for
secondary crushers and 20,000 liters for
primary crushers within 15 days.
V.R.WOOD ART LTD
Name of the Industry
:V.R.Wood Art Ltd.
Date of Inspection
: 9-03-05
Name of the Product/s
: Treated and semi finished rubber
wood plants
Process:
Production Process involves Chemical treatment of plants of rubber wood in pressurized reactor,
drying and cutting to required size.
Findings:
1. Total consumption of water is to the tune of 5000 litres per day.
2. The unit has obtained the Board’s consent under the Air Act valid upto 31-12-05.
3. The unit has a boiler fired by firewood and chimney of about 20 metres height above
ground level is provided to the boiler.
4. A DG set of 380 KVA is installed in open area of the factory building. Height of the
vent pipe is below the roof level. Acoustic enclosure is not provided to the D.G Set.
5. Suction arrangement is provided for containing dust generated from the various
cutting and plaining equipments installed in the processing area through dust
collection system. The height of the vent pipes of the dust collection system is about 9
metres and 11 metres above ground level, which is inadequate. The exhaust of the two
dust extraction systems connected to 25 HP and 40 HP blowers containing the
turnings of wood and dust particles are passed through cyclones and the wood
particles are collected in an enclosed room from where it escapes through the door
585
opening into the open area in the factory premises. The wood dust heaped in open area
is creating air pollution problems to the people residing in the southern side of the
factory and vegetation. The nearby residents also complained against the dust
pollution.
6. A dust collector is seen in the factory premises which, is reported to be under failure
and not connected to the system.
7. Exhaust of the Wide Belt Sander machine containing fine dust particles is connected
to a bag filter in open area. The cleaning of the bag is reported to be done after each
batch of operation by manual shaking. The dust removed from the bag is likely to
create fugitive emissions as the area is open.
8. Boiler ash is disposed on the adjacent land in northern side of the factory. There are
chances of run off into the river during rain.
9. A compound wall of about 1.25 - 1.50 metres is provided all around the factory.
Measures directed to be implemented to contain pollution:
1. The unit should provide adequate air pollution control measures at the various sources
of dust generation. The Unit should contain the dust heaped in open area. The
efficiency of the dust collection system should be enhanced by adding a second line
dust collector of adequate capacity. All the dust collection equipments should be
roofed and enclosed.
2. The height of the vent pipe of the dust collector is to be increased to the required level.
3. The boiler ash generated should be disposed of in secured landfill.
4. Fast growing trees are to be planted along the periphery of the factory to develop a
thick green belt.
5. Storm water drain is to be protected and solid wastes are to be disposed of properly.
6. The waste water from washbasin containing food particles should be treated before
discharging.
7. Green belt not seen provided. The unit is directed to grow fast growing and long
lasting trees all along the boundary and report planting of seedlings within one month
to the Pollution Control Board.
8. Grow curtain plants (jaivaveli or bio fencing) all along the boundary at a height of 20
feet and start maintaining the plants.
9. Acoustic enclosure to be provided for the D.G. Set. It has to be provided within one
month.
10. At present the Unit does not have adequate Air pollution control systems. The
Consent order has not specified the rate of emission from the chimneys I & II. The
Consent order has to be revised by the Pollution Control Board immediately.
586
11. The dust generating points requires to be enclosed failing which, the Unit should be
directed to provide scrubbing system to suppress the dust particles.
G.K.GASES & CHEMICALS,EDAYAR.
Name of the Industry
:G.K.Gases & Chemicals,Edayar
Date of Inspection
: 31-12-2004.
Name of the Product/s
:Anhydrous Ammonia.
:Ammonium hydroxide.
Raw materials
:Anhydrous ammonia gas.
Process:
Anhydrous ammonia gas brought from FACT and Mangalore are stored in tankers for filling in
cylinders as per requirement. Ammonia liquor is prepared by dissolving ammonia gas in water and
stored.
Findings:
1. The unit has obtained Board’s consent under the Air Act for filling of 900 tonnes per
month of ammonia gas and for the production of 120 KL /month of liquor ammonia.
A DG Set of 7 KVA is also operated.
2. Source of water is well and water consumption reported by the firm is 7000 litres /day.
Water used for cooling the absorber is recirculated. Wild bush growth is noticed in the
rear yard.
3. House keeping is very poor.
4. Ammonia gas escaping during the absorption is scrubbed with water in another
absorber.
5. There is no proper drain for storm water.
Recommendation:
1. House keeping is to be improved
2. Storm water drain with delay pond is to be provided.
3. Wild bushes in the rear yard to be cleared forthwith.
TAMIL NADU AMMONIA PVT. LTD, EDAYAR.
587
Name of the Industry
:Tamil Nadu Ammonia Pvt. Ltd
Edayar
Date of Inspection
: 31-12-04
Name of the Product/s
: Ammonia bottling – 150 ammonia cylinders of 50
kg capacity each per month.
: Ammonia hydroxide-10000litre/month
Raw materials
: Anhydrous ammonia gas.
Process:
Storage of compressed ammonia gas in tankers, ammonia gas filling in cylinders and preparation of
ammonium hydroxide by absorbing ammonia in water.
Findings/ Recommendations:
1. The unit has obtained Board’s consent under the Air Act valid upto 31-12-2005 for
storing 3.28 t/day of anhydrous ammonia and 328.76 litre per day of liquor ammonia.
2. Cooling water used in ammonia absorber is recirculated.
3. Vent pipe provided to the absorber.
4. The unit has got valid licence from the controller of explosives to store compressed
gas in cylinders.
5. House keeping is to be improved.
NEPTUNE READYMIX CONCRETE PVT. LTD, EDAYAR.
Name of the Industry
: Neptune Readymix Concrete Pvt. Ltd.
Edayar.
Date of Inspection
: 18-11-2004 / 12-05/05 & 25/05/05
Name of the Product/s
: Readymix concrete - 3000-3500 m3 /
month.
Raw materials
: Cement, 20 mm Jelly, M sand, water
and Naphthalene based compound as
admixture.
Process:
The raw materials are transferred automatically through a closed system into the pan mixer and the
product concrete mix is transferred to transit mixer drum and transported to site.
588
Waste:
The sources of waste water are curing tank, floor washings, jelly washings, washing of truck carrying
concrete mix and canteen. There are four outlets discharging waste water without any treatment into
the River Periyar. Solid waste of concrete mix is seen dumped in adjacent land, roadside and river
bank near Pathalam bridge
Findings:
The Unit is on the banks of the River Periyar.
Concrete mixing is automatic and is sophisticated. An enclosed building is provided for storing
cement bags from where cement is transferred through a closed system into two overhead silos of
1000 tonnes capacity.
The source of water is open well in the premises of the unit near river. Water requirement according to
the company is 15000 litres /day. Water is used for processing, jelly washing, floor washing, water
spraying and domestic purposes.
There are 4 outlets discharging waste water into the River Periyar, without any treatment. The outlets
are from canteen, curing tank, open yard and storm water drain. Crushed granite and sand is washed
in the open area and the waste water is discharged directly into the River. Also no treatment is
provided for canteen effluent. The unit has not obtained Board’s consent under the Water Act.
Solid waste of concrete mix is seen dumped in adjacent land, roadside and river bank near Pathalam
bridge creating nuisance to the nearby units and the public.
The unit has obtained the Board’s consent under the Air (Prevention &Control of Pollution) Act valid
up to 31-12-2005.
Recommendations:
1. The Waste water from the process and washing contains heavy metals since the raw
material used is Cement, which contains all types of heavy metals.
2. The effluent now discharged is without any treatment directly into the River Periyar.
In view of the presence of heavy metals in the effluent, the Unit should forthwith set
up Effluent Treatment Plant and obtain Consent under the Water Act.
3. During the subsequent inspection on 25th May, it is found that the Unit is in the
process of installing an ETP. The efficacy of the ETP has to be verified by the
Pollution Control Board before issuing the Consent under the Water Act. It is
shocking that the Unit has been functioning for more than 2 years without consent.
4. All wash water streams are to be collected and reused after treatment
5. Conditions stipulated in the Board’s consent under the Air (Prevention and Control of
Pollution) Act should be complied with.
6. The Unit must be directed to grow fast growing and long lasting trees in its premises
to form a green belt and report planting of seedling within one month to the Pollution
Control Board.
7. Waste concrete mix should not be dumped in the open places near the River Periyar.
COCHIN SURFACTANTS (P) LTD, EDAYAR.
589
Name of the Industry
: Cochin Surfactants Pvt. Ltd.
Date of Inspection
: 5-1-05
Name of the Product/s
: Activated carbon 5 t/day
Raw materials
: Coconut shell 15 t/day.
Diesel 80 litre /day.
Process:
Activated carbon is manufactured from coconut shell charcoal using steam and air in Rotary kiln.
Waste:
9kg/day silica containing impurities removed from the kiln forms the solid wastes, which is disposed
for land filling. The waste oil from DG Set is stored in drums for disposal to authorized dealers. Back
wash water from water softener and boiler blow down constitute 500 litre of waste water discharged
into land.
Findings:
1. The unit has obtained consent under the Air Act valid upto 31-12-2005 for operating
diesel fired boiler 2 t/hr and DG Set of 180 KVA.
2. Chimney of 30 meters height is provided to the boiler stack.
3. The unit has obtained consent under the Water (Prevention and Control of Pollution)
Act 1974 for discharging 1500 litres /day of effluent into a percolation pit through two
outlets. The consent is valid upto 31-12-2004.
4. Waste water treatment facility is not provided in water softener plant.
5. The unit has not applied for authorization under HW Rules for disposal of used / waste
oil.
Recommendations:
1. The unit should obtain Authorisation under the HW Rules for disposal of used / waste
oil.
2. The Unit must be directed to renew the Consent under Water Act, which has expired
on 31-12-2004.
3. Dust collection system should be provided for controlling the fugitive emissions from
the product crushing and sieving operations.
4. Inplant air pollution control should be provided for controlling the dust emanation
from the product crushing and classifying plant
5. Waste water including back wash of water softener should be treated.
6. Steps may be taken for reusing boiler blow down.
7. Fast growing plants are to be planted along the periphery of the unit for greenbelt
development.
590
Consented Parameters and Limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
Characteristic
pH
BOD(3Days at 270 C)
Suspended Solids
Oil and Grease
Unit
mg/l
,,
,,
Tolerance
limit
5.5-9
30
100
10
GEE YEE CONCRETE BLOCKS,EDAYAR.
Name of the Industry
: Gee Yee Concrete Blocks,Edayar
Date of Inspection
: 18-11-2004
About 1000 interlocking bricks are produced per day. Raw Materials used are cement, sand, aggregate
and water. There is no discharge of waste water and no hazardous waste generation.
CONSTRUCTION MATERIALS COMPANY , EDAYAR.
Name of the Industry
: Construction Materials Company ,Edayar
Date of Inspection
: 18-11-2004
Interlocking tiles are produced. Connected load is 65 Hp. Unit is functioning in an enclosed building.
The Production capacity is 600 sq.ft /day of paving tiles. Source of water is well. Raw Materials used
are cement, sand, aggregate, red oxide and water. Water requirement for production is 500 litres / day
and 2000 liters /day for curing purpose. There is no waste water discharge and no hazardous waste
generation.
INDO GERMAN CARBONS LTD, EDAYAR.
Name of the Industry
: Indo German Carbons Ltd, Edayar
Date of Inspection
: 05-01-05
Name of the Product/s
: Activated Carbon- 10.2 t/day
Raw materials
: Coconut shell Charcoal 30 t/day.
Furnace Oil 300 litre /day.
Process:
591
Activated carbon is produced by admitting steam and air through charcoal in a Rotary kiln. The
product is crushed and sieved.
Waste:
20kg/day clinker removed from the Rotary kiln containing mainly silica and iron in the solid waste,
which is bagged and stored in the company premises reportedly for land filling.
Source of water is well and Periyar river. Water consumption is 60.8 kl/day (process- 800
litre /day, Boiler feed – 50 kl/day, domestic- 10 kl/day). 1000 L/day waste water generated
from boiler blow down and water softener plant are discharged into land for percolation. Used
oil and sludge from furnace oil tank are stored in drums for disposal.
Findings:
1. The unit has obtained consent under the Air Act for operating two boilers(2.5
t/hr)kilns (2 nos) and generator set of 500 KVA , valid upto 31-12-2005.
2. A common chimney of 30 meters height is provided to both the boilers. The company
is also having a drier stack and D.G stack
3. Air pollution control measures are not provided for controlling fugitive emission from
the product crushing and classifying plant.
4. The waste water from the backwash of water softener, canteen and boiler blow down
are discharged without any treatment.
5. There are three storm water outlets into the river.
6. The unit has obtained consent under the Water (Prevention and Control of Pollution)
Act 1974 upto 31-12-2004.
7. Process plant for producing charcoal from coconut shell is also seen installed.
8. The unit is reported to have applied for authorization under HW Rules.
Recommendations:
1. The unit should obtain authorization under HW Rules for the disposal of used / spent
oil. The application pending with the PCB should be disposed of on merits
immediately.
2. The Unit must be directed to renew the Consent under Water Act, which has expired
on 31-12-2004.
3. The charcoal production unit is to be included in the consent and proper air pollution
control measures are to be implemented.
4. Air pollution control measures / dust collection systems are to be provided for fugitive
emissions from product crushing and classifying plant.
5. Steps for reusing boiler blow down may be initiated.
6. Adequate treatment should be provided for the canteen effluent and softener back
wash.
7. The Unit must be directed to grow fast growing and long lasting trees in its premises
and all along its boundary to develop a thick green belt. The unit must be directed to
report on the planting of seedlings within one month to the Pollution control Board.
8. House keeping is to be improved.
592
M.G.RUBBERS,EDAYAR
Name of the Industry
: M.G.Rubbers,Edayar
Date of Inspection
: 16-11-2004
Name of the Product/s
: Reclaimed rubber powder
Raw materials
: Tyre and tread rubber waste.
Findings:
The unit produces reclaimed rubber powder by shearing and powdering of tyre and tread rubber
waste. Water required for cooling the machines is recirculated. The sides of the unit is enclosed.
Chances of Pollution problems are less.
Recommendation:
The unit should obtain the Board’s consent under the Air (Prevention and Control of
Pollution) Act 1981.
House keeping is to be improved.
MANORAMA CARBONICS, ELOOR
Name of the Industry
: Manorama Carbonics, Eloor
Date of Inspection
: 9-3-05
Name of the Product/s
: Liquid CO2 filled cylinders
Raw materials
: CO2 gas.
Process:
Carbon dioxide gas brought to the factory through pipeline is purified by passing it through a
scrubber containing KmnO4 solution, compressed, filtered, dehydrated and liquefied to
produce liquefied Carbon dioxide.
Waste:
An open well in the premises is the source of water. Cooling water is recirculated after
cooling in a cooling tower. Water contaminated with used oil from compressor and waste
water from carbon dioxide scrubber are discharged into the land without any treatment.
According to the factory authorities, used oil is collected in barrel for further disposal.
Findings/ recommendations:
593
1. Effluent containing oil is seen discharged into land. An Oil trap system for separation
of oil is to be provided.
2. A Genset of 90 KVA is installed in the unit.
3. The unit has not obtained consent under the Water (Prevention and Control of
Pollution) Act 1974, Air (Prevention and Control of Pollution) Act 1981 and
authorization under Hazardous Waste (Management and Handling) Rules 1989 for
disposal of used / waste oil. The Unit should obtain consent under the Water & Air
Act and Authorisation under the HW Rules.
4. Waste oil should be disposed only to the registered recycler.
ORGANO FERTILISERS (INDIA) PVT. LTD.
Name of the Industry
: Organo Fertilisers India Pvt. Ltd.
Date of Inspection
: 04-11-2004; 10/11/2004; 27/04/2005
25/05/2005
: Karthika brand Calciphos organic
Fertilizers (of different NPK values)
Name of the Product/s
and
10 mt/day
Raw materials :
KCPL process waste
Mustard cake
Neem cake
Bone meal
Leather meal
Potash
Magnesium Sulphate
1500 mt /year
500
,,
250
,,
250
,,
250
,,
50
,,
40
,,
Process:
The process waste of Kerala Chemicals & Proteins Ltd. (KCPL) having 15% phosphate
and 20% calcium is mixed with bone meal, mustard cake, neem cake, leather meal,
magnesium sulphate, potash in specified proportions. The end product having 5%
Nitrogen, 10% Phosphate, 5% potash is packed in 50 kg bags under the name of Karthika
organic mixture and sold. The raw material load is taken from the KCPL by this unit.
They are using machineries like pulveriser, disintegrator and the expeller for producing
the product.
Findings:
1. The raw material is dumped on ground, which is having high nutrient content and can
reach the River Periyar by leaching through the ground or by the rain run off.
2. There is no confined raw material storage for the bulk of the input.
3. The Board has not issued to the Unit the consent to operate under the Air Act since
the construction of the raw material storage is not completed with roof.
594
4. It is understood that the PCB had issued Notices to the Unit time and again to
complete the work and obtain the consent of the Board. On 13-5-2003, the unit has
requested time of six months for the construction of the confined storage. On
inspection, it was found that they have not started any work of construction and it was
informed by them that they will be able to complete the work by February–March
2005. The recent inspection on 25th May, 2005, revealed that the construction is still
not completed. The Unit is taking the PCB for a ride by mere promises.
5. No confined drains were seen around the unit for effectively tackling the rainwater
runoff.
Recommendations:
1. The industry should obtain all the required consent from the KSPCB under Air Act &
Water Act and comply with all the directions and conditions including the submission
of the periodical returns.
2. The Unit must be directed to provide a Bank Guarantee of Rs. 2.00 lacs as security for
completing the construction of confined raw material storage with roofings and for
obtaining the required Consent under Air Act & Water Act within 15 days time,
failing which the Unit should be directed to be closed down. Bank Guarantee for this
Unit should be insisted for this Unit having regard to its track record of not keeping up
the promises.
3. Raw material storage should be in an enclosed building under permanent roof and
impervious floor. No leachate should be produced by the storage of neither the raw
material nor the finished product. Raw material should not be stored or detained for
long period of time so as to get it putrefied by dampness, as is happening at present.
4.
Chimney of height 15 metres from the ground level has to be provided, with sufficient
draft using blower/ fan so as to have the appropriate exit velocity to provide dispersion
and dilution of the nuisance smell, in the raw bone storage enclosure and should
provide appropriate bio-filter to contain the nuisance gas coming out from the storage.
5. Confined drain should be constructed around the unit and it should only carry the rain
run off and at no circumstances the putrefiable raw material or the products should be
carried by the drains and in such case the run off should also be subjected to treatment.
6. Nuisance due to smell while storing of raw material / product should be avoided
through Best available technology.
7. The surrounding premises should be kept hygienic.
8. The Unit should be instructed to maintain good house keeping and to control odour.
9. The unit should be directed to grow fast growing and long lasting trees inside its
premises and report planting of seedlings within one month to the Pollution Control
Board.
595
PAULOSE AND MATHEWS PVT. LTD, ELOOR.
Name of the Industry
: Paulose and Mathews Pvt.Ltd, Eloor
Date of Inspection
: 9-3-05
Name of the Product/s
: Liquid CO2
Process:
CO2 gas brought through pipe lines from FACT is scrubbed in KmnO4 solution to remove the
impurities, passed through ceramic filter, carbon filter and compressed in various stages and
filled in cylinders for despatch.
Findings/ Recommendations:
1. Source of water is well and municipal water supply. Cooling water is recirculated after
cooling in a cooling tower.
2. Effluent containing oil is seen discharged in the premises and collected in a
percolation tank of about 5 feet depth in the premises. Oil trap system for the removal
and recovery of used oil is to be provided.
3. One Generator set of 125 KVA is installed in the factory.
4
The unit has not obtained the Board’s consent under the Air (Prevention and Control
of Pollution) Act 1981 and Water(Prevention and Control of Pollution) Act 1974 and
authorization under Hazardous Waste (Management and Handling) Rules 1989 for the
disposal of used oil / spent oil (category 5.1).
5
The Unit must be directed to obtain the above Consent under Air & Water Act and
Authorisation under the HW Rules.
POPULAR CARBONICS, ELOOR.
Name of the Industry
: Popular Carbonics, Eloor
Date of Inspection
: 9-3-05
Name of the Product/s
: Liquid CO2
Process:
Carbon dioxide gas brought to the factory through pipeline from FACT is purified by passing
it through a scrubber containing KmnO4 solution, compressed, filtered, dehydrated and
liquefied to produce liquefied Carbon dioxide.
Waste:
596
Cooling water is recirculated after cooling in a cooling tower. Water contaminated with used oil from
compressor and waste water from carbon dioxide scrubber are discharged into the land without any
treatment.
Findings/ recommendations:
1. Effluent containing oil is seen discharged into land. An Oil trap system for separation
of oil is to be provided.
2. The unit has not obtained consent under the Water (Prevention and Control of
Pollution) Act 1974 and authorization under Hazardous Waste (Management and
Handling) Rules 1989 for disposal of used / waste oil.
3. The Unit should obtain consent under the Water Act and Authorisation under the HW
Rules.
4. Used oil should be disposed only to the registered recycler.
PREMIUM FERRO ALLOYS LIMITED, EDAYAR.
Name of the Industry
:Premium Ferro Alloys Ltd, Edayar
Date of Inspection
:23-11-2004.
Name of the Product/s
: Mild steel ingots
CTD bars
Steel Scrap
Raw materials
: M.S.Scrap
Silico Manganese
Aluminium Scrap
Steam coal
Process:
About 80% of the raw material M.S. Scrap is imported. The production process involves melting of
the scrap in induction furnace to produce ingots and then re-rolling of the ingots to get CTD bars.
Waste:
The impurities in the molten mass from the furnace forms top layer and is removed and quenched to
form slag. About 500 kg slag is generated per day and the mode of disposal is land filling.
Findings:
The company has obtained Board’s valid consent under the Air (Prevention and Control of
Pollution) Act 1981 upto 31-12-2005. There are three chimneys ie., for emissions from the
induction furnace, re-rolling furnace, oil mill and 125 KVA DG set.
About 10200 litres of water is consumed per day for cooling and domestic purpose. Source
of water is open well and Kerala Water Authority. Cooling water is reported to be recirculated.
597
Imported MS Scrap is used as raw material. The company claims to have permit from the
Director General of Foreign Trade (DGFT) for import of MS Scrap.
The hazardous waste (slag) is reported to be disposed for land filling. A part of the waste is
seen dumped in open area near the process plant.
Recommendations
The company claims that the slag does not fall under Sl. No. 13.1 read with 27.1 of
Hazardous Waste (M&H) Rules. This is a matter to be verified after analyzing the slag by
taking samples. PCB to ensure this without further delay. Authorisation, if any, under the
HW Rules, if required should be directed to be obtained.
Proper treatment of cooling water should be ensured for complete recirculation of cooling
water.
The Unit should be directed to grow fast growing and long lasting trees in its premises
and all along its boundary to form a green belt and report planting of seedling within
one month to the Pollution Control Board and LAEC.
House keeping is to be improved.
THRIVENI CARBONICS, ELOOR.
Name of the Industry
: Thriveni Carbonics, Eloor
Date of Inspection
: 9-3-05
Name of the Product/s
: Liquid CO2
Process:
Carbon dioxide gas brought to the factory through pipeline is purified by passing it through a
scrubber containing KmnO4 solution, compressed, filtered, dehydrated and liquefied to
produce liquefied Carbon dioxide.
Waste:
Cooling water is recirculated after cooling in a cooling tower. Water contaminated with used
oil from compressor and waste water from carbon dioxide scrubber are discharged into the
land without any treatment.
Findings/ recommendations:
Effluent containing oil is seen discharged into land. An Oil trap system for separation
of oil is to be provided.
The unit has not obtained consent under the Water (Prevention and Control of
Pollution) Act 1974 and authorization under Hazardous Waste (Management and
Handling) Rules 1989 for disposal of used / waste oil.
The Unit should obtain consent under the Water Act and Authorisation under the HW
Rules.
598
Waste oil should be disposed only to the registered recycler.
MARK RUBBER PRODUCTS, EDAYAR.
Name of the Industry
: Mark Rubber Products, Edayar
Date of Inspection
: 7-3-05
This is a tread rubber manufacture unit, established in 1990. According to the factory
authorities the production rate is 150t/yr of tread rubber.
Findings :
1. The unit has not obtained the Board’s consent under Air Act. The company
authorities informed that the Unit had obtained water consent ,but now they are not
discharging any waste water and hence the consent is not renewed.
2. Water consumption is reported to be 500 litres per day. Source of water is open well
and KWA. The cooling water used for cooling purpose is returned to the well and
recirculated.
3. The unit has one mixing mill installed in a separate room and air pollution control
equipments are not provided for dust control.
4. Partial greenery exists around the factory.
5. House keeping is very poor. Waste water from bathroom is not disposed properly.
Recommendation:
The unit should apply and obtain the Board’s consent under the Air (Prevention and
Control of Pollution) Act 1981
Air pollution control equipments should be provided to the mixing mill.
The Unit must be directed to grow fast growing and long lasting trees in its premises
and all along its boundary to form a green belt.
House keeping should be improved. The waste water from bathrooms are to be
disposed properly.
MARK POLYMERS, EDAYAR.
Name of the Industry
Date of Inspection
:Mark Polymers, Edayar.
: 7-3-05
599
This is the sister concern of Mark Rubber Products.
At present, the Unit is not functioning. It is informed by M/s Mark Rubber Products that the
unit was sealed due to Revenue recovery.
MARK PRE-TREADS, EDAYAR.
Name of the Industry
:Mark Pre-treads, Edayar.
Date of Inspection
: 7-3-05
Raw material
: Compounded rubber strips.
Product
: Pre- cured tread rubber - 300 kg/day.
Findings:
1. The unit has not obtained consent under the Air(Prevention and Control of
Pollution)Act 1981 .
2. The Proprietor of the unit complained of severe odour nuisance from the nearby bone
meal unit viz., M/s Sigma Fertilizers, which is unbearable and requested LAEC to
initiate necessary action for controlling the odour problems.
3. Source of water is municipal water supply. Water used for cooling purpose is
recirculated. Water consumption, as reported by the unit is 500 litres per day.
4. A thermic fluid heater fired by diesel is operated in the unit.
5. Rubber cutting waste is seen heaped in the premises, which according to the
proprietor is returned to the recycler for producing reclaimed rubber.
6. Adequate greenbelt is not provided.
Recommendations:
1. The unit should provide adequate air pollution control measures and obtain the
consent of the Board under the Air (Prevention and Control of Pollution) Act 1981.
2. The Unit must be asked to collect used/spend oil and dispose of the same to the
authorized refineries.
3. House keeping is to be improved.
4. The Unit must be directed to grow fast growing and long lasting plants in its premises
to form a green belt.
MILTON RUBBERS, EDAYAR.
Name of the Industry
:Milton Rubbers, Edayar
Date of Inspection
: 7-3-05
Product
: Tread rubber.
600
Findings:
1. This is a tread rubber manufacturing unit. Dust collector is not provided to the mixing
mill for dust control.
2. Source of water is well in the factory premises. Cooling water is partially discharged.
3. There is no green belt in the factory premises.
4. House Keeping is not satisfactory.
Recommendations :
The unit should obtain Board’s consent under Air (Prevention and Control of
Pollution) Act 1981 .
The Unit should provide dust collection system to the mixing mill.
Cooling water recirculation arrangement is to be improved.
The Unit must be directed to grow fast growing and long lasting plants in their
premises to form a green belt.
House keeping is to be improved.
PERIYAR POLYMER PRODUCTS, EDAYAR.
Name of the Industry
: Periyar Polymer Products, Edayar
Date of Inspection
: 7-3-05
Name of the Product/s
: Rubber moulded goods, flaps.
Process:
Rubber sheet, fillers and rubber chemicals are mixed in the mixing mill to form rubber compound,
which is extruded and cut.
Findings:
1. The unit is having a baby boiler. Stack height provided is inadequate . The unit has no
valid consent under the Air (Prevention and Control of Pollution) Act 1981. The
proprietor informed that the unit had obtained Air Consent some years ago but has not
renewed for the successive terms reportedly due to the hike in consent fee.
2. Source of water is CMRL. Cooling water is recirculated.
3. Flap waste is sold to recyclers.
4. Green belt exists.
5. Well in the premises is not being used reportedly due to contamination.
Recommendations:
1. The unit should obtain the Board’s consent under the Air (Prevention and Control of
Pollution) Act 1981 .
601
2. Air Pollution control measures are to be provided.
3. House keeping is to be improved.
NEELIMA CHEMICALS, EDAYAR.
Name of the Industry
: Neelima Chemicals, Edayar
Date of Inspection
: 7-3-05
Purification of organic solvents by distillation and packing of solvents, sulphur etc are done on job
basis.
Findings:
1. The unit is functioning in an enclosed area.
2. Cooling water is recirculated.
3. House keeping is not satisfactory.
Recommendation:
1. Vessel washings and distillation residue should be collected separately and treated
before discharging.
2. The Unit must set up an Effluent treatment plant and obtain Consent under the Water
Act
3. Waste plastic bags/ containers should be segregated and disposed to recyclers.
4. House keeping should be improved.
SS CHEMICALS, EDAYAR.
Name of the Industry
: SS Chemicals, Edayar.
Date of Inspection
: 7-3-05
It is informed that the operation of the unit was suspended six months back.
Product
: Sodium silicate.
Year of establishment is 1996.
Source of water is bore well and purchase from outside.
CHEMI TECH ENGINEERS
Name of the Industry
: Chemi tech Engineers
Date of Inspection
: 7-3-05
Name of the Product/s
: Sodium silicate- 300 t/month.
Raw materials
: Caustic soda lye, Quartz powder and
Bleach liquor
602
Process:
Finely ground quartz is dissolved in caustic soda lye in autoclave at a pressure of 9 kg/sqcm. The
product is sodium silicate, which is taken into a storage tank.
The Unit is reportedly using sodium silicate glass instead of caustic soda for producing sodium
silicate. This fact has not been reported to the KSPCB in the Application for the Consent.
Sodium silicate glass is dissolved in water at about 3 atmosphere pressure in a digester for 4
to 5 hours. Bleach liquor is added to remove dark colour and soda ash is added to increase
the alkalinity. The product liquid sodium silicate is stored in tanks for sale.
Findings:
1. The unit has no valid consent under the Air (Prevention and Control of Pollution) Act,
1981 and Consent under the Water (Prevention and Control of Pollution) Act 1974
2. There is a boiler fired by firewood. Thermic fluid heater is used for heating the
reactor.
3. A DG Set of 63 KVA is installed in an enclosed room. Height of the vent pipe is 1.5
metres above the roof level.
4. Water requirement is 10 KL / day and the source is from M/s SS Chemicals.
5. Waste water from washings is seen collected in a collection tank inside the factory.
6. The change in raw materials from Caustic soda to Sodium silicate glass is not reported
to the Pollution Control Board.
Recommendation:
The unit should obtain the Board’s Consent under the Air (Prevention and Control of
Pollution)Act 1981 and Consent under the Water(Prevention and Control of
Pollution)Act 1974.
Measures for fugitive emission control from raw material storage area should be
provided.
Waste water from plant washings is to be treated with a proper ETP system.
The unit should obtain authorization under HW Rules for the disposal of used /spent
oil.(category 5.1)
STERLING INDUSTRIAL CHEMICALS & ALLIED INDUSTRIES PVT. LTD, EDAYAR
Name of the Industry
: Sterling Industrial Chemicals &
Allied Industries Pvt. Ltd, Edayar
Date of Inspection
: 05-01-05
Raw materials / Product/ Process
:
603
Purification of various solvents by distillation, purification of solids by recrystallization, preparation of
chemical/ reagent of organic and inorganic solids and liquids and packing are being done in this unit.
Ammonium hydroxide is also produced by absorbing anhydrous ammonia in water.
Findings/ Recommendations :
Source of water is well in the premises and about 3700 litre water is used per day for
production and washing purposes.
An effluent treatment plant consisting of effluent collection tank, mixing channel,
settling tank and sludge drying bed is constructed.
The unit has obtained Board’s consent under the Water Act for discharging 3700 litre /
day effluent into land for percolation.
Source of hazardous waste is the ETP sludge. The unit should obtain authorization for
the disposal of ETP sludge under Hazardous Waste (Management and Handling)
Rules 1989.
Natural greenbelt exists around the boundary of the unit.
House keeping is good.
Consented Parameters and Limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Characteristic
pH
Suspended Solids
Oil and Grease
Hexavalant Chromium
Total Chromium
Manganese (as mn)
Nickel (as ni)
Copper(as cu)
Zinc (as zn)
Cadmium (as cd)
Lead
Mercury
Cyanide
Total heavy metals
Unit
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
Colour code
Red: Pollutants not conforming to the standards stipulated in consent order.
Pink: Pollutants in effluent not included in consent order
Tolerance
limit
6-8.5
30
10
0.1
2
2
2
2
5
0.2
0.1
0.01
0.2
7
604
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
: Sterling Industrial chemicals.
: 5-1-05
: LAEC 14(Chemical namely Enviro floc used for chemical
precipitation
Name of the Lab
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Sl.
Determinant
Unit Chemical namely Enviro floc used for
No.
chemical precipitation
1
PH
1.4
2
TDS
mg/l 622030
3
Iron
256250
4
Lead
79.8
5
Copper
2.4
6
Nickel
2.59
7
Arsenic
ND
8
Chlorides
136057
9
Sulphate
ND
SRI SRINIVAS ROLLER FLOUR MILLS (P) LTD., EDAYAR.
Name of the Industry
:Sri Srinivas Roller Flour Mills Pvt. Ltd., Edayar.
Date of Inspection
: 8-4-05
Name of the Product/s
: Maida, Atta, Rava
Raw materials
: Wheat
Process:
Raw wheat is destoned, washed with water and air cleaned. The dust laden air is passed
through cyclones and vent out through ducts. There are 4 exhaust ducts. The quantity of wash
water is very less and is discharged into land for percolation.
Findings/Recommendations:
1. The unit is having an old treatment system consisting of an aeration tank and settling
tank, which is in an abandoned condition. The unit should be directed to have a
efficient ETP to treat effluent. The consumption of water of the unit is quite high and
605
2.
3.
4.
5.
6.
the claim of the unit that its water requirement is negligible cannot be accepted while
appreciating the need for cleaning the wheat.
Waste of wheat and wheat products are burnt in the premises.
The Unit is generating huge quantity of wheat waste which is at present burnt in open
premises. The unit should be directed to provide a bio gas plant to dispose of wheat
refraction(waste).
The unit has consent under Air(Prevention and Control of Pollution)Act 1981.
There are three generator sets of 125 KVA. The height of the vent pipes of the dust
collector are below the roof level and fugitive emissions are noticed.
The unit should be directed to take steps to control fugitive emission and increase the
height of the vent pipes .
7. The unit surrounding is kept untidy and unbearable foul smell from decaying waste is
felt. The unit should be directed to improve its house keeping forthwith .
8. Greenbelt should be developed around the periphery of the unit. Banana plantation
may be developed for the proper utilization of treated effluent.
NEW KERALA RUBBER UDYOG. & NEW KERALA POLYMERS , EDAYAR.
Name of the Industry
: New Kerala Rubber Udyog & New Kerala
Polymers , Edayar.
Date of Inspection
: 7-4-05
Name of the Product/s
: Chappall Sheets
Raw materials
: Natural rubber , Reclaimed rubber ,
Crumb powder , Clay powder, Sulphur, Stearic acid,
Mixing oil , Accelerator and DNPT blowing agent.
Process:
The raw materials are Natural rubber is mixed with fillers and chemicals in kneader
and sheeted out in mixing mill. This is pressed in hydraulic press under temperature and
pressure to get the final product.
Findings/ Recommendations:
1. Two units are functioning in the same premises.
2. Process area is enclosed on three sides .
606
3. Water used for cooling the machinery is returned to the well for recirculation. There
is fugitive emission in the process .
4. The factory premises are shabby with oil barrels and raw rubber particles.
5. Both the units have not obtained Board’s consent under the Air(Prevention and
Control of Pollution)Act 1981. The units should be directed to obtain consent under
Air(Prevention and Control of Pollution)Act 1981.
6. The unit should provide adequate cooling water recirculation arrangements.
7. Should plant fast growing trees along the periphery of the premises.
8. House keeping is to be improved.
SHALIMAR POLYSACKS, EDAYAR.
Name of the Industry
: Shalimar Polysacks, Edayar.
Date of Inspection
: 8-4-05
Name of the Product/s
: Polythene sacks
Raw materials
: HDPE Fabric, Ink and Yarn
Process
Polythene sacks are produced by cutting fabric using electronic cutting machine and stitching
the sides. Printing is also done .
Findings /Recommendations:
1. Cutting waste is seen stored in the processing hall for disposal to recyclers. There is no
other solid , liquid and gaseous pollutant.
2. It is a tiny unit . The cutting waste should be disposed to recyclers and not allowed to
be spread over by neglecting its disposal.
KUMARSONS WIRE PRODUCTS, EDAYAR.
Name of the Industry
: Kumarsons wire products, Edayar.
Date of Inspection
: 8-4-05
Name of the Product/s
: Nails
Raw materials
: Wire Rods.
Process:
607
Nails are produced by drawing wire rods. Production capacity is 400 kg per day. The factory
started functioning on 1-1-2004. Scale removed from the rod surfaces and waste husk used for
polishing are the source of solid waste. There is no other solid, liquid or gaseous waste.
Findings/recommendations:
The unit is a tiny industry. The process is taking place in a confined room. No
pollution that can take cognizance by PCB. However to keep the industrial belt healthy and
environmentally friendly the unit may be directed to plant long lasting trees to form a green
belt.
MACFIELD BEVERAGES (INDIA ) PVT. LTD.
Name of the Industry
: Macfield Beverages (India ) Pvt. Ltd.
Date of Inspection
: 8-4-05.
Name of the Product/s
: Aerated water
Raw materials
: Raw water from well and
Carbon dioxide
Process:
The factory is producing 300 cases of carbonated water(soda) /day. Raw water
from the well in the factory premises is treated by adding alum and passing
through carbon filter, sand filter and disinfector. Treated water is chilled and
carbon dioxide gas is passed in glass bottles . Product is sold under the trade
name Bagpiper . Before use the bottles are washed using vim powder and rinsed
with water. The effluent from bottle washing is discharged into an underground
tank from where the overflow reaches the adjacent land. The tank is completely
filled . Sludge is seen accumulated on land near the effluent tank.
Findings /Recommendations:
1. The unit should obtain the Board’s consent under the Water Act.
2. The unit is discharging the water used for washing the bottles which contains vim
powder and other detergents etc. Provide treatment to the effluent before discharging.
The effluent shall not be discharged into the adjacent land.
3. The unit should improve house keeping.
4. To keep the industrial belt healthy and environmentally friendly the unit may be
directed to plant long lasting trees to form a green belt.
5. The unit should dispose of the waste of fillers in an environmentally friendly manner.
608
KUNNATH CHEMICALS PVT LTD, EDAYAR.
Name of the Industry
: Kunnath Chemicals Pvt Ltd, Edayar.
Date of Inspection
: 29-11-04 & 23-03-2005
Name of the Product/s
: Bleaching Powder
Raw materials
: Hydrated lime
Chlorine
Process:
Bleaching powder is produced by passing Chlorine gas through hydrated lime
under vaccum. Source of water is well and KWA. Water is consumed mainly for
cooling, boiler feed and domestic purposes.
Findings :
The unit has obtained the Board’s consent under the Water (Prevention and Control of
Pollution) Act 1974, and Air (Prevention and Control of Pollution) Act 1981 upto 31-122004 and 31-12-2005 respectively.
The boiler (firewood- fuel) stack is having a height of 10 metres above ground
level.
A generator set of 82.5 KVA is installed in the unit.
Water scrubbing is provided for the Chlorine gas escaping through the vaccum arrangement.
Cooling water is recirculated.
Existing lime kiln is not seen operating and is reported to be not in use as the
raw material hydrated lime is brought from outside.
House keeping is very poor. The raw material lime is seen dumped in open area and product
bleaching powder is spilled over the packing area.
This Unit is adjacent to Merchem Ltd., Edayar unit. The sludge from the backyard of this
Unit was collected for analysis. The results show as under:
Zinc – 448.4 mg/kg
Iron – 86535 mg/kg
Lead – 337.4 mg/kg
Cadmium
– 9.3 mg/kg
Total Chromium – 1344 mg/kg
Manganese
– 1098.70 mg/kg
The Effluent treatment facility in the Unit is found not in operation. The ETP
tanks are in a totally neglected condition. The effluent is discharged into the
open land.
609
When LAEC inspected the Unit, the team found an attempt by the Unit to
camouflage the sludge by spreading red earth. The sludge is now covered with
red earth.
The Unit was inspected again on 23-03-05 on receiving a complaint from the Unit
regarding the escape of Chlorine gas through the exhaust fan of Merchem Ltd,
Edayar. The Chairman, LAEC along with member, Mr. M. Asokan and board
officials consisting of Smt. Chitrakumari.D, EE, KSPCB, Mr. K.S. Soman, AEE and
Mr. KVMV.Shanavas, Asst. Scientist reached the spot to ascertain the situation.
It is found that there was no emission of Chlorine gas from M/s Merchem Ltd, Edayar as
alleged by M/s Kunnath Chemicals Pvt.Ltd. The source of emission of the Chlorine gas is the
bleaching powder packing area especially the vent PVC pipe line attached to the bleaching
powder collection tank of M/s. Kunnath Chemicals Pvt. Ltd. itself.
Recommendations:
1. The Unit must be directed to set up and maintain proper ETP within one month’s time
and to obtain consent under the Water Act .
2. The Unit must be directed to remove the entire hazardous sludge lying scattered in its
backyard and now covered with red earth and keep it in safe storage in secured
landfill.
3. House keeping is to be improved.
4. Raw material lime powder and product are to be stored in enclosed areas.
5. Adequate facility is to be provided for treating the effluent.
6. Open burning of waste materials should be stopped and waste plastic materials are to
be disposed to recyclers.
7. The Unit must be directed to provide all precautionary measures for preventing the
release of Chlorine gas into the surrounding area.
8. The Unit must further be directed to refrain from dumping of bleaching powder in
open area and to prevent the escape of Chlorine gas.
9. The Unit must be directed to plant fast growing and long lasting trees and provide an
extensive green belt in its premises.
Colour code
Red: Pollutants not conforming to the standards .
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
: Kunnath Chemicals Pvt Ltd, Edayar.
: 29-11-04
: LAEC 15(Sludge from stagnant pond of effluent in premises
of Kunnath Chemicals near Merchem Edayar.)
: Central Laboratory, Gandhi Nagar.
610
Sl.
No.
1.
2
3
4
5
6
Determinant
zinc
Iron
Lead
Cadmium
Total Chromium
Manganese
Source
Date of sample collection
Sample Identification No
Name of the Lab
Unit
Sludge from stagnant pond of effluent in
premises of Kunnath Chemicals near
Merchem Edayar
mg/kg 448.4
86535.0
337.4
9.3
1344.0
1098.7
: Kunnath Chemicals Pvt Ltd, Edayar.
: 29-11-04
: LAEC 37(Effluent stagnated in premises of Kunnath
Chemicals near Merchem Edayar)
: Central Laboratory, Gandhi Nagar.
Sl.
Determinant
Unit Effluent stagnated in premises of Kunnath
No.
Chemicals near Merchem Edayar
1.
pH
4.83
2
SS
mg/l
22
3
TDS
866
4
Zinc
ND
5
Chlorides
230
6
Sulphates
18
7
Phenolic Compounds
0.1
8
Oil and grease
ND
Source
: Kunnath Chemicals Pvt Ltd, Edayar.
Date of sample collection : 29-11-04
Sample Identification No : LAEC 36(Waste water from Recirculation tank( discharge)),
LAEC38(Treated effluent from collection tank.)
Name of the Lab
: Central Laboratory, Gandhi Nagar.
Sl.
No.
1
2
3
4
5
Determinand
PH
SS
TDS
Chlorides
Residual Chlorine
Unit
mg/l
Waste water from
Recirculation tank
(discharge)
6.9
18
668
160
ND
SURYA RUBBERS ,EDAYAR
Name of the Industry
: Surya Rubbers ,Edayar
Treated effluent
from collection tank.
7.03
14
1100
280
ND
611
Date of Inspection
: 6-4-05
This is a used pet bottle crushing unit. Pet bottles collected from the local area is clean, if
required and then crushed in a small crusher. The Industry is not causing any pollution
problems. The units should be directed to grow fast growing and long lasting trees all along
the boundary
ALWAYE FIBRE INDUSTRIES,EDAYAR
Name of the Industry
: Alwaye Fibre Industries,Edayar
Date of Inspection
: 6-4-05
Name of the Product/s
: Fibre Glass doors
Raw materials
: Glass Fibre , resin
The industry is engaged in the production of Fibre Glass doors. They produce
about 75 doors in a month. Glass Fibre , resin etc are mixed and moulded to get
the required product. The industry is not generating any liquid effluent or
emission. The unit should be directed to grow fast growing and long lasting trees
all along the boundary
LAKSHMI CHEMICAL INDUSTRIES, EDAYAR.
Name of the Industry
:Lakshmi Chemical Industries, Edayar.
Date of Inspection
: 6-4-05
Name of the Product/s
: Calcium Carbide
Raw materials
: Lime shell , Charcoal , Carbon waste
and Leco.
Process:
The raw materials are mixed in prescribed proportion and is charged into the Electric Arc
Furnace. At about 2000 0C temperature the materials combines and forms molten Calcium
Carbide.
Findings/Recommendations:
1. The industry is not generating any liquid effluent . During inspection the industry was
seen locked.
2. The furnace is provided with a chimney having height 30 M above ground level which
is adequate as per norms .
612
3. Major pollutant in the emission is suspended particulate matter .
4. The unit has consent under Air Act valid upto 31-12-2005.
5. Air monitoring has not been done. Air monitoring is to be done to ensure that air
emission does not exceed the standard limits.
6. House keeping should be improved.
7. The unit should be directed to grow fast growing and long lasting trees all along the
boundary
WELCOME ENTERPRISES , EDAYAR.
Date of Inspection
: 6-4-05
This is an SSI unit engaged in the production of Zinc oxide. The unit is found to be
permanently closed .
Microtrol Sterilisaton Services (P) Ltd, Edayar.
Name of the Industry
:Microtrol Sterilisaton Services Pvt.Ltd, Edayar.
Nature of Activity
: Sterlisation of different items like disposable medical
devices , pharmaceutical raw materials, spices etc.
: 6-4-05
Date of Inspection
Process:
The materials to be sterilized are loaded into chambers . It is then closed and a vaccum is
created by using vaccum pump. A mixture of Ethylene oxide and Carbon dioxide is released
into the chamber. The material is kept for about 6 to 8 hours. After the desired exposure time
the gas is evacuated from the chambers and the material is taken out .
Findings/Recommendations:
1. Unit has provided a chimney having height 11.4 metre above ground level for making
emission from the sterilization chamber.
2. An air wash facility is provided before releasing the gas through the chimney .
3. Another chimney having height 2.3 M above roof level is provided for the 125KVA
diesel generator .
4. Good House keeping. Comparatively a good Unit.
5. The units should be directed to grow fast growing and long lasting trees all along the
boundary
613
HARISREE TECHNICALLY SPECIFIED BLOCK RUBBER P. LTD, EDAYAR
Name of the Industry
Date of Inspection
: Harisree Technically Specified Block
Rubber P. Ltd, Edayar.
: 7.4.05
Name of the Product/s
: Crumb rubber(ISNR)
Raw materials
: Scrap rubber
Findings / Recommendations:
1.
2.
3.
4.
5.
6.
About 1,30,000 litre/day water is consumed for processing and domestic purposes.
Water source is Periyar river.
The waste water generated is discharged into Periyar river.
The quantity of effluent is reported as 1,00,000 litre/day.
The unit has obtained Board’s consent under the Water act expired on 31.12.2004.
The factory was not working. It was reported that production had been stopped with
effect from 10th January 2005 due to raw material shortage and labour problem.
7. The effluent treatment system is inadequate and is to be augmented. The unit has
provided three earthern ponds for the retention of the effluent.
8. Wood Gasifier is used for heating the drier. The wood tar produced during gasification
is reportedly disposed for making/repairing country boats.
9. Should obtain the Board’s consent under the Air(Prevention and Control of
Pollution)Act 1981.
10. Wild bush grown in the backyard is to be cleared.
11. Toilets and Soak pits are seen constructed very near to river bank. I should be
relocated in the premises elsewhere.
12. The unit should be directed to grow fast growing and long lasting trees all along the
boundary
THAMARACHALIL POLYMERS, EDAYAR.
Name of the Industry
: Thamarachalil Polymers,Edayar.
Date of Inspection
: 6-4-05
Name of the Product/s
: Polythene sheet
Raw materials
: Waste plastic bags, sheets and
colouring agents
Process:
The raw material is put into an extruder. The molten mass is manually cut into
pieces. It is then put into a grinder and then taken into the mixer machine for
adding colouring agent. The coloured material is then put into another extruder
and blower where it is converted into sheets and then rolled for dispatch.
614
Findings/Recommendations:
1. The company has not obtained authorization from the PCB under Recycled Plastic
Manufacture and Usage Rules 1999.
2. The unit is not generating any liquid effluent.
3. Disposal of plastic waste by landfill has to be forthwith stopped.
4. The unit should be directed to grow fast growing and long lasting trees all along the
boundary.
EMINENT COMPOSITES PVT LTD,EDAYAR
Name of the Industry
: Eminent Composites Pvt Ltd, Edayar
Date of Inspection
: 7-4-05
Name of the Product/s
: Acrylic bath tub(10 nos/day),
Acrylic shower tray (2 no/day)
Acrylic boat by moulding acrylic
Sheet.
Raw materials
: Acrylic Sheet – 200 ft 2 /day
C.S mat - 35 kg/day
Polyester resin – 70 kg/day.
Gelcot – 20 kg/day
Cobalt Octoate-250ml
Catalyst-250ml
Pigment-2kg/day
Process:
Acrylic sheet is moulded to the specified shape and coloured with gelcot and pigment. Then
reinforced with C.S mat and polyester resin.
Spray painting is done in an enclosed room.
Findings/Recommendation.:
1. There is no liquid effluent.
2. Acrylic sheet cuttings with C S mat are seen dumped in the premises reportedly for
disposal as scrap.
3. The quantity of waste generation is reported as 12 kg/day acrylic sheet cuttings.
4. The unit should obtain the Board’s consent under the Air (Prevention and Control of
Pollution) Act 1981.
5. The scrap accumulated is to be disposed of properly.
6. Open burning of the waste should not be carried out.
7. Adequate air pollution control measures are to be provided to the spray-painting
booth.
8. Greenbelt of fast growing trees is to be planted around the premises.
COCHIN CHEMICALS INDUSTRIES
615
Name of the Industry
: Cochin chemicals Industries
Date of Inspection
: 02-02-05; 15-02-05
Name of the Product/s
: Potassium nitrate and magnesium
chloride
Raw materials
: Magnesium Carbonate , Nitric Acid, Potasium
Chloride, Firewood.
Process
There are two sets of reaction chambers . In the first reactor magnesium carbonate and nitric
acid are mixed using a stirrer for 6 to 7 hours . For a single loading it requires 1250 kg
magnesium carbonate and 1424kg concentrated nitric acid . The supernatent from the first
reactor is pumped to the second reactor using a pump and is mixed with potassium chloride.
In the second reactor 1750kg magnesium nitrate is mixed with 1250kg of potassium chloride
at 95o C for 1 ½ hrs. Let it cool and drain the settled potassium nitrate to tanks for washing
and cooling. After cooling Potassium Nitrate is dried using steam and then crystallized and
packed. The remaining Ammonium Chloride solution in the second reactor is heated and
dried and packed. The unreacted portion from the first reactor is drained to a tank which is
mixed with polyelectolytes to settle and then solidified sludge is dumped near Periyar.
Findings / Recommendations:
1. There is no protection walls or compound wall for the sludge dumping site which is
very close to the Periyar river.
2. The housekeeping is found to be very poor.
3. The company is having valid Air consent from Kerala State Pollution Control Board.
4. From the sales register it is seen that 95 tonne of Potassium Nitrate is sold in the
month of January 2005 alone. According to the company officials yearly purchase of
magnesite is 250 tonnes. There is wide variation in the quantity of production . The
company is directed to furnish the purchase and sales details of the last year and assess
the production capacity .
5. The lab report of the sludge collected from the premises of the units disclosed the
following characters :
Source
: Cochin Chemical Industries
Date of Sample Collection : 2.2.05
Sample Identification No : LAEC 47(Sludge near River)
LAEC 48 (Bottom sludge of the Digester)
LAEC 49(Sludge dumped in the compound)
Sl.
Determinant
Unit Sludge Bottom Sludge
No.
near
sludge
dumped
River
of the
in the
Digester compound
1
pH
5.73
6.24
6.5
2
TDS
mg/kg 482800 477400 227200
3
Fluoride
11.4
10.6
17
616
4
5
6
Chlorides
Nitrates as N
Magnesium
1400
1250
43900
50000
920
7320
6000
1120
4880
This indicates that the sludge comes in the category of hazardous waste . The unit however
hasn’t obtain authorisation under Hazardous Waste(Management and Handling)Rules 1989.
The Unit cannot be allowed to function without obtaining authorisation as it would be clear
violation of the order of the Hon'ble Supreme Court dated 20-10-2003. The unit has no claim
that it has applied for authorisation.
The unit has to be served with a show cause notice before closure order to explain as to why
orders of closure should not be passed for operating in violation of Hazardous
Waste(Management and Handling)Rules 1989 and further actions may be initiated in
accordance with law including a direction to remove the sludge dumped in the premises close
by the River periyar to a temporary storage facility pending its final disposal at TSDF.
617
618
PAZHUMADATHIL PAINTS, EDAYAR
Name of the Industry
: Pazhumadathil paints, Edayar
Date of Inspection
: 6-4-05
Name of the Product/s
: Cement paint
Raw materials
: White cement , Lime powder and
colouring agent
Process:
The process includes just mixing of the raw materials in a mill and packing.
Findings/Recommendations:
1. The chances of pollution from the unit is just emission during the handling of the
materials .
2. Proper enclosure is to be provided for the material handling area.
3. The units should be directed to grow fast growing and long lasting trees all along the
boundary
VALIYAPARAMBATH INDUSTRIES
Name of the Industry
: Valiyaparambath Industries
Date of Inspection
: 5-3-05.
Name of the Product/s
: Crushed Tyre Waste.
Raw materials
: Waste Tyre.
Process:
Waste rubber mainly used tyre pieces are purchased and is crushed to small
pieces using a crusher. This is being carried on job work basis.
Findings/ Recommendations:
1. The waste tyre pieces, which are used as raw material is found, collected in open
spaces inside the compound.
2. The well in the premises is the source of water.
3. Water is used only for cooling the machinery, which is recirculated.
4. House keeping is found to be satisfactory but to be improved.
5. The unit should be directed to grow fast growing and long lasting trees all along the
boundary
619
V. J. RUBBER INDUSTRIES
Name of the Industry
: V. J. Rubber Industries
Date of Inspection
: 5-3-05
Name of the Product/s
: Powdering tyre waste.
Raw materials
: Waste Tyre
Process:
Tyre waste is ground and powdered using mechanical grinder and passed
through mechanical sieve.
Findings/ Recommendations:
1. Obtained board’s NOC for producing 14 ton / month of scrap flap cutting
powder.
2. Daily production is 900 kg crumb powder.
3. The unit has not obtained board’s consent under the Air (Prevention and
Control of Pollution) Act 1981.
4. The unit may be directed to obtain consent under Air (Prevention and
Control of Pollution) Act 1981.
5. The unit should be directed to grow fast growing and long lasting trees all
along the boundary.
COCHIN RUBBER COMPLEX
Name of the Industry
: Cochin Rubber Complex
Date of Inspection
: 5-3-05
Name of the Product/s
: Powdering tyre waste and Rubber sheet.
Raw materials
: Waste Tyre
Process:
Raw material is moulded rubber product waste and is crushed and powdered to produce
rubber powder.
Findings/ Recommendations:
1.
2.
3.
4.
5.
This fine rubber powder is used as filler for chappal making.
Approximate production is 5 tonnes/day
House keeping is found to be very poor
Fugitive emissions from the grinder are very high. It is to be controlled
The unit should obtain the consent of the board under the Air (Prevention and Control
of Pollution) Act 1981.
620
6.
The unit should be directed to grow fast growing and long lasting trees all along the
boundary.
PANANGHAT POLYMER PACKAGING PVT. LTD
Name of the Industry
: Pananghat Polymer Packaging Pvt.Ltd
Date of Inspection
: 5-3-05
Name of the Product/s
: Polythene Carry Bags
Raw materials
: Polythene granules
Process:
This is a polythene carry bags manufacturing unit with facilities for printing. The
unit is producing food material packing grade polythene covers. Only virgin
material is manufactured. Polythene granules are purchased and are converted
into flat tubes in an extruder. After making sheets of required thickness, they are
passed through the printing machine. Colour printing facility is available.
Findings/Recommendations:
1. Approximate production is 240 kg/day.
2. The unit is having valid consent under the Air Act.
3. The unit has installed a 110 KVA DG Set. It is reported that the DG Set is not in use at
present.
4. The Unit must be directed to provide acoustic covering.
MILLENNIUM POLY PACKS & PROCESSORS (P) LTD, EDAYAR.
Name of the Industry
Date of Inspection
: Millennium Poly Packs and Processors (P) Ltd,
Edayar.
: 5-3-05
Name of the Product/s
: Polythene tubes and covers
Raw materials
: Polythene granules
This unit is a sister concern of Pananghat Polymer Packaging Pvt. Ltd. Polythene tubes and
covers of food material packing grade are manufactured from virgin polythene granules. The
facility for colour printing is available.
Findings/Recommendations.
621
1. Approximate production is 240 kg /day.
2. The unit should obtain the certificate of registration from PCB for the manufacture of
plastic carry bags and containers under the Recycled Plastics Manufacture and Usage
Rules.
3. The unit must maintain proper house keeping .
PERIYAR POLY
FILMS, EDAYAR
Name of the Industry
: Periyar Poly films, Edayar
Date of Inspection
: 5-3-05
Name of the Product/s
: Polythene bags and tubes
Raw materials
: Polythene granules
Process:
Periyar Poly Films is a Polythene bags and tubes manufacturing unit. Production
capacity is 800-kg/day. Polythene granules are fed to a hopper of the extruder.
The lay flat tube coming through the dye is connected to the winding roller after
cooling. Blower is used for cooling. This roll is fed to cutting and sealing machine
to make polyethylene bags.
Findings:
1. The cut ends of the polyethylene bags are the main solid waste, which is
fed to the agglomerate for reprocessing.
2. The reprocessed material is used for making bags.
3. The unit is having valid registration for the manufacture of plastic carry
bags and containers.
4. On inspection, it is noted that the condition no. 8 and 9 of the registration
is not complied.
PERIYAR PLASTICS, EDAYAR.
Name of the Industry
: Periyar Plastics, Edayar.
Date of Inspection
: 5-3-05
Name of the Product/s
: Polythene bags and tubes
Raw materials
: Polythene granules
Process:
Periyar plastics is a Polythene bags and tubes manufacturing unit, producing
approx. 600 kg/ day. The polythene granules are fed to the hopper of the
622
extruder. The lay flat tubes coming through the dye are connected to the winding
roller after cooling. Blower is used for cooling. This roll is fed to cutting and
sealing machine to make polyethylene bags.
Findings / Recommendations:
1. The cut ends of the polyethylene bags are the main solid waste, which is
fed to the agglomerator for reprocessing.
2. The reprocessed material is used for making bags.
3. The unit is having valid registration for the manufacture of plastic carry
bags and containers.
4. On inspection it is noted that the Condition no. 8 and 9 of the registration
certificate is not complied.
M/S UNIPACK (INDIA ) PVT.LTD
Name of the Industry
:M/s Unipack (India ) Pvt.Ltd
Date of Inspection
: 5-3-05
Name of the Product/s
: Polyethylene tubes and films 105 kg max per day
Raw materials
: Polyethylene granules-3.2tonne per month
Printing ink
Process:
The raw material is fed into an extruder. The tubes/films formed is diverted to the rotograverprinting machine for making prints as per requirements.
Findings:
1. The unit has obtained Board’s permit under Recycled Plastics (Manufacture and
Usage) rules valid upto 31-12-05.
2. The industry is not generating any liquid effluent or solid waste.
M/S SILVER STREAM POLYMERS.
Name of the Industry
: M/s Silver Stream Polymers.
Date of Inspection
: 5-3-05
Name of the Product/s
: Fibreglass doors and sheets.
Raw materials
: Glass fibre, Solvent, Resin
Process:
623
The industry is producing fibreglass doors and sheets. Glass fibre, Solvent, Resin
etc are mixed and then applied on the mould to get the required product.
Findings:
There is no effluent discharge or emission from this industry.
M/S AL ARAFA PLASTICS
Name of the Industry
: M/s Al Arafa Plastics
Date of Inspection
: 5-3-05
Name of the Product/s
: Plastic Granules and Chips.
Raw materials
: Waste Plastic materials
Process:
The industry is producing plastic granules and chips using waste plastic
materials. Waste plastic is fed into the extruder. The Solid mass is cooled and
then fed in the grinder to make chips. Required colour is added in the mixer to
make plastic granules.
Findings:
During inspection, plastic waste is seen dumped in their compound creating an unhygienic
condition.
Recommendation:
1. The company has to make storage facility with roofing for the storage of raw
materials.
2. The Unit should obtain the Registration certificate from the Board under Recycled
Plastics Manufacture and Usage Rules.
3. The Unit must be directed to maintain good house keeping.
4. The Unit must be directed to forthwith stop dumping of plastic wastes in their
compound.
M/s Vinayaka Industries
Name of the Industry
Date of Inspection
Name of the Product/s
Raw materials
Findings/recommendations:
: M/s Vinayaka Industries
: 20-1-05
: Grease
: Base oil, Hydrogenated castor oil and filler materials
624
1.
2.
3.
4.
5.
This is a new SSI unit under trial run now.
The Unit is engaged in the production of grease.
The industry is not generating any liquid waste or solid waste.
The Unit has installed a 15 KVA Generator set.
The Unit must obtain the consent of the Board under the Air (Prevention
and Control of Pollution) Act 1981.
GIJAS RUBBERS, EDAYAR
Name of the Industry
:Gijas Rubbers, Edayar
Date of Inspection
: 03-03-05.
Name of the Product
: Reclaimed rubber- 2000 kg/ day
Raw materials
: 1.Waste tyre, Tyre cutting waste,
Buffing dust -2000 kg/day.
2. Rubber process oil, pine tar, asphalt black – 50
kg/day.
Process:
The raw materials are mixed and extruded in an extruder. It is then sheeted in a
roller mill. Little quantity of water is also added for proper cooking. They have
provided chimney for the extruding section. Fugitive emissions are noticed from
the processing area. Cooling water is collected in a ground level tank and reused.
The quantity of foreign particles waste like Metal pieces, stones, wooden pieces
etc. is about 10 kg / month. This is disposed by open burning. They have not
provided facility for storage of raw materials. The company comes under the
purview of the Air (Prevention and Control of Pollution) Act 1981.
Recommendations.
1. The Unit must obtain consent under the Air (Prevention and Control of Pollution) Act
1981.
2. Processing area is to be enclosed.
3. Facilities are to be provided for reducing foul smell and emission of dust from the
industry.
4. Cooling water re-circulation arrangements are to be improved.
5. Proper facility with roofing is to be provided for the storage of raw materials.
6. Housekeeping is to be improved.
TRANSEL WIRES
Name of the Industry
: Transel Wires
Date of Inspection
: 5-3-05
Name of the Product/s
: 0.1 mm to 3 mm aluminum cables
625
Raw materials
: 9 mm thick aluminum cables
Process.
Transel Wires is cable-manufacturing unit. Thick aluminum cables of 9mm are drawn
through a Bull Blower to make them thin cables of 0.1 mm to 3 mm, as per requirement and
then insulated using thick paper.
Findings/Recommendations.
1. D.G Set of 55 KVA is installed.
2. No effluent discharge.
M/S S.M INDUSTRIES
Name of the Industry
: M/s S.M Industries
Date of Inspection
: 5-3-05
Name of the Product/s
: RCC pipes and tanks
Raw materials
:Steel , Sand , Cement ,and Metal
Chips.
Process:
Steel reinforcement is placed in the moulds. Raw materials are mixed in the mixing machine
and then applied in the moulds as per requirement. Curing is done by spraying water.
Findings:
The industry is not generating liquid effluent or solid waste.
M/S ALWAYE SMITHY WORKSHOP.
Name of the Industry
:M/s Alwaye Smithy Workshop.
Date of Inspection
: 5-3-05
Nature of Industry
: Lathe works and welding works.
Findings:
1. The industry is engaged in lathe works and welding works.
2. The unit is undertaking only job works.
M/S SIMLA WOOD INDUSTRIES, EDAYAR.
626
Name of the Industry
: M/s Simla Wood Industries,Edayar.
Date of Inspection
: 5-3-05
Nature of industry
: Doing job works for producing Wooden doors,
Windows etc
This is an SSI unit undertaking job works for producing wooden doors, Windows etc. The
plant includes sawmill, Cutting machines, Plaining machines, Drilling machines etc.
Findings:
1. The chances of pollution are sound and dust.
2. The unit is working in an enclosed building.
Recommendations:
1. The Unit should obtain the Board’s consent under Air (Prevention and Control of
Pollution) Act 1981.
AJITH CARBONS & PIGMENTS LTD
Name of the Industry
: Ajith Carbons and Pigments Ltd
Date of Inspection
: 05-03-05
Name of the Product/s
: Beta blue pigments –20t /year
Raw materials
: Copper Pthalocyanine
Crude - 140 kg/day
Wetting agent- 3kg
Process:
The company produces 20 t/year Beta blue pigments, which is used for paint and ink
manufacturing. Raw materials are charged into a ball mill for crushing. The product from the
ball mill is transferred to a reaction vessel and heated at 90 0 C for 18 to 24 hrs. Then filtered
using a mechanical press.
Findings:
1.
2.
3.
4.
5.
The unit is having valid Air consent from PCB.
Cooling water is re-circulated and hence there is no effluent.
There is a baby boiler with 13m high chimney and Genset.
House keeping is found to be very poor.
Blue coloured pigment is seen spread everywhere inside the factory especially on the
floor. It is noticed that the pigment is spread due to improper handling of the materials.
627
6. Packing materials of HDPE sacks and bags are stored for disposal.
Recommendations.
1. Inplant control measures for preventing the emissions of pigment must be provided.
2. House keeping should be improved and the unit must be directed to maintain the
premises neatly and totally avoid the spillage of pigment in the floor ,wall and
nearby areas.
3. Thick belt of fast growing trees should be developed.
M/S JONARIN CHEMICALS.
Name of the Industry
: M/s Jonarin Chemicals.
Date of Inspection
: 20-1-05
Name of the Product/s
: Cleaning powder
-1000 kg/day
Washing powder
-750 ,,
Sodium Hypo chlorite -4000 ,,
Raw materials
: Soda ash,
Acid Slurry,
Trisodium Phosphate
Calcite powder
Caustic Soda
Chlorine Gas
Process:
Production process includes only mixing of raw materials.
Findings / Recommendations:
1. The industry is not generating any liquid effluent or solid waste.
2. Liquid chlorine was seen stored in drums.
3. The Unit may be directed to provide details regarding the storage and
handling of the raw materials / finished products.
4. The Unit must be directed to obtain the Board’s consent under the Air Act.
M/S TRAVANCORE AMMONIA PVT. LTD.
Name of the Industry
: M/s Travancore Ammonia Pvt. Ltd.
Date of Inspection
: 20-01-05
Name of the Product/s
: Ammonium Hydroxide 7750 litres per day
628
Bottled Anhydrous Ammonia 580 kg/day.
Raw materials
: Anhydrous Ammonia 3250 kg/day
Process:
Anhydrous Ammonia is dissolved in water in M.S.Vessels. The product is bottled
for despatch. Anhydrous Ammonia as such is also bottled in cylinders.
Findings:
1. The Unit has provided water scrubbing system to avoid any leakage of the gas.
2. The Company is not discharging any effluent or solid waste.
M/S MANCHESTER CHEMICALS, EDAYAR
Name of the Industry
: M/s Manchester Chemicals, Edayar
Date of Inspection
: 20-1-05
Name of the Product/s
: Phenolic resin
Potassium based silicate
Acid proof cement
Asphalt mastic
CNSL Resin
Raw materials
:Phenol
Quartz powder
PTS acid
Silica sand
Bitumen
Potassium Hydroxide.
Findings:
1. The products are used for anti-corrosive treatment.
2. Production process involves the mixing of raw materials.
3. The Unit is not generating any waste.
M/S MANSWILL CHEMICALS (P) LTD.
Name of the Industry
: M/s Manswill Chemicals (P) Ltd.
Date of Inspection
: 24-1-05
Name of the Product/s
: Calcium Silicate 200 kg/day
629
Sodium silicate 50 kg/day
Raw materials
: Hydrochloric Acid – 100 kg per day
Silica Powder- 100 kg/day
Lime 25 kg/day
Caustic soda – 25 kg/day
Process:
Dilute Sodium Silicate is reacted with dilute Hydrochloric Acid to form silicic acid
and sodium chloride. Silicic acid is then reacted with lime solution to form
calcium silicate. The precipitated Calcium Silicate is filtered and dried.
Findings:
1. The sodium Chloride remains in the filtrate comes out along with the
effluent.
2. The effluent gets diluted during filtration and washing.
3. The effluent is discharged to natural drain leading to Periyar River. The
company is permitted to discharge 5000 litres of effluent per day.
4. Consent under the Water Act issued was valid upto 31-12-2004.
Recommendations:
1. The Unit should obtain the consent under Water (Prevention and Control of
Pollution) Act 1974.
2. The Unit should set up an ETP for effluent treatment.
3. The Unit must be directed to maintain good house keeping.
M/S GALILEA CHEMICALS
Name of the Industry
: M/s Galilea Chemicals
Date of Inspection
: 24-1-05
Name of the Product/s
: Printing ink
Raw materials
:Organic pigment, Oil, resin, Carbon black, sealing
compound and linseed oil.
Process:
The industry is engaged in the production of printing ink. Raw materials used are
organic pigment, Oil, resin, Carbon black, sealing compound and linseed oil.
They are producing about 200 kg per day of printing ink. Mixture of the
ingredients is put in the roller grinder. The material is packed in drums.
Findings:
630
The industry is not generating any liquid effluent or solid waste.
SOLVAY CHEMICALS
Name of the Industry
Date of Inspection
Name of the Product/s
Raw materials
: Solvay Chemicals
: 05-03-05
: Soduim hypochlorate-0.5 tonne/day
: Caustic Soda, Chlorine, Ice
Findings:
1.
2.
3.
4.
At present there is no manufacturing and only re-packing is carried out.
Approximate quantity is 0.5 t/ day.
The unit has no valid consent from the PCB.
The factory manufactures sodium hypochlorite solution using chlorine and caustic
soda.
TMV NATURAL OILS & EXTRACTS (P) LTD.
Name of the Industry
:TMV Natural oils and Extracts Pvt. Ltd.
Date of Inspection
: 30-3-05
Name of the Product/s
: Herbal extracts and
Spice oils-1 l/month
: Herbal items-6 t/month
Spices- 1 t/month
Solvents-750 kg/month
Fuels-5 t/month
Raw materials
The company produces herbal extracts and Spice oils approximate one tonne / month. The
process involves steam distillation and Solvent extraction of spices and herbal materials.
Dried herbal powder is charged to a reaction vessel along with solvents like Ethelene di
Chloride or Ethyl acetate. Reaction time is approx. 3 hrs. After that the solvent is drained into
a distillation vessel. The solvent is reused after distillation. About 10% to 15% solid waste is
generated. Approximate 8 T of solid waste per month is generated. This solid waste is dried
and used as fuel in the boiler.
Findings:
1. Boiler is provided with 12 meter high chimney.
2. Water consumption is approximately 1500 L / day. Source of water is a well in the
premises.
3. Effluent generated is approximate 500 L/ days. Main source of effluent is wash water
from the reaction vessel. Effluent is dark brownish to black in colour with aromatic
smell.
4. An underground collection tank is provided for primary settling. Provision for
chemical addition is also provided. This system was not working at the time of
631
5.
6.
7.
8.
inspection. It is reported that normally even this present system, which is inadequate,
is also operated only once in a week.
Treated effluent is discharged to public drain.
House keeping is found to be satisfactory.
Company is having valid Air Consent.
The Unit does not have a proper Effluent treatment plant.
Recommendations:
1. The Unit must provide adequate Effluent treatment plant.
2. The Board must ensure that the Unit has a proper ETP, prior to giving consent under
the Water Act.
3. The Unit must obtain consent under the Water Act.
4. The Unit must be directed to plant fast growing and long lasting trees to form a green
belt all along its premises and report planting of seedlings within one month to the
PCB.
M/S NINI CREPE MILLS.
Name of the Industry
: M/s Nini Crepe Mills
Date of Inspection
: 5-3-05.
Name of the Product/s
: Crepe Rubber 35 tonne/month
Raw materials
: Scrap rubber 1.5 tonne per day.
Process:
Production rate 35 tonne of crepe rubber per month
The industry is producing crepe rubber by processing scrap rubber. Scrap rubber
is soaked in water for 8 hours to remove dirt, milled in roller mills and naturally
dried by hanging in the air.
Findings:
The water discharged after soaking and the water discharged from milling section are the
source of effluent. They are discharging 5000 litres of effluent per day.
The unit has valid consent under the Water Act upto 31-12-04.
At the time of inspection, it is noticed that the Unit is also engaged in processing of skimmed
rubber, which is not mentioned in the Consent order. The effluent from processing of
skimmed rubber is highly pollutant, which requires adequate treatment through a proper ETP.
Rubber trap and settling tanks provided are seen damaged. The effluent is
seen stagnating in the premises and in the nearby property, which may ultimately result in
carrying of the effluent into the River Periyar.
Recommendations:
632
1. The Unit must be directed to set up a proper effluent treatment system.
2. It is noticed that the Unit is processing skimmed rubber, which is in violation
of the Consent order and the Board may initiate appropriate action.
3. House keeping is to be improved.
4. The Board must direct the Unit to furnish a Bank Guarantee for Rs. 3.00 lacs
as security towards setting up of proper ETP within 3 months, failing which
the Bank Guarantee shall be forfeited and the Unit must be directed to stop
production thereafter.
5. The Unit must be directed to grow fast growing and long lasting trees all
along its premises to form a green belt and report planting of seedlings
within one month to the PCB.
6. The Unit must its improve house keeping.
M/S SHEPHERD PLASTIC EXTRUSION PVT. LTD
Inspected on 20-1-05
Industry is shifted to Kalamassery.
M/S BRIGHT PIGMENTS
Inspected on 24-1-05
During inspection it was seen that this is a closed unit.
M/S JOYCE WELFARE MAHILA SAMAJAM(NEW JYOTHI FOODS)
Inspected on 24-1-05
This is a closed unit.
The following Units in Edayar development area are closed and found so in the inspection.
Inspected on 13-06-05
1. Navin Engineering Industries.
2. GEM Enterprises.
3. W-Electrochemicals
3. Thachavallath Industries.
4. Abin Granites
5. Thottakkattu Distilleries
6. Parur Poweloom Co-op Society Ltd.
BARATH POLYMERS
633
This is an existing recycled plastic manufacturing unit purchased by the present occupier.
Raw material is waste plastic carry bags. Commercial production is not started.
The Unit should obtain the Registration certificate from the Board under Recycled
Plastics (Manufacture and Usage) Rules.
SPECTRUM REGULATES AND CHEMICALS
Repacking of laboratory chemicals are done in this unit. No waste generation.
PAYYAPPILLYS GLOSSY GRANITES
The unit is found closed.
CLASSIC
This is a new dye industry. Not started production. During the time of inspection
responsible persons were not available for getting information.
D.L. ENGINEERING
Motor rewinding and general engineering works are done in this unit.
Scrap from lathe is disposed by sale. There is a Genset of 10 KVA.
JAGADAMBA CONTAINERS
The unit is engaged in the manufacture white jerry cans from virgin granules and recycled
granules produced from the rejects.
The unit should obtain certificate of registration from PCB under the Recycled Plastics (M &
U) Rules.
CHAVARA PIPE
Date of Inspection-10-6-05, The unit is found closed.
SARALA INDUSTRIES.
Date of Inspection-10-6-05
This is a tiny stitching Unit not seen functioning during the time of inspection.
BEST ELECTRICALS & ENGINEERS.
Date of Inspection-10-6-05
The Unit is engaged in electrical repair works of motor winding. Connected load is 7.5
HP.
634
EXCEL ELECTRICALS
Date of Inspection-10-6-05
The unit is not working. Renovation work for starting production is seen carried
out.
GLASS TECH
Date of Inspection-10-6-05
Glass cutting and designing works are done.
NEXA CONDINENTS PVT. LTD.,EDAYAR
Date of Inspection-10-6-05
Findings:
This is a chilly grinding Unit producing 800-kg/day chilly powders using a
pulverizer of 50 HP. The unit is functioning in an enclosed building.
Recommendations:
1. The Unit must be directed to obtain consent under the Air (Prevention &
Control of Pollution) Act, 1981.
2. The Unit must be directed to grow fast growing and long lasting trees in its
premises to form a green belt and report planting of seedlings within one
month to the Pollution Control Board.
KRIPA FOODS PVT.LTD.
Date of Inspection-10-6-05
Findings:
Powdering of ginger, coriander and fennen are done in this unit. Two pulverizer
of 40 HP and 50 HP and Genset of 63 KVA are installed in the Unit.
Recommendations:
1. The Unit must be directed to obtain consent under the Air (Prevention &
Control of Pollution) Act, 1981.
635
2. The Unit must be directed to grow fast growing and long lasting trees in its
premises to form a green belt and report planting of seedlings within one
month to the Pollution Control Board.
SEVANA INDUSTRIES
Date of Inspection-10-6-05
Findings:
Chilly Powder and curry powder are produced using three pulverizer 35 HP (1No)
and 10 HP (2No).
Recommendations:
1. The Unit must be directed to obtain consent under the Air (Prevention &
Control of Pollution) Act, 1981.
2. The Unit must be directed to grow fast growing and long lasting trees in its
premises to form a green belt and report planting of seedlings within one
month to the Pollution Control Board.
TECHNO FLEX CABLES PVT.LTD.
Date of Inspection-10-6-05
Findings:
The unit has not started functioning. It is proposed to produce power cables.
Machinery erection is being carried out.
Recommendations:
The unit is required to obtain Board’s consent under the Air (Prevention & Control of
Pollution) Act, 1981.
MARUTHI FOAM.
Date of Inspection-10-6-05
Findings:
There is no production during the time of inspection. As per records the unit is producing
50 kg/day foam mattresses from 250 kg rubber latex.
A treatment tank having three compartments is seen constructed. Chemical
treatment and
settling tank is constructed. No arrangement is provided for the chemical
addition and mixing of the effluent.
636
There is a baby boiler fired by firewood.
The unit is not having valid consent under the Water Act and Air Act.
Recommendations.
1. The Unit should obtain the Board’s consent under the Water Act and Air Act.
2. House keeping is poor and should be improved.
3.
The Unit must be directed to grow fast growing and long lasting trees in its premises
to form a green belt and report planting of seedlings within one month to the Pollution
Control Board.
LARZEN AND TOUBRO READY MIX CONCRETE PLANT, EDAYAR.
Date of Inspection-10-6-05
Findings:
1. The unit has obtained Board’s consent to establish a Ready mix concrete plant vide
Consent No. PCB/EKM/CE 43/05 dt. 06-05-05.
2. The construction work and machinery erection are almost over.
Production is not yet started .
The plant capacity is 100 m3 /day RMC.
3. For treating the effluent, a tank having three compartments is seen constructed.
4. Enclosed godown for cement storage and three overhead cement storage bins are
provided.
5. Source of Water is purchase from outside.
Recommendations:
1. The Wastewater from the process and washing should be treated and the Unit should
be directed to set up an Effluent Treatment Plant and obtain Consent under the Water
(Prevention and Control of Pollution) Act 1974.
2. All wash water streams are to be collected and reused after treatment
3. The Unit must be directed not to mix storm water with the effluent.
4. The Unit must be directed to obtain consent under the Air Act.
637
5. The Unit must be directed to grow fast growing and long lasting tress in its premises
to form a green belt and report planting of seedlings within one month to the Pollution
Control Board.
6. The Unit must be directed to ensure that waste concrete mix should not be dumped in
the open land or nearby areas.
WIRES AND NAILS, EDAYAR.
Date of Inspection- 14-06-05
A closed unit not in operation.
RAHUL FLOUR MILL, EDAYAR.
Date of Inspection- 14-06-05
A closed unit not in operation.
Star Refinery, Edayar.
Date of Inspection- 14-06-05
A closed unit not in operation.
AMMA FOOD PRODUCTS PVT.LTD.
Date of Inspection- 14-06-05
A closed unit not in operation.
PNEUMO HYDRAULICS, EDAYAR.
Date of Inspection- 14-06-05
A closed unit not in operation.
TECMAN CAPACITORS PVT.LTD, EDAYAR.
Date of Inspection- 14-06-05
Raw materials
- MPP film -10 kg
-Zinc wire –3 kg
-Resin-2.5 kg
-Hardener-6.25 gms
- Plastic items-500 nos each (Can, Core, Disc etc)
638
Product
- Capacitors-500nos/day
Process:
Metalised Polypropylene film (Zn, Al) is wound by an automatic winding machine under
fully air condition / dust free atmosphere. Supervision of qualified Engineers during
operation confirms the high accuracy.
After winding zinc is sprayed on the elements. It is performed by specially designed metal
spray gun, which melt the Zinc using oxygen and LPG
The sprayed elements are heated in an industrial oven for 5-6 hours to confirm the
humidity parameters. The thin layers of metal dust enveloped on elements are cleared
before the terminals/wire fastened on the elements.
The elements are placed in its containers filled with resin and tested.
Waste:
Zinc dust formed during the melting while spraying of Zinc on elements is the hazardous
waste. Waste zinc dust formed is accumulated inside the factory.
Findings:
1. The unit started functioning in 1984.
2. There is no effluent discharge.
3. An exhaust fan is provided at the spraying chamber, but no arrangement is there,
collecting the fumes.
4. The unit has not obtained Boards consent under the Air Act.
5. Not obtained authorization under HW Rules.
Recommendations :
1. The unit should obtain Board’s Consent under the Air (Prevention and Control
of Pollution) Act 1981.
2. Should obtain authorization under HW Rules for the disposal of Zinc fumes
and dust. (Category No.6, Schedule I).
LAKSHMI ACETYLENE PRIVATE LIMITED, EDAYAR.
Date of Inspection- 14-06-05
Raw material – Calcium carbide- 900 kg/day
Product
- Acetylene gas – 360 m3 /day (max)
639
Process:
Calcium carbide is treated with water to form acetylene gas and lime. The gas is
purified, compressed and filled in cylinders. The lime sludge is collected in pits
and settled. Supernatant liquid is recirculated in process. The lime sludge is
reportedly disposed to other parties by sale.
Waste:
According to the company about 1250 kg/day lime sludge is generated which is
drained into open pits for settling. The clear liquid is drained into collection tank
for recirculation in process and the lime sludge is disposed by sale. Effluent
generated from the unit namely M/s Atchuth Nitrous Company functioning in the
same compound is also discharged into the slurry pit.
Findings :
1. The unit has obtained Board’s NOC dated 27-8-92 for producing 5000 m3/month
Acetylene and 30 t/month lime sludge.
2. Source of water is well in the premises. Process water requirement is 3000 lit/day.
3. Cooling water recirculation arrangement is provided.
4. Lime slurry generated in the reactor is drained into open pits and the clear liquid is
collected in a tank. According to the company authorities this effluent is recirculated
in the reactor for producing acetylene gas.
5. Lime sludge recovered from the pits is dumped in the premises of the slurry pit and
collection tank making the whole premises shabby.
6. Effluent contaminated with ammonia generated from the adjacent Nitrous oxide
manufacturing factory is reaching the effluent drain of Lakshmi acetylene leading to
the lime slurry pit.
7. There is a Genset of 50 KVA.
8. The unit has not obtained Board’s consent under the Air Act and Water Act.
9. House keeping is very poor .
10.Sample of lime sludge and effluent are collected for analysis.
Recommendation:
1. The unit should obtain the consent under the Air Act and Water Act.
2. The company is required to take necessary action for the secured storage and disposal
of sludge as per HW Rule based on the report of analysis of the sample.
3. House keeping is to be improved.
Colour code
Red: Pollutants not conforming to the standards.
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
: Lakshmi Acetylene Private Limited.
640
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Determinant
PH
BOD
COD
SS
TDS
Nitrates as N
Phosphates
Sulphates
Cyanides
Free ammonia
TKN
Amm:Nitrogen
Hexavalent chromium
Total Chromium
Manganese
Oil & grease
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1.
2
3
4
5
6
7
8
9
10
Determinant
pH
Zinc
Iron
Lead
Cadmium
Nitrates
Cyanides
Free Ammonia
Manganese
Inorganic Cyanide
Compounds
: 16-06-2005.
: LAEC 221(Effluent).
: Central Laboratory, Gandhi Nagar.
Unit
Effluent
mg/l
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
,,
13
4.2
104
85
10992
966
ND
60
ND
300
302
300
ND
ND
ND
ND
: Lakshmi Acetylene Private Limited
: 16-06-2005
: AQ2(Sludge Sample)
: Central Laboratory, Gandhi Nagar.
Unit
Sludge Sample
13.03
mg/kg 71.03
,,
1048
,,
198
,,
8.4
,,
180
,,
BDL
,,
BDL
,,
22.4
,,
BDL
ATCHUTH NITROUS COMPANY, EDAYAR.
Date of Inspection- 14-06-05
641
Raw material - Ammonium Nitrate - 600 kg/day.
-LPG- 30 kg/day.
Product
-Nitrous oxide IP- 160 m3/day.
Process:
Ammonium nitrate is melted in a melting pot and fed to a reactor where it
decomposes thermally to nitrous oxide and water. The gas is fed to a water
scrubber and a cooler where most of the water is condensed and separated. The
gas then passes through purification towers for water washing and potassium
permanganate washing. Purified gas is collected in gasholder and compressed.
Waste:
1200 L/day wastewater discharged from the factory is taken to the lime slurry pit of the
parent unit of M/s Lakshmi Acetylene Pvt. Ltd. producing acetylene gas.
Used oil from the compressor is stored in barrels for disposal.
Findings:
The unit has not obtained Board’s consent under the Water Act and Authorisation under HW
Rules.
Recommendation:
1. Should obtain the Board’s consent under the Water Act for discharging the effluent.
2. Should obtain authorization under HW Rules for the disposal of used oil.
3. House keeping is to be improved.
Colour code
Red: Pollutants not conforming to the standards.
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
Determinant
PH
BOD
COD
:Atchuth Nitrous Company , Edayar.
: 16-06-2005
: LAEC 222( Scrubber out let)
: Central Laboratory, Gandhi Nagar.
Unit
mg/l
,,
Scrubber
out let
2.4
0.8
16
642
4
5
6
7
8
9
SS
Nitrates as N
Free Ammonia
Amm:Nitrogen
Phenolic compounds
Oil and Grease
,,
,,
,,
,,
,,
,,
10
2037
Nil
1250
ND
ND
MANIFOLD INDUSTRIES, EDAYAR.
Date of Inspection- 14-06-05
This is an engineering workshop producing rollers.
Chances of pollution are negligible.
MALAYALAM CHEMICALS (P) LTD, EDAYAR.
Date of Inspection- 14-06-05
Production capacity of the plant is 1250 kg/day calcium carbide. The unit has got
valid consent under the Air Act upto 31-12-2005. A chimney of 30 M height with
a dust collector is provided to the furnace. All the four sides of the furnace are
completely enclosed. (Cooling water is recirculated) Slag is reportedly disposed
for land filling purposes. Source of water is bore well and open well. There is a
Genset of 15 KVA.
SPECTRUM CHEMICALS.
Date of Inspection- 14-06-05
Engaged in the packing of chemicals for supplying to clinical laboratories.
SOUTH INDIAN FERTILIZERS, EDAYAR (PACKING UNIT)
Date of Inspection- 14-06-05
Process:
The fertilizers produced in South Indian Fertilizers is brought to this unit, manually mixed
with nitrogen, Phosphorus and Calcium and packed for dispatch.
Recommendation:
The unit should obtain Board’s consent under the Air (Prevention and Control of Pollution)
Act 1981.
643
TECCAP ELECTRONICS PVT.LTD, EDAYAR.
Date of Inspection- 14-06-05
Job works of capacitor production and spare parts cleaning are carried out.
During inspection capacitor production plant is not seen working.
For controlling the emission of zinc dust a dust collector is provided.
Recommendations:
1. The unit is not having the Board’s clearance or authorization as per HW Rules.
2. Should obtain the Board’s consent under the Air Act and authorization for the
disposal of zinc dust.
SHALIMAR INKS AND CHEMICALS, EDAYAR.
Date of Inspection- 14-06-05
1500 kg/month printing ink is manufactured from Bitumen, Spent oil, Carton black.
Production process involves mixing, blending and grinding.
Drums are cleaned by heating and the residue is seen disposed on land.
Oil from factory premises is seen carried along with storm water to the road.
Recommendations:
1. The unit should obtain Board’s consent under the Air Act.
2. Also provide roofed yard for storing empty drums.
R.S.COMPOUND, EDAYAR.
Date of Inspection- 14-06-05
The factory produces alum by treating bauxite powder with weak sulphuric acid and curing
the product.
Recommendations:
The unit is not having consent under the Air Act. Should obtain the Air Consent.
EXCEL ENTERPRISES, EDAYAR.
Date of Inspection- 14-06-05
644
In this unit waste rubber gloves (rejected gloves from Hindustan Latex) are ground to produce
reclaimed rubber. The gloves are ground with clay powder in a grinder, heated using LPG,
and moulded as rubber blocks. Two hoods are seen attached to the roof of the heating area.
But no arrangement is provided for collecting the dust.
Findings:
House keeping is very poor.
The unit has already applied for Board’s consent under the Air Act.
Recommendation:
The unit should improve housekeeping.
NATH SPUN PIPES, EDAYAR.
Date of Inspection- 16-6-05
RCC pipes and tanks are produced in this unit. The unit started functioning in 1994. Raw
materials are M.Sand, metal, cement and water. Source of water is open well; bore well and
purchase from outside. The unit complained that this well water has been contaminated by the
surrounding pollution from other industries.pH of well water and bore well are 2.9 and 3.3
respectively.
Water used for curing is discharged once in a while. Remains of the concrete mix are dumped
in the factory compound.
Recommendation :
House keeping is to be improved.
FILCO POLYMERS, EDAYAR.
Date of Inspection- 16-6-05
The unit is engaged in the production of PVC pipes. The raw materials PVC
resins, citric acid, wax, calcium carbonate are fed to the mixing mill, sieved,
heated and extruded to produce PVC pipes. Water used for cooling is
recirculated.
Recommendations:
1. The unit is required to obtain the Boards consent under the Air Act.
2. The solid materials removed from the sieve are to be disposed safely.
ALWAYE TECHNO ENGINEERING (P) LTD, EDAYAR
Date of Inspection: 24-6-05
645
The industry is a closed one.
JANSONS BALERS.,EDAYAR
Date of Inspection: 24-6-05
The unit is engaged in the finishing work of rubber doormats.
The work includes just cutting of edges and packing.
This is a 100% EOU. The unit is not generating any liquid effluent or gaseous emission.
M.G.R.INDUSTRIES.
Date of Inspection: 24-6-05
This is a tiny unit engaged in the production of waste rubber powder, using waste tyres and
other rubber items as raw materials .The process includes just grinding of waste rubber.
The unit comes under the purview of the Air Act. Quantity of raw material processed
is 2.5 t/day. The company should apply and obtain the Boards consent under the Air act.
CARMEL THREADS.
Date of Inspection: 24-6-05
Tyre retreading unit –Closed.
STAR MARK
Date of Inspection: 24-6-05; Closed unit.
CHEMMANNUR G.R.PVT .LTD
Date of Inspection: 24-6-05 ; Closed unit.
PIGMENT INDIA LTD
Date of Inspection: 24-6-05 ; Closed unit
ASIATIC PRODUCTS.
Date of Inspection: 24-6-05
This is a tiny unit making knife handles with wood.
The unit is not causing pollution problems.
KOCHI CASTING & MFG. PVT. LTD.
646
Date of Inspection: 24-6-05 ;
Raw Materials:
Pig iron ,Scrap iron –6t/m
Aluminium Gun metal-20Kg/m
Products:
Ferrous and Nonferrous castings-6t/m
Process:
Raw materials are fed into the furnace, melted by using coke as fuel. The molten mass
is poured into moulds and allowed to cool. Scrap portion is again used along with raw
materials.
Findings:
1. Operation of the company is coming under the purview of the Air Act. They have
obtained consent of the board, which is valid up to31-12 –2005.
2. Provided hood and Chimney arrangement for control of Air Pollution.
3. There is no effluent discharge from the unit.
BODY GEAR INTERNATIONAL PVT. LTD. EDAYAR
Name of the Industry
:Body Gear International Pvt. Ltd. Edayar
Date of Inspection
: 3-3-05
Name of the Product/s
: Stuffed toys
Raw materials
: Fibre and imported fabric
The unit is engaged in the production of stuffed toys. The industry is a 100%
export oriented unit. They are not discharging any trade effluent. About 25kg
/day cutting cloth, synthetic fibre and cotton is disposed by open burning.
Received complaint regarding the open burning of wastes. A generator having
capacity 100KVA is used by them. The company is coming under the purview of
the Air(Prevention and Control of Pollution)Act 1981 .
Recommendations.
1. Incinerator is to be provided for the disposal of solid waste.
2. Consent from Kerala State Pollution Control Board is to be obtained.
3. Used oil is to be disposed as per Hazardous Waste (Management and Handling) Rules
1989.
647
BUENA VISTA INTERNATIONAL PVT LTD, EDAYAR.
Name of the Industry
:Buena Vista International Pvt Ltd, Edayar
Date of Inspection
: 8-4-05
The industrial unit produces 3tonne/day chilly powder, turmeric powder,
coriander powder and curry powder by pulverization, blending, drying (electric)
and packing.
During inspection there was no production. The company authorities informed
that the unit is stopping production on account of marketing problems and
planning to get disposed soon. The unit is functioning in an enclosed building and
for dust collection fabric filter is used. There is no source of liquid or solid waste.
CHILTON REFRIGERATION PVT. LTD, EDAYAR.
Name of the Industry
: Chilton Refrigeration Pvt. Ltd, Edayar
Date of Inspection
: 8-4-05
Findings:
The unit produces hydraulic oil cooler, blood bag refrigerator, and control panel
refrigeration items by sheet metal fabrication, painting and assembling.
The company authorities informed that non-CFC refrigerant is used. Raw
materials are CR, GI Sheet, Compressors, Copper tube, SS Sheet, Fan motor etc.
There is no liquid effluent. The GI/SS foil and sheet scrap (10 kg/day) are
reported to be disposed by sale as scrap. Solid waste of folyol formed during the
puffing to give insulation, is seen dumped in open area near the plant. This is to
be disposed safely.
The housekeeping is poor. A Genset of 25KVA is operated.
The wastes and residues of paints used for industrial purpose comes under the
hazardous waste category 21.1.
Recommendations:
1.The unit should obtain Board’s consent and maintain the premises.
2.House keeping should be improved.
648
SARSON POLYMERS, EDAYAR.
Date of inspection: 30-5-05
The industry is engaged in the production of Plastic granules using raw materials like
waste plastic covers and sheets .The production rate is 5 t/month. Production process is as
detailed below.
Manually cleaned raw material is put into an extruder. The mass is cut into pieces and then
put into cutting machine for size reduction. The material is then taken to the mixing machine,
necessary colouring pigment is added and then granulized. The industry does not generate any
liquid effluent .
Recommendation.
1. The company should apply and obtain registration under the recycled plastics
manufacture and usage rules 1999.
2. Should obtain the boards consent under the Air Act.
3. Should provide green belt around the factory premises.
GAMA PAINTS.
Date of inspection: 30-5-05
The industry is producing thinner, wood polish and sealer. The raw materials and products are
detailed below.
Raw materials:
1.Thinner
:-Ethyl Acetate-120 litres/day.
Methanol
-270 ,,
Butyl Acetate-30
,,
Diaceton
-30 ,,
2. Wood polish
:- Methanol-150 litres/day
Lac
-18 kg/day
Rosin
-12 kg/day
3. Sealor
:–Nitro cellulose - 100 kg/day.
Zinc sterite
-50 kg/day.
Methanol-150 litres/day.
Products:
1. Thinner-550 litres/day.
2.Wood polish-180 lites/day.
3.Sealor – 300 litres/day.
Process:
649
Mixing of raw materials indifferent proportions, filtering with cloth and packing. The industry
is not generating any liquid effluent.
The industry comes under the purview of the Air Act. The Unit should apply and
obtain consent of the Board for operating the plant.
ENVIRO DESIGNS AND EQUIPMENTS.
Date of inspection: 30-5-05
This is an engineering industry doing fabricatin of equipments required for operating effluent
treatment plants and preparation of coagulant. The quantity of steel used for fabrication works
comes about 2 tonnes per year. The crap is disposed by sale .The company is permitted to
handle 50tonnes of spent acid in a year. Polyelectrolyte is mixed with spent acid to formulate
coagulant. Mixing is done manually in HDPE containers .The unit is not generating any
effluent or emission. They have obtained authorization under Hazardous waste (M& H) Rules
1989.
EXCEL THREADS.
Date of inspection: 30-5-05
The industry was engaged in producing cotton threads .Now the unit is closed.
SUCCESS SPINNING PVT. LTD.
Date of inspection: 30-5-05
The industry is producing polyester yarn. Production rate is 36.2 t/Year. Raw material is
synthetic fibre and the quantity comes 37 t/year. The raw material is in the form of
compressed bundles. The fibre is converted into yarn by passing through different spindles.
The industry is not generating any liquid effluent.
There are chances for sound pollution and spreading of polyester dust.
The Company is required to obtain the consent under the Air Act1981.
PACAFIC PACKAGINGS
Date of Inspection: 27-6-05
The industry is engaged in the production of corrugated packing sheets .The raw
materials used are paper reals and gun. The production process is as follows.
Paper real is passed through a corrugation machine. Corrugated paper is pasted
in a pasting machine after application of gum. Required covering paper is pasted
over the corrugated pasted sheet. This is then pressed in a hydraulic press and
650
then packed. The industry is operating with 30 HP connected load. The unit is not
generating any effluent or emission.
POPULAR MEGA MOTORS (P) LTD
Date of Inspection: 27-6-05
The unit is engaged in servicing of vehicles and bus body building .The quantity of
waste oil collected during servicing comes to 1200litre/m. This is collected in a masonry tank
and disposed to authorised recycler Southern Refineries. The company has obtained
authorization under the HW (M&H) rules and consent under the Water Act from Pollution
Control Board upto 31.12.2007. The quantity of effluent generation is 1500 lit/day. An Oil`
trap is provided for separation of oil and grease. Treated effluent is discharged into land for
percolation. The industry is also doing bus bodybuilding and accident repair works. About
seven nos of bus bodybuilding is done in a month.
Recommendation:
Should obtain the Boards consent under the Air Act.
MEERAN ACIDS PVT LTD, ELOOR.
Date of Inspection: 23-06-05
Engaged in the storage and distribution of commercial acids and chemicals. .An
enclosed room is provided for storing Sulphuric acid,Nitric acid, Hydrochloric
acid, Phosphoric acid acid chemicals like caustic soda, washing soda etc. Soak pit
near sulphuric acid storage tank is seen containing acidic effluent (pH-1.2). Has
obtained board’s consent under the air act upto 31-12-2005.Arrangement for
neutralizing the effluent should be provided.
Colour code
Red: Pollutants not conforming to the standards.
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.
Analysis Reports of the Effluent/ Sludge.
Source
Date of sample collection
Sample Identification No
Name of the Lab
Sl.
No.
1
2
3
4
Determinant
PH
Nitrates as N
Phosphates
Sulphates
: Meeran Acids- Pit near acid storage.
: 30-6-05
: LAEC 236(Pit near acid storage )
: Central Laboratory, K.S.P.C.B, Gandhi Nagar.
Unit
Pit near acid storage
mg/l
,,
,,
2.1
11.0
ND
2250
651
AGAR AGAR MANUFACTURING UNIT.
Date of Inspection: 23-06-05
Production not started. The unit has obtained board’s NOC
KINGSTON POLYMERS.
Date of Inspection: 23-06-05
Remains closed.
JAYSONS INDUSTRIES EDAYAR.
Date of Inspection: 23-06-05
This unit produces Audiocassette covers, CD covers, by moulding virgin plastic granules.
The rejects are reused.
STEEL ARC RODS AND WIRES.
Date of Inspection: 23-06-05
In this unit MS wires are copper plated .the unit has not obtained board’s
consent under the water act for discharging the effluent from plating activities.
Should make arrangements for treating the liquid effluent and obtain the water
consent. Scrap is disposed by sale.
PNEUNO HYDRAULICS PVT LTD.
Date of Inspection: 23-06-05
They are engaged in the design and assembling of hydraulic equipments as per customer’s
requirement.
CEE GEE CEE ENGG WORKS.
Date of Inspection: 23-06-05
It is found closed.
CEE JEE LUBRICANTS, EDAYAR.
652
Name of Industry
: Cee Jee Lubricants, Edayar.
Date of Inspection
: 16-3-05.
Raw materials
:Used oil- 16 KL/ day.
Waste oil – 20 KL/day.
Clay – 240 kg/day.
LDO/ Diesel – 200 litre
Products
: Lube base stock- 10400 litres
Light oil
- 800 liter
Spindle oil
- 800 liter
RPFO
-13000 liter.
Grease
-1MT
Process:
1.For used oil
Thin film distillation based process is adopted for re refining used oil. Used oil
taken in storage tank is passed through coarse filter. Filtered used oil containing
high percentage of colloids is fed in dehydration cum defueling kettle. Filtered
used oil containing very low amount or no colloid is fed to dehydration cum
defueling kettle. Vaccum is applied below 200 mm Hg by vaccum pump and light
oil is collected in receiver.
During dehydration water is collected in dehydration receiver. From both the
kettle, dehydrated oil is filtered by rotary vaccum filter when filtered oil is
collected in receiver. The colloidal dirts collected in tray amounts to be hardly
5kg/1000kg of oil. The filtered oil is taken in depol kettle where fine
polymeric/dirts are centrifuged out by centrifuge. The clear but deep colour oil is
distilled in thin film evaporator under high ultra vaccum.
The distilled base oil, if required to be fractioned, it is done in the same thin film
evaporator in a continuous duration as found necessary just by raising
temperature and increasing vaccum. Some type of base oil so obtained is
required to be clay treated and polished by 2-3%clay and filtered.
2.For waste oil
The main purpose of the waste oil processing is to increase the fluidity and
Flammability of the waste oil and purify by removing water and foreign matters
including gritty inorganic materials, metals, plastics, cotton waste etc using
methods such as Heating, Filtering, Gravity Settling, Centrifuging, Dehydration,
Viscosity adjustment etc.
653
Waste oil is stored in the MS tanks, allowed to remain for several hours. During this time
gravity settling is applied. Water and other heavy solid materials are removed from the bottom
of the storage tank to the effluent tank. Fairly clean oil left in the storage tank transferred to
the dehydration vessel. In the dehydrated vessel the oil is heated to a temperature of 650C for
adjusting viscosity of the oil and thoroughly circulated for mixing by a screw pump. This oil
is allowed to remain for one hour. Then the free water settled at the bottom is drained to an
effluent tank. The remained fine oil is again heated upto the temperature of 120oC using a
thermic fluid heating system under vaccum for removing the moisture content.
The waste oil may contain 5 to 30 % of water. The drained water, after treatment, is used for
industrial application in the cooling tower, incinerator scrubber, Pump Gland Cooling etc.
The treated oil is pumped into a Bucket type centrifuge for removing fine foreign particles
that is present in the oil. After centrifuging the oil is discharged to a sump tank by gravity.
Then oil pumped into a blending kettle for mixing LDO or Kerosene, whichever is available
and viable in the market, to improve its fuel character and viscosity. About 5 to 15 % of LDO/
Kerosene is blended based on the characteristics of the waste oil. The product is pumped into
the Product storage tank.
Waste:
Spent Clay- 20 kg
ETP sludge-25 kg.
Incinerator ash –18 kg
Findings:
1. During the time of inspection there was no processing of used oil/waste oil. The
factory is seen producing grease from lube base oil using steam-jacketed reactor.
2. The unit has obtained Board’s authorization under Hazardous Waste (Management
and Handling) Rules 1989 vide order No. PCB/HWMA/R1/56/2001 dated 28-7-01 for
five years to operate a facility for collection, reception, treatment, storage, transport
and disposal of hazardous waste.
This authorization was amended vide order dated 2-5-02 to handle used oil only upto
9000 KLA.
CPCB vide order no: B-29016 (279)/ 1 (Reg)/04/HWMD dated 28-9-04 granted
approval to permit re refining of used oil valid upto 31-12-04. The authorization dated
28-7-2001 was amended vide order dated 11-3-2005 in the light of the CPCB direction
that the Board should ensure that unit stops all procurements and re refining activities
with effect from 1-1-05 and the unit should not start the activities without obtaining
registration from CPCB. The unit was permitted to conduct trial run for recycling of
waste oil and re refining of used oil for a period of three months strictly following the
provisions of the HW Rules.
CPCB also imposed that the unit shall ensure that the re refining of all the used oil
procured during the period upto 31-12-2004 is completed by 31st December 2004 and
no further procurement / re refining of used oil shall be carried out without obtaining
the required registration from CPCB.
654
3. The unit has obtained Board’s consent under the Air (Prevention and Control of
Pollution) Act 1981 valid upto 31-12-2005 to process waste oil and oil containing
sludge to produce rubber process oil 101 and 102, process oil medium and process oil
II grade and making emissions from the mini boiler, vaccum distillation, incinerator
and generator.
4. Obtained consent under Water Act valid upto 31-12-2007 for discharging trade
effluent through outlet No. 1 and storm water from the compound through oil
separator through outlet No 2 to roadside drain. Condition was also imposed to obtain
clearances from the Board including the consent under the Air Act, authorization
under HW Rules and registration from the CPCB.
5. It is reported by the firm that their application for registration of used / waste oil
recycling / re refining is pending with CPCB.
6. New plant and machinery for re refining of used oil installed by the unit consists of
thin film technology accepted by EST under HW Rules. It is also reported by the firm
that individual file of equipments for thin film evaporators are over.
7. An incinerator is provided for disposal of residue arising out of recycling/re refining.
8. There is one boiler of capacity one tonne per hour fired by firewood provided with a
chimney of 11 meters, a thermic fluid heater of stack height 30 meters and an
incinerator stack of 31 meters.
9. Existing generator set of 63 KVA is reported to be replaced with another one of 125
KVA.
10. The effluent and storm water are taken to collection tank provided with oil trap. Two
number of large oil traps having four chambers each are provided to increase the
efficiency of these traps. Also for controlling oil spillage oil sumps at places likely to
have oil leakage is provided. After removing the oil, the effluent is let out to roadside
through the authorized outlet.
11. Source of water is water supply scheme of water authority and water consumption is
reported as 5000 liter per day.
12. Grease production is seen going on.
Recommendation:
1. Air pollution control measures for incinerator emission such as scrubbing system shall
be provided.
2. Scrubber water shall be disposed only after providing treatment. Oil spillage from the
premises of the storage tanks shall be collected separately for further refining.
3. Only one outlet is constructed for discharging the storm water and the effluent. Storm
water drain shall not be combined with effluent drain and separate outlets as specified
in the consent order shall be provided.
4 A delay pond shall be constructed for storm water drain.
5. Thick green belt shall be grown and maintained along the premises.
6. Treated water shall be recycled or reused
655
7. Adequate stack height shall be provided to the Genset.
CUBE INDIA RUBBERS (P) LTD, EDAYAR
Name of the Industry
:Cube India Rubbers Pvt.Ltd,Edayar
Date of Inspection
: 7-4-05
Name of the Product/s
: Hawai chappal
Raw materials
: Rubber sheet and allied chemicals
This is an existing unit renovated recently for producing 2000 pairs hawai
chappal per day. Commercial production is not started. The rawmaterials rubber
sheet and allied chemicals are fed to grinder and the product is pressed and cut
into required size to produce chappals . The source of water is well and cooling
water is recirculated. There is no source of process effluent.
The unit is having a thermic fluid heater provided with 32 ft high and a generator set of 125
KVA .
During the visit the factory authorities have complained against the nuisance of carbon dust
from Sree Sakthi paper mill
Recommendations:
1. The unit is required to obtain the Board’s consent under the Air(Prevention and
Control of Pollution)Act 1981
2. Used oil is to be disposed as per Hazardous Waste (Management and Handling) Rules
1989
3. Green belt is to be developed around the premises.
GREENFIELD CHEMICALS AND FOOT WEARS,EDAYAR.
Name of the Industry
:Greenfield Chemicals and Foot wears,
Edayar.
Date of Inspection
: 03-03-05
Name of the Product/s
: Moulded shoes and Chappals – 30000
Pairs / month.
Raw materials
: Waste Chappals
Process:
Waste plastic chappals are ground and then extruded in an extruder. Blowing
agent and stearic acid are added and the product is made in moulding machine.
656
Cutting waste was seen disposed by open burning. Received complaint regarding
the open burning of wastes. They are using a generator set having capacity of
125 KVA.
Recommendations:
1. Consent under the Air (Prevention and Control of Pollution) Act 1981 is to be
obtained.
2. Open burning of waste is to be stopped.
3. Facility for the disposal of solid waste is to be provided.
4. Used oil is to be disposed as per Hazardous Waste (Management and Handling) Rules
1989.
JYOTHI CHEMICAL INDUSTRIES, EDAYAR.
Name of the Industry
: Jyothi Chemical Industries, Edayar.
Date of Inspection
: 03-03-05
Name of the Product/s
: Dish wash bar. Packing of Ant repellant and washing
soda are also carried out in the factory.
Raw materials
:
For Cleaning powder
For Soap
:Dolomite powder, soda ash, mixing Slurry.
:Mixing slurry, soda ash, dolomite and Sodium silicate.
Findings:
The products are seen put on the floor of the factory for packing. The industry is not
generating any liquid waste or solid waste.
Recommendations.
1. The company may be asked to produce copy of document showing permission for
production/packing of the items.
2. If they are having permission for packing of ant repellant and washing soda, they may
be directed to provide separate area for the purpose.
JYOTHIS INDUSTRIES, EDAYAR
Name of the Industry
:Jyothis Industries, Edayar
Date of Inspection
: 03-03-05
This is an SSI Unit engaged in bottling of cleaning liquid.
The industry is not generating any liquid or solid waste.
SOUTHERN COMPOSITES PVT. LTD.
657
Name of the Industry
: Southern Composites Pvt. Ltd.
Date of Inspection
: 30-03-05
Name of the Product/s
: Polyester resins-2300kg/day
PVA emulsion-50 kg of /day
Raw materials
: Propylene glycol, styrene monomer,
maleic unhydride etc.
Process for manufacturing polyester resin:
Production process involves polyesterification reaction and
condensation polymerization and the only by product of the reaction is water
vapour. The amount of water vapour coming out during the reactions is about 68 %. The water molecules formed is passed through a packed rectification
column. Column temperature is controlled with a temperature controller, which is
set to a maximum of 1000 C, to ensure that no reactants like glycol are distilled
off. As soon as the desired degree of polymerization is attained the batch is
cooled and transferred to another blender where it is mixed with another
monomer. This blended product is filtered to get polyester resin.
Process for manufacturing PVA granules:
About 35kg of water is taken into a clean aluminium vessel and it
is heated to a temperature 95-100oC. PVA granules (5-7kg) are added and
stirred well to dissolve the granules completely. It is allowed to cool and then
packed into cans.
Findings:
1.
2.
3.
4.
Company is having two diesel generator sets of 63 KVA and 125 KVA.
No effluent is generated from the production process.
No fugitive emissions are found.
House keeping found to be good.
Recommendations:
Company should obtain the Board’s consent under Air act.
WINNER SEALS PVT LTD.
The industry is producing rubber seals for machineries.
Raw materials
: Synthetic rubber –8 kg/day.
Rubber Chemicals –2kg/day.
Fabric –5 metres/day.
Products
: Rubber seals-1000 nos/day.
658
Process :
The ingredients are mixed and converted into sheet in a roller mill. The sheet is cut into
required size. This is placed over the mould and vulcanized in electrically heated press at a
temperature range from 800C to 1500C according to the size of the seal. The company is
making iron moulds in the unit itself by using lathe. There is no liquid waste or emission from
the industry. Cutting waste of rubber is the only waste generated from the unit. Quantity of
the same is negligible .The company had obtained NOC from KSPCB before starting the unit.
DUROCOATS PAINTS PVT LTD.
The industry is engaged in the production of paints and primers.
Raw materials
: Extenders -116kg/day.
Solvents -100kg/day.
Pigments -14 kg/day.
Resin
- 65 kg/day.
In addition to the above the industry is using 6 kgs of Fungicide in a
month (0.1 % in water emulsion paint.)
Products
: Alkyd paints and primers-135 kg/day.
: Emulsion paints-160 kg/day.
Process:
The raw materials are mixed in various proportions in attritors and mixer. The attritor
is surrounded by a water column to control temperature. The cooling water used is recycled.
The formulated product is packed in drums /tins.
Findings:
The total quantity of water consumed by the industry is 2000 litres/day which includes
consumption for domestic purpose also.
The mixing unit is washed occasionally. The quantity of effluent comes about 20 litres per
day.
Company has obtained consent of the Board under the water act. This is discharged into their
own land for production.
Recommendation:
1. Effluent should be treated properly before discharge.
2. Should obtain authorization as per HW rule for the disposal of residue and etp sludge.
3. The company may be directed to maintain good house keeping.
KRISHNA ENGINEERING WORKS.
659
This is a tiny unit doing fabrication works of gates, grills etc. Job work is carried out as per
orders. The industry is not causing pollution problems.
ALBA POLYMERS.
Date of Inspection
: 27-4-05
Raw materials
:Virgin granules
Products
: Polythene bags and Packing materials
Process:
The virgin granules purchased are fed to an extruder. The films formed are used
for manufacturing polythene bags and packing sheets. The capacity of the unit is
approx: 200kg/day. The unit is having registration certificate for handling plastic.
House keeping is satisfactory. No effluent is generated. (The unit is established
in the year 1996).
PANAKKAL POLYMERS.
Date of Inspection
:27-4-05
Raw materials
:Virgin granules
Products
:Plastic mats and virgin granules are purchased and fed to
extruders and converted into fibres which are fed in to power
looms for weaving mats.
Four sets of extruder are installed in the unit. Average production is 2.5 t/m of
the plastic mats. The unit has obtained valid registration certificate under Plastic
Rules from Pollution Control Board for handling plastics. House keeping found to
be satisfactory.
NEW PLASTIC INDUSTRIES.
Date of Inspection
:27-4-05
Raw materials
:Virgin granules
Products
: Plastic Bags
Process:
Virgin granules are fed into an extruder and film formed is used for
manufacturing plastic bags. Approx: 5 t/month plastic is manufactured .The unit
660
is having single extruder. The unit is not having registration certificate from
Pollution Control Board for handling plastic.
Recommendation:
Should obtain Boards certificate of registration under Plastic Rules.
R.K.CARTONS.
Date of Inspection
:27-4-05
Raw materials
:Kraft paper-1t
Gum-30 kg
Stitchingwire-.4kg,
Ink-1kg
Products
:Corrugated Paper Cartons
The unit is producing approx: 1t/day corrugated cartons for packing. The facilities for printing
is available. House keeping found to be good.
UNAUTHORISED LIME UNIT OWNED BY MR. SURESH.
Date of Inspection
:23-3-05 & 29-3-05.
This industry is situated near and behind M/s Kunnath Chemicals,Edayar.It is producing lime
powder. There are two kilns. Lime shell is washed in open area and then put into the kiln.
After loading the kilns with lime shell and required quantity of coke, it is fired .Air is supplied
using a 5 HP blower. The operation of the kiln is twice in a week .The product is taken out,
powdered,sieved and packed .The quantity of product is 2.75 T per kiln in one batch.
This unit has not produced any order issued by the District Industries Centre (DIC) to justify
the valid occupation of the land in its favour. It is doubtful whether the unit is having any
registration with DIC for operation. The Board has not issued any consent under Air Act or
Water Act. There is no record in Pollution Control Board (PCB) regarding the operation of
this unit. The unit could not produce any consent orders issued.The committee therefore
resolve to take measure for closure of the unit forthwith and resume land.
UNAUTHORIZED TALLOW EXTRACTION UNITS.
Date of Inspection
: 4-11-05 & 16-11-05.
661
1. Ashan Exports, Edayar,
2. Tallow Unit of Mr.Siraj, Edayar
3. Juno Industries of Mr. Jaison, Edayar.
Ashan Exports Edayar is situated near Adithtya engineering works Edayar.
Tallow unit of Mr. Siraj Edayar is a unit functioning near AES Industries Edayar; the
phone num:of the owner Mr. Siraj is 2443066.
Juno industry is near Cee Jee Lubricants.
These units are engaged in extraction of tallow from fat collected from different
slaughterhouses. The material is put into iron drums and heated by using firewood as
fuel and filtered. Severe foul smell is found coming out during the process. There are no
facilities to control Air Pollution problems. The unit is not having any facility for the
proper collection, storage and disposal of filter residue.
These units have not filled the profoma and submitted any records for operating the
unit. It is even doubtful whether they are the real allottees of land of the District
Industries Centre (DIC) Ernakulam.The units could not produce any registration with
the DIC Ernakulam nor the order of allotment in their favour.
Pollution Control Board (PCB) also have not issued any consent under Water act. To
justify the operation of these units there is absolutely no records with PCB. These units
are unauthorized and illegal and are liable to be closed down forthwith.
The land allotted to this unit may also be resumed if these units are not found to be not the
authorized allottees. The board and DIC may therefore jointly take action to ensure the illegal
operation of these units which are causing serious air pollution and nuisance to the nearby
industries.
POWER CONTROLS, EDAYAR
Date of inspection
: 05/03/05, 26/09/05
Raw material
: Lead ingots-3000 kg /month
Lead oxide-2000 kg/month
DM water carbide black, and Sulphuric Acid.
Product
:Tubular battery plate: Positive plate- 150 per day
Negative plate- 180 per day.
Production process:
662
Lead ingot is melted in an open lead-melting furnace heated by LPG burner and casted into
positive and negative grid. Lead oxide pasting is applied to negative plate, pressed and cured
at room temperature. The positive grids are filled with lead oxide in a separate chamber,
dipped in sulphuric acid and cured. The cured positive and negative plates are charged by
dipping in sulphuric acid. Plates are then washed in distilled water, dried in air and
assembled.
Waste:
The wastewater generated from plate washing is highly acidic and is discharged into a pit
where it is reportedly treated with lime. The treated effluent is collected in a collection tank
Lead oxide powder is seen spread all over the processing area.
Findings:
1. Factory building is very old and roof height is very low. It is unsuitable for conducting
an industry.
2. Lead oxide powder, a toxic carcinogen is seen spread all over the processing area.
3. Lead oxide filling is done manually into bare hands. Workers are not provided with
mask and gloves and are found carelessly handling the lead dust.
4. Lead oxide filling is done manually with bare hands. Workers are not provided with
mask and gloves and are carelessly handling the lead dust.
5. Air Pollution Control measures are not provided at the Lead melting pot. A hood is
provided at the Lead oxide-filling chamber without any dust collection arrangement.
The factory authorities reported that the system is dismantled for repair.
6. Wastewaters from plate washings are discharged into a pit from where it reaches
another collection tank. According to the authorities effluent in the collection pit is
neutralized using lime before discharging into the collection tank. The pH of the
effluent in the first soak pit and second collection tank are noted as 1.8 and 5.0
respectively. The well water showed a pH 3.2. The well water pH during previous
inspection on 5-3-05 was 2.8.Report of the effluent shows that the effluent is highly
acidic.
7. Effluent treatment facility is not adequate. Report of analysis of the effluent shows
that the effluent is highly acidic
8. Due to the land discharge of untreated acidic effluent, the well in the factory
compound has become highly acidic. The unit has not obtained Board’s consent under
the Water Act and Air Act.
9. The unit has not obtained authorization as per Hazardous Waste (Management and
Handling) Rules 1989 for the disposal of the residue of lead powder from furnace.
Recommendation:
1. Should provide arrangement for the collection of lead fumes from the melting furnace.
2. Adequate arrangement for dosing the chemicals and treating the effluent should be
provided.
3. The effluent pit should be made percolation free.
4. Should obtain Board’s consent under the Air (Prevention and Control of Pollution)
Act 1981 and Water (Prevention and Control of Pollution) Act 1974.
5. Proper attention should be given to prevent any seepage of acidic effluent into land.
6. The well in the premises is highly acidic and it should be directed to be closed.
663
7. The units should be directed to obtain consent under Batteries (Management and
Handling) Rules, 2001.
The committee decided to call the occupier of the unit and hear him on the report.
Accordingly the occupier was called to appear before the committee on 16-7-05 .The
occupiers Mr.K.A.joseph and Biju Kuriyan appeared on 16-7-05 and assured to
implement effective measures to content the pollution and to construct necessary building.
He submitted a letter 18-7-05 undertaking to do certain work within a time frame. The
committee again inspected on 26-9-05 to assess the improvement made pursuant to the
undertaking. During inspection the following works have been found carried out.
Findings.
The unit has completed the work of effluent settling tank. The well in the premises
(contaminated) is closed. The building work is half way through. Work being in progress,
the unit may be inspected father after 15-10-05 being the last date of completion of work
as per the undertaking of the unit.
ULTRA TILES (P) LTD
Date of Inspection: 27/06/05,26/09/05
The industry is producing designer tiles. The raw materials used are
Cement –170 t/m.
Sand –30,,
Gravel-150,,
Black furnishing slag – 170 to 200 t/m.
Pigment – 3 t/m
1.
2.
3.
4.
5.
The raw materials are mixed in required proportions and moulded in moulds having different
shapes. The production rate is 6500 sq ft per day. Curing of the product is done in open air for
3 to 7 days. There is no effluent discharge from the industry. They have installed a 25 KVA
Genset. The Company should apply and obtain consent under the Air Act. The analysis report
of the black furnishing slag reveals the following result.
Sl.
No.
1.
2
3
4
Determinant
Unit
Zinc
Iron
Lead
Cadmium
LAEC
A26
mg/kg 4.34
,,
11150
,,
156
”
7.8
5
6
7
8
9
Copper
Nickel
Phosphate
Cyanides
Magnesium
”
”
”
”
”
6.2
25.8
14.11
BDL
87.2
664
10
11
12
Hexavalent Chromium
Total Chromium
Manganese
”
”
”
BDL
107.2
2690
In the light of this lab report the unit has to obtain Authorization under Hazardous Waste
(Management and Handling) Rules 1989.The unit should also obtain consent Air (prevention
and control) Act.
COCHIN CHEMICALS, EDAYAR.
Date of inspection
: 5/4/2005, 21/9/05, 22/9/05,26/9/05
Cochin Chemicals is a unit producing Envirofloc, aluminum chloride and ferrous chloride as
per the Performa submitted by the unit. The raw materials are waste pickling liquors and
pharmaceutical waste. According to the unit the production process is mixing different types
of waste acid in different proportion .The unit claims no waste generation.
LAEC inspected this unit 4 times on various dates along with officials of PCB
namely Mr.K.S.Soman Environmental Engineer and Mr.Shanavaz, Assistant Scientists.
During its first inspection on 2-2-05, there was no processing activity. There was no gate at
the entry point. LAEC could find two HDPE and two MS tanks and one tanker lorry in the
premises of the unit. The ETP was found idle and neglected. There was wild growth around
the ETP .The pump seen near ETP was rusted. Near the ETP, the land was wet by the
discharge of some effluent. LAEC took samples of sludge found near ETP. There was only
one employ in the unit at the time of inspection.
LAEC on its second inspection on 1-9-05 found the unit closed by a gate. There was nobody
inside the unit to open the gate for inspection. LAEC returned without being able to inspect.
Thereafter LAEC conducted 3 consecutive inspections on 21-9-05, 22-9-05,and 26-9-05.
During these inspections also, there was no processing activity in the unit. However the
inspecting team could find two tanker lorries carrying hot waste ferrous chloride brought from
M/S CMRL. There was emission of fumes from the vent on the top of the tanker lorries. The
display board in the tanker lorries claims license to carry hydrochloric acid. The lorries were
owned by Dr P.Sivasnakara Pillai.
According to the driver of the lorry, the waste ferrous chloride in the tanker lorries
were brought from CMRL, Edayar and the effluent will be transported to various destinations
as per the instructions from the unit. The two HDP tanks in the premises having
approximately 4000litres capacity were full. LAEC took samples from these two tanks.
During the inspections, LAEC detected two holes in the bottom of the compound wall of the
unit used for discharging effluent in to an illegal drain carrying effluent to the adjacent plot
and ultimately reaching River Periyar. When asked the driver of the tanker lorry explained
that after unloading the waste ferrous chloride brought from CMRL in different batches to
various destinations, the trucker lorries are brought back to the unit and the sludge
accumulated in the tanker lorries are discharged in to the premises. The effluents so
discharged flows into open land through two holes cut at the bottom of the compound wall of
the unit. The effluent reaches the open land lying on the southern side of the unit and
ultimately river Periyar.
LAEC took samples from the adjacent land on southern side of the unit and also from
the premises of the unit. According to the tanker lorry driver, waste ferrous chloride is
transported from CMRL to other destinations in the tanker lorries of Dr P.Sivasnakara Pillai
and there will be minimum 100 to 150 kgs sludge in each two trips under the bottom of these
665
lorries. This sludge is discharged in to the open premises. There were 3 lorries in the premises
(belonging to Dr P.Sivasnakara Pillai) used for the said purpose.
The sample taken from two HDP tanks and from open premises both inside and outside the
premises were got analyzed in central laboratory .The result of the analyses of the sample
from HDPE tank indicates the following parameters.
Sl.
Determinant
Unit
LAEC Enviro
Soil from the Sludge
No.
50
floc
tanker
from
sample
washing area adjacent
compound
H
1
p
3.91
3.37
7.38
7.34
2
TDS
mg/kg 11600
3
Zinc
169.2 167.6
116.46
4
Iron
71400 165000
116375
116625
5
Lead
214
122
122
146
6
Mercury
0.1
7
Cadmium
5.4
BDL
BDL
BDL
8
Copper
69.6
52.8
48.6
43.8
9
Nickel
83.6
74
102
89.8
10
Fluoride
7.85
11
Chlorides
5000
150000
1200
2000
12
Nitrates as N
250
13
Sulphate
188
14
Sulphide
BDL
80
15
Magnesium
244
16
Acidity
1000
17
Phenolic
BDL
Compounds
18
Total Chromium
113.8 285.4
252.6
253
19
Manganese
101.6 1220
86.2
20
Hexa chromium
1.55
The result shows that the sludge discharged in to the open premises contains hazardous waste
and could not have been discharged so casually and negligently especially due to the
hazardous nature of the effluent/sludge in the manner as done by the unit.
LAEC took sample of the envirofloc, the alleged product of the unit, which on lab analyzing
found to have the following parameters.
Sl.
No.
1.
2
3
4
5
6
7
8
9
Determinant
Unit
pH
TDS
Iron
Lead
Copper
Nickel
Arsenic
Chlorides
Sulphate
mg/l
LAEC
14
1.4
622030
256250
79.8
2.4
2.59
ND
136057
ND
666
According to the unit, the enviro floc is used as floculant for accelerating the settling
of the effluent. The raw material of this floculant is ferrous chloride. Ferrous chloride is a
component for effluent treatment, sewage treatment etc. The waste ferrous chloride of CMRL
is highly acidic with pH 0.5 - 1.5 and contains toxic pollutants such as Zinc 10.06 mg/litre,
Lead 9.9 mg/litre, Cadmium 0.5 mg/litre, Copper 2.41 mg/litre, nickel 6.1mg/litre, total
chromium 46.78mg/litre, manganese 19.24 mg/litre. It is admittedly a hazardous waste
obtained from M/S CMRL. This hazardous waste, which is being used by this unit, is not after
removing the heavy metals and the sludge. The unit is using the effluent without any
treatment and adds some chemicals directly, which involve no process as cold be seen from
inspection. The envirofloc supplied by this unit when used by other units for treatment, their
sludge get all sorts of heavy metals, though there is no scope otherwise for heavy metal’s
presence in their sludge. This unit under the guise of making envirofloc and distributing the
same as floucculant is virtually distributing hazardous waste containing hazardous chemicals
to other units. This unit does not have facilities for disposal of hazardous waste. The enviro
floc supplied by this unit cause serious environment problems in all areas as their flocculent
contains all heavy metals and hazardous chemicals.
Ferrous chloride is used for treatment of effluent. Using waste ferrous chloride for the
preparation of flocculant (as is being done by this unit) and its distribution as flocculent is to
permit the distribution of hazardous waste of one unit to the other units. Use of Enviro floc of
this unit, as flocculent by other units render their sludge in the category of hazardous nature
by virtue of the presence of hazardous chemicals in the sludge. Since the waste ferrous
chloride solution is highly acidic, the metals are in the dissolved state, its direct application
leads contamination of wastewater to be treated with these metals. The unit has no facility to
remove the heavy metals from the waste ferrous chloride before the use of the same for the
preparation of Envirofloc of the unit.
The analysis reports of the sludge sample collected from the adjacent land of M/s
Cochin Chemicals show high concentration of Iron(1,16,625mg/kg),Chlorides
2000mg/kg with Lead 164mg/kg,Copper 43.8mg/kg, Nickel 89.8mg/kg,
Sulphides 80mg/kg, Total Chromium 253mg/kg and Hexa chromium 1.55mg/kg
These results indicate the similarity in the content of Iron, (165000&116375mg/kg),
Chlorides(1,50,000&1200mg/kg),Lead(122&122mg/kg),Copper(52.8&48.6mg/kg),Nickel(74
&102mg/kg),Total chromium(285.4&252.6mg/kg)etc in the floc sample and soil sample
collected from tanker lorry washing area of the company respectively leads to the inference
that the sludge in the adjacent area is the hazardous waste discharged by the company.
This unit has obtained authorization under the Hazardous Waste (Management and
Handling) Rules 1989 valid upto 5 year from the 30-3-02.The unit has no hazardous waste
disposal facility to discharge the sludge containing hazardous chemicals. It has no water
consent under Water (Prevention and Control of Pollution) Act 1974. The unit was found not
complying with any of the conditions of authorization issued under the Hazardous Waste
(Management and Handling) Rules 1989. Though it claims that it generates no waste, the
premises of the unit and adjacent land are found as a hazardous waste disposal site. Trade
effluent of other companies are found discharged in this unit .The unit is liable to account for
the sludge seen in its premises and in the adjacent premises leading through an illegal drain
maintained clandestinely in between two walls.
667
The owner of this unit Dr P.Sivasankara Pillai is known environmental consultant
and one of the accredited consultants of the PCB. Many senior officials of the board are his
students. The occupier of this unit is the consultant of certain major units in Eloor Edayar belt.
Some of the units where he is consultant have been booked for serious violation
environmental laws and even the ETP there found to be deceptive. He being an environmental
expert and consultant for many major units and being fully conscious of the impact of
indiscriminate discharge of pollutant, his conduct has to be seriously viewed as a calculated
affront on the environment.
The unit has not accounted for any sludge generation. Effluent from the premises of
the unit is seen reaching a drain constructed in between the compound wall of M/s Cochin
chemicals and adjacent property through an opening in the bottom of compound wall of the
unit. One fails to understand why there is two compound walls, one of which is half of the
size of the other wall, leaving a space of half feet in between the walls .It is through this gap
the drain is cut to carry effluent to the adjacent land finally reaching the Periyar which is
hardly 125 meters away from the site. Looking at the wall from the compound of this unit,
one would not get the presence of any drain in-between the walls. This deceptive way of
discharging effluent to the Periyar and near by land was unfortunately could not be detected
by the Board.
The unit does not have hazardous waste storage facility though it has obtained
authorization under Hazardous Waste (Management and Handling) Rules 1989 .It has also not
filed any returns to the Board. The unit is liable to account for the presents of hazardous
chemical sludge accumulated in its premises and in the adjacent premises. The trade effluent
discharged into the premises is an illegal activity prohibited by law. The unit has not obtained
consent under Water Act. The only activity LAEC could find in the unit is collection of waste
ferrous chloride solution from M/s CMRL and transport through tanker, which is licensed to
transport only hydrochloric acid. The unit has been issued with authorization for collection,
reception, treatment, storage, transport and disposal of ferrous chloride, which specifies that
the entire quantity of hazardous waste collected, received and stored, shall be utilized as raw
material for the production of chemical of wastewater treatment. The unit is found violating
this condition of authorization in as much as waste fereous chloride has been found
discharged into the open land leading to the river. As per the authorization he is required to
maintain form 9 under condition number 3. However no such form is seen issued. The Board
has reported that this unit as required under the authorization files no manifest.
Having regard to the serious ness of the nature of discharge of hazardous waste by
this unit owned by none other than an accredited senior environmental consultant of PCB and
considering the fact that illegal activities being going on undetectably by PCB, LAEC find no
justification except to recommend closure of the unit forthwith. The unit should be allowed to
start function only after it provides adequate effluent treatment plant and other remedial
measures to content the pollution. The unit should also be directed to remove the sludge
accumulated in its premises and adjacent land. The unit must be asked to set up secured
landfill for disposal of hazardous waste, before allowing the unit to restart.
668
669
FALCON INFRASTRUCTURES LTD , ELOOR.
670
This truck terminal project is commissioned in July 2004.The facilities of the
project include Go down, workshop, weigh bridge, dormitory facilities, restaurant
and service station. The construction of the service station is almost over, and is
yet to commence operation.
The source of water is an open well in the premises near to River Periyar. For
discharging wastewater from service station, a grit chamber and an oil trap are
constructed. The quantity of discharge is reportedly 2000 lit/day. The unit has
applied for Boards consent under the Water Act.
Recommendations:
1. Should provide adequate treatment facility to the whole quantity of wastewater
generated from the various establishments functioning under M/s of Falcon
Enterprises and should obtain Boards consent under the Water Act.
2. Should obtain the authorization under HW Rules for the disposal of used oil from the
proposed workshop / service station.
3. Oil trap system constructed for treating effluent from the service station is to be
augmented for the maximum quantity of effluent discharge anticipated from the
service station with the proposed target of trucks.
4. Oil traps and delay pond is to be provided in the storm water drains leading to River
Periyar for containing oil spillage.
COPPER BLUES, EDAYAR
Date of Inspection : 4-2-05
Raw material
:Wire copper scraps-298.5 kg/day
Sulphuric acid-447 kg/day and
Fire wood-200kg/day
Product
: Copper sulphate 1MT/day
Unit is established in 1994.
Process:
Capacity 2.5 tons/day.
Scrap copper purchased is reacted in dilute copper sulphate solution containing sulphuric acid
in presence of air at 70-75 deg.centigrade. The concentrated CuSo4 solution is drained in to
PVC drums and cooled. The crystals are collected and dried in centrifuge before packing. The
mother liquor remaining in the drum and filtrate from the centrifuge are recycled for the next
batch and operation. The spillage is collected by mixing with sand and washed to get back
copper sulphate. The sand is mixed with hydrated lime for neutralization and disposed on
land.
671
Findings/Recommendation.
1. Discharge of effluent into the adjacent premises is noticed during the inspection. This
should be stopped and arrangement should be provided for collecting the spillage and
flour washings.
2. Should obtain the Board’s consent under the Air Act and water Act.
GENERAL CHEMICAL AND POLYMERS,EDAYAR
Date of inspection
: 4-2-05
Raw materials
:Toluene,
Mineral turpentine oil,
Spirit,
Acetone,
Ethyl acetate and
Butyl acetate.
Product :
Thinners and additives approx 4000lit/month
Inflammable chemicals stored in underground storage facilities are taken and blended in
barrels as per requirements.
Recommendation
1. Should obtain the Boards consent under the Air Act.
2. Should obtain the Authorisation under HW rules.
3. Should provide thick green belt of fast growing trees.
SOUTHERN MARKETING ASSOCIATES,EDAYAR
Southern marketing associates is the authorized stockists of virgin plastics of Gas
authority of India ltd. At present this office is functioning as a go down .Two
different grades of virgin plastic granules are stored in sacks. This is a sister
concern of M/s Panangat Polymer Packings Pvt Ltd.
ANASWARA FIBRE INDUSTRIES,EDAYAR
This is a very tiny unit manufacturing motor covers, and bathtubs. The unit is using 2Kg resin
100gm accelerator and 100gms of catalyst for manufacturing 16 No:s of motor covers. There
is no chance of wastewater generation. Wool and fibre cutting waste disposed to outside
parties.
Recommendation
The unit should obtain Board’s consent under Air Act.
672
ASSOCIATED CHEMICALS INDUSTRIES, EDAYAR
Inspected on 2-02-05, 20-8-05
This unit found to be closed .No authorized person present.
EAST HILL RUBBERS,EDAYAR
Date of Inspection
: 04/02/05
Raw materials
: Natural rubber,
Carbon black,
Zinc oxide,
Sulphur,
Stearic acid,
Process oil,
Accelerator
Product
:Tread rubber-20T/month
Process:
Natural rubber and chemicals mixed together to get homogenous mixture and kept for aging.
After aging the compound will be extruded in different sizes as per requirement.
Findings:
1.
2.
3.
4.
The unit has got valid water consent up to 31-12-04.
House keeping found to be very poor.
Cooling water generated is recycled for the extruder.
Air Pollution control measures are not provided.
Recommendation
1. Should provide air pollution control measures and obtain Board’s consent under the
Air Act and Water Act.
2. Should provide a thick green belt of fast growing trees all along the periphery.
3. And improve House keeping
M/S KINGSTON PACKINGS.
Date of inspection
: 30/3/05
673
Raw materials
:Virgin granules
Products
: Plastic bags & packings- 3t/month
Process:
Virgin plastic granules are fed to extruder and the poly films thus formed is used
to make polythene bags. There is no effluent discharge or waste generation. The
unit is having air consent which is issued to M/s Kingston packings, under the
proprietorship of Mr.Shanavas.V.Ibrahim. But at present the unit is running in
the name M/s King plastics owned by Mr. Abdul Samad.
Recommendation
1. Should obtain the Certificate of Registration as per Recycled Plastics (Manufacture &
Usage) Rules.
2. The name of unit and ownership should be got changed in the consent order.
M/S MAMPAD RUBBER MANUFACTURING CO. LTD,EDAYAR
Date of inspection
:25/02/05
Raw materials
:Rubber scrap-3.5t/day
Product
:Crump rubber-3t/day
Process.
The unit purchases rubber scrap which is soaked in water, milled, dried and marketed as
crumb rubber.
The unit is having water consent up to 31-12-04 for discharging 6000l/day effluent into
Periyar River. The unit is temporarily closed since January 05. Rubber trap and two lagoons
are seen provided for effluent treatment.
Recommendation:
1. The ETP is totally inadequate for achieving the prescribed quality.
2. Consent under Water Act has to be renewed
VARKEYS INDUSTRIES,EDAYAR.
Date of inspection
: 04/02/05
Raw materials
:Intestine and Tendone of mammals collected from slaughterhouse.
674
Process:
Preliminary cleaned intestine is collected, cleaned and fat is removed using knife. Then
cleaned using water, socked in water for a day, and air filled manually, checked for puncture
if any, tied using thread, and sun dried for a day before preserving in 1/10 formalin solution
and sold to pharmaceutical units.
Findings:
1.Waste is collected in concrete tanks, and lime (CaO) powder is sprayed.
2.House keeping is found to be very poor. Unhygienic situation prevails inside the factory and
premises.
3.Wastewater is collected in a covered pit which is found to be leaching.
4.The unit has not obtained any clearance from the Board. An application for consent under
water act is reportedly submitted to Board.
Recommendation:
1. Should provide good house keeping.
2. Should provide pucca building facilities for storage and raw materials product and
processing.
3. Maintain better hygienic practices, especially for the workers.
4. Provide proper effluent treatment facilities.
5. Should obtain Board’s consent under the water Act.
6. Until the unit obtain necessary consent and make facilities for treating the effluent, the
unit should be asked to stop operation.
675
676
Name of the Industry
A.K.ChemicSals
: A.K.Chemicals, Edayar.
Date of Inspection
: 24/6/05
Raw Materials
: Fresh Prawn shell – 75 T/ Month
Anti caking agent - 100 kg/month
Lemon grass oil- 4 kg/month
Products :
: Prawn shell powder- 10.5 T/month
Production Process:
Fresh prawn shell is collected from peeling sheds. This is sun dried in
cemended open yard. Dried shell is grinded and packed for despatch.
Effluent generation:
Since wet prawns shell is used as raw material there will be some flow of
effluent from the drying yard. Septic tank and soak pit arrangement is
provided for the discharge of this effluent. The maximum quantity of effluent
comes to 500 liters/day. They have obtained consent under the
Water(Prevention and Control of Pollution)Act 1974 for the discharge of effluent .
Air Pollution.
The industry is using lemom grass oil for readucing foul smell in the
surroundings . This is sprayed in the yard. Sides of the yard is enclosed with
polythene sheet to avoid and spreading foul smell. Consent under the
Air(Prevention and Control of Pollution)Act 1981 is obtained for operating the
unit.
Findings:
The industry was not working during the time of inspection.
Recommendation.
Good house keeping is to be maintained by the company.
PRAXAIR CARBONDIOXIDE PVT.LTD, ELOOR
677
Name of the Industry
: Praxair Carbondioxide Pvt.Ltd, Eloor
Date of Inspection
: 28/06/05
Name of the Product/s
: Liquid CO2 - 8 t/day.
Process:
Carbon dioxide gas brought to the factory through pipeline from FACT is purified by passing
it through a scrubber containing KmnO4 solution, compressed, filtered, dehydrated and
liquefied to produce liquefied Carbon dioxide.
Waste:
Water contaminated with used oil from compressor and waste water from carbon
dioxide scrubber are discharged into the land after neutralization.
Findings/ recommendations:
3. Water consumption and effluent discharge are reported as 6200 l/day and 3000 l/day
respectively.
4. Neutralization facility is provided for treating the effluent. Effluent after neutralization
is discharged into open land for percolation.
5. An Oil trap system for separation of oil is to be provided.
6. The unit has obtained consent under the Water (Prevention and Control of Pollution)
Act 1974
7. 380 KVA genset is installed in the unit for operating the genset .
8. The Unit should obtain Board’s consent under Air(Prevention and Control of
Pollution)Act 1981and Authorisation under the Hazardous Waste(Management and
Handling)Rules 1989.
9. Used oil should be disposed only to the registered recycler.
Action taken should be reported immediately.
AKSHAY GASES
678
Name of the Industry
Date of Inspection
: 28/06/05
Name of the Product/s
: Liquid CO2 – 40 t/month.
: Akshay gases
Process:
Carbon dioxide gas brought to the factory through pipeline from FACT is purified by passing
it through a scrubber containing KmnO4 solution, compressed, filtered, dehydrated and
liquefied to produce liquefied Carbon dioxide.
Waste:
Water contaminated with used oil from compressor and waste water from carbon
dioxide scrubber are discharged without any treatment.
Findings/ recommendations:
1. An Oil trap system should be provided for removing oil from the effluent.
2. The unit has not obtained consent under the Water (Prevention and Control of
Pollution) Act 1974 for discharging the effluent.
3. The unit has not obtained authorizsation under Hazardous Waste(Management and
Handling)Rules 1989.
4. The Unit should obtain consent under the Water(Prevention and Control of
Pollution)Act 1974 and Authorisation under the Hazardous Waste(Management and
Handling)Rules 1989.
5. Used oil should be disposed only to the registered recycler.
Action taken should be reported immediately.
SOUTHERN GAS LTD.
Name of Industry
:Southern gas Ltd.
679
Date of Inspection
:28-6-05
Raw material
:Calcium carbide Air
Products
:Acetylene and Oxygen
Production Process:
1. Acetylene
Calcium carbide reacts with water forming acetylene gas and calcium hydroxide.
Acetylene gas is purified, dried compressed and filled in cylinders. Slurry of
Calcium hydroxide is discharged in to the open pond.
2. Oxygen - Air separation process.
Air drawn from atmosphere through filter, compressed, purified and liquefied in
the separating column is recirculated through heat exchangers and converted in
to gas and filled in cylinders.
Waste:
CaOH : 800kg/day
Findings/ Recommendation:
1. Calcium hydroxide formed during the production process is discharged into open
pond.
2. The discharge is found to be highly alkaline in nature. Arrangements for the
neutralization to be made.
3. Condensate is found in the channel, which leads to the pit.
4. The Unit should obtain Board’s cosent under the Water(Prevention and Control of
Pollution)Act 1974.
MASTERS MULTIPACK
Name of Industry
: Masters Multipack
Date of inspection
:13/06/05
Raw material
: Polythene granules- 100 kg/day.
Product
: Polythene tubes and sheets- 100 kg/day.
Process
: The raw material of virgin granules are
extruded to get polythene tubes and sheets.
Findings/ Recommendation:
1. The unit has obtained Board’s consent to establish the industry for producing 24
t/year extrusion tube.
2. Cooling water is recirculated and hence no effluent discharge
3. Not obtained Board’s registration under Recycled Plastics (Manufacture and Usage)
Rules, 1999.
680
RIA ENTERPRISES.
Name of Industry
: Ria Enterprises.
Date of inspection
: 18/11/04; 27/06/05
Raw material
: Name
Quantity per day.
Natural rubber
180 kg,
Zinc oxide
7.2 kg,
Stearic acid
3.6 kg,
BSM
1 kg,
BL
1.5 lt,
Carbon Black
90 kg,
Rubber grade sulphur
4.5 kg,
Process oil
13.6
Wood resin
2 kg/week,
Solvent (SBPS) etc.
360 lt/week
Product
:Name
Quantity
Tread Rubber.
Cushion gun
Vulcanising solution
300kg/day.
100kg/week.
400 lit/week.
Process:
Natural rubber mixing with other chemicals to form rubber compound. All products based
on Rubber compound.
Findings/ Recommendation:
1. The unit is mainly engaged in the manufacture of tread rubber .
2. Air pollution control measures are not provided for controlling dust emission from
mixing mill.
3. The unit has not obtained Boards consent under the Air(Prevention and Control of
Pollution)Act 1981.
4. Should obtain Board’s consent under the Air(Prevention and Control of Pollution)Act
1981.
5. Cooling water recirculation arrangements are to be provided.
6. The units should be directed to grow fast growing and long lasting trees all along the
boundary.
7. House keeping is to be improved.
PERIYAR CHEMICALS LTD,EDAYAR.
Name of Industry
: Periyar Chemicals Ltd,Edayar.
Date of Inspection
: 06/05/05
Raw material
: Name
Quantity per day
681
Products
1. Soduim Formate
3700kg
2. Sulphur Acid
2600 kg
3. Furnace Oil
310 litre
4. Diesel
20 litre
: Name
Quantity(t/day)
Daily Avg.
Maximum
production in
a day during last
one year.
1. Formic Acid
2.5
2.8
2. Sodium Sulphate
3.8
4.2
Production Process :
Sodium formate on reaction with sulphuric acid gives a slurry of Sodium
Sulphate and Formic acid, which is prepared batch wise. This slurry on vaccum
distillation gives formic acid and sodium sulphate. Formic acid is filled in HDPE
jerry cans and sodium sulphate in HDPE bags for marketing .
Findings/Recommendation:
1. The company authorities informed that the company remained closed for the last four
years and now production is taken only once in a while due to shortage of working
capital.
2. For treating the effluent a treatment plant consisting of oil trap, neutralization
tanks ,settling tanks and cascade aeration facility are provided. The treated
effluent is discharged into the downstream of pathalam bund in periyar river.
3. Source of water is well and purchase from outside.
4. There is one boiler of 1.5 t/hr using furnace oil, provided with a chimney of height
32 m and a Genset of 320 KVA .
5. The unit is not having valid consent under the Water(Prevention and Control of
Pollution)Act 1974 and Air(Prevention and Control of Pollution)Act 1981.
682
6. Should renew the Board’s consent under the Water(Prevention and Control of
Pollution)Act 1974 and Air(Prevention and Control of Pollution)Act 1981 and
authorization under Hazardous Waste(Management and Handling)Rules 1989.
Paper I
Revival of Periyar- Study paper submitted by the scientists
Restoration of fish habitat, ecosystem and Fisheries of
downstream part of Periyar river.
By
Dr.Madusoodanakurupu
(School of Industrial fisheries , CUSAT)
Status: The results of the recent studies conducted on the habitat and fishery of the
downstream part of the Periyar lake revealed that these regions almost reached a moribund
stage in terms of its physical environment and ecological conditions. The assessment on the
health status of this river stretch was made by the widely and globally acclaimed indices such
as physical habitat quality (HQ), water quality, diversity indices and index of biotic integrity
(IBI) . The various indices were prepared on the basis of 68 physico chemical parameters,
Habitat quality was worked out on the basis of 48 parameters which is indicative of the
physical state of environment of the river which is the net stock of man induced perturbations
in the river such as intensity of soil erosion, nature of substratum, in stream cover, sinuosity
and width/depth ratio etc which was as low as 20, thus belonging to the poorest category. For
a healthy river system these values should score more than 50 as per international standards.
On the other hand, the water quality index worked out on the basis of 20 water quality
parameters was as high as 202 which is indicative of its high polluted nature due to high
concentration of trace and heavy metals, Total residues, high coliform bacterial load, acidic
nature, etc;. While comparing with the ICMR standards, this water is not fit for domestic
consumption. The study also revealed the heavy loss incurred to fish biodiversity and fishery
wealth of this water body with in a span of 20 years. Most importantly, the index of biotic
integrity (IBI) which is used as a tool to express the relationship between fish community and
habitat quality, which is further used to assess the health status of the rivers, was found to be
683
at rock bottom level of around 15 in the study area which is far below of 40 which denotes a
satisfactory correlation between habitat quality and fish habitats. The extreme low IBI score
of the study area are clear cut manifestations of a high contaminated and degraded habitat
where normally imbalanced trophic community structure can generally occur.
Action plans for the restoration of aquatic ecosystem, fish habitat , fish biodiversity and
fisheries.
1.
Strengthening of data base is found essential on the following aspects:
1. Water and soil quality, flow velocity, water balance structure, sediment
transportation
2. Habitat parameters given below at every 500 m interval: Sinuosity,
Entrenchment ratio, Slope, W/d ratio, Shrub cover along bank, Tree cover
along bank
Bare ground along bank
Fines
Gravels
Cobbles
Boulders
Rock
Bedrock
Turbulance
Depth
Small woody debris
Large woody debris
Overhanging vegetation
Submerged vegetation
Emergent vegetation
Floating vegetation
Turbulant white water boulders
Scour out pools
Overhangs stream boulders
Undercut bank
Total cover
Falls
Cascade
Rapids
Riffle
Chute
Sheet
Run
Eddy
Trench
Midchannel
Cinvergence
Glide
Plane bed
Pocket water
Lateral pools
Pluge
684
Debris
Landslide
Backwater
Abandoned channels
Flow velocity
Mean channel width
Mean channel depth
3. traceability studies in the fin and shell fishes of the down stream part of Periyar
river for locating the origin of various contaminants
4. Construct an ecopath model for the study region in order to understand
cascading effect of human interventions.
Action Plans suggested
1.
2.
Removal of highly contaminated soil from the river bottom: The available results
reveal that the sediment of the downstream part of the river stretch contains high
concentration of heavy and trace metals which are non biodegradable. Since these
are having long shell life, any organisms reared in this water body will have the
fate of bioaccumulation and biomagnifications. The only solution to minimize the
high concentration of these heavy metals and other lethal pollutants accumulated
in the sediments of the river is are physical removal of the sediment. However
there will be difficulties in the physical removal of sediments from the river
bottom. The pumping of bottom slurry by a slurry pump can be attempted as an
experimental basis. The slurry will have to be disposed of at least 20 km away
from the coast.
In order to improve the biotic integrity at the downstream reaches of Periyar river
system, increase of microhabitat diversity, in stream cover, improvement of water
quality parameters development of riparian zone and improvement of the
substratum are inevitable. The following management measures are proposed for
restoration of fish microhabitats.
1. Sand mining activity at this stretch of the river system shall be stopped.
2. No more construction of boundaries with boulders in the riverbank
3. Ensure zero level effluents discharge from the factories. Levels of trace metals
and heavy metals and other pollutants in the effluents should not exceed the
standards prescribed by LAEC/PCB
4. IBI scoring shall be elevated to 50 and above by resorting to improving the
water quality parameters, in stream cover, microhabitat diversity and quality of
substrates.
5. Install different types of deflectors for improving the flow velocity and
direction, which will, helps to increase the heterogeneity of in stream cover,
microhabitats and substrates.
6. In stream and stream side cover shall be improved by boulder placement,
placement of stumps, roots or debris, artificial undercut banks formed by
overhanging cover structure, tree planting in banks and the removal of
overhanging vegetation in the bank shall be stopped.
7. Substrate reinstatement by replacing the sediments with well-sorted gravels,
cobbles or even with crushed rocks which will helps to improve the fish and
invertebrate habitat
8. The micro invertebrates which forms a good source of food to stream fishes
need to be improved by increasing the density of woody debris we land
vegetation and restoration of riffle type microhabitats in streams.
685
Restoration of Fish biodiversity and fisheries wealth
1.
2.
Transplant/Translocate the fish and crustacean species disappeared from the water
body. This can be done by providing the required habitat of the respective species.
The habitat suitability index models developed by the Scientist of Cochin
University of Science & Technology can be utilized for such translocation of
species.
Once the IBI scores are elevated to beyond 50, massive ranching of the region with
hatchery produced seeds can be planned and executed. The following species are
recommended for river ranching of the area.
Giant prawn Macrobrachium rosenbergii, Crabs, Tiger prawn
Labeo dussumieri, Puntius carnaticus, puntius sarana subnasutus, Clarian
dussumieri, Indian major carps, Etroplus suratensis, Channa spp. Chanos chanos,
Lates calcarifer. The ranching shall be done following scientific methods and
techniques. The fringes of the river can be utilized for nursery rearing of the frys
and fingerlings of the species selected for ranching. The nursery rearing and
ranching shall be done with participation of local bodies, fishermen, NGOs etc;
The success of these programmes are fully dependent on the participatory
management by various stake holders.
3.
Cage culture in the river proper.
4. In those part of the river where the depth is more than 4m, low coast cages can be erected
by the local fishermen for fish culture. Species such as giant prawn, milk fish, pearl spot,
etc can be reared in high density. This will provide employment avocation to the
fisherwomen of the area.
Setting up of fish and shell fish sanctuaries, freshwater reserves cum recreational
centers, etc; in the river proper
Suitable regions of the river stretch can be identified for establishing fish sanctuaries. The
areas so selected can provide with tripods or other structures favouring spawning
environment. The fishing of such regions can be stopped by erecting either fences or coconut
stumps so that the spawing stocks will not be exploited. The centers so developed will serve
as regular source of recruits of various fin and shell fishes to the river which can take care of
the sustainability since there will be regular recharging of seedlings to the open water body.
Such regions can also be utilized as recreational centers as part of ecotourism by introducing
species such as freshwater sharks, Sea bass, etc;
Follow up studies:
1.
2.
3.
4.
Regular monitoring of Habitat quality scoring Index, biotic integrity scoring and
diversity indices shall be done at monthly intervals in order to assess the status of
aquatic ecosystem and the biotic integrity. The results so compiled should publish
in the medias at par with the daily temperature and rainfalls. While doing so, the
public will able to understand the status of river from time to time.
Impact assessment studies on aquatic biodiversity and fisheries
Effects of freshwater reserves and sanctuaries on regeneration of fishery wealth
Socio economic status of fishermen population subsisting on Periyar lake
686
5.
Quality assessment of food fishes and other aquatic organisms harvested from the
study area for human consumption.
Paper II
Periyar – An Action Plan.
By
Dr. N. Chandramohanakumar
(School of Marine Fisheries CUSAT)
There shall be seven broad program areas in the Plan. These are sediment management, water
quality assessment, agricultural non point sources, biological assessment, hydrology and
hydrodynamic modeling, interagency coordination and public awareness, and environmental
education. Within each of these program areas, there shall be a number of projects which are
intended to provide recourse managers with the understanding necessary to develop or
implement workable restoration and protection strategies.
1.
This includes a basin-wide assessment of sediments and, within priority sub
basins, intensive sediment surveys. Sediment samples are collected and analyzed
for priority pollutants that may exist at levels which are known to be harmful to
organisms. Once identified, areas of contaminated sediments are mapped and
contaminants quantified area are described and their project managers identified.
2.
3.
4.
Included in this work area is an assessment of submersed aquatic vegetation
(SAV). SAV is the most important component of the river’s natural systems,
providing nursery areas and refuge for fish, substrate for invertebrates and
epiphytes, food for endangered species such as the manatee, and functions as a
water filter by converting nutrients present in the water into new plant material.
The assessment includes identification and mapping of areas where SAV exist
within the basin and determination of growth characteristics. These findings are
then related to water and sediment quality characteristics. In this way, water
quality can be managed, through permitting and regulations, to protect and
enhance plans, assessments of phytoplankton and macro invertebrate communities,
and examinations of primary productivity and nutrient limitation.
The first step in accomplishing this is consistent monitoring of ambient water
quality. A multi-agency task force which coordinates the collection of water
quality data may be organized ensuring that there is a minimum of redundancy and
that data collection and constituents are uniform and compatible among agencies.
In addition to the routine monitoring of ambient water quality basin wide, there are
special studies which intensively examine water quality in priority locations and
under special conditions. These include storm water sampling, point source
discharge sampling and sampling in conjunction with other studies such as
sediment and biological assessments.
A second major component of this effort is the development of water quality
models. The Plan includes programmers.
1. To identify the relation between climate changes and human activities
including pollution to the effect of hydrological cycle and environment
degradation, and poverty, and assess the effect of re-vegetation policy.
2. To figure out the ecosystem water demand for the heavy-and-coarse sediment
yield area in Riverine and estuarine area
687
3. To put forward effective methods environment protection and ecosystem
restoration for headwater region as well as important river reaches including
the estuary area.
4. To formulate effective water pollution control schemes for Periyar River Basin
to ensure the food security and health.
Study areas
The Periyar River basin in the Eloor Edayar Region
The estuary area of Periyar
Topics
1. Valuation of Ecosystem goods and services, and the cost of degradation .
What are the monetary and non-monetary values of ecologic system
How does the long-term run off influence the aquatic ecology and wetland in the
estuary?
What are the social and economic consequences of the degradation of aquatic
ecosystems in the headwater region and heavy-and-coarse sediment yield area?
2. The ecosystem and environment protection and restoration in Study area
The environment evolution trend of the headwater region and heavy-and coarse
sediment source area
To quantify the environmental water demand of the headwater region and heavy-andcoarse sediment yield area?
To quantify water requirement of the typical measures of soil and water conservation
in heavy-and coarse sediment yield area, and the sediment yield reduction due to soil
and water conservation
Effective measures on ecosystem and environment protection and restoration in head
water region and heavy-and –coarse sediment yield area
3. The ecosystem and environment protection and improvement in the River
To characterize and quantify the environmental water requirement of the rive channel
To quantify the minimum river channel flow demand to maintain a health live of river
To quantify the environmental water requirement of the estuary and the measures and
policy to protect wetland and aquatic ecosystem protection
The minimum water requirement for sediment transportation in order to maintain an
equivalence of scouring and deposition of rive channel
4. Pilot project for water pollution control in important rive reach
The characteristics of self-purification and waste water load capacity of Eloor reach
The total pollutant release amount control scheme
The city drinking water source protection measures
The effective policies and institutional mechanisms of functional water areas
management
Waste water irrigation
Studies on Upper reaches
Improve the water resources management system to achieve sustainable water
utilization in the Periyar River Basin.
Topics
A.
B.
C.
The interactive relation of different water use pattern and different regions
Agriculture water use assessment
River water resources and evolution trend analysis
688
D.
E.
F.
G.
H.
Integrated Decision-support tools
Policy and institutional development
The effective institutional mechanisms and polices for integrated water resources
management
The stockholders participant mechanism on river basin planning
Different water allocation mechanisms and their impact on agriculture, water
productivity, and food production
Paper III
Afforestation Programmes
By
Dr. C.M.Joy
(Reader ,Sacred Heart College. Thevara, Kochi)
Periyar catchement area should be afforested to maintain summer flow in the river. A buffer
zone of trees has to be established along the riverbanks. This will help the recharging of river
water during summer season and also helps to attain maximum flow of water during rainy
season.
Survey of River Basin
The entire stretch of the river should be surveyed and the boundaries are to be demarcated.
Eviction of encroachers should be done. A stretch of at least 5 M on both the banks of the
river should be maintained as a buffer zone of riverine vegetation.
Pollution Control
Pollution due to local bodies on the banks
All sewage canals leading to the river has to be closed. Direct waste dumping into the river
should be stopped with the help of instruction boards and awareness programmers. No
farming inside the river and on close bank areas should be allowed. Incoming sources of
fertilizers and pesticides into the river should be pre vented. No slaughter house and market
place on the river bank should be permitted. Brick choolas and brick making on the river
banks must be prohibited.
Pollution due to industrial installations
All unauthorized effluent outlets into the river should be closed. Untreated ad partially treated
effluent should be allowed to either into the river basin. All authorized out lets from the
factories into the river should be marked. Close the factories without appropriate and
functional treatment plants. No wastewater discharge from the factories should be allowed
into the river Dumping of any solid waste into the river from industries should be prohibited.
Prevention of Salinity incursion
Scientifically operated regulator cum bund should be constructed above the industrial area to
prevent saline water incursion during summer months.
Other Action Plan Programmes
689
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
Establish pollution monitoring centers at the industrial area, upstream and
downstream.
Analytical lab and a monitoring center should be maintained at the industrial
area.
Establish a river protection force
Planting of trees and riverine plants on the banks for the bank protection
Sand mining should be controlled
Grow indigenous fish species in the river
Establish bathing ghats in the river
Conduct public awareness programs
River management fund should be used for the protection of the river.
Establish sewage treatment plant to local bodies
Establish toilet facilities with septic tanks on the river banks
Construction of check dams and dams in the river should be prohibited
Establish a river authority and a river board for Periyar.
LOCAL AREA ENVIRONMENTAL COMMITTEE For ELOOR – EDAYAR AREA
(LAEC) (CONSTITUTED AS PER THE ORDER No PCB/HO/HWM/SCMC/503/2004 DATED 15.10.2004)
Office: 2nd floor, Kaloor Towers, Kaloor, Kochi-17. Ph: 04843952393
www.scmc.info, www.keralapcb.org e-mail: laecperiyar@yahoo.co.in
LOCAL AREA ENVIRONMENTAL COMMITTEE For ELOOR – EDAYAR AREA (LAEC)
(CONSTITUTED AS PER THE ORDER No PCB/HO/HWM/SCMC/503/2004 DATED 15.10.2004)
Office: 2nd floor, Kaloor Towers, Kaloor, Kochi-17. Ph: 04843952393
www.scmc.info, www.keralapcb.org e-mail: laecperiyar@yahoo.co.in
Report on the Public hearing held on Saturday, 4th December, 2004
at Eloor Site Office of the KSPCB
Members Present:
Mr. Jacob Lazer, PUCL
Mr. G. Anand, CII
Mr. Satheeshan Thampuran, Liaison Officer
1. Written complaint submitted jointly by one Mr. V.A. Salim & Mr. Anil Kumar. Mr.
Salim was present for the hearing. According to Mr. Salim, the quantity of drinking
690
water, which M/s. Binani Zinc has agreed to supply to the local residents pursuant to
the Agreement entered into between the Company and the Local Area Environment
protection Committtee (set up exclusively for providing drinking water) was awefully
inadequate. The total quantity agreed to be supplied is 10,000 litres per month (330
litres per day). According to him, there are 8 members in his family and 330 litres per
day would be inadequate. Moreover, he is residing in the immediate vicinity of the
Company and the well water is fully contaminated and the same cannot be used even
for washing, toilet and other non-drinking purposes. Mr. Salim further submitted that
neither the PCB nor the Local area environment protection committee had tested the
well to find out the extent and nature of contamination. According to him, the local
residents have a right to know as to the extent and nature of contaminants in his/her
well. Mr. Salim could be contacted at Tel. No. 2541603. The members present
informed Mr.Salim that his complaints would be looked into and discussed at the
LAEC meeting and he will be informed of the views / decisions of the LAEC before
the next public hearing viz., 18th December, 2004.
2. Submission by Mr. Abdul Salim and Mr. Nazer of Edayar Paristhithi Samrakshana
Samithi. According to Mr. Salim and Mr. Nazer, during evenings it is difficult to
travel through the road from the sub-station junction due to severe dust entering into
eyes. Two-wheeler travelers find it extremely difficult due to this. According to them
the units in the area include Sree Sakthi Paper Mills, Cochin Alloys, Hi-tech Electro
Thermics; Malayalam Chemicals; Thankam Chemicals; Lakshmi Chemicals; W
Chemicals etc. It was also submitted that LAEC should insist on proper maintenance
of Air filters in the aforesaid units.
3. Mr. Abdul Salim and Mr. Nazer also submitted that the bone and leather units are
causing severe problems due to intolerable odour. LAEC should look into this and
redress their grievances. Contact no. Mr. Abdul Salim – 2555592 and Mr. Nazer –
94473 28889.
4. Mr. Abdul Salim and Mr. Nazer further submitted the following:
a. The stack of M/s. National Batteries is in close proximity to the High Tension
line and no precaution is taken in this regard.
b. The Edayattuchaal field is fully contaminated primarily due to sludge deposits
from M/s. Arjuna Aromatics, Shalimar Inks etc.
c. M/s. Neptune Readymix has encroached the River Periyar and it is understood
that the Unit is involved in illegal sand mining through sophisticated systems.
The Panchayath license for Neptune Readymix is for storage of cement and not
for manufacturing readymix concrete.
5. The following residents of Eloor Panchayath near to Kuzhikandam Thodu were
present and represented their grievances.
Mr. Babu
Mr. Josey – Tel No. 2547124
Mr. Kumaran
Mr Adam Kutty
Smt. Hymavathy
Smt. Sheeba
691
Smt. Sumathi
Smt. Pushpa
Their grievances are summed up as under:
a.
Hindustan Insecticides Ltd, FACT, Merchem and IRE are responsible for
contaminating the Kuzhikandam Thodu. The residents in and around the creek
suffer from skin ailments, vomiting, allergy, breathing problems, phlegm,
abdomen cancer etc.
b. Merchem Ltd, Eloor has encroached the Kuzhikandam Thodu. The residents are
facing severe environmental problems ever since Merchem has started functioning
from Eloor. The ETP systems of the Merchem do not work properly and during
night hours the company unauthorisedly releases H2S into the atmosphere without
proper incineration. Merchem also dumps NaOH solution into the creek.
c. Residents of ward nos. 1, 2, 3, 4 and 17 suffer from severe environmental impact.
Their rice fields and vegetable cultivation is devastated due to illegal dumping of
wastes. Wells in the area are fully contaminated.
d. The residents demanded the following:




Merchem Ltd, Eloor to be immediately closed
Provide drinking water to the affected community
Provide medical care and treatment facility to the affected community
Prevent dumping of waste into the creek, water bodies, River Periyar etc.
forthwith.
 Kuzhikandam thodu to immediately cleaned up after ensuring safe
disposal of the waste dumped into it.
6. One Mr. Shajahan of Eloor mentioned that FACT is carrying Gypsum to its yard
through the public road through lorry. Gypsum spillage on the road is carried into the
eyes of the road users. FACT does not wash the road regularly after gypsum is
carried. Washing of road also causes slipping of bikes and accidents to the
passengers. It was suggested that FACT should immediately stop carrying of gypsum
through the pubic road and take it through their South Gate ie., through the road
adjacent to the quarters of their Management staff.
7. There is no proper disaster preparedness plan for Eloor and Edayar Area. There are
around 4,000 families in the above mentioned 5 wards of Eloor. For instance in the
recent fire at HIL (Endosulfan plant), the company siren was heard after more than 50
minutes ie., around 02.50 hrs, whereas the fire broke out at 02.00 hrs and by the time
the siren was on the locals have started fleeing the place. Eloor is an island
surrounded by water on 3 sides without proper exit bridges.
8. The Primary Health Centre in Eloor does not function properly. Medicines are not
available at the PHC. Due to this, the local residents have to approach private
hospitals for their treatment, which is highly expensive.
9. The residents of the panchayath colony in Ward no. 3 of Eloor Panchayath suffer from
severe drinking water problem.
692
10. The license of Merchem Limited, Eloor was cancelled by the Panchayath. The matter
is now pending before the Hon’ble High Court of Kerala.
11. Mr. M S Sivasankaran of CITU said that there must be regular monitoring of the River
Periyar to identify the unauthorized outlets and to prevent unlawful dumping of
hazardous waste. Mr. Sivasankaran has agreed to point out the unauthorized outlets in
the River Periyar. He can be contacted at 2557995.
12. One Mr. Sadakath, a teacher in Edayar said that the quantity of drinking water agreed
to be supplied by the M/s. Binani Zinc viz., 330 litres per day is inadequate. Mr.
Sadakath is residing very near to the Unit and according to him, his well is fully
contaminated and cannot be used even for washing, toilet and other non-drinking
purposes. He said that the representatives of Periyar Malineekarana Viruddha Samithi
and the Edayar Paristhithi Samrakshana Samiti had agreed to the quantity of water
without consultation with others. He further mentioned that the Agreement entered
into between M/s. Binani Zinc and the Local Area Environment Protection Committee
(for supply of drinking water) mentions that water will be supplied to the local
residents only till such time the company exists / will be in operation. This according
to him is not acceptable and prejudicial to the interests of the local community.
13. One Mr. Yousuf and one Mr. Joy, who were present during the hearing, said that the
general law & order in and around Eloor and Pollution problems were under control
during the tenure of one Mr. Abdul Rehman, Sub inspector of Police, Eloor. This was
endorsed by all present and the public demanded bringing back Mr. Abdul Rehman to
Eloor in the larger interests of the society.
The Report of the Public Hearing held on Saturday, 16th April, 2005 at Yuvajana
Vayanashala, Eloor North to Enquire into the incident of fugitive emission reported at
Eloor on 13/03/2005.
(Extracts of the 54th meeting held on 07-05-2005)
On the basis of complaints from local residents of Eloor about fugitive emission from M/s.
Merchem Ltd. on 13th March, 2005, LAEC members rushed to the spot and ascertained the
situation.
LAEC members reported about the fugitive emission from M/s. Merchem Ltd., and the
representative of KSPCB, Mr. Satheeshan Thampuran, Senior Environmental Engineer, reported
to the Committee that there was fugitive emission in the Unit and some remedial measures have
to be taken to avoid any such recurrence in future.
An emergency meeting of the LAEC was convened on 14/03/05, wherein it was decided to
direct the KSPCB to issue show cause notice to the company and to take suitable action against
the Company.
693
Accordingly, the KSPCB vide notice no. KSPCB/A/CHN/206/97 dated 15/03/2005, directed
the Company to show-cause as to why action shall not be taken against the Company under the
Air (Prevention & Control of Pollution) Act. The said notice mentioned that the investigation by
the Board officers had led to the inference that the foul smell in the area west of the Unit was
caused by fugitive emissions from the Merchem factory.
At the joint inspection during the trial run, the LAEC, KSPCB officials and Dr. Sharma of the
Central Pollution Control Board had directed the company to contain fugitive emissions of any
kind. Despite this, the Unit is found negligent in taking adequate measures to contain the fugitive
emission. LAEC, therefore, at the aforesaid emergent meeting held on 14/03/2005, also
resolved to report the matter to the Hon’ble High Court and seek review of the trial run.
Accordingly, LAEC brought the incident of fugitive emission before the Hon’ble High Court
through an Interlocutory Application. M/s. Merchem Ltd., Eloor in its Counter Affidavit
contended that no such fugitive emission had occurred on 13-3-2005. Further, vide its reply no.
1505/278 dated 18th March, 2005 to the show-cause notice issued by the KSPCB, also refuted the
allegation regarding fugitive emission and submitted that there was no emission causing foul
smell from their factory on 13/03/2005 between 07.00 pm and 11.00 p.m.
The Hon’ble High Court in its order dated 4th April, 2005, extended the trial run upto 17th May,
2005 and as regards the fugitive emission, the Hon’ble Court observed that it is not going to the
details as a trial and error proceedings are on, as supervised by an expert body.
During the course of the hearing before the Hon’ble High Court, the counsel for the KSPCB
made a submission contrary to the stand of the KSPCB that the emission was from Hindustan
Insecticides Ltd (HIL). The matter was brought to the notice of Mr. Sateeshan Thampuram,
Chief Environmental Engineer (CEE) of KSPCB, who was present in the Hon’ble Court. He
could not explain the reason for such a wrong submission by the Counsel for the KSPCB before
the Hon’ble High Court.
LAEC upon enquiry with the Regional Office of KSPCB was informed that further action
pursuant to the show cause notice has been dropped against the company. LAEC at its 48th
meeting held on 04/04/2005, deliberated this aspect and observed that all show-cause notices
issued by the KSPCB are closed after obtaining reply from the Company. This practice has set a
bad trend among the companies to go scot-free after committing damage to the environment and
nuisance to the public. LAEC strongly disapproved such practice as that would forfeit the
confidence of the people in the law enforcing agency.
LAEC, in the aforesaid circumstances, resolved to conduct a public hearing on the complaint of
fugitive emission and to take evidence in the matter. The Committee resolved to hold the public
enquiry on Saturday, 16th April, 2005 at Yuvajana Vayanashala, Eloor North from 10.00 a.m.
onwards.
LAEC informed the public regarding the public enquiry through newspapers and requested the
public to give evidence before the Committee on the alleged incident of fugitive emission.
Proceedings at the Public Hearing:
The Public hearing commenced at 10:00 hrs. Adv. P.K. Ibrahim, Chairman, LAEC presided.
LAEC members viz., Mr. G. Anand; Mr. S. Jayathilakan; Mr. Purushan Eloor; Mr. Jacob V. Lazer
694
and Mr. M. Asokan were present. KSPCB was represented by Mr. Sateeshan Thampuram, CEE,
KSPCB and Mr. Farook Sait, EE, KSPCB.
The Managing Director, Merchem Ltd, Eloor was given a separate letter to attend the public
hearing. In reply to the above letter, Merchem Ltd., vide its letter no. 1505/003 dated 12/04/05
to the Chairman, LAEC informed that the Company has placed materials before the Hon’ble
court to demonstrate that the alleged incident on 13.03.05 was only a drama enacted to tarnish
the image of the Company and there was no fugitive emission and that the matter was already
brought to the notice of the Hon’ble High Court in IA 4287/205, any further steps may be taken
only after getting due permission from the Hon’ble High Court.
The Company dis-associated itself with the public hearing. The plea raised by the company is
absolutely of no merit since the Court has not been seized of resolving the dispute on the fugitive
emission. The Hon’ble Court did not choose to go into the details as the Company is on trial
and error proceedings, as supervised by an expert body.
The public hearing was well attended by the local public and the LAEC collected oral evidence
from 28 persons, who have personal knowledge about the incident. The collection of evidence
was confined only to ascertaining the facts leading to the alleged incident of fugitive emission.
Mr. K.K. Joseph, General manager, Hindustan Insecticides Ltd and senior officers viz., Mr. A.
Unnikrishnan, Plant-in-charge and Mr. K.R. Venugopala Pillai, DGM were present. Mr.
Amanullah, Trade union leader, INTUC also tendered evidence.
Mr. Sudheer, Apprentice of KSPCB (on duty at Merchem at the time of the incident) and
Doctors of JNM Lakshmi Hospital (where the victims underwent treatment) did not turn up
despite the directions from LAEC. However, the report submitted by Mr. Sudheer, Apprentice
of KSPCB on duty at Merchem, has been forwarded to LAEC by KSPCB.
Issues for consideration
The following issues arise for consideration:
1. Whether any incident of foul smell / fugitive emission had occurred on 13 th March, 2005
at Merchem Ltd., Eloor?
2. If so, what action is to be taken against the Company?
Isssue 1:
Whether any incident of foul smell / fugitive emission had occurred on 13th April, 2005 at
Merchem Ltd., Eloor?
The facts reported to the LAEC at the emergency meeting held on 14th April, 2005 are as under:
………… Few local people were rushed to a nearby hospital and were given emergency treatment.
On getting information about the fugitive emission causing severe headache, chest pain, nausea and
abdominal congestion to the local residents, the members of LAEC rushed to Merchem Ltd., at about
10.45 p.m. A huge gathering of local residents were seen agitated raising slogans in front of the
Company. The local residents also blocked the vehicle of the LAEC members. One member, was about
to be assaulted by the agitated group. Somehow, the situation was managed and the agitated crowd was
assured of immediate action to contain the fugitive emission. LAEC members went inside the factory and
experienced around the NaMBT plant severe piercing odour, similar to the one experienced outside. The
695
entire company premises and outside was having a misty look. The Plant-in-charge of Merchem Ltd, Mr.
Paul Raj, however insisted that the odour is one from Hindustan Insecticides Limited and that Merchem
Ltd., has nothing to do with the fugitive emission / other emission.
Members of LAEC went to inspect HIL to ascertain whether there is any emission from HIL. Of the
four plants in HIL, three were idle and only one plant viz., Dicofol plant was found working. No
emission or odour was felt inside the HIL.
On account of public upsurge, the SI of Police, Cheranallore, who was in charge of Eloor came to
Merchem Ltd., alongwith other police personnel and the District Panachayath Member, Mr. Sajan
Malayil. The police officials and Mr. Sajan Malayil could feel the smell and asked the company either to
stop the plant or to do mitigating measures.
-
Extracts from the LAEC Report dated 14th April, 2005
The Company in its Counter Affidavit filed before the Hon’ble High Court had stated that the
trial run is being closely monitored by the officials of the Kerala State Pollution Control Board
round the clock. On 13.3.05, the plant was running normal and that the shift-in-charge had
shown to LAEC members who have visited the plant at 10.45 p.m. the LPG cylinder position
and also quality of ambient with regard to H2S, using the electronic monitoring device of the writ
petitioner. The company also claimed that the LAEC members were also convinced with that
explanation and confirmed that H2S was not present in the ambient. The Company further took
the stand that the alleged incident on 13.03.05 was only a drama enacted to tarnish the image of
the Company and there was no fugitive emission.
The contention that the LAEC members who visited the plant were convinced with the
explanation and confirmed that H2S was not present in the ambient is not correct. As a matter of
fact, the officials of the KSPCB were convinced that the origin of the foul smell was from
Merchem factory. The show-cause notice issued by Mr. Jeyaprasad, Chief Environmental
Engineer, who visited the site on that day bears testimony to this fact, which is corroborated by
the Report of Mr. Sateeshan Thampuran, Senior Environmental Engineer, KSPCB and the
Report filed by Mr. Sudheer, the Apprentice of KSPCB, who was on duty at the time of the
incident.
The claim of the company that KSPCB is closely monitoring the trial run though technically
correct, LAEC has time and again observed that the trial run as directed by the Hon’ble High
Court is being made a mockery by the KSPCB by posting temporary apprentices, who are not
found effective. LAEC on several occasions has pointed out that senior and experienced officers
of the KSPCB should be posted so that the trial run could be effectively monitored. The
monitoring of the trial run through Apprentices was not effective as is revealed from the
incident.
The company further contended in its counter affidavit before the Hon’ble High Court that the
wind direction during the reported hours was from East to West side and that the people who
claim to have affected also were from East side of the Eloor depot road, which is 1500 metres
away from the factory and is close to the Edayar industrial area. The same claim was repeated by
the Company in its reply to show-cause notice dated 18/03/2005.
One, Adamkutty, who resides on the northern side of Merchem had reported at the public
hearing that his nephew, Hafeez from Kaloor, who came for a visit to his home, experienced
severe respiratory problems and was admitted to JNM Lakshmi Hospital.
696
Another witness, Mr. Naushad, who also resides on the northern side of Merchem Limited and
within 1 km distance from Merchem, on experiencing the severe foul smell walked towards
Merchem Limited and experienced severe chest pain, breathlessness, headache and abdominal
pain. He was immediately rushed to the hospital in an ambulance and was given Oxygen.
Naushad also deposed that he was advised by the duty doctor at JNM Lakshmi Hospital to get
admitted but, he was not inclined as he had left his shop – “Nisha Auto garage” open. He
underwent treatment at the “Casualty” for more than 3 ½ hours and the doctor had prescribed
oral medicine for him.
One, V.B. Mohammed Harris, who resides in the northern side of Merchem, which is below 300
mtrs distance from the Company experienced severe foul smell when he reached the Eloor
Jamaath mosque, where counting of election votes was going on. Eloor Jamaaath mosque is on
the north-eastern side of Merchem Limited. Mohammed Harris experienced the severity as he
moved closer to the factory gate. He was taken to the hospital as he had severe abdominal pain
and cough. He was administered oxygen for almost one hour duration at the casualty.
Mohammed Harris also deposed that apart from him, one, Naushad and Kareem also underwent
treatment at the Casualty and that the SI of Police informed them that the Company shall meet
the cost of treatment and hence, the victims were not asked to pay by the Hospital.
Mr. A. Unnikrishnan, Plant-in-charge of HIL at the time of the incident deposed at the Public
hearing that there was no foul smell / emission from HIL on that day and that out of 4 plants in
HIL only one plant viz., the dicofol plant was working. This fact was noted by LAEC members
and the officers of the KSPCB, who visited HIL on that night. This fact was also reported to the
Committee by the members who visited HIL at the time of the incident.
Mr. K.M. Amanullah, S/o. K.A. Muhammed, who is a trade union leader said that around 8.30
p.m. while he was standing outside the Eloor Mahallu Jamaath Mosque, which is on the northeastern side of Merchem, where counting of votes was taking place, he experienced severe
piercing smell. The people, who had assembled there went to find out the cause of the piercing
smell and he also went towards Merchem factory. Lot of people had assembled outside the
factory gate of Merchem and there were 2 police jeeps waiting outside. People had assembled
there due to the severe piercing smell. Later he came to know that LAEC members and District
panchayath member are inside the Merchem factory. From there he again went to the votes
counting centre and after one hour again went to Merchem factory gate. At that time, he found
police taking some of the victims to the Hospital. The people were taken to JNM Lakshmi
Hospital. He also came to know that on account of denial by Merchem and that the piercing
odour is from nearby factory, then LAEC members and the District Panchayath Member went to
HIL factory. After 10 – 15 minutes, he also went to HIL and got convinced that there was no
odour of any kind from HIL. The KSPCB officials also inspected the factory in the early hours
and he was also present in that area at that time.
Considering the above, the submission before the Hon’ble High Court by the Counsel for the
KSPCB that the foul smell was from HIL is totally false and baseless. However, it is seen that no
explanation is sought from the counsel despite his wrong submission. The submission on a
crucial matter like this cannot be viewed lightly and LAEC directs the KSPCB to ascertain as to
why such wrong submissions are made on behalf of KSPCB and to obtain explanation from the
Standing Counsel and to report action taken to LAEC within one week’s time.
One, Kumaran, residing on the Western side of Merchem factory deposed that due to the foul
smell, people experienced breathlessness. He asked them to tie wet clothes on their face. When,
he proceeded towards Merchem to ascertain about the incident, he felt uneasiness and had to
697
retract. He found lot of people assembled outside the factory gate of Merchem. Mr. Kumaran
also deposed that the smell was of the nature of the one from Merchem with severity.
One, Aliyarkutty, residing in the northern side of Merchem Ltd., had around 9 p.m experienced
piercing foul smell and suffered chest congestion, nausea and irritation in the eyes from inside the
house and when he went outside for getting fresh air, the situation further worsened with
piercing smell. Mr. Aliyarkutty was admitted at Manjummel Hospital the next morning ie., on
14/03/2005 and underwent treatment as in-patient for 7 days. He also deposed that he was
admitted to the hospital due to inhalation of foul smell in the previous day. He further said that
on that night there was no much breeze and that the foul smell was of the nature of the one from
Merchem. He said that he could easily identify the smell and is also familiar with the smell from
HIL, TCC and FACT.
Another witness, Mr. Sakeer deposed that the foul smell was identical to that of rotten egg and
septic tank.
Another witness, Manichan, residing within 250 metres from Merchem on the western side of
Merchem factory experienced rotten smell from 6.30 p.m. onwards. Another witness, Mr. K.K.
Sasi, who resides within 300 metres from Merchem on the western side said that they regularly
meet outside the shop of Kuzhikandam Kunjoonju in the evenings and on that day he
experienced rotten smell from 6 p.m. onwards.
Another witness, Smt. M.K. Asha, Member, Eloor Panchayath, residing on the western side of
Merchem Ltd, adjacent to the Kuzhikandam thodu, deposed that by about 7.30 p.m. the foul
smell became severe and that the local community is suffering from breathlessness and
respiratory problems ever since Merchem Ltd., has set up the factory in their locality. She also
mentioned of the severe water and air pollution caused by Merchem. Apart from Smt. Asha the
issue of severe environmental problems incl. air and water pollution caused by Merchem factory
came out in evidence from all the witnesses / participants at the public hearing.
Another witness, Smt. Zuhara, W/o. Kareem Shah, who is residing on the northern side of
Merchem factory said that she felt severe rotten smell on that day and that her son, Rameez
Shah experienced severe breathing problems. She also mentioned that this type of smell is an
usual phenomenon and to get rid of the respiratory problems, they take butter milk, which gives a
soothing effect.
One Mr. Unnikrishnan, residing on the north-western side of Merchem Ltd., deposed that the
smell was of the same nature of what they experience from the thodu. At about 7 p.m., the foul
smell became severe and only then he could identify that it was from Air and not from the thodu.
He immediately put wet clothes on the face of his two little children, as they were experiencing
breathlessness and severe cough. He further said that because of the severity of water pollution
in the thodu, the locals are not able even to use tap water.
Another witness, Zuhara w/o Ismail and residing on the northern side of Merchem Ltd.,
experienced severe foul smell and eye irritation on that day. She immediately closed the doors
and remained indoors. The next morning, her neighbours informed of their similar experience of
foul smell.
Another witness, Mr. Rajappan, residing on the immediate western side of Merchem factory, near
to Kuzhikandam thodu said that he is residing in the area for more than 45 years and he is fully
aware that the smell from Merchem is that of rotten egg, which was experienced with severity
698
that day. He said that the foul smell is a regular phenomenon and he is not able to live there. He
is not even able to switch on the fan. Even if the doors are closed, the foul smell usually enters
through the gaps in the tiled ceilings (kazhukolu).
Mr. P.M. Mani, S/o. Unni Milan, residing on the north-western side of Merchem experienced
foul smell around 7 p.m. Around 10 pm, he experienced the foul smell of a nature of one from
breakage of septic tank. He further said that ever since Merchem Ltd., has started functioning in
this area, these type of smell is experienced. He further said that he can identify the smell from
various companies. He can easily identify smell from FACT, TCC and Merchem. The smell
from Merchem is rotten, he said.
Smt. Agnus Raju, w/o. Mr. Raju residing on the northern side of Merchem within 300 metres
distance said that her house does not have window panes and on 13th March night between 7.30
pm & 8.00 p.m. the rotten smell become severe. Her children aged 10 years and 6 years started
coughing and the youngest had fever after 2 days from the incident. She further said that she
could identify the smell from Merchem. She is a graduate in Zoology and can easily identify the
smell of Hydrogen Sulphide and that Merchem is the only factory in that area which generates
H2S. According to her the rotten smell is regular in the area and they used to cover their face
with wet clothes, when they experience such foul smell. She also said that the smell is severe ever
since the commencement of the trial run.
Another witness, Mr. Sebastian, who resides on the Western side of Merchem within 250 metres
from the factory, experienced foul smell at about 7 p.m and the smell become more and more
severe by 10 p.m. He found lot of people gathered outside the factory gate around 10 p.m. He
further said that they could not see any flare from the stack of Merchem. Mr. Sebastian also
deposed that the agitated crowd tried to attack one of the LAEC members, Mr. Jacob Lazer, who
arrived at the factory gate for enquiry. He further said that the SI of Cheranalloore took the
victims to the Hospital and that the SI obtained the cost of treatment from the Company and
remitted at the Hospital and left around 2 a.m.
One, Smt. Savitri, residing on the immediate northern side of Merchem said that severe foul
smell was experienced around 10 p.m. There was no much wind or breeze on that night and
hence the emission was severe.
Another witness, Mr. K.M. Mohammed, said that while he was standing in the Alunkal Junction
he experienced severe foul smell around 8 p.m. He found several people moving fast with their
nose covered. He felt uneasiness when he reached home, which is on the northern side of
Merchem within ½ kilometer distance. He further said that such smell is regular and will be
occasionally severe especially during rain. His grandson had severe respiratory problems on that
night and is undergoing Homoeo treatment.
Another witness, Mr. Antony, who resides on the immediate western side of Merchem said that
around 7 pm, while they were offering prayers they experienced foul smell. This resulted in
severe respiratory problems. They immediately stopped the prayers, closed the doors and
remained indoors. Wet clothes were spread on their faces to get rid of the foul smell. He found
lot of people marching towards Merchem. He further said that he experienced severe abdominal
trouble that night.
One, Mr. V.K. Abdul Khader said that he is residing on the north-eastern side of Merchem and
experienced severe foul smell around 9 p.m. He went to the mosque, where counting of votes
699
was taking place. In that area, the smell was even severe and returned home immediately. His
wife experienced breathlessness.
Another witness, Mr. Ali S/o Muhammed said that he is residing on the northern side of
Merhem and is working as a driver. He reached home around 9.30 pm and experienced sever
foul smell. His children were screaming. He switched-off the fan immediately. He found several
people marching towards Merchem and he also went along with them. They did not find any
flare in the stack at the time. After some time, LAEC members reached the spot. The agitated
crowd tried to attack LAEC members and that he tried to control the crowd. LAEC members
entered inside the factory. Lot of people experienced uneasiness and some were taken to the
hospital and he also accompanied them to the hospital. Those taken to hospital were given
oxygen for more than 1 ½ hours.
Another witness, Mr. Sakeer Hussain, who resides on the northern side of
Merchem within 1 ½ kilometers experienced severe foul smell on that day around
9 p.m. His young child started mentioning that the “Company smell” has started
coming. He immediately closed all doors and windows. He went in a bicycle to
the residence of LAEC member, Mr. Purushan Eloor. On account of the foul
smell, Mr. Purushan was sitting inside the house, with all doors and windows
closed. Both of them went to Eloor Depot side, where the smell was even
severe. Purushan informed other LAEC members over phone. They came to
know that lot of people have assembled outside Merchem gate. Both of them
also went to Merchem. They found only smoke going out of the stack and there
was no flare at that time. Other members of LAEC, who reached the spot were
about to be assaulted by the angry crowd. Cheranalloore SI also reached the
spot and made a round of the entire area. By about 11.30 pm – 12:00 midnight,
the smell got reduced .
The Company in its counter affidavit and in its reply to the show-cause notice has relied on a
letter dated 15/03/2005 from one, Dr. K.V. Nair, Medical Superintendent of Lakshmi Hospital
addressed to Mr. Kuriakose Jacob, Manager-IR of Merchem Ltd., to the effect that on
examination all the patients were in good general condition with little or no physical signs.
Hafeez was the only one who was admitted for observation. The other 4 were discharged with
first aid. Hafeez was seen by the doctor on 14/03/05 (ie., next day) and he had no complaints
and was discharged on the same day.
The above letter trivializes the incident and the hospital authorities have not explained as to why
Oxygen were given to all the patients and why they were treated in the hospital for more than 5
to 6 hours at the Casualty and as to why one, Hafeez was admitted at the Hospital and the
circumstances in which the victims had to be brought to the hospital in an ambulance.
LAEC had vide letter no. LAEC/KSPCB/GEN/05 dated 09/04/2005 directed the Managing
Director of the Lakshmi Hospital to participate in the public hearing alongwith his colleagues,
who were having first hand information on the incident. The authorities of Lakshmi Hospital
chose not to participate in the public hearing and LAEC takes strong exception to the
irresponsible behaviour of the authorities of Lakshmi Hospital and it is decided to recommend
strict action including cancellation of license of the erring hospital. It is also decided to approach
the Indian Medical Council to initiate disciplinary action against the doctor on duty and the
Medical Superintendent for professional misconduct in making false and misleading statements in
its letter dated 15/03/2005.
700
On an appreciation of the various evidence adduced at the public hearing, it is beyond doubt that
the people affected by the fugitive emission / foul smell were from north-eastern side and also
from the Western side of Merchem Limited.
It is borne out in evidence at the public hearing that the people who assembled in front of the
factory gate experienced severity in the foul smell as they moved more and more closer
towards Merchem factory. Further, evidence is also adduced to the effect that there was no
much wind or breeze at the time of incident thus, negating the claim of the company that the
wind direction was from East to West. Even assuming arguendo that the wind direction was
from East to West, it does not in any way substantiate the claim of the company as people
from the Western side of Merchem have also experienced severe foul smell of the same nature
from that of Merchem. Apart from the residents from the western side of Merchem, foul
smell was also experienced on that night by those residing in the north-eastern side of
Merchem. This further negates another claim of the company that people whoever claim to
have affected were from East side of Eloor depot road.
It is also borne out in evidence that the foul smell was of the nature of smell from rotten egg or
septic tank. The local community, who were present at the public hearing vouched to the fact
that the smell was the one from Merchem with severity. LAEC is convinced that the public can
easily identify the smell. It is needless to mention that the smell of H2S is identical to rotten egg
and there is no other unit generating H2S in the locality. The general public is familiar with the
smell from Merchem Ltd., Eloor.
It is further borne out in evidence that Merchem Ltd., Eloor had met the cost of treatment of the
victims at the hospital. It is hard to believe that a company, which refutes the allegation of
fugitive emission / foul smell, could have met the cost of treatment of victims.
Lot of evidence has been adduced to the effect that there was no flare from the stack. This is a
serious lapse on the part of the company and should be dealt with seriously by the KSPCB,
especially when the trial run is monitored by them.
The LAEC has in detail considered the various evidence tendered before it during the Public
hearing. It has also considered the version of Mr. Sateeshan Thampuram, SEE, KSPCB and the
Report filed by Mr. Sudheer, Apprentice of KSPCB, who was on duty at the time of the incident.
LAEC also considered the version of its members viz., Mr. G. Anand, Mr. Jacob V. Lazer and
Mr. Purushan Eloor, who had rushed to the spot on that day ie., 13th April, 2005.
After a careful consideration of all the above, it is clearly established that the severe foul smell on
the night of 13th March, 2005 is the result of the fugitive emission from M/s. Merchem Ltd.,
Eloor. The company is grossly negligent and is responsible for the Air Pollution for which the
KSPCB shall initiate appropriate action on the basis of its show-cause notice. KSPCB to report
action taken to LAEC within 15 days time.
Issue 2:
If so, what action is to be taken against the Company?
It has been brought out in evidence that the company is not maintaining the flare in its stack.
This is a serious lapse on the part of the company. It is reported that the factory had released
untreated effluent into the kuzhikandam thodu on 25/04/05 and the
Chief Environmental Engineer, Regional Office, KSPCB has issued orders to suspend
701
production. The action taken by KSPCB is timely and LAEC places on record its appreciation
for the pro-active step taken by the CEE of KSPCB in the matter.
A local area environment protection committee with participatory process is essential to make
sure that the erring company does not violate environmental laws and does not pollute air and
water. LAEC therefore, recommends to the SCMC to direct the KSPCB to constitute a local
area environment protection committee to act as a watch-dog on Merchem Ltd., Eloor.
For the serious damage caused to the environment and to the local community on 13th March,
2005 (air pollution), LAEC recommends KSPCB to the impose a penalty of Rs. 5
Lacs and to
obtain a Bank guarantee of Rs. 5 lacs. Merchem Ltd., shall forthwith install an on-line digital
ambient air monitoring system in their factory. The company has to ensure that flare is properly
maintained round the clock. This must be complied with immediately. The Bank guarantee will
be forfeited if the company fails to comply with the directions or if any such incident of air
pollution from the company is reported in future.
The penalty collected from Merchem (incl. release of Bank guarantee, if any) shall form a corpus
for compensating / mitigating the sufferings of the local community.
LAEC will once again review the functioning of Merchem Ltd., Eloor and if it is found that the
above measures are not yielding results, then, LAEC will have no hesitation to order closure and
re-location of the factory.
The action taken should be reported to LAEC within 15 days time.
Summary of Findings & Directions
 It is clearly established that the severe foul smell on the night of 13th March, 2005
is the result of the fugitive emission from M/s. Merchem Ltd., Eloor. At the joint
inspection during the trial run, the LAEC, KSPCB officials and Dr. Sharma of the
Central Pollution Control Board had directed the company to contain fugitive
emissions of any kind. Despite this, the Unit is found negligent in taking
adequate measures to contain the fugitive emission.
 Merchem Ltd, Eloor is grossly negligent and is responsible for the Air Pollution
for which the KSPCB shall initiate appropriate action on the basis of its showcause notice. KSPCB to report action taken to LAEC within 15 days time.
 LAEC on several occasions has pointed out that senior and experienced officers of
the KSPCB should be posted so that the trial run at M/s. Merchem Ltd., Eloor
could be effectively monitored. KSPCB should assign duty of tiral run supervision
at Merchem Ltd, Eloor by permanent competent officers.
 A local area environment protection committee with a participatory process is
essential to make sure that the erring company viz., Merchem Ltd., Eloor does not
violate environmental laws and does not pollute air and water. LAEC therefore,
recommends to the SCMC to direct KSPCB to constitute a local area environment
protection committee to act as a watch-dog on Merchem Ltd., Eloor.
702
 For the serious damage caused to the environment and to the local community on
13th March, 2005 (air pollution), LAEC recommends KSPCB to the impose a
penalty of Rs. 5.00 Lacs and to obtain a Bank guarantee of Rs. 5.00 lacs from M/s.
Merchem Ltd., Eloor. The Bank guarantee will be forfeited if the company fails
to comply with the directions or if any such incident of air pollution from the
company is reported in future.
 KSPCB shall direct Merchem Ltd., to forthwith install an on-line digital ambient
air monitoring system in their factory.
 The authorities of JNM Lakshmi Hospital, Eloor chose not to participate in the
public hearing and LAEC takes strong exception to the irresponsible behaviour of
the authorities of the Hospital. It is decided to recommend strict action including
cancellation of license of the erring hospital. LAEC shall also approach the
Indian Medical Council to initiate disciplinary action against the doctor on duty
and the Medical Superintendent of JNM Lakshmi Hospital for professional
misconduct in making false and misleading statements in its letter dated
15/03/2005.
 The submission before the Hon’ble High Court by the Counsel for the KSPCB
that the foul smell was from HIL is against the instruction of the KSPCB. LAEC
directs the KSPCB to obtain explanation from the Standing Counsel and take
action for acting against the interest of the KSPCB.
LOCAL AREA ENVIRONMENTAL COMMITTEE For ELOOR – EDAYAR AREA
(LAEC) (CONSTITUTED AS PER THE ORDER No PCB/HO/HWM/SCMC/503/2004 DATED 15.10.2004)
Office: 2nd floor, Kaloor Towers, Kaloor, Kochi-17. Ph: 04843952393
www.scmc.info, www.keralapcb.org e-mail: laecperiyar@yahoo.co.in
LOCAL AREA ENVIRONMENTAL COMMITTEE For ELOOR – EDAYAR AREA (LAEC)
(CONSTITUTED AS PER THE ORDER No PCB/HO/HWM/SCMC/503/2004 DATED 15.10.2004)
Office: 2nd floor, Kaloor Towers, Kaloor, Kochi-17. Ph: 04843952393
www.scmc.info, www.keralapcb.org e-mail: laecperiyar@yahoo.co.in
Report on Human Resources and Infrastructure issues in the
Kerala State Pollution Control Board
LAEC deliberated the HR & infrastructure issues in KSPCB arising out of its
interaction with the Scientific and Engineering wings of the PCB organized on 182-2005 at the Regional Office of KSPCB, Ernakulam. Considering various views
aired by the staff, the Committee unanimously observed as under:
Genesis
The issue relating to environment has been given less importance. The Govt. found solace in
the symbolic presence of the Board and made the Board a scapegoat for the failure of the
State to protect the environment which is a basic component to sustain life.
703
The present state of environment is very fragile. Water bodies have lost life. Land has been
rendered contaminated with Hazardous Waste. Air quality is highly toxic causing respiratory
diseases in cites and industrial belts. Industries are setup violating environmental laws even in
residential areas and people suffer in silence not being able to stop illegal activities.
Kerala State Pollution Control Board was established in 1976 to discharge the functions under
the Water (Prevention and Control of Pollution) Act 1974, and Air (Prevention and Control of
Pollution) Act 1981 and Rules made there under.
The staff pattern of the Board evolved then has not taken any significant modifications ever
since its constitution in 1976. However the duties of the Board continued to multiply by
heaping on it more functions under various statutes subsequently enacted by the Parliament to
protect the environment. The following are the new enactments after the constitution of the
State Board.
1.
2.
3.
4.
5.
6.
7.
8.
9.
Air(Prevention and Control of Pollution)Act 1981
Environment Protection Act 1986,
The Hazardous Waste(Management and Handling) Rules 1989,
Rules for manufacture, use, import, export and storage of hazardous micro organisms /
genetically engineered organisms or cells 1989,
The Bio-medical Waste (Management and Handling) Rules 1998,
The Plastic Manufacture, Sales and usage Rules 1999,
The Noise Pollution Regulation and Control Rules 2000,
The Municipal Solid Waste (Management and Handling) Rules 2000,
The Batteries(Management and Handling) Rules 2001
What ails PCB?
The machinery set up to protect the environment discharging functions cast under different
statutes as aforesaid however was not provided with infrastructure proportionate to the work
load assigned to it. This has virtually made the machinery failing in its duty and resulted in
earning bad reputation.
The demand for improving the infrastructure and strengthening the Board with sufficient staff
still remain a far cry notwithstanding the directions of the Hon'ble High Court to appoint
sufficient staff to make the Board functional.
The officers in the board itself are unhappy. Many in the services are working as temporary
hands. Many permanent staff is working without any promotions over 15 to 18 years. There
are no promotion chances in many posts as per the staff pattern. At some Regional offices of
the Board, persons from employment exchanges are employed. These persons have no
previous training and experience. Their engagement is often found as a sheer waste of money.
The air monitoring, stack monitoring, periodical inspection of the industry, enquiry on the
complaints, processing of applications for consents/ authorization, study of the unit to
determine the parameters of the consent, evaluating the statutory returns filed by the unit etc.
have not been systematically undertaken by Pollution Control Board. The scarcity of staff and
704
centralization of power in few hands have contributed the machinery to become less
transparent.
Role of the Government
The sorry state of affairs of the Pollution Control Board depicts poor governance of the state.
Maintaining machinery for name sake is a fraud on the statutes and an act of deception on the
people. The presence of regulatory machinery as at present in is of no consequence and is
better to be dismantled if the Govt. is not serious to make it functional by providing necessary
infrastructure and staff proportionate to the work load, having regard to its duties under
various statutes. The expenditure to sustain Pollution Control Board in the present form is a
waste of public money.
This sorry state must change. Delay will cause irreversible damage. The demand to make
Pollution Control Board functional should receive immediate attention and there must be
sincere efforts from the State Government and all concerned to bring in effective changes.
Recommendations
LAEC has the following recommendations to rejuvenate the Board and make it efficient to
meet the growing challenge and to transform the Board as a body to monitor and check
pollution menace from various establishments.
1.
The Board is expected to discharge its functions involving a close working
arrangement with frequent interaction between its Engineering and Scientific Service wings.
The efficiency of the Pollution Regulatory system can be best assured by the Engineering and
Scientific wing working together in the field. However, as of now barring in few exceptional
cases, the scientific service has not been made use of to assess the adequacy of the Pollution
Regulatory Measures installed by the industrial / other establishments. Confining the services
of the scientific wing only for lab analysis is certainly a waste of human resources when the
Board is already running short of adequate staff.
2.
Involving the Scientific services especially in consent administration and monitoring
will be useful. The parameters of certain chemical industries now fixed by the Board fall short
of many important parameters resulting in making the consent parameters redundant. It is in
this context LAEC had to recommend to review the consent issued to all the major units in
Eloor-Edayar area. The Board having Engineering and Scientific personnel to discharge its
functions must not hesitate to use their services in all aspects of its function which will make
both services more responsible and accountable.
3.
The site office at Eloor to monitor 247 industrial units is presently ill equipped and
understaffed. It is understood that the work load of this area would be more than that of
district offices like Idukki, Wayanad etc, The purpose of Eloor site office is to monitor the
industries round the clock. The office therefore must have all facilities with well equipped lab
and other infrastructure such as telephone, vehicle, computer systems etc. There should be
sufficient staff from Engineering and Scientific wings to independently discharge the works
relating to industries in and around Eloor – Edayar area. A separate staff pattern for this office
705
is therefore recommended for effective round-the-clock monitoring. The following staff
pattern may kindly be examined and with or without modifications the same can be adopted.
Staff pattern
Environmental Engineer
Environmental Scientist
(To be attached to the Central Lab)
Assistant Environmental Engineer
Assistant Environmental Scientist
Assistant Engineer
Assistant Scientist
Peon
Lab Attender
Driver
:1
:1
:1
:1
: 2
: 2
: 1
: 1
: 2
SCMC during its visit on 10th May 2005 has already suggested to make the Eloor-Edayar
office as an emergency response centre with round the clock duty for which Ministry of
Environment and Forests (MOEF) has ear-marked separate funds. The Board explore the
possibilities of availing the said funds from MoEF for setting up of a full fledged office in
Eloor.
4.
The staff pattern of the Board has to be immediately modified by creating posts
according to the work load in each district. Various posts remaining vacant for long time has
to be filled immediately. Already, the Hon'ble High Court of Kerala has directed to create 33
posts and to fill-up the vacant posts. The additional requirements can be ascertained at a later
stage. The filling-up of posts as already identified should not be further delayed having
regard to the present state of deficit staff strength in the Board.
5.
The post of Chief Environmental Scientist is a post vacant for the past 3 years. Though
the post is promotional post of Senior Environmental Scientist, there is no reason to hold up
the promotion and keep the post vacant. The resultant vacancy in the post of Senior
Environmental Scientist and other consequent vacancies should also be filled. This move will
certainly motivate the personnel in the scientific services. It is noted that there is not even a
single permanent Junior Scientific Assistant (JSA). So is the case of Assistant Engineers. The
Board is engaging provisional hands from Employment Exchanges. This arrangement is
absolutely very unhealthy since there will not be any experienced hand in the lower category
of scientific and engineering wings. The Senior Scientific Assistants, Assistant Scientist and
Assistant Environmental Scientist are continuing in service without any promotion for over a
period ranging from 10 to 15 years. This is certainly causing frustration and is prejudicially
affecting their morale. The permanent appointment to these posts and promotions overdue
without further delay will motivate the staff. Another disturbing aspect found is that the
promotion prospects of the Scientific staff is very limited and most of the staff in the
Scientific wing are in the same cadre for 16 years whereas their counterparts in Engineering
wings are occupying higher posts. Even junior staffs by 5 years are either in the level of same
cadre or higher. This anomaly must be removed for the simple reason that the qualification for
the scientific staff for the post of Assistant Scientist is Post Graduation in the relevant subject.
The lack of promotion in scientific wing paves way to the juniors in the engineering wing to
take a march over the seniors in the scientific wing which is causing embarrassment.
706
6.
The Research and Development Wing (R&D) of the Board which is now in
the control of Chief Environmental Scientist has to be revived. Regulatory
machinery like the PCB should have its own Research wing with capable
personnel from both streams who can contribute to the Board.
7.
The board should introduce separate Cell for Air quality monitoring, hazardous wastes
management and bio-medical waste handling with sufficient staff from both the streams
namely, Engineering and Scientific.
LOCAL AREA ENVIRONMENTAL COMMITTEE For ELOOR – EDAYAR AREA
(LAEC) (CONSTITUTED AS PER THE ORDER No PCB/HO/HWM/SCMC/503/2004 DATED 15.10.2004)
Office: 2nd floor, Kaloor Towers, Kaloor, Kochi-17. Ph: 04843952393
www.scmc.info, www.keralapcb.org e-mail: laecperiyar@yahoo.co.in
LOCAL AREA ENVIRONMENTAL COMMITTEE For ELOOR – EDAYAR AREA (LAEC)
(CONSTITUTED AS PER THE ORDER No PCB/HO/HWM/SCMC/503/2004 DATED 15.10.2004)
Office: 2nd floor, Kaloor Towers, Kaloor, Kochi-17. Ph: 04843952393
www.scmc.info, www.keralapcb.org e-mail: laecperiyar@yahoo.co.in
Resolutions of LAEC Meetings
1st meeting held on 25-10-2004, Monday at 3 pm at Regional office of the Kerala State
Pollution Control Board, Kadavanthra, Kochi-20.
Shri K.P.George, the former Chairman of the Local Area Environmental Committee and
Shri:R.V.Satheeshan Thampuran, Senior Environmental Officer P.C.B were also present.
Shri:K.P.George the former chairman of the committee briefed activities completed by the
earlier committee.
Chairman Mr. P.K. Ibrahim in his introductory speech stressed the need for protecting the
environment from the irreversible harm caused by the hazardous chemicals and wastes in
violation of environmental loss by the industrial sector and the threat posed to river Periyar .
He has also expressed the need for enlightening the entrepreneurs to respect the law. The
Chairman remarked that the proforma prepared already fall short of certain important aspects
especially in the matter of elucidating information regarding the nature of products as to
whether it is a Hazardous chemicals , whether the waste generated is covered by Hazardous
Waste Rules etc. He stressed the need for collecting samples during inspection of the
industries and getting analyzed in the CPCB accredited laboratories to ascertain the toxicity of
the wastes. He has also remarked that assistance from few of the scientists who are associated
with the environmental field have to be associated with the inspection of the industries.
Mr. Jayathilakan of KMA opined that the industries, which have not yet responded by filling
the proforma should be inspected to make sure whether the units are defunct.
Mr. Pursuhan remarked that the information contained in the reports in the custody of the
state pollution control board on the river Periyar and illegal outlets will help the Local Area
Environmental Committee to asses the situation and to take remedial measures. He has also
remarked that few of the scientists who from the environmental area could be associated with
the committee
707
It is resolved that the Proforma received from industries should be scrutinized to identify the
industries dealing in hazardous chemicals and generating hazardous wastes.
The applications so scrutinized should be placed before the LAEC in the next meeting to take
appropriate decision regarding inspection etc. of units. It is also decided to take declaration
from industries dealing in hazardous chemicals /hazardous wastes and obtain copies of the
permission /consent on the strength of which such industries are functioning by way of an
additional query.
Resolved that the Pollution Control Board will place the study report of Periyar River and the
illegal outlets identified by them before the LAEC within 15 days.
Resolved to solicit the assistance of the scientists in the team of inspecting the industries if
required.
Resolved to find a suitable office space for LAEC at Kaloor, Ernakulam. In the meanwhile the
office of the LAEC shall function at the Regional Office of the PCB and PCB shall allot a
separate room for LAEC with necessary infrastructure.
Resolved to request PCB to make available a computer, telephone with internet facilities and
other infrastructure for the use of LAEC. It was also decided to appoint a peon and a DataEntry –Operator on Contract basis at the office of the LAEC.
Resolved to request PCB to ascertain the present state of those units which have not
responded to proforma and report to the LAEC.
Mr. Indulal, Member secretary, PCB assured all assistance and co-operation to the LAEC and
designated Mr.Sateeshan ,Senior Environmental Officer , PCB as Liaison Officer at
Ernakulan to act on his behalf .
It was also decided to meet again on Friday 29th of October 2004, at 4 pm at the same venue .
2nd meeting held on 29-10-2004, Friday at 4.30pm at Regional office of the Kerala State
Pollution Control Board, Kadavanthra, Kochi-20.
Minutes of the previous meeting was approved with minor corrections. Chairman
Adv.P.K.Ibrahim expressed regret for not been able to get the scrutiny of the Proforma
received from various industries and complete the task of identifying the industries dealing in
hazardous chemicals /generating hazardous wastes.
Chairman requested the Member Secretary to make available the service of one assistant
Environmental Engineer and the service of apprentice immediately as per the order of the
State P.C.B dated 04.09.2004 so that the secretarial work of the committee can be entrusted to
them for being completed adhering to the time schedule.
The Member Secretary, Mr.K.V Indulal assured that he would pass orders posting Mr. K.S.
Soman, Assistant Environmental Engineer and Ms. Sulfiyath, Apprentice for the secretarial
work of LAEC immediately and their service would be available from 1st of November, 2004
onwards.
708
The Chairman informed the committee that an office space at Kaloor for the LAEC is
identified for a rent of Rs. 3750/- and the room will be available from 2nd November 2004.
The committee resolved to take possession of that room from 2nd November 2004 agreeing to
the Rent of Rs.3750/-.
Member secretary assured to make available a room in the ground floor of the Kerala State
Pollution Control Board , Regional Office for the use of LAEC with the necessary staff. The
key of the said room will be either with the Chairman or with the person whom he authorizes.
The Chairman informed the Committee that ten industries have been identified as industries
dealing in hazardous chemicals /hazardous waste. The meeting resolved to start inspection of
these industries to oversee the compliance of Environmental Laws from 2nd November 2004.
The names of the industries which will be covered in the 1st phase of the visit are:
1. Premium Ferro Alloys
3. Cochin Leathers.
5. Shalimar Inks
7.Sterling Industrial Chemicals
9 Copper Blues
2. Ramanand Electrocoats.
4. TMS Leathers.
6.Sree Lakshmi Industries.
8. Galiela Blues.
10.Enviro Designs and Equipments.
Resolved to proceed with the inspection without insisting the presence of the entire committee
members. However, the Inspecting team shall consist of minimum two members of the
LAEC, one Environmental Officer from the KSPCB and a Scientist, if required. At the end of
the inspection the members of the inspection panel will hear the local residents and the trade
union leaders if an audience is sought by them. The industrial units will be given 24 hour
notice intimating the inspection of the panel. The industries will be requested to ensure the
presence of the owner / occupier / authorized competent person who knows the state of affairs
of the industry. The industry should also be asked to give notice to its employees /workers
giving them an opportunity to place their grievances, if any before the inspecting panel. The
industry should be asked to make available the copies of the statutory orders issued by them
under various environmental laws such as Environmental Protection Act, Manufacture,
Storage and Import of Hazardous Chemical Rules, 1989, Hazardous Waste (Managing and
Handling )Rules 1989; Water (Prevention and Control of Pollution) Act, The Air (Prevention
and Control of Pollution) Act etc.
The industries should be asked to make available the form No 5 - Environmental Audit Report
and laboratory reports of the accredited agencies. It should be asked to keep ready other
records which are to be maintained statutorily for inspection of the LAEC.
Resolved to hear public on every first and third Saturday of the month at the Eloor site office
of the Pollution Control Board from 2.30 pm onwards. The office at Kaloor will receive
complaints from public.
The matter regarding the finalization of names of the Scientists to assist the Committee stands
deferred to the next meeting.
709
The Chairman shall prepare a checklist to be given to the inspecting panel indicating the
matters to be ascertained by the inspecting team and for reporting to LAEC and the same will
be given to Shri: G. Anand for being circulated among the committee members.
Resolved to open a web site in the name of the LAEC and Shri: Indulal, Member Secretary is
authorized by the committee to ensure that the website is created immediately.
Resolved to take the assistance of LAEF a body of High Court Advocates working for
Conservation of Environment .
Resolved to have a joint meeting of the scientists and members of LAEF.
Shri. Purushan submitted five copies of a complaint received from Shri. Sojan Joseph for the
consideration of the Committee. Chairman expressed that this complaint will be looked into
and will be discussed in the next meeting. Copies of the complaints were distributed among
the members .
The meeting expressed anguish over the report, which appeared in the press regarding the
proceedings of the committee in the last meeting . The committee confirmed that the chairman
of the committee will brief the press about the final decision of the committee.
Resolved to send the minutes of the proceedings of the first meeting to the
Supreme Court Monitoring Committee.
3rd meeting held on 2/11/2004, Tuesday at 4.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The members shared their views on the industries inspected namely TMS leathers at Edayar
and Cochin Leathers Pvt. Ltd. Edayar. It is resolved that the members of the inspecting team
will give their individual report to compile a final report.
Resolved to visit the remaining leather units and bone meal units on 4-11-04
Resolved to take the scientific advice from the following panel members in the matter of
saving Periyar river and for combating the environmental threat caused by the industrial units
at Eloor and Edayar by their indiscriminate disposal of hazardous wastes. The following
names of the scientists have been approved.
1. Prof .M.KPrasad
2. Dr. C.M Joy
3. Dr Madusoodanakurup
4. Dr.V.N.Sivasankarapillai
5. Dr.M.V.Sukumaran nair
6. Dr. Chandra mohan
7. Mr.R .Sreedhar
8 .Dr.M.L. Joseph
9. Dr. G.Madhu
710
4th meeting held on 4/11/2004, Thursday at 4.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The members shared their views on the industries inspected namely:
1.Kairali leather industries Edayar
2.AES Industries Edayar .
3.Cochin Fertilizers ,Edayar .
4.Sigma Industries .
5. An unit unauthorisedly being run by Mr. Shahul (Tallow unit). Ph: 2443066
6. Asha exports an unauthorized unit being run by Mr. Elthose Ph: 2551990 & 2459216 (R)
It is resolved that the members of the inspecting team will give their individual report to
compile a final report.
Resolved to have six chairs and one almirah for LAEC office. Mr. Sateeshan will take up the
matter with the member secretary and do needful to provide the facility.
5th meeting held on 6/11/2004, Saturday at 11 am at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolved that the minutes of the previous meetings held on 29/10/04, 2/11/04 and 4/11/04 is
adopted. Resolved to consider the reports of the units visited on 2/11/2004 & 4/11/04 in the
meeting to be on held Friday 12/11/04.
Resolved to visit the following units.
1.
2.
3.
4.
5.
6.
7.
8.
9.
Yeoman Bone and Allied products.
Kaveri Bone
Nelkadir Bone
Organo Fertilizer
Organic Fertilizer
Panchami Fertilizer
S.R.S. Industries.
South Indian Industries
National Industries
Resolved to give notice to these units on 6/11/04 informing the visit of the panel of the LAEC
on 10/11/2004 at 10 am.
Resolved to inspect the following Units, the exact dates will be finalized at the meeting to be
held on 12/11/2004
On 16-11-04:
1. Steel engineering works Edayar.
2. J.M.J Machines and Equipments Edayar
3 Damodar Industries Edayar.
4. S.B.N Engineering works .Edayar
5 Rini Engineering works
711
6 Star Engineers
7 Ramanand Electrocoats
8 High tech seals Pvt Ltd.
9 Adithya Engineering Company
10.Accruate Components and Tools .
On 17-11-04
1.
2.
3.
4.
5.
6.
7.
Southern Carbons Pvt Ltd
Manoj Engineering works
St.George Industries
V more engineering works
Poduval Industries
National Granities
Vijay Associates
On 20-11-04
1 Sud Chemie India Pvt Ltd
2 Njavallil Latex.
3 Nini Crepe mill
Resolved to chart out the inspection of the units after categorizing the units, product- wise.
Mr. Asokan has been entrusted to categorize the industrial units. The list will be made
available in the meeting on 12/11/2004.
The PCB will make available the report on Periyar without fail before 9/11/2004 and that will
be placed for discussion on 12/11/04.
Resolved to have a joint meeting of the scientists and LEAF on 13/11/04 at Y.M.C.A at 10.00
hrs. Mr. Purushan is entrusted to arrange the conference hall and lunch at Y.M.C.A.
Chairman reported to the committee that he had issued a press release regarding the decision
to take the assistance from the scientists and members of LEAF. The press release also
announced the opening of new premises and notified to the public that the complaint will be
received at the office from public or other corners on the environmental pollution cause by the
units. The press release also notified the decision of the LAEC to hold public hearing at the
site office Eloor on every first Saturday and third Saturday from 2 pm.
Resolved to consider the complaints by Mr. Sojan after inspecting the concerned unit.
6th meeting held on 12/11/2004, Friday at 4.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
LAEC on their inspection at Eloor –Edayar area on 2-11-04 found the site office of pollution
control board at Eloor closed. The office set up in the industrial belt is non functional for a
pretty long time. There is absolutely no infrastructure such as lab facilities, lab technicians
and other competent personnel for conducting inspections and monitoring the units at regular
712
intervals. There was no arrangement even to attend to emergency situations. The LAEC
chairman expressed the view it is not surprising why the environmental laws are violated by
the industrial units with impunity. He expressed shock on this sorry state of affairs and
wondered why the office set up in the middle of 247 industries in Eloor-Edayar area was
neglected in such manner.
The Hon’ble Members strongly disapproved the manner in which the site office is maintained.
The LAEC resolved to demand PCB to immediately open its site office at Eloor-Edayar and
start its function with necessary infrastructure having regard to the significance and important
of such an office in the industrial belt for ensuring the continuous monitoring and surprise
visits to industrial units to check and control the indiscriminate manner in which industries
operate. The office at Eloor be made functional with necessary infrastructure such as
telephone, fax, laboratory, vehicle, lab technicians and other staff for periodic and surprise
inspections and analyzing the samples.
It is suggested by Hon’ble member, Mr. Purushan that at Eloor Ferry adjacent to Eloor village
office, a site has to be acquired for establishing a lab unit by the PCB, which would help the
Pollution Control Board to continuously monitor the water quality in River Periyar. Member
Secretary, PCB reported that there is already a proposal pending before the Dist. Collector for
allotting 15 cents of land in favour of PCB for setting a lab unit. Local Area Environmental
Committee resolved to take up the matter with the Dist Collector, Ernakulam, Pollution
Control Board, District Industries Centre and concerned local bodies for taking forward the
proposal. Hon’ble member, Mr. Purushan will take follow up action in this matter.
Chairman reported in the meeting that Hon’be members of LAEC, Mr Jayathilakan , Mr
Asokan, Mr Anand, Mr Jacob Lazer, Mr. Purushan and Mr. Sateeshan Thampuran were
present at the site office on 6-11-04 for a public hearing. The Committee did not receive any
complaints. It is decided to issue notice to various organization working in Eloor- Edayar area
for their active participation in combating the pollution.
Chairman expressed his concern about the employees working in various industrial units
particularly industries engaged in bone meal, hoofs, tallow etc. and the lack of facility
available in units for their basic requirements and other working conditions. The members of
LAEC who inspected these units insisted that LAEC should explore all possible means to
ensure good working condition and basic requirement including drinking water to the
employees of this unit. Appreciating the pathetic state of affair of the working class there,
LAEC decided to take up the matter with the Dist. Medical officer, inspectors and boilers and
other labour officers for ensuring better working amenities.
Hon’ble member, Mr Asokan brought to the notice LAEC that the industrial units at Eloor &
Edayar are setup in the plots allotted by DIC. The industrial units in the area are facing acute
drinking water shortage on account of insufficient number of water connections. Industrial
units are not getting drinking water connection from Kerala Water Authorities, due to the
objection from DIC in laying pipe. The DIC and Water Authorities should be appraised about
the problem and steps should be taken to remove the stalemate if any, and solve the drinking
water problem. LAEC shall take up this matter with the authorities to ensure water supply and
Hon’ble member, Mr Asokan is entrusted to follow up the matter .
713
Member secretary, Pollution control board made available the report on Periyar as requested
by LAEC in its previous meetings. Copies of these reports will be circulated among the
members of LAEC .
Hon’ble member Mr Asokan prepared the list of industrial units product wise for
inspection. Inspection of the following 10 engineering units will be made on 15 -11-2004.
1.Steel Engg.Works.
2.JMJ Machines &Equipments.
3.Damodar Industries
4.SBN Engineering Works
5.High Tech Seals (p)Ltd
6.Rini Engineering Works.
7.Star Engineers .
8.Ramanand Electrocoats.
9.Accurate Components and Tools
10.Adithya Engineering Company.
Notice shall be issued to these units on 13 -11-2004. Mr Asokan, Hon’ble Member of LAEC
is entrusted to ensure the service of notice to these units.
On 16-11-04 the following 5 engineering units and 3 metal crusher units will be inspected .
1.Manoj Engineering works
2.Poduval Industries
3.V More Engineering works
4.St.George Industries
5.K.K.Engineering works.
6.Vijay Associates
7.National Granites.
8.Kummancheriyil Metals
Resolved to categorize the medium and large scale industries product wise in the meeting to
be held on 17-11-04 for fixing the date of inspection. On 17-11-04 inspection report of the
units visited on 15-11-04 and 16-11-04 will be finalized .
LAEC will inspect Sud chemie India Pvt Ltd, Njavallil Latex Pvt Ltd and Nini crepe mills at
Edayar on 20-11-2004 at 10 am. Notice shall be issued to these units.
During the local inspection of the industrial belt, LAEC has come to know that there are many
unauthorized industries function. The LAEC has decided to seek details from Dist. Industries
Centre regarding the names and address of the allottees, the product for which the land is
allotted, the extent of land etc. and to take action against these units including cancellation of
allotment.
A complaint from Edayar small scale industrial units against unauthorized blocking of public
road by M/s CMRL Ltd., was received and it was decided to consider it in the next meeting.
714
Report of the industrial units inspected on 2-11-04 and 4-11-04 were placed before
committee. The meeting was adjourned for want of time and the next meeting will be held on
19-11-04.
Resolved that the chairman would brief the press and the media about the decision of the
LAEC meetings.
Member secretary, Pollution Control Board reported that he attended the meeting convened
on 9-11-2004 by Kerala State Industrial Development Corporation (KSIDC) to discuss the
Treatment Storage and Disposal Facilities (TSDF). He informed LAEC that a decision has
been taken to form a company for implementing the project and adhoc committee for the
said purpose has been constituted . It is also decided to select a suitable site at Ambalamedu in
the premises of FACT Cochin division. A three member committee was constituted for
identifying the site within three days
Joint meeting of LAEC with Scientists held on 13/11/2004, Saturday at 10.30 am at
Y.M.C.A. , Chittoor Road, Ernakulam with the presence of invited Lawyers(LEAF)
Honourable member Mr.Purushan invited the Chairman Local Area Environmental
Committee(LAEC), Mr.K.V.Indulal (hon. member)and Prof’M.K.Prasad to the podium to
join the meeting . The meeting started at 10.40 a.m.
Mr.Indulal Member Secretary of KSPCB and member of LAEC welcomed the gathering and
briefed the formation of the LAEC by the Supreme Court .
Adv.P.K.Ibrahim, Chairman of LAEC presided over the meeting. In his presidential address,
he stressed the need to protect the environment and the new initiative taken by the Supreme
Court against the indiscriminate handling of hazardous waste. Chairman pointed out that the
Local Area Environmental Committee started its work in the direction mentioned by the
Supreme Court Monitoring Committee(SCMC).Chairman (LAEC) called on the scientists,
technocrats and N.G.O’s to be the part of LAEC mission and sought their all-round
participation to protect the environment and especially River Periyar..
Prof. M.K.Prasad in his keynote address expressed his gratitude that the committee has
invited the scientists for a discussion. He expressed his concern about the effectiveness of the
TSDF . According to him the working of such units throughout India is not satisfactory as
pointed out by Sri.Gopichander, Prof. Prasad also said that there should be an Environmental
Impact Assessment(EIA) study and the SCMC should supervise the construction.
Dr.Sivasankarapillai of CUSAT spoke on the Periyar action plan.
Dr.Madusudhanakurup of CUSAT spoke on the impact of industries on the life of Periyar.
Dr.Sivasankarapillai emphasized the need for an environmental performance evaluation and
the environmental audit .He said that the rule in Hazardous Waste is not complete and there
exists no inventory regarding Hazardous Waste.
715
Mr.Sreedar of Thanal, NGO has pointed out the importance of pollution imparted by HIL and
its analysis. He exclaimed that the results of the Pollution Control Board’s analysis is better
than the ones by the accredited laboratories.
Dr.Madusoodanakurup said that the fish wealth is important and the renovation of the
environmental quality of the rivers in Kerala is important and the CUSAT has formulated
some sort of an index with which the status of the rivers can be assessed .He has also said the
twelve varieties of the fishes which are present in Periyar is not seen any where in the world
and he also said that the restoration of the fishes health should be made with the polluter pays
principle.
Dr.Joy of Sacred Heart College pointed out about the non-formation of the inventory of
polluters. He also said the unauthorized effluent outlets of industries identified earlier should
be closed down and the river banks should be protected .The standards should be made more
strict since the quantity of the river flow has been reduced.
Mr.Purushan expressed that the SCMC has instructed to take action against the industries
within six months if compliance is not achieved.
Mr.Sreedhar said the data available with PCB on Periyar River should be compiled and there
should be a workshop. The workshop should take place in December 2004.
LEAF representative said that the industrial labour relation is very poor and the working
condition of the labourers have to be investigated and improved.
Prof. M L Joseph of St.Alberts College said that a socio economic inventory should be
prepared and it should be analyzed for decisions.
The meeting concluded with the following decisions
Dr.Sivasankara Pillai of CUSAT has volunteered to prepare a check list of the environmental
performance evaluation report. The proforma of process details of industries will be handed
over to him by the LAEC
Mr.Anand will start a Yahoo Group for interaction with the scientists and to exchange
informations.
Dr.Madhusudhanakurup of CUSAT will make a bio-diversity index data for Periyar and will
be distributed for reference in the seminar.
The committee will seek advice from Prof.M.K.Prasad on TSDF matter.
Dr. Joy was entrusted with the charge of preparing a water shed management programme
The Workshop on Periyar to be conducted on 20-12-2004.
Thanal and CII is entrusted with preparing a white paper on toxic reduction and recycling of
wastes.
716
Prof.M.L.Joseph is entrusted to submit a report on Socio
environmental cost calculation .
economic aspects and the
Honb’le member Jayathilakan expressed the vote of Thanks.
7th meeting held on 17/11/2004, Wednesday at 3.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Hon’ble member, Mr. Anand expressed his view that the inspecting team should be provided
with some minimum safety measures, such as masks, helmet etc. and that the team should
take samples of the waste to make sure whether the unit is adhering to the conditions imposed
in the consent order, lest the inspection will be a mere formality.
The committee unanimously resolved to request Pollution Control Board to provide mask and
other facilities and also make arrangements for taking samples from ETP sludge, Effluent,
Stack Emissions, Noise and Ambient Air for laboratory analysis.
The committee also decided to incorporate in the notice to the individual industrial units to
provide mask and other safety devices while inspecting their units.
The committee finalized the inspection reports of TMS leathers, Cochin leathers, and Kairali
leathers .
8th meeting held on 19/11/2004, Friday at 4.45 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolved to take samples while inspecting M/s Sud Chemie India Pvt.Ltd.on 20-112004(Saturday).
There was difference of opinion regarding the assistance to be sought from the panel of
scientist approved by the committee while inspecting M/s Sud Chemie and other medium
scale industries on 20-11-2004. Hon’ble Member, Mr Jayathilakan and Mr Asokan opined
that the presence of experts need to be sought only if the inspecting team feels absolutely
necessary during the course of inspection.
Mr. Purushan expressed that the assistance from chemist from the panel of scientist should be
availed in addition to the presence of Environmental Engineer Mrs. Chitrakumari of PCB.
Chairman strongly expressed his view that Sud Chemie being a medium scale unit dealing in
hazardous chemicals and hazardous waste, it is highly expedient to have the assistance of an
expert, for the reliability and credibility of the report of LAEC. Further the inspection being a
time consuming process, there is time constraints for LAEC to accomplish its work.
For the above reasons, Chairman having found divergent opinion in the meeting among the
four members and exercising his discretion as the Chairman ruled to seek the assistance of an
expert from the scientists panel approved subject to the availability of the scientist from the
approved panel.
717
The report appeared in the Press on the large scale killing of fish in River Periyar was
discussed. The cause for killing of fish can only be attributed to the large scale discharge of
wastes from various sources. LAEC has taken strong exception to such disposal of waste into
Periyar River and condemned such act in strongest terms.
It is decided to take strong action against persons resorting to such disposal of waste in future
causing damage to the aquatic life. All concerned were advised not to resort to such short cut
methods of disposal of waste into River Periyar. The public was also requested to raise voice
against such indiscriminate discharge of effluent to the River Periyar and help LAEC to
capture the culprits red handed.
9th meeting held on 22/11/2004, Monday at 4.45 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The LAEC in its urgent extra ordinary meeting held on 22 .11.04 at 4.30 pm expressed deep
concern over the colour change in River Periyar yesterday ie, 21-11-2004. The colour change
in River Periyar was detected from the portion starting from M/s CMRL to downstream upto
Eloor ferry. The Industries situated in between these area are suspected to be the culprits in
discharging untreated effluent to the River Periyar .
The LAEC has resolved to undertake river monitoring periodically and take water samples
from the outlets of these factories. It is noticed that many of the industries do not have
enclosed compound wall and therefore these industries have direct access to Periyar.
There are wild bushes covering the outlets of effluents open to River Periyar.
Therefore it is decided to instruct all the units situated on the banks of the River Periyar to
clear bushes and other wild growth from their boundaries to the river mouth and make the
outlets visible. The unit should be request to do this work forthwith to enable LAEC for
monitoring river from 26-11-04 onwards.
Pollution Control Board shall arrange a boat on 26-11-04 and other subsequent dates for
periodical inspection. The committee requested Mr Purushan to arrange divers for diving in
Periyar to detect concealed / unauthorized outlets in the river.
It is Resolved to request DIC Ernakulam to block the Periyar Chemicals Road having its dead
end at Periyar permanently to prevent tanker and other lorries going to river side for illegal
activities.
10th meeting held on 25/11/2004, Thursday at 4.50 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The LAEC suspended the inspection scheduled today for want of arrangement on the part of
Pollution Control Board for monitoring stacks. The units already visited have stacks and stack
monitoring of those units have to be carried out. It is resolved to carry out stack monitoring in
718
Sud Chemie Pvt.Ltd, Hi- Tec Electro Thermics and Sree Sakthi Paper Mills etc. The noise
level and ambient air quality at the stone crusher units will also have to be undertaken.
Hon’ble member, Mr. Anand reported that there was no arrangement to take stack monitoring
when the team visited medium scale industries such as Sud Chemie, Hi- Tech Electro
Thermics etc. He also pointed out that there was no facility for monitoring air quality, noise
level, and ambient air quality. The committee was informed by Mr.Sateshan Thampuran that
there are no trained persons to climb the stack for monitoring stack in the Pollution Control
Board and to take samples from stacks. The staff presently available owing to their age factor
cannot climb the stack and that the Board has not taken regular samples for the last 2 years.
It is observed that that the Board used to engage persons from employment exchange to meet
the deficiency of staff, but none of the staff so engaged are trained for taking samples from
stacks.
LAEC is shocked by this information and expressed its concern over this pathetic state of
affairs of the PCB. Eloor-Edayar area being an industrial belt with medium and large scale
industries having a minimum of at least 50 stacks ranging at the height from 15 – 75 metres, it
is a clear case of negligence on the part of the Pollution Control Board in the matter of
monitoring air quality. Admittedly, Pollution Control Board has qualified persons to supervise
the air quality but they are not engaged for monitoring air having regard to the age factor and
the resultant inability to climb the stacks. According to PCB, they rely on the reports of the
accredited agency.
LAEC having regard to the statutory function of PCB strongly disapproves the casual
approach of the Pollution Control Board in monitoring air quality. Their plea that sufficient
staff are not available to monitor the air quality cannot be accepted, since Pollution Control
Board have been recruiting persons from employment exchange to make up the deficiency of
staff. It is understood that the Hon’ble High Court of Kerala have issued directions to
engaged sufficient staff to make the Board functional.
LAEC in the circumstances has resolved to demand Pollution Control Board for making
arrangements for stack monitoring, noise level monitoring and ambient air quality monitoring
in Eloor –Edayar industrial belt forthwith.
The meeting condoled the death of the beloved father of Member Secretary, Mr. Indulal and
decided to convey the condolence message to the bereaved family.
It is resolved to conduct surprise inspection at all suspected industrial units discharging
untreated effluent into Periyar and take samples of solid waste, liquid waste etc. from these
industries.
11th meeting held on 1/12/2004, Wednesday at 5 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Meeting finalized the Report to SCMC
719
Meeting resolved to conduct survey of the river bank through Periyar and Eloor-Edayar
industrial belt with the officials of DIC to appraise them of the damage caused to the Periyar
and in the areas of the industrial belt by the indiscriminate discharge of effluent and solid
waste to the river and land by the industrial units.
The meeting decided to address a letter to the General manager of DIC seeking his cooperation in the inspection proposed to be held on 4-12-2004.
The meeting entrusted the chairman to fix the salary of the Data Entry Operator and peon
taking into account various aspects such as normal salary of the staff in PCB in equivalent
post and also the work load etc.
12th meeting held on 3/12/2004, Friday at 5.10 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Local Area Environmental Committee conducted a surprise inspection at Binani Zinc Ltd in
Edayar industrial belt on 2nd December 2004 from 10.00 am. The inspection team during its
combing operation in and around jarosite pond, discovered an illegal effluent outlet
approximately at a distance of 10 metres from the bank of Periyar river in the premises of
Binani Zinc Ltd.. The effluent from the said illegal outlet was seen discharged into an open
land. The land was found reddish in colour and a water channel carrying the effluent from the
land to the river was clearly visible. On dipping a stick into the said land, slushy material at a
depth of 30 cm could be seen accumulated. Deposit of red particles was seen in the
surrounding areas of Periyar close to the outlet. The vegetation in the water channel and in
and around the land was seen damaged presumably on account of the toxicity of the liquid
discharged in to the land.
The team made an endeavor to trace the origin of the outlet by back tracing .The origin of the
outlet was found at land adjacent to the capped pond .The silt in the water channel at its
source was found red in color. The open channel after taking some diversion and at the point
of pond no 4 continued further down underground through a concrete pipe providing 8
manholes at different places having depth at the range of 7 to 12 feet approximately. The
water and silt collected in these manholes were also seen red in color. The land/sand color in
the area as a whole was not red .However the color of the silt seen in the drain was reddish.
The inspecting team collected samples from various points. The lab report of the collected
samples is awaited.
The inspection was conducted in the presence of senior officials of the company namely Dr.
K Sasi , Mr. Roy Kurian, Mr. Sudheer, Mr. Roshan . They admitted that the outlet detected by
the team is unauthorized. The company has not provided the sketch and plan of the drainage
and the purpose for which it was being used to the pollution control board.
The outlet provided in their premises leading its effluent to Periyar River is undoubtedly
illegal and unauthorized. The company officials could not explain the reasons for the red color
of the effluent seen in the manholes and at the dead end of the outlet. According to them it is a
storm water drainage constructed to prevent flow of rain water in to adjacent land and outside
720
their premises. Only two outlets are permitted by the Pollution Control Board, one for
discharging treated effluent and other for storm water through ETP.
The outlet detected by the inspecting team was found carrying effluent. The inspecting team
has directed the company official to stop using this drainage for any purpose and furnish a
sketch and plan marking the location of ponds and distance from Periyar River to the outlet
etc. The company officials also directed not to disturb the land or meddle with the present
character of the land.
The team found an open land close to Popular Industries with wet red color mud accumulated
with clear water channel indicating carrying of effluent into the adjacent plots. The opening to
this land was through an underground culvert across the Paravur-Pathalam Road. On the other
end of the culvert is the compound of the Binani Zinc. The inspecting team could find the area
wet with red color mud. The inspecting team accompanied the company officials went to the
premises and inspected that particular area. There were clearly visible signs of effluent being
discharged into the land where huge quantity of semi-dried sludge was seen. The vegetation
there was also seen damaged.
According to the company officials, there is possibility of pumping of effluent into their
premises from outside. The explanation was not satisfactory. The inspection team found the
company using open land for discharging effluent and making its run of through low lying
areas.
It is also found that there are few other water channels here and there in the premises of the
Binani Zinc Company containing sludge carry off in reddish color up to the bank of River
periyar. There is no compound wall in the river side all along the company boundary facing
river.
M/s. Binani Zinc Ltd is found causing damage to the land and river by discharging untreated
effluent indiscriminately and causing irreversible damage. The untreated effluent with solids
carry of hazardous waste has caused extensive damage done to the land and water.
LAEC resolved therefore to place this report before KSPCB and request to take following
action forthwith.
To conduct random excavation in the company premises as to ascertain the quantum
of hazardous waste dumped in to the land and locations where it is dumped.
To direct the company to dismantle the illegal outlet provided under the ground.
To direct the company to remove the sludge collected at the points of outlets and got
accumulated at other various points.
To direct the company to construct a compound wall to prevent any discharge from
their premises accidental or otherwise to River Periyar.
To initiate all legal action including prosecution against the company after fully
complying with the procedure.
721
The company should be directed to clear the wild undergrowth all along the boundary
of the company facing the river.
13th meeting held on 5/12/2004, Sunday at 10.15 am at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
LAEC for Eloor-Edayar area may be furnished with the names of the unit dealing in
hazardous chemicals and hazardous waste giving break-up of units having authorization under
Hazardous Waste (Handling and Management Rules) 1989 separately. The Pollution Control
Board may also give information as to the action taken on the application pending for
authorization and the names of the Units whose application are pending before PCB for
authorization. The details may be furnished immediately, in any case before 7-12-2004.
E-mail dated 1-12-2004 appreciating the work of LAEC received from Dr. Claude Alvares,
Member-SCMC was read for the information of members. As requested by him the details of
units generating hazardous wastes will be furnished after obtaining necessary details from
PCB.
The LAEC expressed various problems confronting its functioning for want of sufficient
funds at its disposal. Even salaries and honorarium to the members could not be paid in time.
The committee therefore requested the Member Secretary to do needful by transferring
sufficient funds to LAEC account to meet its expenditure and to authorize an officer in the
PCB to operate the account. Honb’le Member Secretary agreed to the proposal of the
committee and assured that the fund will be made available at the disposal of the committee.
The following resolution was passed:
“The committee resolved to open an account in the name of Local Area Environmental
Committee for Eloor- Edayar area in any of the Nationalized Bank at Ernakulam and the
convener of the Local Area Environmental Committee, Mr. Indulal, Member Secretary,
Kerala State Pollution Control Board is authorized to do the needful and open the account on
behalf of the Local Area Environmental Committee and operate either by himself or through
his authorized person”
LAEC resolved to request PCB to provide adequate manpower in the Central laboratory to
ensure speedy and timely laboratory reports on the samples collected from the industrial units
by the LAEC.
Resolved to meet the Chief Minister on 14th December or any other near date available to
appraise him of the problems and seeking the support of the State Government in solving
them. Member Secretary, who is the Convener of the Local Area Environmental Committee is
entrusted to take an appointment for meeting the Chief Minister.
It is decided to have a press conference on Sunday, 12th December, 2004 at the Press Club
Ernakulam.
Local Area Environmental Committee during its river survey found the following companies
are yet to carry out the directions issued to them for clearing the wild undergrowth along their
boundaries facing the river.
722
1. Binani Zinc
2. FACT (notice not earlier issued)
3. Indo German Carbons
4. Njavallil Latex Pvt.Ltd
5. Oasis Industries
6. Cochin chemicals
7. Star Rubbers
8. Ambedkar Cooperative society
9. Kairali leather
10. Abco Accumulators
11. Pioneer chemicals
12. Horra Paints
13. Harisree Rubbers
14. Cochin Minerals and Rutiles Ltd
15. Alwaye Techno Engg. Pvt Ltd.
Fresh notice shall be issued to these units directing them to clear wild growth along their
boundary facing the river.
During the joint inspection of LAEC with officials of DIC namely Smt. Kamalamma
(Manager, DIC), Smt. Jnanamma (Industrial officer, D A Edayar) and Mr. Ravi
(Field Officer, DIC) at Eloor -Edayar industrial belt, the team found industrial
waste dumped in open land behind Arjuna Natural Aromatics and illegal sand
mining at different points namely Chirayamkadavu in Alangadu panchayat;
Methanam in Eloor Panchayat; point near to V.R Woods; point near to Yeoman
Bone Industries and Binani Zinc Ltd.
Near to Sud Chemie (I) Pvt. Ltd, illegal sand was found loaded into a lorry bearing reg. no.
KL 06 –2903.
The inspecting team suggested that the officials of the DIC should either block
the road by fixing post across the road at four locations, viz., near Sud Chemie,
Arjuna Natural Extracts, Neptune Readymix Concrete (P) Ltd; across the road
between Binani Zinc and Sud Chemie or in the alternative to permit the PCB to
fix the poles and block the road. The inspecting team appraised the DIC officials
of the need for having a clearance of minimum 20 metres from the factory
building to the river bank to protect the river from dumping waste both solid and
liquid effluents. The officials have agreed to take up the matter with higher
officials.
LAEC also during its inspection found an internal industrial road being blocked near to the
Cochin Fertilizers. This road is the only one, which gives uninterrupted access to various
industrial units. By blocking the road the regulatory agencies often face problems for
inspecting industrial units and are compelled to take diversion. There is absolutely no
justification in blocking public road for the exclusive use of one or two units.
The space occupied by the road if allotted to any unit has to be resumed and the
road should be opened forthwith for public use. If the road has been blocked by
any private person for the use of their unit illegally that unit should be directed
to remove the obstruction forthwith. It is also brought to the notice of the LAEC
that similar road blocking can be seen at the road leading Merchem, Edayar.
723
LAEC resolved that all illegal blocking of internal roads obstructing the traffic
have to be removed.
The District Industries Centre, Ernakulam had furnished a list industries in whose favor land
allotment have been made. LAEC resolved to examine the real occupant in the area viz-a-viz
allotment to find out the illegal occupants .
LAEC members namely, Mr. Anand, Mr. Jacob Lazar and Senior Environmental
Engineer Mr. Sateeshan Thampuran attended the site office for public hearing.
The report of the public hearing forms part of this proceedings. LAEC resolved to
request the Govt. to take action against the following industries who have made
construction encroaching the river.
1.
2.
3.
4.
5.
6.
7.
Yeoman Bone and allied products
Sud Chemie India Pvt Ltd
Indo German Carbon Ltd.
Crescent Industries
Southern Minerals and chemicals
Merchem Ltd.
Neptune Readimix Concrete and others
A meeting of the scientists with LAEC is proposed to be held on 8th December 2004 evening
at 5 pm.
Mr. Purushan, the Hon’ble member of LAEC reported that there was an explosion
in Binani Zinc Ltd. yesterday at about 9.15 pm. Upon hearing this, members,
Mr. Jacob.V.Lazar, Mr. G. Anand and Mr. Asokan reached Binani Zinc at 10 pm.
All senior officials of the unit were present and they explained to the LAEC
Members that the reasons for the blast is due to a flame in their bag house in
the Zinc melting plant. Following this a rubber elbow bursted and damaged the
asbestos roofing resulting in big noise and smoke. There was no injury to any
person. Everything was brought under control immediately .The three members
left the unit at 11 pm. The members found local residents assembled outside the
company anxious to know what has happened. The members of the Local Area
Environmental Committee requested the company officials to take necessary
action and alleviate the anxiety of the public.
Binani Zinc Co. submitted their sketch of the “storm water drain” detected by the
committee as unauthorized outlet. A Photocopy of this sketch and plan should be
forwarded to PCB to ensure its dismantling forthwith
14th
meeting held on 7/12/2004, Tuesday at 5.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Hon’ble member, Mr. Anand pointed out that in the proforma submitted by the units there is
deliberate attempt to mislead by not furnishing the information relevant to question. The
proforma of the following industries and documents furnished by them has to be thoroughly
scrutinized and a report on the compliance / non compliance of the environmental laws has to
be prepared. The committee resolved to entrust the said work to Mr. Sateeshan Thampuran
who will scrutinize the proforma and other documents furnished to the LAEC and will submit
724
a record case by case on each units to LAEC in the next meeting which is proposed to be held
on 10th December 2004.
Following units selected on random basis are will cover the first phase of the above task.
1. Cochin Minerals and Rutiles Ltd
2. Binani Zinc
3. Sud Chemie India Pvt Ltd
4. Indo German Carbon Ltd.
5. TMS Leathers
6. Njavallil Latex Pvt.Ltd
7. Merchem Ltd Edayar
8. Cochin Leathers Pvt Ltd
9. Sree Sakthi Paper Mills Ltd
10. Periyar Chemicals Ltd
11. Hi-Tech Electrothermics Pvt.Ltd
Resolved to contact Member Secretary to fix a date for the inspection of CMRL.
Dr. Madhu and Prof. M.K. Prasad to be requested to be present during the
inspection
Resolved to issue identity card to the members of LAEC which each member will
carry during every inspections Mr.Anand is entrusted to do necessary follow-up
actions in the matter of issuing identity cards.
Resolved to meet the Collector to seek co-operation of the district administration for the
smooth functioning of the LAEC. Mr. Anand will seek an appointment.
.
Resolved to hold a Press conference on Wednesday, 16th December at 11 am
Resolved to sanction Rs.350/-as honorarium to scientists / experts attending the meeting
convened by LAEC forthwith. Dr. Joy who accompanied the LAEC team in the boat trip for
evaluating Periyar bank should also be paid Rs.350/-as honorarium.
Joint meeting of LAEC with Scientists held on 11/12/2004, Saturday at 10.30am at
Local Area Environmental Committee Office, Kaloor Towers, Kaloor.
Resolved to hold a workshop on Periyar on 8th January 2005.
The manuscript of the papers to be presented in the seminar shall be submitted on or before
3rd January, 2005. The scientists and committee members will meet at 5.30 pm on 5 th January,
2005 to prepare a draft recommendation of the workshop based on the papers submitted for
presentation.
The following topics are finalized for presentation of papers in the workshop.
1. Past and present status of River Periyar – Its condition from upstream to downstream
by Dr. A.C.Paul
2. Sand mining and Periyar River by Prof. Sitharaman.
725
3. Habitat restoration of River Periyar by Dr.Madusoodanakurupu
4. Inventory of Industrial and urban discharge into Periyar by Dr. V.N. Sivasankara
Pillai.
It is resolved to invite NGOs and Representatives of Industries, representatives form PCB,
Environmentalists etc. to the workshop. Minimum 50 participants should be ensured
15th
meeting held on 14/12/2004, Tuesday at 3.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Chairman briefed the committee members about the information he received from an
informant about the ETP operation of Merchem Ltd, Eloor and the device resorted to
discharge the untreated effluent into Kuzhikandamthodu. The name of the informant was
not divulged even to the committee members keeping in view of the security of the
informant . The visit of the LAEC team on 9-12-04 was only a pilot visit for familiarizing
with the ETP system . The inspection conducted on 13-12-04 was in pursuance to the
details provided to the Chairman. The observations during the inspections were more or
less corroborating the information supplied by the informant. Merchem Ltd, Eloor was
resorting to unfair means in discharging the untreated effluent by maintaining a
deceptive treatment plant. This meeting unanimously endorse the inspection report of
Merchem Limited .
The committee resolved to forward the report to the State Pollution Control Board and to
the SCMC immediately for necessary follow up action .
16th meeting held on 17/12/2004, Friday at 7.10 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolved to discuss the inspection on CMRL and Sud Chemie in the next meeting.
The report of the visit to the small scale industries which is pending has to be
finalized without further delay .
Resolved that photographs that may be taken during inspection shall be the property of
LAEC and be kept in LAEC files. It is further Resolved that the photographs shall not be
distributed to press or media without the permission of the Chairman. During inspection,
LAEC members may direct the company officials to operate or do such acts as warranted and
on their failure if the same can be operated by any of the member of the LAEC team with the
permission of the Chairman, the same can be done.
During inspection members of LAEC shall not engage in any arguments with the owner /
occupier of the Units. Whatever clarifications are required can be sought and their reply can
be recorded as such. The inference and findings of the committee shall not be disclosed by
any committee member.
Resolcved that minimum 2 to 5 days or such number of days at the discretion of the
Chairman depending on the urgency and gravity of the matter be given to PCB for taking
action on the reports submitted to PCB before publishing the report. PCB will be asked to
726
take actions on the report within a specified time. The report will be released to the press and
for the public only thereafter by the Chairman.
Chairman expressed his concern on the move of ome of the organizations to recall their
nominated members to LAEC to substitute them with another. Chairman emphasized the need
to continue with the present team and the importance of having security to the term of
members to the LAEC by various organizations.
Unless security of tenure is guaranteed, the members of LAEC will be under pressure in
discharging their duties and it will subvert the larger objectives of LAEC. Members who
have inspected various industries will be in full knowledge of the facts & circumstances of
each case and recall of them by their respective organizations will obstruct the functioning of
LAEC. Chairman did not agree to the request of Mr. M. Asokan, representing the Edayar
Small Scale Industries Association, to relieve him and to substitute him with another member
from the Association. Chairman observed that such requests could not be entertained for the
reason that other organizations, which have nominated their representatives, may also
approach with similar and / or other such requests.
The term of the LAEC is for six months only. Substitution / recall of members will not be in
the public interest and it will prejudicially affect the larger interests of continuity and effective
functioning of LAEC. It is needless to mention that the members of LAEC shall exercise their
wisdom and act independently and impartially according to their conscience. There must be
security of tenure to ensure smooth and effective functioning of the LAEC.
Chairman requested the members representing various associations to convey this feeling to
their respective organizations and direct them to extend co-operation to accomplish the task
ultimately given to LAEC. The meeting resolved to write to SCMC and seek clarification on
this matter. It was decided to approach the SCMC and to obtain clarification.
17th meeting held on 18/12/2004, Saturday at 6.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Chairman appraised the committee that the LAEC requires the service of an office assistant
and that the work of the LAEC. The office assistant Ms. Sulfiyath NP posted by PCB is
completing her one year period on 21-12-2004 and that after 21-12-2004, unless she is
appointed by the LAEC it would be difficult to avail her service .
Ms. Sulfiyath NP has put up an application expressing her willingness to continue. Having
regard to the pressure of work and the necessity to have the service of a qualified engineer, it
is resolved to seek the service of Miss Sulfiyath NP on a consolidated monthly pay of Rs
3,500 and that she should be ready to work even on holidays till the term of present LAEC or
such other date, LAEC decides whichever is earlier.
The meeting reviewed its functioning generally. The Chairman brought to the notice of the
committee that he had telephonic discussion with Dr.Claude Alvaris over the issue of
recalling the representative by the associations and that he has assured to ensure continuity of
the members and communication to that effect will soon be sent after discussing with the
other members of the SCMC.
727
18th
meeting held on 21/12/2004, Tuesday at 6.45 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
This meeting was specially convened to discuss with the Chairman and Member Secretary of
the Pollution Control Board on the follow up actions taken by the Pollution Control Board on
the report of the LAEC. Chairman, LAEC requested that delay should be avoided in taking
action on the reports of the LAEC. A request was made to take steps authorizing the Govt.
Laboratory at Ernakulam for analyzing the statutory samples taken from the units instead of
the sample being sent to Trivandrum for analysing. The Chairman appraised them of the
necessity to recruit sufficient staff at Regional office Ernakulam and at site office Eloor for
smooth functioning of both the offices and effective monitoring of the units.
The Chairman PCB assured all his co-operation and prompt action on the reports. Regarding
the notification of any laboratory at Ernakulam for analyzing statutory samples is a matter to
be examined and that he would do needful if such a course is possible . On the recruitment of
staff, Chairman assured that he would expedite the procedure and in the event of delay, they
would recruit temporary hands to meet the immediate requirements.
19th meeting held on 3-1-2005, Monday at 6.20 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The committee discussed that the parameters fixed in many consent orders by the PCB fall
short of important parameters. The nature of the product, various chemicals used for the
manufacturing the product, the composition of the effluent etc varies from unit to unit. The
Board while issuing consent orders has unfortunately not applied its mind with specific
reference to these aspects which in fact is a fundamental exercise ought to have been
undertaken before issuing consent orders.
It is observed that the Cochin Minerals & Rutiles Ltd is producing Synthetic Rutiles and by
product Ferric Chloride by utilizing raw materials such as Ilmenite, Coke, Hydrochloric
Acid , Fuel Oil, Chlorine and the effluent therefore would necessarily contain high Iron,
Chlorides, Copper and TDS. The consent issued by the Pollution Control Board therefore
necessarily ought to have prescribed the parameter for Iron, Chloride, Copper, TDS etc in the
treated effluent. Unfortunately these important parameters are not seen included in the
consent.
Similarly Merchem Limited, Eloor is producing Accelerators, Antioxidant, Sodium Sulphide
by utilizing raw materials such as:
20. Aniline
21. Acetone
22. Carbon disulphide
23. Industrial Methylated Spirit
24. Caustic Soda Lye
25. Sulphuric Acid
26. Hydrochloric Acid
27. Toluene
728
28. Soda Ash
29. Trichloroethylene
30. Chlorine
31. Hydrogen peroxide
32. Hexachlorobenzene
33. Sodium Sulphide
34. Sulphur
35. Elasto 245 oil
36. Sodium Sulphite
37. Ferric Chloride
38. Mixed Sulphate Salt
The effluent necessarily contains high COD, Mercaptans, Sulphates, TDS, Chlorides along
with other parameters.
Similar is the case with Merchem Ltd., Edayar. The unit is manufacturing the products such
as F, ZDC, ZDBC, ZBEC using raw materials such as Carbon disulphide, Zinc Oxide, Zinc
Chloride, Di Ethyl Amine, Di n Butyl Amine, Di Benzyl Amine, Caustic Soda, Hexamine,
DPG, MBTS and the effluent necessarily contain COD.
Another industry namely Sud-Chemie India Pvt.Ltd is producing Catalyst Type C12, C18
and G1 using raw materials such as:
1. Ferrous Sulphate
2. Sulphuric Acid
3. Caustic soda
4. Sodium bicarbonate
5. Zinc
6. Copper
7. Alumina
8. Ammonia
9. Carbon dioxide
10. Magnesium oxide
11. Soda ash
12. Commercial Zinc oxide
13. Ammonium molybdate
14. China Clay
15. Lime Powder
16. Graphite
17. Ammonium bicarbonate
18. Barium Hydroxide
19. Furnace oil
20. MTO
The effluent necessarily should fix parameters for Sulphate, TDS and BOD.
Binani Zinc Limited is producing Zinc, Sulphuric Acid , Cadmium by using raw materials
such as Zinc Concentrate and Fuel . The effluent necessarily contains Iron and Nickel.
729
Another Industry namely Minar Chemicals is manufacturing Precipitated Silica and Sodium
Silicate by using raw materials like, Sodium Silicate, Hydrochloric Acid, Caustic Soda,
Quartz Powder and Firewood. The effluent would contain Chloride and therefore parameter
should be fixed for Chloride.
The consent issued by the Pollution Control Board ought to have prescribed necessary
parameters in the consent order of aforesaid companies. Similar is the case with many other
chemical industries in Eloor- Edayar area. The consent order issued to the chemical industries
is therefore highly defective and absolutely useless to contain pollution.
In the above circumstances, LAEC resolves that the PCB should undertake the exercise of
revising the parameters issued to each chemical industries in Eloor – Edayar area case by case
and include the parameters which are necessary, having regard to the nature of effluent
generated by the units.
Having regard to the nature of pollution generated by the chemical industries, the scientists
who are competent to ascertain and determine the pollution in the effluent at various stages
have to be necessary involved in monitoring the company in the field who alone can by their
scientific knowledge and experience contribute suggestions to improve the system. LAEC is
at a loss to understand why the scientists in the PCB have not been involved in monitoring the
industries in the field along with the engineering division. To discuss this matter, it is decided
to hold a joint meeting of the engineering and scientist wing of PCB at the Regional office,
Ernakulam immediately with notice to the Chairman and the Member secretary of the
Pollution Control Board.
The committee further reviewed the operation of trial run undertaken by Merchem Ltd in
pursuance to the interim order issued by the Hon’ble High Court. Members of LAEC namely
Mr. Anand, Mr. Purushan, Mr Asokan and Mr.Jacob Lazar who were present with the PCB
officials monitoring the unit brought to notice of the committee that the unit has dumped
sludge in the open yard close to the Kuzhikandam thodu.
The bushes all along the Kuzhikandam thodu has covered the drains taking effluent to the
Kuzhikandam thodu. Therefore, unless the bushes and wild growth from the open yard all
along the boundary of the Kuzhikandam thodu are cleared, it will be difficult to ascertain how
many numbers of illegal outlets are connected to Kuzhikandam thodu from the unit. The
committee resolved to request PCB to take the following aspects into consideration and issue
necessary direction to the company.
1. PCB shall ensure that no bypass line is a directly connected to authorized outlet from
the untreated effluent line.
2. PCB should ascertain from the register of the unit the total production , raw materials
used etc. and take the stock of mass balance of the company and quantify the total
quantity of the solid waste to be found over these years in the unit and satisfy that the
unit has stored the entire solid in its premises in a secured manner or has disposed of
as per the Hazardous Waste(Management and Handling) Rules 1989
3. The PCB should also ensure that the unit remove the solid waste dumped in the open
yard to a secured storage place.
730
4. The bushes and wild growths in the open area all along the Kuzhikandam thodu may
by directed to be cleared forthwith.
The LAEC discussed about the seminar proposed to be held on 8th January 2005. The
scientists who agreed to make available the manuscript of the papers to be presented in the
seminar have informed that it could not be completed for want of follow up action. LAEC
failed to understand what follow up action is required after the decision is taken in the
presence of scientist themselves. Having regard to this development it is not possible to hold
the Seminar on 8th January 2005. It is therefore decided to adjourn the meeting proposed on
8-1-2005.
20th meeting held on 4-1-2005, Tuesday at 5.45 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Members of the Local Area Environmental Committee alongwith officials of the
Pollution Control Board Shri. R.V Sateeshan Thampuran (Senior Environmental Engineer),
Shri. Farook Sait A. (Environmental Engineer),Smt.Chitrakumari D.(Environmental Engineer
), Shri. Shanavas (Asst Environmental Scientist ) conducted a surprise inspection at Ms/
Njavallil latex Ltd, Binanipuram, Edayar today (4-1-2005). Mr. Sridhara Vydiar, Accountant
of the Unit and Managing Partner, Sri. Antony Kurian were present during the inspection.
The inspecting team found untreated effluent being discharged into an open pit near the
Periyar River approximately at a distance of 5 metres . Waste oil is seen discharged into an
open drain in the premises of the unit leading to Periyar River. Further a portable generatorcum-pump set is seen near the composite tank from where a water hose having length of 49.5
metres with 5 inch diameter was seen connected to Periyar River and a pond near river side.
The hose was found full of untreated effluent which was pumped from composite pond for
discharge to the river Periyar. The effluent contains high BOD, COD and suspended solids.
The discharge of waste oil through its drain into Periyar is illegal and an objectionable act of
the unit. The liquid effluent and sludge require careful handling. The unit is seen indulged in
discharging untreated effluent and waste oil into the River Periyar. It has violated the
conditions of the consent order issued under the Water (Prevention and Control of
Pollution)Act 1974.
The unit is not having an efficient ETP to treat the untreated effluent containing chemicals.
There are no adequate provisions for handling the effluent and the waste oil. The industry is
situated on the banks of the River Periyar. This unit is in operation for several years and
shockingly the efficiency of the ETP has not been verified by the PCB while renewing the
consent under the Water (Prevention and Control of Pollution) Act 1974 from time to time.
The ETP is totally out dated and is of no use. The unit could not account the sludge generated
from the ETP over these years showing its storage in its premises.
Having regard to the above facts and detection of the illegal activity of the unit, the LAEC
resolve to request the PCB to direct the closure of the unit immediately. The unit shall be
permitted to function only after satisfying the efficiency of the ETP. PCB shall make sure that
the unit is having sufficient facility to dispose of the waste oil from washing empty drums,
which are being used as containers for filling Rubber Latex.
731
PCB shall also ensure removal of sludge dumped in the premises to a secured place. The
report of the inspection is hereby forwarded for immediate action to the Chief Environmental
Engineer of PCB. A copy of this report is also is forwarded to the SCMC, Chairman and
Member Secretary of the Kerala State Pollution Control Board
21st Meeting held on 8-1-2005 , Saturday at 3.40 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolved to inspect Hi tech Electro Thermics on Wednesday, 12th January 2005.
Resolved to request the Pollution Control Board to dispose of the nine applications pending
consideration for authorization under the Hazardous waste management rules from the
industries in Eloor-Edayar area.
The following Units have applied for Authorisation under HW Rules.
1.
2.
3.
4.
5.
6.
7.
8.
9.
Arjuna Natural Extracts Ltd
Excel Petrochemicals,
Indo German Carbons Limited
Merchem Limited, Edayar
Popular Mega motors
Sree Sakthi Paper Mills Ltd.
TMS Industries.
Falcon Infrastructure.
Praxair Carbon dioxide.
Chairman informed the committee that the Dr. D.B. Boralkar, Member, SCMC is visiting
Trivandrum to attend a Seminar organized by KMML at Kovalam. LAEC decided to visit
Trivandrum and to appraise him of the activities of the LAEC and seek further guidance. The
delegation will also furnish a copy of the memorandum proposed to be submitted to the Chief
Minister to SCMC, on the various measures to be taken at the level of State Pollution Control
Board and Govt. and other authorities for effective monitoring of the industries and seek
appropriate direction from SCMC to these agencies for meeting the demands in the
memorandum.
Member Secretary will look into the question of issuing notifications notifying the Govt.
Laboratory at Ernakulam as authorized laboratory for analyzing statutory samples and will
avoid further delay.
The LAEC delegation going to Trivandrum to meet Dr. Boralkar will also attend the seminar
conducted by KMML at Kovalam . The Member Secretary will arrange a meeting with Chief
Minister for appraising him of the various problems confronting PCB and LAEC in
effectively monitoring the industries at Eloor- Edayar belt. A memorandum will be submitted
to the Chief Minister highlighting immediate action required to be taken by the Government.
The meeting further discussed the parameters fixed for the industries in Eloor- Edayar belt
and appraised the member secretary of the necessity to revise the consent order or in the
alternative prescribe additional parameters to combat pollution.
732
22nd meeting held on 11-1-2005, Tuesday at 6.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
It is resolved to hold meeting every Tuesdays and Thursdays at 5.00 pm and on Saturdays at
3.00pm. and conduct inspections on every Monday, Wednesday, and Friday. No separate
notice will be given to the members notifying the meetings and inspections except for the
extraordinary meetings that may be convened by the Chairman. Intimation regarding
extraordinary meetings will be given through telephone from the office.
The two letters addressed to the Chairman LAEC from Njavallil latex Pvt. Ltd bearing dates
7-1-05, and 8-1-05 were placed before committee for discussion. Committee resolved to fine
2 lakhs to Njavallil and allow trial run for a week subject to such conditions that would be
fixed in consultation with the officials of the PCB after conducting an inspection of the unit
tomorrow ie, dated: 12-1-2005 and prescribing additional parameters that are required for
containing pollution.
23rd meeting held on 13-1-2005, Thursday at 6.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Mr Purushan will give a report on inspection of Njavallil Latex on 12-1-05.
Minutes of Previous Two meetings 21st and 22nd is approved.
Mr. Jayathilakan and Mr. Jacob Lazar representing LAEC and Mr. Shanavas, Asst. Scientists
deputed to LAEC were present during the inspection at Merchem Ltd. The Chief
Environmental Engineer Mr. S.D. Jayaprasad alongwith Mr. A. Farook Sait, Environmental
Engineer of PCB were also present during the inspection as per the directions of the Hon’ble
High Court. LAEC members reported to the committee that they have found the proposal
submitted by the Unit on 5-1-05 to recover products from the non-biodegradable fraction
being implemented. It is informed that the system will be ready for trail run today itself.
A new compressor has been installed and pipeline installed on the wall of the aeration tank
with dip tubes extended to the bottom. Abundant frothing is found throughout the surface of
the aeration tank.
Water line earlier used to dilute the effluent from a line near the tea center which was
disconnected earlier has been dismantled by the employees in our presence .
The company officials informed that all remedies suggested will be carried out within
the timeframe indicated by PCB.
It is shocking to note that the unit has not disclosed even to the Board in its consent
application the names of various Sulphanamides products, Thiazole products and antioxidants. The unit should be directed to disclose the name of products and the quantity of
production item wise under the general headings Sulphanamides, Thiazole and anti-oxidants.
733
The Board should specify only those items in the consent order which passes through the trial
run and not any other products.
24th meeting held on 17-1-2005, Monday at 5.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Discussed the letter from M/s. Njavallil Latex in continuation of the decision taken in the 22 nd
meeting held on 11-1-2005 . The committee resolved to refer the request of the company for
trial run to PCB for examining its feasibility and to grant trial run subject to the compliance of
the statutory provisions. The fine of Rs.2 lakh as token may be recovered from the unit which
will be used for revival of Periyar River. The said fine may be accounted into the fund of
Rs.2.50 crores which the SCMC has directed to collect from the polluting industrial units. The
fine of Rs.2 lakhs imposed is without prejudice to recovery of further amount that may be
quantified later on Polluter Pay Principles.
Resolved that the request from Merchem Ltd, Eloor for trial run cannot be entertained.
Since the matter is sub-judice. The meeting took serious note of the notice published by the
BMS Union of Merchem Ltd and resolved to address a letter to the union leaders affording an
opportunity to them to express regret for their uncharitable comments made against the LAEC
and PCB. The meeting expressed that the contents of the notice is distasteful and amounts to
interference with the enforcement of the order of the Hon’ble Supreme Court. Chairman will
address a letter to the union leaders. The matter can be brought to the notice of the SCMC and
Supreme Court after the reply, if any is obtained from them.
It is Resolved that LAEC shall meet on every 2nd and 4th Saturday of the month at 3 pm. This
is in modification of the earlier resolution of the committee resolving to hold meeting on
every Saturdays.
25th meeting held on 22-1-2005, Saturday at 4.25 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolved to defer the minutes of 23rd meeting of LAEC as one of the member Jacob lazar
expressed that certain findings do not find place in the draft minutes placed for approval.
Resolved to have a one day seminar on Periyar on 12th February 200. Mr.Purushan Eloor is
entrusted the responsibility to arrange for the one day seminar.
Resolved to hold a joint meeting of representatives of Industry and Trade Union leaders on
29th January or the Saturday after that.
Resolved to have a joint meeting with scientists on 18th February, 2005.
Resolved to send quarterly reports to SCMC before 5th February, 2005.
LAEC decided to have a surprise inspection at Binani Zinc.
Decided to postpone the discussion on CMRL to the next meeting.
734
26th meeting held on 23-1-2005, Sunday at 2.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Considered the request of the M/s Merchem Ltd, Eloor in their letter dated
14/01/2005 and 21/05/2005. The committee is totally unhappy with the various
comments contained in the letter dated: 14-01-2005 distorting the findings of
the LAEC to create an impression that the findings of the LAEC are either on
apprehensions or insignificant. Notwithstanding this distorted comments in the
aforesaid letter, the committee resolved unanimously to permit the unit to take a
trial run for one Month under the supervision of NEERI, Nagpur or the Centre for
Environment Education (CEE), Ahmedabad and monitored by PCB and LAEC,
considering the modifications made in the ETP and introduction of a new plant to
treat toxic effluent pursuant to the inspection of the LAEC.
The company may be permitted to take trial run for one month under the
supervision of the NEERI / CEE and subject to the following conditions to assess
the efficiency of the modified system.
A fine of Rs. 5.00 lacs shall be imposed for violating the consent conditions
and Hazardous Waste (Management and Handling) Rules 1989, which will
be credited into the fund of the Periyar Revival programme. The fine
imposed shall be without prejudice to the recovery of further sum/s that
may be quantified later on ‘Polluter Pays’ principle.
The track record of Merchem Ltd., Eloor indicates that the COD is very
high. During trial run, COD has to be ascertained and if found consistently
above 250 as limited by the statutes, the company should be directed to
set up a tertiary treatment plant before permitting the unit to start
commercial production. If necessary Bio-assay test should be insisted.
The complaints of the public and nearby residents against the company by
and large is the odour coming out of the company during its operation
especially during nights. The odour is caused by the discharge of
Hydrogen sulphide which is a toxic substance polluting the environment.
Flare in the stack has to be continuously maintained. The scrubbing
process using caustic soda should be insisted to control the air pollution.
The polishing tank now in operation has to be emptied and inspected to
make sure that there is no clandestine pipe connection carrying raw water
to dilute the effluent in the polishing tank before starting the trial and
discharge of the outflow from the secondary settling tank.
The old settling tank near the mixing channel, which is claimed to be not
in use, must be dismantled.
The PVC pipeline carrying untreated effluent to the mixing channel should
be insulated with metal pipe.
Before allowing the trial run, the PCB should revise the consent order
incorporating parameters for COD, Mercaptans, Sulphates, TDS, Chlorides
etc. and the quantity of the effluent per day to be discharged.
735
The trial run should be permitted only to produce 1.1 tonne per day as per
the original consent. The PCB in the meanwhile shall assess the mass
balance of the Unit based on this production rate during the period of one
month.
The effectiveness of treatment for toxic effluent should be separately
documented and the damage to the air by the process of evaporation has
to be assessed.
The company should be directed to prepare a blue print of the drainage
system of the company including the authorized outlet, storm water drain
and such other drain in their premises. All drains other than the
authorized outlet and the authorized storm water drain should be
dismantled and routed either through the ETP or the authorized storm
water drain.
The raw water line from the Tea Centre to dilute the effluent in the final
polishing tank should be fully dismantled to the satisfaction of PCB. The
by pass line from mixing channel to the outlet carrying untreated effluent
and the PVC pipeline from the old settling tank near the mixing channel to
the final polishing pond should be dismantled. All such similar lines and by
pass lines should also be dismantled. The company shall forfeit its right
to operate forthwith if any such unauthorized pipeline is detected in future.
In addition to these conditions, the PCB may impose such other conditions
that is warranted on the facts and in the circumstances of the case for trial
run.
The Company may be permitted to commence commercial production
subject to the result of the trial run to be submitted by NEERI / CEE to the
satisfaction of the PCB and LAEC and complying the following directions.
All hazardous waste scattered in the premises should be excavated
and deposited in a secured landfill.
The entire factory premises especially the kuzhikandam thodu side
should be cleared of all wild bushes and undergrowth and the area
should be leveled and kept clean.
The side of the kuzhikandam thodu adjoining the factory premises
shall be lined with rubble masonry.
The company shall undertake to provide water to the affected
community in nearby areas. The quantity of water to be supplied,
the affected community, the companies responsible for
contaminating the areas etc., shall be independently assessed in
due course.
The company shall submit a mass balance report supported by the
records of raw materials used, production records and such other
documents substantiating the mass balance report within a period of
1 month.
The company should not use domestic LPG cylinders for flaring up
the stack.
To ensure the compliance of points (a) to (f) above, the company
shall furnish a bank guarantee from a nationalized bank for
Rs.5.00 lacs. This will be in addition to the fine imposed vide para 1
above.
736
The PCB should ensure that the company has obtained license under
the Manufacture, storage and import of hazardous chemicals rules,
1989,if applicable.
In addition to these conditions, the PCB may impose such other
conditions that are warranted on the facts and in circumstances of
the case before permitting commercial production.
27th meeting held on 24-1-2005, Monday at 7.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The report of M/s. CMRL has to be completed after conducting an inspection once again. The
committee discussed the result of the samples handed over to it (green coloured effluent) by
the local people of the area with members of a voluntary organization namely, SOLIDARITY
from the final outlet of the company. The result of the analysis done by the Pollution Control
Board showed low pH 4.4, SS 1410 mg/l, Iron 12238 mg/l, Lead 4.29 mg/l, Chlorides 33500
mg/l and Manganese 11.2 mg/l. The result is disturbing. The matter needs serious
consideration. CMRL case has to be examined closely.
28th meeting held on 26-1-2005, Wednesday at 3.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Member Secretary, Mr.Indulal could not regularly attend the LAEC meetings which are of
most emergent nature. Meetings with short notices are called most often having regard to the
importance of the various matters. The absence of Member Secretary in the circumstances has
deprived the committee of effective assistance and guidance from the PCB. The Member
Secretary is therefore requested to instruct the Regional office, Ernakulam to depute one
representative to the meetings of LAEC.
Emergency meeting held on 27-01-2005, Thursday at 10.00 am at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The meeting endorsed the report on CMRL, Edayar and resolved to forward to the Pollution
Control Board and SCMC for information and appropriate action.
29th meeting held on 29-1-2005, Saturday at 5.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The Trade Unions representing the employees of the CMRL met Chairman LAEC at the
office of the LAEC and discussed the issues related to the discharge of untreated effluent to
Periyar River. The Union leaders requested to have a joint meeting of LAEC with the
company management and Trade Union Representatives to prevent a closure order by suitable
safeguards against such illegal discharge of effluents into the River Periyar. Chairman agreed
to place the matter before LAEC and to take a decision in the matter.
The committee unanimously agreed for such a meeting.
737
30th meeting held on 1-2-2005, Tuesday at 5.15 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The committee unanimously felt that the joint meeting of Management and trade union
leaders of CMRL with the members of LAEC as fruitful and the deliberations held as
constructive and positive. The committee felt that the assurance of the company to implement
adequate pollution control measures as genuine and decided to allow some more time and to
keep in abeyance the recommendations for closure of the Unit. The committee will assess the
progress made by the company from time to time. The assurance of the company that no
untreated effluent will be discharged hereafter to the Periyar is recorded and the Board may be
requested to keep in abeyance further proceedings pursuant to the recommendations for
closure vide resolution of the emergency meeting held on 27-1-05.
31st meeting held on 2-2-2005, Wednesday at 7.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The committee endorsed the following memorandum for submission to Dr. Claude Alvaris on
his visit to Thrissur. The members shall meet him at Thrissur tomorrow.
Memorandum submitted to the Supreme Court Monitoring Committee, by the
Local Area Environmental Committee, for Eloor- Edayar area.
Local Area Environmental Committee constituted by Kerala State Pollution Control Board as
directed by the Supreme Court Monitoring Committee started its environmental auditing from
2nd November 2004, visiting the industries one by one in Eloor – Edayar area which is a
cluster of 247 industries situated on the banks of the river Periyar . The committee, over the
last 2 ½ months has visited nearly 100 industries which include small, medium and large
scale industries. The committee could identify the following reasons as major causes for
polluting the environment comprising Land, Water and Air.
1. Consent issued by the Pollution Control Board to various industrial units under the
Water (Prevention and Control of Pollution)Act 1974 do not have necessary
parameters which the company has to observed strictly having regard to the nature of
the manufacturing process of each units. The Pollution Control Board committed
gross negligence in
discharging this function. The committee has resolved
therefore to revise the parameters of all the industries forthwith. Extracts of the
resolution of the committee in its 19th meeting held on 3-1-05 is as follows.
“The committee discussed that the parameters fixed in many consent orders by the PCB
fall short of important parameters. The nature of the product, various chemicals used for
the manufacturing the product, the composition of the effluent etc varies from unit to
unit. The Board while issuing consent have unfortunately not applied its mind with
specific reference to these aspects which infact is a fundamental exercise ought to have
undertaken before issuing consent orders.
It is observed that M/.s. Cochin Minerals & Rutile Ltd is producing Synthetic Rutiles and
by product Ferric Chloride by utilizing raw material such as Ilmenite, Coke, Hydrochloric
Acid , Fuel Oil , Chlorine and the effluent therefore would necessarily contain high Iron,
Chlorides, Copper and TDS. The consent issued by the Pollution Control Board therefore
738
necessarily ought to have prescribed the parameter for Iron, Chloride, Copper, TDS etc in
the treated effluent. Unfortunately these important parameters are not seen included in the
consent.
Similarly, Merchem Limited, Eloor is producing Accelerators, Antioxidants, Sodium
Sulphate by utilizing raw materials such as:
1.Aniline
2.Acetone
3.Carbon disulphide
4.Industrial Methylated Spirit
5.Caustic Soda Lye
6.Sulphuric Acid
7.Hydrochloric Acid
8.Toluene
9.Soda Ash
10. Trichloroethylene
11. Chlorine`
12. Hydrogen peroxide
13 Hexachlorobenzene
14. Sodium Sulphide
15. Sulphur
16. Elasto 245 oil
17. Sodium Sulphite
18. Ferric Chloride
19. Mixed Sulphate Salt
739
The effluent necessarily contains COD, Mercaptans, Sulphates, TDS, Chlorides
alongwith other parameters.
Similar is the case with Merchem Ltd., Edayar. The unit is manufacturing the
products such as F, ZDC, ZDBC, ZBEC using raw materials such as Carbon
disulphide, Zinc Oxide, Zinc Chloride, Di Ethyl Amine, Di n Butyl Amine, Di
Benzyl Amine, Caustic Soda, Hexamine, DPG, MBTS and the effluent necessarily
contain COD.
Another industry namely Sud-Chemie India Pvt.Ltd is producing Catalyst Type C12,
C18 and G1 using raw materials such as:
1. Ferrous Sulphate
2. Sulphuric Acid
3. Caustic soda
4. Sodium bicarbonate
5. Zinc
6. Copper
7. Alumina
8. Ammonia
9. Carbon dioxide
10. Magnesium oxide
11. Soda ash
12. Commercial Zinc oxide
13. Ammonium molybdate
14. China Clay
15. Lime Powder
16. Graphite
17. Ammonium bicarbonate
18. Barium Hydroxide
19. Furnace oil
20. MTO
The effluent necessarily should fix parameters for Sulphate, TDS and BOD.
Binani Zinc Limited is producing Zinc, Sulphuric Acid and Cadmium by using raw
materials such as Zinc Concentrate and Fuel . The effluent necessarily contains Iron
and Nickel.
Another Unit, M./s. Minar Chemicals is manufacturing Precipitated Silica and
Sodium Silicate by using raw materials such as Sodium Silicate, Hydrochloric Acid,
Caustic Soda, Quartz Powder, and Firewood. The effluent would contain Chloride
and therefore parameter should be fixed for Chloride.
740
The consent issued by the Pollution Control Board ought to have prescribed
necessary parameters in the consent order of aforesaid companies. Similar is the
case with many other chemical industries in Eloor- Edayar area. The consent order
issued to the chemical industries is therefore highly defective and absolutely useless
to contain pollution.
In the above circumstance LAEC resolved that the PCB should undertake the exercise
of revising the parameters issued for each chemical unit in Eloor–Edayar area case by
case and include the parameters which are necessary, having regard to the nature of
effluent generated by the units.”
The pollution control board is yet to act on this resolution in spite of its urgency.
2. The committee during its inspection found that no stack monitoring has been
conducted for over three years by the PCB with the result the entire Eloor –
Edayar area is fully contaminated with air pollution. The local residents are
suffering from various respiratory diseases. The committee requested Pollution
Control Board to undertake stack monitoring the units in its 10th meeting held on
25-11-04. Extracts of the resolution of the committee in its 10th meeting is as
follows.
“LAEC having regard to the statutory function of PCB strongly disapprove the
casual approach of the Pollution Control Board in monitoring air quality. Their
plea that sufficient staffs are not available to monitor the air quality cannot be
accepted, since Pollution Control Board has been appointing persons from
employment exchange to make up the deficiency of staffs. It is understood that
Honb’le High Court of Kerala have issued directions to engaged sufficient staffs
to make the Board functional.
LAEC in the circumstances has resolved to demand Pollution Control Board for
making arrangements for stack monitoring, noise level monitoring and ambient
air quality monitoring in Eloor –Edayar industrial belt forthwith”.
Pollution Control Board despite such a clear direction has not cared to do
anything to monitor the stacks .
3. Local Area Environmental Committee during its inspection was astonished to
note that the site office of the Pollution Control Board in Eloor- Edayar area is
remaining closed for several years. The necessity to reopen the site office and to
make it functional for carrying out round the clock monitoring has been
emphasized in its resolution in its 6th meeting held on 12-11-2004. Extracts of the
resolution of the committee in its 6th meeting is as follows.
LAEC on their inspection at Eloor –Edayar area on 2-11-04 found the site office of
pollution control board at Eloor closed. The office set up in the industrial belt is non
741
functional for a pretty long time . There is absolutely no infrastructure such as lab
facilities , lab technicians and other competent personnel for conducting inspections
and monitoring the units at regular intervals. There was no arrangement even to
attend emergency situations. The LAEC chairman expressed that there is no wonder
why the environmental laws are violated by the industrial units with impunity. He
expressed shock on this sorry state of affair and wondered why the office set up in the
middle of 247 industries in Eloor-Edayar area was neglected in such manner.
The Hon’ble Members strongly disapproved the manner in which the site office is
maintained . The LAEC resolved to demand PCB to immediately open its site
office at Eloor-Edayar and start its function with necessary infrastructure having
regard to the significance and important of such an office in the industrial belt for
ensuring the continuous monitoring and surprise visits to industrial units to check
and control the indiscriminate manner in which industries operate. The office at
Eloor be made functional with necessary infrastructure such as telephone, fax, lab,
vehicle, lab technicians and other staffs for periodic and surprise inspections
and analyzing the samples .
The Pollution Control Board is yet to take any action to ensure the compliance of
the above resolution which would have compelled the units to mend their way.
4. Local Area Environmental Committee during its meeting held on 23-1-2005
considered the request of Merchem Limited, a unit closed down under our
direction for not having efficient effluent treatment system and recommended for
retrial subject to conditions including a fine of Rs. 5 lakhs. The Pollution Control
Board did not take any prompt action on the aforesaid resolution, thereby
compelling the unit to obtain order from High Court. The Kerala State Pollution
Control Board was rather unconcerned by the suffering of the units by its closure
and slept over the matter without passing orders for trial run and recover the fine
amount imposed by the committee for Periyar revival project. The resolution
passed by the committee allowing re trial in its 26th meeting is extracted below.
“Considered the request of the M/s Merchem Ltd, Eloor in their letter
dated 14/01/2005 and 21/05/2005. The committee is totally unhappy
with the various comments contained in the letter dated: 14-01-2005
distorting the findings of the LAEC to create an impression that the
findings of the LAEC are either on apprehensions or insignificant.
Notwithstanding this distorted comments in the aforesaid letter, the
committee resolved unanimously to permit the unit to take a trial run
for One Month under the supervision of NEERI, Nagpur or the Centre
for Environment Education (CEE), Ahmedabad and monitored by PCB
and LAEC, considering the modifications made in the ETP and
introduction of a new plant to treat toxic effluent pursuant to the
inspection of the LAEC. The company may be permit to take trial run
for one month under the supervision of the NEERI and subject to the
following conditions to assess the efficiency of the modified system.
742
1. A fine of Rs. 5.00 lacs shall be imposed for violating the consent
conditions and Hazardous Waste (Management and Handling) Rules
1989, which will be credited into the fund of the Periyar Revival
programme. The fine imposed shall be without prejudice to the
recovery of further sum/s that may be quantified later on ‘Polluter
Pays’ principle.
2. The track record of Merchem Ltd., Eloor indicates that the COD is
very high. During trial run, COD has to be ascertained and if found
consistently above 250 as limited by the statutes, the company
should be directed to set up a tertiary treatment plant before
permitting the unit to start commercial production. If necessary
Bio-assay test should be insisted.
3. The complaints of the public and nearby residents against the
company by and large is the odour coming out of the company
during its operation especially during nights. The odour is caused
by the discharge of Hydrogen sulphide which is a toxic substance
polluting the environment. Flare in the stack has to be
continuously maintained. The scrubbing process using caustic soda
should be insisted to control the air pollution.
4. The polishing tank now in operation has to be emptied and
inspected to make sure that there is no clandestine pipe connection
carrying raw water to dilute the effluent in the polishing tank before
starting the trial and discharge of the outflow from the secondary
settling tank.
5. The old settling tank near the mixing channel, which is claimed to
be not in use, must be dismantled.
6. The PVC pipeline carrying untreated effluent to the mixing channel
should be insulated with metal pipe.
7. Before allowing the trial run, the PCB should revise the consent
order incorporating parameters for COD, Mercaptans, Sulphates,
TDS, Chlorides etc. and the quantity of the effluent per day to be
discharged.
8. The trial run should be permitted only to produce 1.1 tonne per day
as per the original consent. The PCB in the meanwhile shall assess
the mass balance of the Unit based on this production rate during
the period of one month.
9. The effectiveness of treatment for toxic effluent should be
separately documented and the damage to the air by the process of
evaporation has to be assessed.
743
10.The company should be directed to prepare a blue print of the
drainage system of the company including the authorized outlet,
storm water drain and such other drain in their premises. All drains
other than the authorized outlet and the authorized storm water
drain should be dismantled and routed either through the ETP or
the authorized storm water drain.
11.The raw water line from the Tea Centre to dilute the effluent in the
final polishing tank should be fully dismantled to the satisfaction of
PCB. The by pass line from mixing channel to the outlet carrying
untreated effluent and the PVC pipeline from the old settling tank
near the mixing channel to the final polishing pond should be
dismantled. All such similar lines and by pass lines should also be
dismantled. The company shall forfeit its right to operate forthwith
if any such unauthorized pipeline is detected in future.
12.In addition to these conditions, the PCB may impose such other
conditions that is warranted on the facts and in the circumstances
of the case for trial run.
13.The Company may be permitted to commence commercial
production subject to the result of the trial run to be submitted by
NEERI / CEE to the satisfaction of the PCB and LAEC and complying
the following directions.
a. All hazardous waste scattered in the premises should be
excavated and deposited in a secured landfill.
b. The entire factory premises especially the kuzhikandam
thodu side should be cleared of all wild bushes and
undergrowth and the area should be leveled and kept clean.
c. The side of the kuzhikandam thodu adjoining the factory
premises shall be lined with rubble masonry.
d. The company shall undertake to provide water to the
affected community in nearby areas. The quantity of water
to be supplied, the affected community, the companies
responsible for contaminating the areas etc., shall be
independently assessed in due course.
e. The company shall submit a mass balance report supported
by the records of raw materials used, production records and
such other documents substantiating the mass balance
report within a period of 1 month.
f. The company should not use domestic LPG cylinders for
flaring up the stack.
g. To ensure the compliance of points (a) to (f) above, the
company shall furnish a bank guarantee from a nationalized
bank for Rs.5.00 lacs. This will be in addition to the fine
imposed vide para 1 above.
744
h. The PCB should ensure that the company has obtained
license under the Manufacture, storage and import of
hazardous chemicals rules, 1989,if applicable.
i. In addition to these conditions, the PCB may impose such
other conditions that are warranted on the facts and in
circumstances of the case before permitting commercial
production.”
5. The Pollution Control Board is dilly-dallying on the order of the
Hon’ble High Court of Kerala to appoint sufficient staff to make its
presence effective and discharge its statutory obligations. The plea of
insufficient staff often raised in the court is only a ruse to cover up
their actions more often influenced by extraneous considerations.
LAEC inspection and findings that most of the units in the EloorEdayar does not have an effluent treatment plant and what is installed
are absolutely not fit. It is difficult to assume that the Board was not
aware of the fact when it has approved the plant and issued the
consent. The officers who have been responsible in issuing the consent
is to be identified and made accountable for their failure to ensure
effectiveness of the so called ETPs. The findings of the LAEC is perhaps
disturbing their sleep and there is deliberate non co-operation which
we find demonstrated in their slow motion on our reports. LAEC has
found the officers of the Regional office at Ernakulam barring the top
ones as committed and sincere.
The LAEC takes proud to bring to your notice that over the past 2 ½ months it
has inspected more than 100 units and identified various irregularities and have
made recommendations to the board. The day and night engagement of the
members of LAEC in the field has started yielding results and industries are
responding, at least when they are driven to the wall. The slow motion of PCB in
taking action on our report and the failure to effectively defend the cases in the
High Court by the PCB is causing great disappointment to the members of LAEC.
The constitution of LAEC is to assist the Supreme Court Monitoring Committee
to achieve its goal in conducting environmental audit and to monitor the units and
Pollution Control Board to ensure the compliance of law and direction of the
Supreme Court. The functioning of LAEC is accountable to the Supreme Court
Monitoring Committee and to the Hon’ble Supreme Court and any challenge of
their finding in any High Court would amount to interference in carrying out the
direction of the Supreme Court. Therefore, it is necessary in the interest of
effective functioning of this body a clarification from the Hon’ble Supreme Court
would be necessary to the effect that the High Court shall not be entertaining any
writ petition challenging the orders of State Pollution Control Board issued on the
recommendation of LAEC.
32nd meeting held on 8-2-2005, Tuesday at 5.15 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
745
Chairman LAEC welcomed Mr. Rajmohan ,Chairman of PCB to the meeting. In his
address Chairman, LAEC stressed the need for joint action against the companies
violating environmental laws and discharging untreated effluent. The action on the
reports of LAEC is expected without any delay and the Board should take certain urgent
measures for making the site office at Edayar functional.
The Chairman, PCB assured full co operation and prompt action on the report of LAEC .
A list of matters pending for action with PCB on the report of LAEC has been handed
over to the chairman.
Chairman assured immediate action on site office, stack monitoring, and refixation of
parameters. PCB will also take up the matter with DIC for removing the illegal blocking
of roads and opening the internal road in Eloor –Edayar.
Considered the issues of Merchem Limited, Eloor. The company started its trial run on 42-2005 from early morning. No prior intimation was given to LAEC regarding the
starting of trial run. A letter from Merchem Ltd was delivered at LAEC office at about 3
pm on 5-2-2005. It is not known whether the company has informed PCB about the trial
run. The regional office PCB at Ernakulam if had information about the trial run it ought
to have informed the LAEC .
The trial run by Merchem has begun without arranging anyone from Central Pollution
Control Board to supervise the trial run. The joint inspection prior to trial run could not
be arranged in the aforesaid circumstances. The trial run of the unit has started without
emptying settling and polishing tank. These tanks ought to have been emptied before
starting the trial run. The polishing tank have to be emptied and inspected to ensure that
no clandestine pipeline connected to this tank for diluting the effluent. The company has
to give water and other mass balance consumed at different stages of its manufacturing
process. The mass balance should be ascertained during the trial run to enable PCB and
LAEC, the nature of waste, the quantity generated and make the company accountable
for the wastes so far accumulated. Pollution Control Board will instruct the officers to
have details of raw materials and water used at different stages on every day production
and a copy will be made available to LAEC every other day to have independent
assessment by the LAEC. Pollution Control Board will also take samples of the raw
effluent and analyze it at different levels of treatment to assess the progress of the
treatment at each step. Copy of the lab test of the samples shall be forwarded to LAEC.
The regional office may brief the progress of the trial run to the members of LAEC in the
meeting scheduled to be held on Friday at 5 pm at LAEC office.
33rd meeting held on 10-2-2005, Thursday at 5.30 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
746
Resolution No 1
The officials deputed to assist the LAEC namely Smt. Chithrakumari, Environmental
Engineer, Mr.Shanavas, Assistant Scientist and Mr. Soman, Assistant Environmental
Engineer have been giving valuable assistance to the LAEC. The postings of these
officers have to be regularized. This matter has been brought to the notice of the new
Chairman who was invited to the meeting of LAEC on 8th February 2005.
If LAEC could function efficiently and book the industrial culprits for violations, it is
more because of the wholehearted support received from the officials deputed for
assisting LAEC. It is understood that there is some move to withdraw these officials and
substitute them with other officers. Such course of substitution will prejudice the
continuity of the functioning of LAEC since these officers have already acquainted
themselves with the problems of the units.
LAEC therefore requests the PCB to retain these officers in LAEC and regularizing their
posting in accordance with law.
Resolution No 2
The Trial run of Merchem Limited, Eloor has commenced from 4-2-2005. The
Pollution Control Board has filed two reports before the Hon’ble High Court on
5-1-05 and 13-1-2005 respectively . The said two reports recommended trial
run subject to remedying the following among other measures.
11. Chemical dosage has to be determined by jar test in each shift and pH
adjustment has to be done with the aid of a portable pH meter.
12. Na MBT slurry is to be continuously dewatered and the solids taken back into the
process . Facility for that is to be put up within two months.
13. All solid waste scattered in the premises are to be collected and deposited in to the
temporary hazardous wastes holding facility and then be shifted to secure landfill
agreed to be provided by the industry by 15-3-2005.
14. Treated trade effluent shall be discharged only through the single outlet
consented by the Board. There should not be any bypass arrangement to deliver
any untreated effluent to that outlet.
15. Effluent generation shall be at the minimum possible level. No dilution with
water is to be done to achieve compliance with tolerance limits laid down by the
Board.
16. Tolerance limit shall be introduced for the following additional parameters in the
effluent discharge from the industry.
747
a. Chemical Oxygen Demand : 250 mg/litre, max.
b. Bioassay
: 90% survival (min) of fish after 96 hours.
Formal order introducing these parameters shall be issued by the Board
separately later.
17.The two storm water drains towards the HIL side shall be combined.
The only other storm water drain permissible is that on the IRE side.
Both storm water drains shall be well- lined open drains (to keep the
inside visible) and should have delay ponds prior to discharge into
Kuzhikandom thodu. This work shall be done within there months.
18.The side of the Kuzhikandom thodu adjoining the Petitioner’s premises
shall be lined with rubble masonry within four months.
19.The factory premises on the Kuzhikandom thodu side shall be cleared
of all wild bushes and undergrowth within a week. The area shall be
leveled within a month and shall be kept clean.
20.The petitioner shall submit to the Board a material balance after one
month of operation, accounting for difference, if any.
34th meeting held on 17-2-2005, Thursday at 6.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
The staff strength of the PCB especially at Regional office, Ernakulam falls short of the
sanctioned post. This is in turn affecting the functioning of the Board especially in the
matters relating to processing the application for consents / renewal, inspection of
factories, stack monitoring, investigation into the complaints etc. The Hon'ble High Court
of Kerala also have expressed strong disapproval for not maintaining sufficient staff
strength to attend the statutory duties of the Board. It is also learnt that provisional
appointments of staff from employment exchange being only a temporary measure is not
producing experienced hand for the board to take its work uninterruptedly. The practice
of engaging employment exchange hands is not a healthy practice. The requirement of
permanent staff need to be attended without further delay. To make board effective and
discharge its statutory function, permanent staff must be recruited without any further
delay. Hon'ble High Court of Kerala in O.P.No. 2193/02 has already directed the Board
to recruit sufficient staff. LAEC is strongly urges the State Govt. and the Board to
recruit sufficient staff and post them at various offices in proportion to the work load in
each office.
748
Resolution No.2
Committee places on record its appreciation to Mr. C. Jayakumar of Thanal,
Thiruvananthapuram for his efficient and scholarly manner of moderating the seminar “Revive Periyar - A task ahead”. The committee resolved to reimburse the taxi fare to
and fro of his journey to attend the seminar.
Resolution No3
Pursuant to the directions of the Hon’ble High Court, members of LAEC alongwith the
officials of the Kerala State Pollution Control Board viz., Smt. Chitrakumari.D and Mr.
Shanavas have conducted several round of inspections during the on-going trial run at
M/s. Merchem Ltd, Eloor.
The following aspects noted by the LAEC are brought to the notice of PCB to ensure that
the trial run is not made a farce. Appropriate orders may be issued to the company.
17. During our inspection, the company is not found producing all products. The unit
has consent to produce Sulphanamides, Thiazoles, Anti-oxidants @ 1.1 tonnes
each per day. During the trial run, the unit should be strictly directed to produce
these items. In Sulphanamides the unit has been producing CBS, MBS and
DCBS. Similarly, the Thiazole products of the unit are MBT, MBTS, and
NaMBT. The product of anti-oxidants of the units is TQ. Primarily, the Board has
to limit the quantity of each Sulphanamides, Thiazole and anti-oxidants and
should specify that no other products should be taken. The unit may be directed to
produce the list of products and the quantity of production daily taken as per the
consent order. It is to be borne in mind that the unit has got an effluent treatment
plant for the treatment of combined effluent of all these products. Therefore to
assess the efficiency of ETP, the unit should be directed to produce
Sulphanamides, Thiazole and anti-oxidants as per the consent order in equal
proportion for the remaining days. It is observed that the unit has produced only
very small quantity of those items, which has got more toxic effluent.
18. During the trial run the sample of effluent of the product item-wise have to be
separately tested. This would help to identify the toxicity of the effluent of each
items.
Presently the unit is producing those items, which has less toxic effluent. The
samples taken by the Pollution Control Board has been tested in the lab and
results are with the Board. Kindly send copies of the lab reports of all the samples
taken so far including the result of the Bio-assay 90 % survival of fish after 96
hours (minimum) test.
19. The Company may be directed to furnish water balance and process-wise water
consumption details. Water balance must be properly verified during the trial run.
749
20. At present, the unit has no device for measuring the total water requirement /
individual requirement at the factory premises. However, the unit has been
submitting water consumption details without fixing meter for reading the
individual water consumption though they have been producing separate readings.
This conduct of the unit is highly reprehensible since the unit has been misleading
the Board by showing fake readings in the returns. In the circumstances, the unit
may be directed to fix water meter at the intake point in the factory premises and
at all points of water delivery for the purpose such as cooling, boiler, domestic
and processing .
21. There is no arrangement for measuring the effluent discharge rate through the
outlet. The company should provide flow measuring devices and pH indicator
recorder both at the inlet and outlet of the Effluent Treatment Plant.
22. Hazardous waste is lying scattered in the premises of the factory. Board may
direct the company to excavate all hazardous waste lying scattered in their
premises and deposit it into the secured landfill.
23. The entire factory premises especially the Kuzhikandam thodu side should be
cleared of all wild bushes and undergrowth. The Board may direct the company
to immediately clear all the wild bushes. This would help the Board to ascertain
whether the hazardous wastes are dumped in that area and also that whether there
is any illegal outlet to Kuzhikandam thodu covered under bushes and
undergrowth.
24. The side of the Kuzhikandam thodu adjoining the factory premises shall be lined
with rubble masonry. The company may be directed to complete this work .
25. Direct the company to submit a mass balance report supported by the records of
raw materials used, production records waste generated and such other documents
substantiating the mass balance report within a period of one month.
26. Air pollution problems are immensely noticed by the committee on several
occasions. Hence, monitoring of Stacks of the company and Ambient Air quality
are essential. Necessary action should be initiated immediately to start the
monitoring of the stack and ambient air quality. The mobile lab (air) may be sent
to the unit for monitoring air quality during the remaining period of trial run since
there are large number of complaints of air pollution which has compelled the
members of LAEC to rush to the unit at odd hours of night.
27. The quantity of high COD
assessed.
effluent taken to the recovery system is to be
28. The treated effluent before reaching the final polishing tank if need to be further
treated, it should be done elsewhere and not near to the mixing channel where the
raw effluent from equalization tank is taken for primary treatment. It is necessary
750
to ensure that the raw effluent is not by-passed and/or mixed with treated effluent
due to the proximity of both the mixing channels. The treated effluent should not
be allowed to bring for further treatment near to the raw effluent mixing channel,
as such arrangement would give chance for contaminating the treated effluent.
29. The total quantity of sludge generated per day by taking production as per the
consent order may also be assessed during trial run.
30. The trial run is supervised by temporary apprentices on behalf of the Kerala State
Pollution Control Board. LAEC disapproves the supervision by the apprentices
especially of a unit which has a high potential of toxic effluent having regard to
the nature of various chemicals and types of products and rapidly changing
quality of effluent and coupled with poor track record of the unit.
The Board may ensure that senior officers of the Pollution control board be posted
at the factory during trial run especially when the unit is directed to take trial run
of all the products proportionately as per the consent. This trial may be initiated
without further delay since there is hardly 10 days more to complete the 30 days
trial.
31. The representatives of Central Pollution Control Board have not yet reached M/s.
Merchem Ltd., to monitor the trial run. The Board may direct the company to
ensure that CPCB officials are available during the trial run. The Board may also
take up the matter with the CPCB.
32. The Unit may be directed to produce a project report of the new toxic treatment
plant with specifications of equipments, quantity of effluent proposed to be
treated, the quantity of products to be recovered and the quantity of effluent
recycled and the nature of emissions. This detailed project is very important for
the reason that the effluent is divided into toxic and non-toxic, toxic being taken
for treatment in the proposed project and non-toxic in the ETP. Presently, the
attention is more given only for the ETP.
The above aspects mentioned were discussed in detail in the meeting.
35th meeting held on 24-02-2005, Thursday at 5.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution 1
LAEC has been inspecting Merchem Ltd., Eloor now under trial. On 20th February,
2005, LAEC members viz., Mr.Asokan, Mr.Purushan, Mr.Jacob V. Lazar and Mr.
Anand inspected the unit at 6.45 am. The staff of the unit, Mr Martin was found
pumping water into the secondary settling tank.. On questioning this act, Mr Martin and
Mr. Suresh, Asst. Plant Engineer explained that the pumping is done to suppress the
751
froth. The explanation was not found satisfactory. The pumping of water by using
approx. 1 ½ to 2 inch diameter flexible white hose will disturb the equation of the
effluent and will dilute the effluent. Thereafter, one of the employees of the unit
confronted Mr. Purushan and Mr. Jacob V. Lazer and questioned their authority. The
employee also warned the members that in future if the unit is closed, they would face the
consequences. This incident was reported to Mr. Suresh, Asst Plant Engineer and asked
him to take action for misbehavior with the members. Though this matter was reported to
the Chairman the issue was given a quietus considering that it was only a stray incident.
However, to the surprise and shock to the members of LAEC viz., Mr. Anand, Mr.
Purushan and Mr. Jacob V. Lazer, who went to conduct a surprise inspection of Merchem
Ltd., on 23rd February, 2005 at 9.00 pm on the instructions of the Chairman to verify the
information received by him over phone from a local resident that unbearable odour
causing breathing problems is felt by the residents near the Kuzhikandam thodu. The
members after inspecting the thodu reached the gate of the unit. The members were
refused entry by the security staff stating that he has instruction from higher officials not
to let any LAEC members inside the unit without prior permission of the work supervisor
or other senior officers. The members were made to wait for more than 10 minutes. When
they were about to return, Mr. Suresh, Asst. Plant Engineer came and opened the gate.
This incident has not only embarrassed the members of LAEC but this incident is an
affront to the monitoring committee and is therefore to be viewed seriously. This
committee takes strong exception to the behaviour of Merchem Ltd., towards members of
LAEC. Their conduct is highly reprehensible and cannot be tolerated for that would not
only affect the morale of the committee but also would affect its further smooth
functioning.
LAEC therefore requests the SCMC and the Kerala State Pollution Control Board to
issue appropriate orders forthwith. The Kerala State Pollution Control Board may
issue appropriate directions within 24 hours from the date of receipt of this letter,
failing which LAEC will be forced to suspend its inspection at Merchem Ltd.,
Eloor.
Resolution 2.
(a) The supervision / monitoring by the PCB through the apprentices posted in the unit is
thoroughly unsatisfactory. A company of this nature handling toxic chemicals, producing
various products through complicated process has to be monitored by experienced senior
officers of the Board having regard to the bad track record of the Unit and the various
complaints against the unit ever since its inception. The LAEC therefore requests the
PCB to post senior officers on rotation basis to supervise the trial run.
(b) LAEC during its inspection found that the company is not taking all the products in
respect of which consent have been obtained and the decision of the unit to produce only
selective items is to make the trial run a farce. The unit may therefore be directed to take
trial run of all its products as per the quantity fixed under the consent orders. This alone
would ensure the efficacy or otherwise of the Effluent treatment plant.
752
36th meeting held on 26-02-2005, Saturday at 9.00 am at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution 1
Mr. Satheeshan Thampuran, Senior Environmental Engineer was designated as the
liaison officer for LAEC. He was attending to LAEC work for sometime. However, for
health reasons he has not been attending the LAEC liaison work. His service was made
available over and above other three technical staff viz., Smt.Chitrakumari, Mr. Shanavas
and Mr. Soman.
Smt. Chitrakumari and Mr. Shanavas are accompanying the LAEC for inspecting the
units and have covered nearly 110 units so far. The report of the inspection of these units
is in various stages of finalization. If LAEC could make any headway, it is because of
the unflinching technical support from these staff, who have been ably assisting the
committee with technical advise and scientific inputs.
Mr.Soman is looking after the office work, correspondence with PCB and liaison with the
Regional Office. Mr.Soman too has been discharging the functions satisfactorily.
We appreciate the concern of the Chairman, PCB that the liaison work between LAEC
and PCB has to be strengthened. However, the move to recall Smt. Chitrakumari, who
has been giving technical assistance to the LAEC is not a step in the right direction as it
will prejudicially affect the smooth functioning of LAEC. To strengthen the liaison work,
Mr. Satheeshan Thampuran may be advised to regularly attend LAEC.
The Environmental auditing is to be completed within six months. The time left now is
less than two months to complete the auditing. The continued presence of the Members
and the above Officials of Pollution Control Board is a must for completing the task
within the time limit . SCMC has therefore, already directed not to disturb the present
setup in its various communication.
LAEC therefore, requests the Chairman, PCB not to disturb the present set up.
37th meeting held on 26-02-2005, Saturday at 4.30 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
It is resolved to discontinue the public hearing scheduled on every 1st and 3rd Saturday
of every month at 2 pm at the site office of the Pollution Control Board, Eloor. However
753
, complaints from the Public will be received at the office of the Local Area
Environmental Committee during office hours.
Members of LAEC reviewed its functioning with introspection. The members conducted
post-mortem of the entire activities of LAEC and resolved to proceed ahead to
accomplish the task entrusted to LAEC in a time bound manner.
38th meeting held on 2-03-2005, Wednesday at 6.00 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
The recommendation of the CPCB and PCB submitted before the Hon’ble High Court in
the Merchem case on deliberation at the meeting was finally passed expressing the
helplessness of the committee in not to agree for a trial run. Dr. Sharma of the Central
Pollution Control Board advised LAEC not to press for closure despite the finding that
the present ETP system is a total failure. The committee expressed consent with great
reluctance bearing in mind that it is nothing but permitting the industry to continue the
breach of mandate under Sec 7 of the Environment protection Act. The committee
unanimously resolved to request the Pollution Control Board to assess the damage caused
to the Environment by discharging pollutants all these years and recover from the
company the loss caused to the Environment. It is also decided to file an additional
Affidavit before the Hon'ble High Court reporting the observations of the committee
independently. The additional Affidavit contains the following aspects.
1. Merchem Limited Eloor commenced its trial run on 4th February 2005 at 50%
production level (3.3 tonne per day). During the manufacturing process a portion of the
stream containing high TDS and COD were diverted to an evaporator system and the
remaining so called non toxic stream were diverted to existing effluent treatment plant.
The toxic stream so diverted to the evaporator system are MBS Aq layer, CBS filtrate,
CBS column bottom and TQ Aq layer. The so called non toxic stream constitute MBT
filtrate and MBTS filtrates. The result of the treated effluent of the so called non toxic
stream found high COD and sudden death of fish in Bio-assay test. It is observed during
the trial run that the treatment of high COD and high TDS effluent through conventional
biological treatment system is rather difficult especially when domestic effluents are not
being mixed with industrial effluent. Mixing of domestic effluent with industrial effluent
will not be feasible in the existing treatment system to achieve a successful compliance.
The present ETP system existing for several years have thus been proved a total failure
and the complaint of the local community stands vindicated. The recommendation of the
LAEC for closure of unit is thus justified.
2.
It was observed that the unit had completed and commissioned the
evaporator system to handle toxic stream upto 20 cubic metre per day,
although the system was receiving effluents to the tune of 15 cubic metre
per day only (Generally the effluent from these streams shall be of the order
of 35 cubic metre per day at peak production levels.) In order to introduce a
fool proof system of treating various streams generated during the
manufacturing process the representative of the Central Pollution Control
Board, Dr.D.C.Sharma enquired with the company its willingness to go for
754
zero discharge. The company after consultation agreed to go for zero
discharge concept. Accordingly, all agreed to the following suggestion.
a)The company agreed to install membrane systems (Rochem brand) to treat a total of
70 cubic metre per day of highly polluting streams at peak production level of 7 tonne per
day, using a disc type which shall deliver almost 70% recovery of treated water
(permeate)leaving behind only 30% of concentrated pollutants to be force evaporated in a
multiple effect evaporator system. The membrane system shall also be useful in reducing
the quantities of effluent to be evaporated to a significant extent. Thus a combination of
membrane systems and evaporated systems shall be installed to achieve the zero
discharge from the industrial Unit.
b)The emission control systems were cross verified. It was observed that the
scrubbed left over gases were being emitted after a flare system at the top of a 30
metre high stack. In order to safeguard against any upset conditions and/or
malfunctions in the existing scrubbing system, a secondary scrubbing system using
ferrous chloride as the scrubbing medium is agreed to be installed so as to contain
even the traces of Hydrogen Sulphide which is thereafter subjected to flaring to avoid
odour nuisance.
c) The non-polluting streams such as condensate water, boiler blow down and
pump gland cooling water etc. can be successfully recycled in the boiler house and
the processes.
d) The existing effluent treatment plant shall be used to treat a total of 40 cubic
metre per day of effluent generating from floor washings, boiler blow down and
domestic effluent. The treated effluents from the ETP shall have to be completely
recycled within the plant premises for gardening and other purposes.
e) As the unit is going for creating a secured land fill of 100 cubic metre capacity,
it was recommended to increase its size upto 150 cubic metre in order to find place
for transfer of the sludge from temporary storage and the sludge generated in the next
two years.
f) The company agreed to clear all wild bushes in its premises. The land (left
after construction of secure landfill) however shall be cleared of all wild bushes and
levelled.
The Central Pollution Control Board and the State Pollution Control Board has made the
following recommendations which has been agreed to by all the parties not withstanding
the fact that the extension of trial run, after being convinced that the treated effluent is of
high COD and the failure in the Bio-assay test, will result in discharging pollutant into
Kuzhikandam thodu which is a creek of Periyar river. This Hon'ble Court may therefore
pass appropriate orders bearing the mandate of sec. 7 of the Environment (Protection Act)
1986. Sec. 7 of the Environment (Protection Act) 1986 reads thus:
755
“ No person carrying on any industry, operation or process shall discharge or
emit or permit to be discharged or emitted any environmental pollutant in
excess of such standards as may be prescribed.”
The industry must complete installation and stabilization of the additional
evaporator system within two months from 5th March 2005. The installation of
membrane system and all other actions related to achieving zero discharge shall be
completed within 5 months.
The additional scrubbing system as proposed shall also be completed within two
months. The installation of hydrogen sulphide sensor cum data logger shall be completed
within a time span of six months.
The Hon’ble Court may be pleased to consider extension of the on going trial run
by another two months at the current production level of 3.3 tonne per day under the
continued monitoring by the State Pollution Control Board and the Local Area
Environmental Committee shall continue to associate with the inspections.
On the additional evaporator system being successfully completed and
commissioned in two months time, the existing ETP shall have to treat only the weak
waste arising from floor washing and domestic effluents. At this point of time, yet
another joint inspection is recommended to review the progress and recommend further
course of action.
39th meeting held on 05-03-2005, Saturday at 3.30 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution No1
The convener of the Local Area Environmental Committee for Eloor- Edayar resigned
from the post OF Member Secretary of the PCB. Pollution Control Board by order dated
28-2-2005 nominated
Mr.R.V Sateeshan Thampuran Senior Environmental
Engineer, Kerala State Pollution Control Board as convener of LAEC in the place of
Shri.K.V.Indulal. In this circumstances, the Committee resolved to request Bank of India,
Kaloor Towers, Kaloor to allow Mr. R.V.Sateeshan Thampuran, Senior Environmental
Engineer, Kerala State Pollution Control Board to operate the account opened in the
name of Local Area Environmental Committee for Eloor –Edayar either by himself or
through his authorized representative.
Resolution no2
Resolved to hold a joint meeting of LAEC and Chairman , Member Secretary and Senior
officials of PCB to discuss the modalities for assessing the environmental damage caused
by various industrial units in Eloor – Edayar industrial belt and recover from them the
cost for remediation programs. The Supreme Court Monitoring Committee has directed
Pollution Control Board and LAEC to collect 2.5 crore for reviving Periyar. This
exercise of determining damages has to be undertaken without further delay. The time to
756
hold a joint meeting shall be fixed by the Chairman in consultation with the Chairman of
Pollution Control Board. The tentative dates could be between 14th March to 18th March.
Resolution No3
Approved the reports of the following Engineering units.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
JMJ Machines and Equipments, Edayar
Star Engineers, Edayar
Accurate Components and Tools, Edayar
Damodar Industries, Edayar
SBN Engineering Works, Edayar
Rini Engineering Works, Edayar
Steel Engineering Works, Edayar
Adithya Engineering Company, Edayar
Southern Carbon Pvt.Ltd., Edayar
V More Engineering, Edayar
K.K.Engineering, Edayar
Manoj Engineering Works, Edayar.
Poduval Industries, Edayar
Southern Engineering Corporation, Edayar.
Techs India Company, Edayar
New Tech Company, Edayar.
Lakshmi Electricals, Edayar.
Resolution No 4
Approved the reports of the following Crusher units
1.
2.
3.
4.
5.
National Granites, Edayar.
Kummencheriyil Metals, Edayar
Hill Rock Metals, Edayar
Edayar Metals, Edayar
Vijay Associates, Edayar.
Resolution No 5
Approved the report of Prima Agro Limited.
40th
meeting held on 08-03-2005, Tuesday at 3.00 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
Finalized the report of Sigma Fertilizers .
757
REPORT
Name of the Industry
:Sigma Fertilizers.
Date of Inspection
: 4-11-2004.(LAEC members were
accompanied by PCB officials namely Mr.
Sateeshan Thampuran, Senior Environmental
Engineer, and Smt.Chitrakumari.D,
Environmental Engineer in the inspection)
Name of the Product/s :
:Bone Meal, Tallow and organic rich
water
Raw materials
: Raw bone
Process:
After boiling the raw bones they are crushed, sieved and packed.
Findings:
Kerala State Pollution Control Board issued consent to establish this fertilizer industry for
production of bone powder by order dated 1-3-2000. Among the conditions imposed the
Board specifically directed this unit to obtain consent from the Board under the
Air(Prevention and Control of Pollution)Act 1981 before commissioning the industry.
The consent to establish the industry directed the unit to plant and maintain trees within
the factory premises to improve the environment.
The Board also specifically directed the unit that it shall not produce tallow.
The unit started without obtained consent under the Air Act and it is continuing its
production. The unit has no consent under the Water(Prevention and Control of
Pollution)Act 1974. There is no green belt in and around the industry and no effort has
been made to comply with the directions of the Board contained in the consent to
establish the industry even after four years.
The Factory and premises are kept untidy and unhygenic. The raw bones are stocked
unhygienically in the premises spread over. Storm water drain with blood dripping is a
disturbing scene. Effluent and storm water in anaerobic condition is seen stagnated in the
adjoining land. Unbearable foul odour emanating from the factory and premises keep a
normal person at least a distance of 50 meters away from the factory. House keeping is
miserably poor . The labourers mostly from other states were found seen taking meals
just by the side of putrefied pond wherein countless worms crawling one over the other,
758
a scene cannot be imagine in any situation of human habitation. Labour officers have not
checked the implementation of welfare laws.
Recommendations:
The unit is functioning without obtaining the consent under the Air(Prevention and
Control of Pollution)Act 1981 and Water(Prevention and Control of Pollution)Act 1974
and found operating against the mandate of Air Act and Water Act and Environmental
Protection Act.
The unit is found producing tallow against the directive in the consent to establish.
The requirement of greenbelt at the time of establishing industry is yet to be materialized.
Air and Water pollution is a cause of nuisance to the near by units and public.
House keeping is miserably poor and absolutely no proper drainage system is
maintained.
For the aforesaid reasons LAEC is of the opinion that the unit should be given a closure
order forthwith and can be allowed to restart only subject to complying the following
stipulations:-
9. The unit should obtain consent of the Board under Water Act and Air Act
10. Raw material should be stored in confined store hygienically.
11. Unit should provide stack /chimney 15 m above ground level with draft /use of
bio filter to expel foul smell out for dilution.
12. Only dried bones should be allowed to process.
13. Storm water drain should not contain any pollutants carried over.
14. Greenbelt of fast growing and long lasting pollutant resistant plant should be
planted where ever possible
15. Proper hygienic house keeping should be practiced in and around the factory
16. The unit should install sophisticated equipments for odour control.
41st meeting held on 10-03-2005, Thursday at 5.20 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
Finalized the report on Kairali Leather Industries, Edayar as follows :
Local Area Environmental Committee members accompanied by officials of
Kerala State Pollution Control Board namely, R.V.Sateeshan Thampuran,
SEE, Smt.Chitrakumari.D, EE, Shri.Farook Sait ,EE, and Mr.Shanavas,
Asst.Scientists conducted a surprise inspection on 22-2-2005 getting
information that the unit is discharging untreated effluent into Periyar River.
On inspection at the out let of the unit the colour of the river water was
found dark. Foul odour of tannery waste in the downstream of the bund was
experienced by the team. The team on inspection of the unit found effluent
759
treatment idle. All the treatment units were almost filled with effluent. The
tanks were found filled with red coloured effluent generated from soaking
tanks. A pump was seen placed near the aeration tank with suction line from
aeration tank and discharge line with hose connection. The inspecting team
observed by this arrangement that the functioning of the aeration tank was
not properly utilized and that the odour in the river bank and discolour seen
in the river water near outlet was the result of directing pumping of effluent
by using pump and hose through the authorized outlet.
The unit is handling raw hides and processing the same using Chromium. It
has a Chromium recovery system but the same has not been put to use. The
unit is depending river Periyar for its water requirement. It is discharging
90000 litres of waste water per day into river Periyar. Discharging effluent
without recovering the Chromium was great danger to River Periyar. Old
Chromium bearing sludge is seen dumped in the premises. The house
keeping of this unit is very poor. The conventional effluent treatment system
is to be modified and upgraded by using the best available technology.
Considering depletion of water in the river, the unit should come forward with
resource saving concept and minimize water consumption by reusing the
water which is discharged into the river for other purposes.
Considering the conduct of this unit (discharging untreated effluent with
impunity) the unit should be asked show cause why stringent action including
closure should not be taken for its failure to comply by the provision of
Environment Protection Act, Water (Prevention and Control of Pollution)Act
1974, and Hazardous Waste(Management and Handling) Rules 1989.
LAEC recommends the following measures.
2. The unit being a tannery unit, the use of Chromium for its process, if
at all insisted, the best method available technology for recovering
the Chromium should be directed to be adopted. It is advisable to go
for a non-Chromium based process.
10.The effluent treatment should be modified and the treated water
should be directed to be used.
11.Minimize the water consumption. Direct the unit to install water meter
for measuring water consumption.
12.Direct to provide V notch at the statutory outlet for measure the
quantity of effluent discharged.
13.The unit may be directed to remove the Chromium sludge dumped in
its premises and store it in a temporary hazardous storage facility.
14.The unit may be directed to give a mass balance statement of the
Chromium sludge and account its disposal/storage.
15.Greenbelt of fast growing and long lasting pollutant resistant plant
should be planted in its premises.
16.The undergrowth and wild bushes all along the boundary of the unit
near the banks of the Periyar river should be directed to be cleared.
760
17.The unit should be directed to go for Zero discharge in a phased
manner and a proposal with a time schedule may be obtained which
should from part of the condition in the consent order.
Resolution No.2
Decided to hold a meeting of LAEC with the Chairman and other officials of KSPCB, to
discuss the modalities for recovering damages from polluting industries on the basis of
Polluter Pay Principle. The meeting will be fixed after ascertaining a convenient date
from the Chairman, KSPCB .
42nd meeting held on 12-03-2005, Saturday at 3.45 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
Finalized the report on Cochin Alloy Products Pvt. Ltd as follows:
The industry was inspected by Local Area Environmental Committee accompanied by
official of the Pollution Control Board, Mr Shanavas, Asst. Scientist. The company is
producing Ferrous Silicon and Calcium carbide. The raw materials used are sea shell,
Wood Charcoal, Carbon paste etc.
The furnace area near chimney is found not properly covered. Fugitive
emission is a problem noticed in the unit. The Pollution Control Board refused
consent under Air (Prevention and Control of Pollution)Act 1981 on 10-31997 for want of adequate air pollution control measures. The unit was
given a closure order by the Pollution Control Board for operating without
consent under the Air Act. Subject to the condition that all air pollution
control measures will be provided, the unit was allowed to operate by a Court
order.
The unit claims to have complied with all pollution control measures and
applied for renewal of consent on 14-6-2002. Pollution Control Board refused
consent on 1-10-2002 stating inadequacy of the pollution control measures
and failure to furnish information on capital investment etc. The unit having
failed to adhere to the pollution control measures Pollution Control Board
filed a complaint before the Judicial First Class Magistrate Court, N. Parur on
6-11-2003 for prosecuting the unit.
Findings:
The Pollution control measures are found inadequate . Fugitive emission is a
problem. The height of the chimney is not adequate. In spite of declining
consent under the Air Act for want of proper system, the unit is functioning
with impunity . It has not cared to satisfy the regulatory Board on the
761
adequacy of the system. The information furnished by the unit to the LAEC
that their application for consent is pending is false. In the above
circumstances LAEC is of opinion that the unit should be directed to be closed
down and be permitted only after providing adequate air pollution control
measures to the satisfaction of the Board.
The unit should be allowed to operate subject to satisfying the following
conditions:
5. The unit should obtain the consent under Air(Prevention and Control
of Pollution)Act 1981.
6. The unit should provide adequate air pollution control measures to
contain fugitive emission.
7. The units should be directed to grow fast growing and long lasting
trees all along the boundary.
8. Grow curtain plants(jaiva veli or bio fencing) all along the boundary at
a height of 20 feet and start maintaining the plant.
43rd meeting held on 14-03-2005, Monday at 10.30 am at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
Report on the complaint of Fugitive emission from Merchem Ltd, Eloor is as follows:
Fugitive emission in Merchem Ltd Eloor on 13-3-2005 between 9 pm to 11
pm had raised alarm and serious apprehension of danger to life of the
people residing nearby the unit in Eloor. Few local people were rushed to a
nearby hospital and were given emergency treatment.
On getting information about the fugitive emission causing severe headache,
chest pain, nausea and abdominal congestion to the people, the members of
LAEC rushed to Merchem Ltd at about 10.45 pm. A huge gathering of local
residents were seen agitated raising slogans in front of the company. The
local residents blocked the vehicle of LAEC members. One member of LAEC
was about to be assaulted by the agitated group. Somehow the situation was
managed and the agitated crowd was assured immediate action to contain
the fugitive emission. LAEC members entered inside the factory and
experienced (around the NAMBT plant) severe piercing odour, similar to the
one experienced outside. The entire company premises and outside was
having a misty look. The plant in charge, Mr.Paul Raj, however insisted that
the odour is one from HIL, and that Merchem Ltd has nothing to do with
fugitive emission / other emission.
762
Members of LAEC went to inspect HIL to ascertain whether there is any
emission from HIL. Of the four plants in HIL, three were idle and only one
plant viz., Dicofol was found working. No emission or odour was felt inside
the HIL. The team returned to Merchem Ltd.
On account of public upsurge, the Sub Inspector of Police, Cheranallore, who
was in charge of Eloor came to Merchem Ltd, Eloor alongwith other police
personnel and the District Panchayat Member, Mr Sajan Malayil. The police
officials and Mr. Sajan Malayil could feel the smell and asked the company
either to stop the plant or do mitigating measures.
The smell initially experienced was a burnt smell which gradually transformed into
severe piercing odour of the kind, which according to local people were experienced in
the early periods of trial run in 1997. Unfortunately, the attitude of the company was not
only indifferent but also very negative. The incident was reported to the Regional Office
of the Kerala State Pollution Control Board, Ernakulam. Mr. Jayprasad, CEE
accompanied by Mr.Sateeshan Thampuran, Convenor of LAEC and Mr. Farook Sait, EE
reached Merchem Ltd. around 2.00 a.m. They collected information from Mr. Sudheer,
the apprentice posted at Merchem Ltd. during the trial run.
Mr. Sateeshan Thampuran reported to the committee that there was fugitive emission in
the unit and some remedial measures have to be taken to avoid any such recurrence in
future.
Merchem Ltd is a company now under trial run by an extented time of one month. The
unit was found not having adequate effluent treatment system. The Effluent treatment
system of the so-called non toxic effluent after its bifurcation was found inadequate and
the treated effluent was found toxic in the laboratory analysis. During the joint
inspection, the complaint regarding fugitive emission was brought to the notice of the
company officials and were directed to take measures to contain fugitive emission. The
unit is now found negligent in taking adequate measures to contain fugitive emission .
The continued trial of this unit causing serious apprehension to the life of people and
nuisance by negligence of Merchem Ltd., is tending to question even the credibility of the
LAEC, which is supposed to act as a catalyst and help the authority to take action against
the unit found violating environmental laws. The very fact that the LAEC members were
restrained by the local people demonstrates the erosion of public confidence in LAEC.
The complaint of the people that the LAEC has failed to appraise the court about the
seriousness of this aspect, though has no basis, in the present context is hard to impress
them.
In the circumstances, LAEC has resolved to report this matter to the Hon'ble High Court
and seek review of the trial run and a direction to install efficient control measures
before allowing any kind of production under whatever name it may be called.
763
During the crisis management in addressing fugitive emission in the Unit,
LAEC members except Shri.RV.Sateeshan Thampuran felt the following
deficiencies which need to be addressed immediately:
4. The site office at Eloor, though revived, is not functioning effectively
and there is no arrangement to address such contingencies /
emergencies.
5. The trial run in Merchem Ltd. monitored by PCB through apprentice is
found not effective. Senior and experienced officers of the Board has
to be posted so that such incidents could have been avoided and the
source of fugitive emission could have been identified.
6. Stack monitoring and the ambient air quality have not been taken
even once during the entire period of trial run to test the efficiency of
the stack and emissions at Merchem Ltd.
The company may be directed to show cause for the fugitive emission
causing apprehension to the life of the people and for causing nuisance
and take such action, as may be warranted in the facts and circumstance
of the case.
44th meeting held on 15-03-2005, Tuesday at 6.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution no 1
Mr. G. .Anand raised a question as to whether LAEC has been given any report by the
PCB on the action taken on various inspection reports forwarded to PCB for action. No
such report is seen submitted from the office of the PCB. In the above circumstances, it is
resolved to request to the Pollution Control Board to give a consolidated report on the
actions taken in pursuance to the reports forwarded to the Board in respect of units in
Eloor- Edayar area. Mr. Sateeshan Thampuran however assured the committee to give an
action taken report on all matters so far forwarded on a day to day basis and shall within a
period of 10 days will submit the entire report on all the inspection reports so far
forwarded to the Board. LAEC thereafter will prepare a consolidated report to be
submitted to the SCMC by 27-3-2005.
Resolution no 2
LAEC further resolved that an environmenal impact assessment on the contamination to
the water and soil in the areas surrounding Kuzhikandam thodu especially ward No.
1,2,3,4,17 will be conducted and polluters identified for providing compensation to the
affected community. The modalities of the study will be worked out later.
764
45th meeting held on 17-03-2005, Thursday at 5.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
Mr.Purushan Eloor and Mr.Jacob.V.Lazar brought to the notice of the LAEC
that Pollution Control Board has no system either to collect the sample of
fugitive emission or to test the nature of contamination of ambient air. It is
reported that Global Community Monitoring, California is having the lab
facility to test the pollutant in the ambient air. Testing ambient air is a very
costly exercise. In India there is no lab facility to test the finger print of the
air. Committee feel proud of the fact the Mr. Purushan and Jacob Lazar have
been trained by the Global Community Monitoring, California and they have
been give the status of “Bucket Brigades” for taking sample. The above said
organization have offered to the Periyar Malineekarana Virudha Samathi to
test three samples of ambient air, free of cost at California. Mr.Purushan and
Jacob.V.Lazar extended this offer to LAEC for getting two samples of ambient
air tested from the said lab on their behalf. In view of the fact that EloorEdayar being a industrial belt the committee would take samples of ambient
air of Eloor- Edayar industrial belt as and when the committee feels
expedient.
Resolution No.2
It is resolved to bring out a white paper on environment in Eloor- Edayar industrial belt
with specific reference to Periyar. The modalities will be worked out later.
Resolution No.3
The Committee (LAEC) today assessed the current situation in the River Periyar. There
has been visible improvement in the quality of water in the River, when compared to that
of the river quality during the early period of LAEC’s inspection in October, 2004. Life
in river Periyar
to a large extent has been restored. Fish population has been
considerably increased and people have started fishing in the river. Despite depletion of
water in river Periyar in the scorching sun, the river quality has visibly improved, thanks
to the industries in the river banks for their belated concern to the river and the
environment.
Since its inception, LAEC had come down heavily on units, which were polluting the
River Periyar and its various streams. In several cases, LAEC had also recommended
immediate closure of the units and other stringent actions. Most of the Units have now
realized that Preventive Environmental Management and Integrated Chemicals
Management leading to a Zero Discharge are alone can sustain them in the field.
765
LAEC in particular lauded the efforts of two medium scale units viz., Cochin Minerals &
Rutile Ltd (CMRL), Edayar and Sud-Chemie India Pvt. Ltd, Edayar.
Sud Chemie India Pvt.Ltd has already implemented Hazardous Waste safe disposal
systems, as per the guidelines of the Central Pollution Control Board well ahead of time.
Cochin Minerals & Rutile Ltd (CMRL) is rapidly progressing in implementing hazardous
waste disposal system aiming at zero discharge. LAEC felt that these units have been
the pathfinders for other units to emulate.
LAEC would continue to act as an “Environmental Watchdog” for checking illegal
dumping and emissions from the units situated in the banks of the River Periyar and its
streams.
LAEC also exhorts all units to look at Waste re-use, Waste recycling and waste recovery
through Best production practices thereby reducing discharges and hazardous waste
generation.
46th meeting held on 29-03-2005, Tuesday at 5.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
Resolved to conduct a river survey on 2-4-05 and take samples from different points to
make a comparative study of river status viz-a-viz the status of river in Nov-Dec 2004.
Resolution No.2
LAEC considered the complaint submitted by Mr. Sojan Joseph against M/s Cochin
Minerals and Rutiles Ltd, Edayar alleging that he suffered damage due to the functioning
of M/s Cochin Minerals and Rutiles Ltd., Edayar violating environmental laws. His
complaint is to recover damages and for compensation. The committee is concerned with
the environmental aspects affecting the community as a whole. Individual cases are not
within its purview. Further it cannot adjudicate the claim for compensation. In the above
circumstances, it is Resolved to inform the complainant to seek remedy in the appropriate
form for injury if any, suffered by him.
47th meeting held on 31-03-2005, Thursday at 5.15 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
The committee evaluated the various reports submitted by the industries from the
accredited labs of Kerala State Pollution Control Board. The lab reports from the
accredited laboratories are found not to reflecting the true nature of the effluents.
766
The credibility of the accredited labs are under challenge. The periodical reports
submitted by various units are identical. The Pollution Control Board therefore has to
reconsider the accreditation so far granted to various laboratories in the State. Only such
laboratories should be considered for the grant of accreditation, which has NABL
accreditation. Further the accredited labs should be strictly directed to certify only those
samples either taken in their presence from the authorized outlet or in the presence of the
officials of PCB. This condition should necessarily be insisted since it is found that the
samples tested by the accredited agencies are the samples made available by the company
itself. The committee therefore resolved that the PCB should reconsider the accreditation
given to various laboratories and those labs which do not have the accreditation of
NABL should be removed from the list of accredited labs of the PCB.
48th meeting held on 04-04-2005, Monday at 6.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
On the complaint of the local residents of Eloor about the fugitive emission from M/s
Merchem Ltd. on 13 3-2005, LAEC members rushed to the spot. The Pollution Control
Board issued show cause notice seeking explanation. The company replied refuting the
allegation. The LAEC brought to the notice of the Hon'ble High Court, the incident of
fugitive emission through an interlocutory application. M/s Merchem Ltd in the counter
affidavit contended that no such Fugitive emission had occurred on
13-3-2005
between 9 pm to 11 pm.
During the course of hearing the counsel for the Pollution Control Board made a
submission contrary to the stand of Pollution Control Board that the emission was from
HIL. Member of LAEC, Mr. Purushan, Eloor, asked as to why such wrongful submission
is made by the counsel of PCB before the Hon’ble High Court. Mr. Sateeshan
Thampuran, CEE, KSPCB, Ernakulam was unable to explain the reason for such a
submission by the Counsel.
The committee on enquiry with the Regional office of the Pollution Control Board was
informed that further action pursuant to the show cause notice has been dropped against
the company.
It is seen from the records that all show cause notices issued by the Pollution Control
Board are closed after obtaining reply from the company. This practice has set a bad
trend among the companies to go scot-free after committing the damage to the
environment and nuisance to the public and residents. LAEC strongly condemn such
practice as that would forfeit the confidence of the people in the law enforcing agency
which will lead to anarchy .
767
The complaint of the local residents on the fugitive emission from Merchem Ltd cannot
be closed based on the reply refuting the allegations. Such practice will certainly leave
the civilian community without any remedy. In the light of the reply refuting the
allegation the Board ought to have conducted an enquiry into the incident alleged and
ought to have come to definite finding on the merits of the complaint. Closing the file
obtaining reply denying the incident is not a good practice as that would seriously
prejudice the public.
LAEC in the aforesaid circumstances, has decided to conduct a public hearing on the
complaint of fugitive emission and take evidence in the matter so that appropriate action
can be recommended against the company redressing the grievance of the residents. The
committee resolved to hold a public enquiry on 16th April, 2005 at Yuvajanavayanashala,
Eloor North at 10 am and to collect evidence from the public. Chairman, Pollution
Control Board may be requested to attend the public hearing. Notice of public hearing
shall be issued to the company and also to the local residents through press release.
Resolution No. 2
The LAEC as part of its environmental audit, proposes to commence stack monitoring
from 11 –4-2005. The committee resolved to request the Pollution Control Board to
arrange suitable personnel for stack monitoring and assist the committee with necessary
equipments. It may be recalled that Stack monitoring has not been conducted by the
Pollution Control Board for over 4 years. The committee recommends PCB that the stack
monitoring should be periodically carried out since the local residents have been
complaining about the air quality in Eloor - Edayar industrial belt.
49th meeting held on 09-04-2005, Saturday at 5.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
The Chairman, LAEC briefed the committee about the transfer order of Mr. G. Anand
representing CII to Hyderabad. He informed the committee that already he had spoken to
the vice chairman of CII Kerala Chapter and appraised him the necessity of Mr.
G.Anand’s presence in the LAEC and inevitability of his service to finalize the
environmental audit of the LAEC .
The committee unanimously endorsed the opinion of the Chairman and resolved to
request the Regional Director, CII to suspend the transfer of Mr. G. Anand till 31st July
2005. The committee is of the view that Mr. G. Anand being a member who has made
maximum visits of industries in connection with environmental audit is experienced and
familiar and his service is of great importance for not only completing the inspection of
remaining industries but also for finalizing comprehensive reports on the environmental
audit.
768
Confederation of Indian Industry (CII) being an important body would realize and
appreciate the importance of its member’s contribution and will extend the service for
completing the task. The committee feels that a new member joining LAEC at the fag
end of the committee’s term will be of no use since by the time he gets himself
familiarized with the activities, the term itself will be over.
In the circumstances, it is resolved to request CII to retain Mr. G. Anand in LAEC.
Chairman LAEC has been authorized to take up the matter with the Supreme Court
Monitoring Committee and CII to ensure the continuance of Mr.G.Anand in LAEC at
Kochi.
50th meeting held on 15-04-2005, Friday at 4.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
The committee approved the reports of the following industries.
1. Minar Chemical Industries, Edayar
2. National Battery Industries, Edayar
3. Hi Tech Electro Thermics Pvt.Ltd, Edayar
4. Ramanand Electro Coats,Edayar
5. G.K.Gases and Chemicals, Edayar
6. National Industries, Edayar
7. V.R.Wood Art Ltd,Eloor
8. Panchami Agro Industries, Edayar
9. Yeoman Bone and Allied Products, Edayar
10. Nelkadir Bone Industries, Edayar
11. Kaveri Bone Industries, Edayar
12. South Indian Fertilizers, Edayar
13. Tamilnadu Ammonia Pvt.Ltd, Edayar
Resolution No. 2
The public hearing posted 16th April 2005 shall be attended by all the members of the
committee. It is resolved that chairman will record the statements of the witnesses
attending the public hearing in connection with the enquiry of the alleged fugitive
emission.
Resolution No. 3
The committee deliberated on the proposed common TSDF at Ambalamedu .Members
expressed their unhappiness on furnishing Rapid EIA and DPR late to the committee by
the Pollution Control Board despite being aware of the fact that TSDF matter is one of
the reference of the LAEC .Owing to lack of time to study the project report and its
suitability , members resolved to request to PCB 15 days time to offer LAEC’s comments
in response to the notification. Accordingly Chairman will address a letter to Pollution
769
Control Board and also will appraise Supreme Court Monitoring Committee these
aspects.
51st meeting held on 22-04-2005, Friday at 4.15 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor
Resolution 1
The committee deliberated on the rapid EIA and DPR on common TSDF proposed to be
established at the premises of FACT at Ambalamedu. Scientists Mr.Chandramohan ,Mr.
Madusoodanakurup and Mr.Sivasankarapillai attended the meeting also expressed that a
local inspection of the site is necessary to evaluate the feasibility of the project. The
committee resolved to have a local inspection of the proposed site with notice to KSIDC
on 25th April 2005 at 3 pm.
52nd meeting held on 26-04-2005, Tuesday at 6.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor
Resolution 1
LAEC deliberated at its meeting held today on the Common Hazardous Waste
TSDF proposed at Ambalamedu in the premises of FACT.
The Committee members along with Experts in the field conducted an inspection of the
site in the presence of the representatives from KSIDC, the nodal agency on 25th April,
2005. Officials of the PCB deputed to assist LAEC were also present.
Resolved the following:
19. One major complaint against the site was regarding the population in and around
the proposed site. The Committee could not find any appreciable population
residing within a radius of 600 metres.
20. The proposed site comprises an area reclaimed by Gypsum dumped by FACT and
adjacent laterite land.
21. Down the site there is a vast extent of wetland with no cultivation. The lake and
adjacent forest in the FACT premises are not affected by the setting up of TSDF
since both these are at a safe distance of 500 metres.
22. The lie of the land is in a zig-zag manner. Having regard to the nature of land, the
cost of land development is likely to be very high, which may result in escalation
of the project cost.
23. The test of soil conducted by the KSDIC is through taking samples from a small
pit. For a project like this, the sample ought to have been taken by boring.
770
24. A two-tier dyke to protect the area from the impact of fugitive loss of hazardous
waste is essential. This is to be constructed with earth removed from the site and
selected vegetation should be raised therein.
25. The monsoon in Kerala stretches for more than half of the year. There must be
temporary storage facility to store the hazardous waste before transferring to the
TSDF after laboratory tests. The quantum of the hazardous waste for one year
therefore, has to be initially assessed to decide the area required for temporary
storage and its design.
26. The concept of covering the TSDF by tarpaulin or any such other material during
rainy season seems to be very theoretical and difficult to be executed. Detailed
study has to be made and more sophisticated and practical solutions have to be
found out to protect the site from heavy rains.
27. Kerala State Pollution Control Board being a regulatory body empowered under
various statutes to enforce law should not be a party to the project which is
essentially floated by a company ie., Kerala Enviro Infrastructure Ltd.
Involvement of PCB officials with the administration / constitution of the
company either as a Director or in any other capacity will erode the confidence of
the general public and also would create a situation of having no regulatory body
to be made accountable for implementing control measures.
28. Air and Water Risk Assessment and Management have not been made in respect
of the proposed site. The flow of water is towards the down stream reaching the
creek, which is affected by tidal waves. A detailed Environmental Risk
Assessment (ERA) should be conducted on Water and Air pollution.
29. The project has not discussed the dust control facility. The quantity of waste to be
incinerated is 3000 tonnes per month. Such a huge quantity is bound to cause
serious air pollution. Wind direction, its speed etc., are therefore matters to be
studied in great depth before finalizing the project.
30. The compatible hazardous waste has to be identified with a transit storage.
31. The laboratory proposed should have NABL accreditation.
32. The waste being hazardous at every stage of its handling great care has to
exercised.
33. To monitor the functioning of the TSDF, a committee of stakeholders like
prominent non-political person from local area; non-political NGOs;
representatives from local bodies; scientists & experts from reputed institutions
like CUSAT etc. have to be essentially involved by way of a participatory
monitoring mechanism and effective implementation.
771
34. The concern of the community is that in the event of any unforeseen calamities
and untoward incidents, who would compensate the loss suffered on account of
the operation of TSDF. A corpus fund therefore, has to be created which should
be made at the disposal of the KSPCB for immediate utilization for relief and
other contingent uses to cope up with all such situations. A fund of Rs. 5.00
crores to be ear-marked for this purpose and it should be deposited in a
nationalized bank. A portion of this fund has to be utilized to provide community
facilities and awareness on disaster preparedness.
35. The Rapid EIA falls short of many important aspects such Risk Assessment &
Management, Soil tests, Air and Water pollution, zig-zag nature of land,
temporary storage of hazardous waste, risks during transportation, laboratory
requirements, laboratory waste, inventory of hazardous waste, its density,
compatibility of various hazardous waste, down stream contamination, drinking
water contamination, strategies for combating heavy monsoon, dust and emissions
etc.
Cochin University of Science and Technology (CUSAT) is one such
institution, which can be entrusted to prepare a detailed Environmental Impact
Assessment & Environmental Risk Management study.
36. The best practices and best available technology in other places especially the
Naroda Eco Park facility should be studied in detail before finalizing the project
and its design.
53rd meeting held on 03-05-2005, Tuesday at 5.15 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
Discussed the visit of SCMC members scheduled on 10-11th May 2005. Letter addressed
to Mr.G.Rajmohan by Dr. Claude Alvaris giving details of their tour was read in the
meeting. Mr.Farook Sait has been entrusted to follow up the matter with PCB and do
needful conforming their travel and stay arrangements.
Resolution No. 2
Resolved to compile the minutes and reports with photographs taken at different stages of
inspection and prepare five copies to be handed over to SCMC during their visit to Kochi
on May 10th 2005.
Resolution No. 3
Resolved to inform The Secretary, Dept of Health and Family Welfare, The
Director, Dept of Industries, The Executive Director, KSIDC about the visit of
SCMC and request their presence for interaction with SCMC.
772
Resolution No. 4
Resolved to bring to the notice of SCMC the initiative taken by the District
administration to clean up the Kuzhikandam thodu at the cost and expenses of industries
such as Merchem, FACT, HIL, and IRE etc. Though many deliberations have taken
place, there is absolutely no progress worth mentioning. It is hence desirable to have a
meeting of the District Collector and Kerala State Pollution Control Board for expediting
the cleaning process of Kuzhikandam thodu. The committee proposes to call the District
Collector for a meeting with SCMC during their visit on 10th may, so that Supreme Court
Monitoring Committee can issue appropriate direction to the District Collector.
Interference of SCMC would certainly strengthen the hand of District Collector and will
help to get good response from all industries without raising much technical objection.
54th meeting held on 03-05-2005, Tuesday at 5.15 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolved that the Report of the Public Hearing held on Saturday, 16th April, 2005 at
Yuvajana Vayanashala, Eloor North to Enquire into the incident of fugitive
emission reported at Eloor on 13/03/2005 given below is hereby approved:
(See the Public hearing , Page No.)
55th meeting held on 08-05-2005, Sunday at 4 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
LAEC noted that no steps have been taken to ensure round the clock effective functioning
of the Site office at Eloor by providing sufficient staff and infrastructure including Lab
facilities and vehicle for inspection. The matter is pending since 12/11/2004.
The LAEC has passed several resolutions on the subject viz., Resolution of the 6 th
Meeting of LAEC held on 12/11/2004; Follow-up Resolution of the 18th meeting held on
21/12/2004; The assurance by Chairman, PCB to the LAEC in the meeting attended by
him on 08/02/2005; Follow-up Resolution at the 43rd meeting held on 14/03/2005.
In continuation of the earlier resolutions passed on the subject, the action reportedly taken
by the Pollution Control Board is to appoint a peon and an Asst. Engineer and a typist.
The committee is totally unhappy with the steps taken for these measures do not improve
the situation.
773
There is no Electricity, Telephone connection, Water connection and even no
arrangement for a lady staff to function since it lacks primary facilities like toilet. No
vehicle has been provided for inspection. There is no laboratory facilities . Even the
facility to collect samples is not provided. The office has no typewriter though the office
has a typist. There are no regular inspection of the various units in the Eloor / Edayar area
from the site office. The office remains closed after 5 PM. The posting of staff serves no
purpose except incurring additional expenditure.
The recommendation of LAEC for 24 hours functional site office with a view to monitor
the industries round the clock is to keep a check on the polluters. Even after six months of
LAEC’s repeated demands to have a functional site office, KSPCB has not taken any
serious action so far. The conduct is strongly disapproved. The Hon'ble High Court has
directed both the Govt. and PCB to recruit sufficient staff. The negligence to comply by
these directions amounts to contempt of Court.
Primarily the location of site office itself has to be shifted. The present office is totally
inadequate to house a functional site office. FACT has many staff quarters vacant as
reported by one of the LAEC member Mr.Jayathilakan . PCB may approach FACT and
get suitable quarter for housing a full fledged site office.
Having regard to the number of companies and workload, the site office at Eloor Edayar
must be upgraded on par with the Dist. Level office. This may be done on war footing
failing the continued monitoring after the term of LAEC will be disrupted and may
reverse the progress so far made.
Resolution 2
Chairman briefed the committee about the letter given to him withdrawing the
nomination of Mr.Asokan from LAEC . The committee also discussed the letter of
resignation by Mr.Asokan. The Chairman read the reply given to the Small Scale
Industries Association Edayar and to Mr.Asokan. The committee approved the action of
the chairman.
The committee also discussed the Writ Petition filed before the Hon'ble High Court by
Edayar Small Scale Industries Association challenging the continuance of Mr.Asokan in
LAEC. The committee authorized the Chairman to take appropriate action to defend the
matter.
Resolution 3
The committee resolved to update the website. A copy of the CD containing the interim
report prepared for submission to the SCMC may be sent to the concerned person in
charge of Website.
Resolution 4
Resolved to approve the reports of the following industries.
774
1.
2.
3.
4.
5.
Abco Accumulators
St.George Industries
Hi-Tech Seals Pvt.Ltd
Arjuna Natural Extracts
Cochin Rubber Industries
56th meeting held on 20-05-2005, Friday at 12 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
Chairman ,Adv.P.K.Ibrahim brought to the notice of the committee the order passed by
the Hon'ble Supreme Court . He stated that the Ministry of Environment and Forest,
Union of India had moved an Interim Application No. 16/2004 in Writ Petition No.
657/95, (a Public interest litigation filed by Research Foundation for Science,
Technology and Natural Resource Policy) praying for an order by the honorable Supreme
Court that no High court/ authority will take cognizance or entertain any challenge
connected with the implementation of its order dated 14.10.2003.
The Supreme Court in its order dated 14.10.03 requires closure of all Industrial
units generating hazardous wastes, operating in violation of the Hazardous Wastes
(Management & Control) Rules, 1989. Directions have also been issued to take actions
against the units running in violation of Environmental Laws such as Air (Prevention and
Control of Pollution)Act 1981, Water(Prevention and Control of Pollution)Act 1974,
Environment Protection Act etc,.
The Union of India in the application filed before the Hon'ble Supreme Court
stated that in compliance with the orders passed by the Supreme Court, when the State
Pollution Control Boards (PCB) take actions against the industrial units at the instance of
the SCMC, the aggrieved units approach the High Courts resulting in delay as well as
violation and non-compliance of the order of the Supreme Court dated 14.10.2003.
Instances of such interference by Kerala High Court and Gujarath High Court were cited
as examples for causing delay in implementing the Supreme Court directions.
The Union of India therefore prayed that the Hon'ble Supreme Court may pass an
order so that the industrial units aggrieved by the order passed by PCBs in
implementation of the Supreme Court Order dated 14.10.03 should approach only the
Supreme Court and no High Court or Authority shall take cognizance or entertain any
challenge connected with the implementation of the order of Supreme Court dated
14.10.2003.
The Hon'ble Supreme Court in the above application filed by the Ministry of
Environment and Forest, Union of India, passed the following order on 09.05.2005.
775
“Having heard learned counsel and perused the records we direct that
no court or authority shall take cognizance or entertain any challenge
connected with the implementation of the order passed by this Court
on 14.10.2003”.
In view of the above order the committee resolved that the order of the Supreme Court
dated 9-5-05 should be brought to the notice of Hon'ble High Court by way of an
affidavit and petition producing the order of the Supreme Court in all the cases pending
and in fresh matters coming for admissions challenging the order of the Board issued
pursuant to the recommendations of the LAEC/SCMC . The Board is requested to
instruct the counsel to do the same promptly and get vacated the interim orders securing
the dismissal of the pending Writ petitions .
Resolution No. 2
The committee further resolved to request the Pollution Control Board to
instruct its Standing Counsel in the High Court to furnish all details of the
writ petitions challenging the orders of the Pollution Control Board which has
direct bearing with the implementation of the order of the Supreme Court
dated 14-10-2003 in relation to Eloor –Edayar area to LAEC and the Court
before which the matter is reaching for admission /hearing with a copy of the
writ petition / petitions so filed. This is necessary for LAEC to follow up and
keep track of the developments in the case.
Resolution No. 3
It is resolved to address complaint against the JNM Lakshmi Hospital and the
Dr. K.V. Nair, Medical Superintendent for taking action in pursuance to the
enquiry report on the fugitive emission from Merchem Ltd Eloor on 13-32005.
57th meeting held on 26-05-2005, Thursday at 5.15 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
Resolved to hold a meeting of Bone meal units in Eloor -Edayar industrial belt
to discuss the problem of air pollution from their unit. And to give directions
to implement regulatory measures to content air pollution which is primarily
on account of extracting tallow from bones and keeping raw bones in open
space. Mr.Jayathilakan Hon'ble member of LAEC will make a study and
suggest measures that can be placed for consideration of the Bone meal
units to content pollution. Mr.Farook Sait convenor LAEC will also join
Mr.Jayathilakan and will prepare a write up containing measures to the
committee for discussion before these suggestions are finally put to the
units.
776
Meeting would be held on at 1st June 2005 at 5 pm .at LAEC office.
Notice will be sent to the units tomorrow itself.
Resolution No.2
Chairman placed before the committee a copy of the letter marked to him by
the Edayar Small Scale Industries Association .The letter is addressed to
LAEC member Mr Asokan informing that his membership from the
association has been cancelled with immediate effect.
LAEC member, Mr Asokan was asked to give a brief statement of the
allegations against him that led to the passing of the resolution by the
general body. According to Mr Asokan the allegation against him is that he
passed wrong information about 3 - 4 small scale industries for being closed
and that he is instrumental in protecting big industries. The letter marked to
the chairman also states that there are complaints against him for continuing
in LAEC as a nominated member of ESSIA.
Since the deliberation at the meeting pertained to Mr.Asokan, he abstained
from the meeting while this matter was being further discussed.
The committee unanimously expressed its full confidence and faith in Mr Asokan’s
untiring efforts to contain pollution in Eloor-Edayar industrial belt causing less
discomfort to the industries including the one he represents. He has been always acting
without fear and favour in the committee, upholding the objects of the committee. As a
fearless person, without any favour or bias towards or against anyone, Mr. Asokan has
served LAEC with absolute integrity. This might have offended some of his association
members who have considered the LAEC a sore in their eye.
The genealogy of the controversy can be traced thus. Mr. Asokan’s term as Secretary of
the Association ended on 26/04/05. Even before handing over the charge the newly
elected body under the chairmanship of Mr George (who is the Managing Director of
Merchem Ltd Edayar, a sister concern of Merchem Ltd Eloor- a unit which was closed
down under the recommendation of LAEC) met on 27-4-05 ie. the very next day of its
election, passed a resolution withdrawing his nomination from LAEC.
LAEC objected to the withdrawal stating that prior consent must be obtained from
SCMC. The association did not approach the SCMC with any serious misconduct
justifying withdrawal of his nomination to LAEC that bring disrepute to the association
or any charge acting against the proclaimed object of the association. The only charge
against him is that he failed to protect the erring units, who are members of his
association. The charge against him that he was instrumented for closure for 3 - 4 small
scale units is absolutely baseless and most unfortunate.
777
LAEC does not function on the opinion of one or two members. It deliberates issues and
considers each issues on its merit. A common consensus is evolved after thorough
deliberations. Each and every member in the LAEC has therefore plays a constructive
role which perhaps may be offending some stakeholders who may be reluctant to respond
to changes.
It is most disheartening that a responsible organization like Edayar Small
Scale Industries Association is victimizing one of its founder member for
acting impartially in LAEC. This conduct demonstrates the association short
sightedness and lack of environmental commitments .
LAEC therefore resolved to disapprove the victimization of its member, Mr. Asokan by
the ESSIA. Keeping in view of Mr. Asokan’s contribution and constructive role being
played by him and also in the interest of ensuring continuity of the monitoring task, it is
necessary for Mr. Asokan to continue to be a member of the LAEC. The Committee
therefore, unanimously requests SCMC to permit Mr Asokan to continue as a member of
LAEC and any request to re-nominate another person as a representative of association
be rejected.
It is pertinent to mention that the ESSIA has already approached the Hon’ble High Court
challenging the continuance of Mr. Asokan in the LAEC.
Resolution No.3
Resolved to have a meeting with tannery units on 28-5-05 at 9.30 am
58th meeting held on 28-05-2005, Saturday at 9.30 am at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
Resolved to inspect TMS leathers to ascertain the efficiency of the chromium recovery
plant newly established by the unit. The unit propose to have a roofing before monsoon.
It is proposed that roofing would be complete with in 10 days. Unit was represented by
Mr.TM Shajahan. (TMS).
Cochin Leathers represented by Mr.T.S.Viswanathan submitted a representation that he
has completed almost all the directions issued to him in the show cause notice issued
after the visit of LAEC and that he would submit detailed work plan stage by stage
regarding the establishment of chromium recovery plant or in alternative the setting up of
temporary storage facility to store hazardous waste in dry form. The unit was cautioned
that the necessary arrangement for the treatment and disposal of hazardous waste
generated from the unit with in a short time should be made failing which action
including closure will follow.
778
Kairali leather represented by Mr.Joseph Joseph submitted that he propose to dispose
off the sludge containing Chromium by sending to Pondichery and that he has sludge
containing chromium upto 10 tonnes only per year. The unit was called that either the
unit must have chromium recovery plant or temporary hazardous waste storage facility
which should be setup shortly. The unit requested time upto 4–6-05 to submit a work
plan for regulating the hazardous waste generated by the unit. The committee has
granted time to the units namely M/s Kairali Leather and M/s Cochin Leather for setting
up adequate treatment and storage facility or to set up ETP for recovering Chromium.
The span and conditions will be decided after the receipt of work plan by the units.
59th meeting held on 30-05-2005, Monday at 5.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
Discussed the reports of Indo German Carbons Ltd.Edayar, Sterling Industrial
Chemicals and Allied Industries Pvt.Ltd, Edayar, Premium Ferro Alloys Ltd,
Edayar and approved the draft .
60th meeting held on 01-06-2005, Wednesday at 5 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
A surprise inspection of Merchem Ltd Eloor was conducted by the members of LAEC
along with the official of PCB. The inspection was conducted based on the information
received from a local person that he saw green coloured effluent being pumped through a
flexible hose to the open land near the newly setup hazardous waste storage place.
The members who inspected the unit found the bushes in the open yard being completely
dried in patches. These patches contain black colour effluent. There was a small pit in
that open land where black coloured liquid found in small quantity. Samples is taken
from the said pit. Similar and identical phenomenon was seen on the back side of the
canteen building. Sample from that area was also collected. The members could seen
green colour raw effluent stored in tank A. Sample from this effluent is also taken for
analysis.
The inspecting team questioned Miss. Prasanna who was deputed by the PCB for
monitoring the Unit. She could not explanation as to why the discharge of effluent into
open land was not informed to the PCB.
It is rather disappointed to note that the persons deputed for monitoring the Unit is totally
ineffective and even the PCB was not informed about the happenings in the Unit. LAEC
779
have to depend outside sources for correct information on the activities happening inside
the unit.
The Unit has claimed Zero discharge during the last visit of LAEC along with members
of PCB and Dr.Sharma representing CPCB. The success and failure of the evaporator
system is yet to be ascertained . It is reliably understood that the entire raw effluent is not
being taken to evaporator for treatment. Raw effluent is being discharged into the open
ground.
The samples collected from the premises has to be analyzed in the central laboratory and
in the event of report of the samples taken from the land matching with the raw effluent
sample taken from Tank A , the unit should ask to explain why raw effluent has been
dumped in open land. The raw effluent contain hazardous waste which could be removed
only by proper treatment. Dumping hazardous waste in open land is an activity which
cannot be permitted at any cost.
The committee adjourned deliberation on this matter further for getting the Lab report of
the Samples.
Resolution No. 2
Various Bone meal industries attended today’s meeting which was called to discuss the
problem relating to their Units. Chairman, LAEC have unequally told the units that the
Units cannot be allowed to function in the manner as it is now being done and that which
ever unit fail to content air pollution will be closed. The industries collectively requested
for time to implement certain measures to control the odour nuisance . The Units have
undertaken to give a proposal by 4-6-2005. This matter will be further discussed after
receipt of their Proposal .
61st meeting held on 02-06-2005, Thursday at 3.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
The committee discussed the various action taken by Minar Chemical Industries pursuant
to the closure order issued by the Pollution Control Board as a follow up of
recommendation made by LAEC. The concealed discharge pipe laid by the Unit has
been removed . The unit also claims to have informed the Board that they do not intend to
manufacture precipitated Silica in the unit. The Unit has also reported that they have
already written to the Pollution Control Board to delete the precipitated silica from the
list of products manufacturing by them. In the circumstances the committee, having
regard to the various steps taken by the Unit, resolved to recommend to the board to
withdraw the order of closure after satisfying itself about the improvements made by the
unit to contain pollution. The unit being under closure order, it is expected that the Board
780
will ensure speedy action to close the file and permit the unit to function in accordance
with the law.
62nd meeting held on 03-06-2005, Friday at 3.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No. 1
The Committee discussed the problem relating to the dumping of hazardous waste to
Kuzhikandam Thodu by various companies like FACT, HIL, Merchem etc. The
deliberation focused on the concern of the committee that how the companies could be
stopped discharging untreated effluent into kuzhikandam thodu by an effective
monitoring.
Kuzhikandam thodu is a public thodu, through which old companies like FACT and HIL
have been discharging trade effluent. In the meanwhile, Merchem Ltd., started, which is
the recent unit among all the industries discharging effluent into Kuzhikandam thodu.
With the operation of Merchem Ltd., the complaint from the public got accelerated
against the discharge of untreated effluent into Kuzhikandam thodu. This was more
because of the toxic & piercing nature of the odour of the effluent from Merchem.
The premises of Merchem Ltd. situate adjacent to kuzhikandam thodu, which is on its
southern boundary. Of the two sides of the thodu, one side is having the compound wall
of HIL. The other side remains open without any compound wall separating the
kuzhikandam thodu and Merchem premises. However, on the western side of Merchem
boundary, the Unit has constructed a wall across the thodu thereby preventing access to
that portion of kuzhikandam thodu, which is on the southern boundary of Merchem Ltd.
By constructing this wall, both public and the Pollution Control Board have lost direct
access to kuzhikandam thodu and to enable the PCB to take samples from different points
of kuzhikandam thodu situate on the southern boundary of Merchem Ltd, without
entering the compound of Merchem Ltd. This has helped this Unit to go scot free and
perpetuate their illegal activity from the sight of public as well as regulatory agencies.
The complaint of the public regarding the construction of wall blocking their access to
the kuzhikandam thodu remains unattended despite various instances of dumping of raw
effluent containing hazardous waste being noticed by the Board. In order to have an
effective monitoring of the thodu and protect it from dumping hazardous waste for the
future, the Committee is of the opinion that Merchem Ltd., Eloor should be directed to
forthwith demolish the wall constructed across the kuzhikandam thodu in its western
boundary and allow access to the public and regulatory agencies for inspection of the
thodu flowing on the southern side of Merchem Ltd. The access to the thodu all along
its full length is necessary for removing the hazardous waste already dumped by various
units and for its remediation. The Board therefore, should issue orders for demolition of
the wall constructed across the kuzhikandam thodu within a period of one week, failing
which the Board shall demolish it and the cost of which will be recovered from the
781
Company. The action taken to be reported to the SCMC, with a copy to LAEC
immediately thereafter.
Resolution no. 2
The discharge of untreated trade effluent by FACT to Kuzhikandam thodu at its starting
ie., on the eastern boundary of Merchem Ltd. The thodu is flowing towards west along
the southern boundary of Merchem. Kuzhikandom thodu is a public thodu. Of the one
side of this public thodu, HIL has constructed a compound wall. On the other side of the
thodu which is the property of Merchem Ltd is left open. The trade effluent from FACT
reaches Kuzhikandom thodu from the compound of HIL. The trade effluent of HIL and
FACT gets mixed somewhere in the middle point of the drain inside the HIL compound.
This drain flows towards Kuzhikandam thodu. The trade effluent of Merchem Ltd., Eloor
also joins at Kuzhikandam thodu at the eastern boundary of Merchem Ltd. The effluent
of these industries further run towards west and reaches Unthithodu. The three industries,
which discharges effluent to Kuzhikandam thodu are chemical industries of which one is
manufacturing pesticides.
The chemical reaction of the trade effluent joining Kuzhikandom thodu causes often
colour changes. Taking advantage of this confluence of effluents at Kuzhikandam thodu
in southern boundary of Merchem Ltd., the companies could easily disown their illegal
activity by laying blame on each other. The confluence of effluent has resulted in the
effluents from various companies losing its separate identity. It has therefore become
difficult to identify the role of each company in polluting Kuzhikandom thodu.
The committee found on its inspection, the discharge of point of HIL at kuzhikandom
thodu . In fact under the consent order, the point of discharge of treated effluent for HIL
is at Unthithodu. The discharge of effluent by HIL to Kuzhaikandam thodu is thus illegal
and unauthorised. HIL should therefore be directed to shift its discharge point to
Unthitodu forthwith.
The trade effluent of FACT is being allowed to be taken across the premises of HIL for
its discharge to Kuzhikandom thodu. However on inspection it is found that the trade
effluent of FACT converge with the effluent of HIL somewhere in the middle of the drain
inside HIL premises and from there both the mixed effluent flows to kuzhikandom thodu.
This practice is totally unapproved and unacceptable. The trade effluent of one industry
should not be allowed to get mixed with the trade effluent of another thereby losing its
separate identity and making it impossible to collect samples. The trade effluent of the
FACT which is allowed to be taken through the premises of HIL should not be allowed
to be mixed with the trade effluent of HIL till the point of its discharge at Kuzhikandom
thodu. Both FACT and HIL should see to it that separate pipeline / drainage is provided
for their respective trade effluents to reach kuzhikandam thodu and unthithodu
respectively, which is the authorized point of discharge. Pollution Control Board shall
issue appropriate direction to these respective companies and the illegal activity as
mentioned aforesaid shall be brought to halt forthwith.
782
Resolution no. 3
The meeting also finalized the report of the following units:
a. AES Industries
b. Cochin Fertilisers
c. Neptune Readymix Concrete (P) Ltd.
63rd meeting held on 04-06-2005, Saturday at 5.00 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution no. 1
The following bone meal units are operating in the Eloor – Edayar industrial belt:
1.
2.
3.
4.
5.
6.
7.
Sigma Fertilisers
Yeoman Bone and Alied Products
Nelkadir Bone Industries
Kaveri Bone Industries
National Industries
AES Industries
Cochin Fertilisers
On inspection of these units, the scene was very horrifying. The inspection team could
not go near to these units due to unbearable foul smell caused by the decay of bone /
flesh. The officers of the PCB accompanying the team and one of our member, Mr.
Jayathilakan some how managed to enter into all these units and found accumulation of
worms and flies inside the units at many places caused by decaying raw material for want
of proper storage and house keeping.
There is a huge backlog of raw bones, collected over a period of 15 days or more lying in
these units without proper confined storage. This heap of raw bones is causing health
hazards and great odour nuisance in the entire area giving rise to consistent complaints
from the adjacent units / local community.
The nuisance from these units have to be taken serious note of. It is being caused on
account of their failure to de-grease and process the raw bones on the same day of its
arrival. The de-greasing process takes place not on first come first basis. The consent
conditions though stipulates that the raw bones brought to the Units should be processed
on the same day itself, it has been found observed in breach. The violation of this consent
condition makes the ambient air unfit for human habitation.
In order to ensure the compliance of the condition in the Consent such as de-greasing and
processing of the raw bones on the same day of its arrival and to avoid odour nuisance
caused by these units, it is necessary to have a stringent measure requiring the units to
783
provide a Bank Guarantee (within 7 days) ranging from Rs. 2.00 – Rs. 5.00 lacs
depending on the size / turnover of the Units for strict compliance of consent conditions
imposed to control odour nuisance within one month’s time. The Bank Guarantee shall
be forfeited, if the Unit is found violating the consent conditions.
This recommendation is made in the light of the suggestions made to LAEC by the
Supreme Court Monitoring Committee (SCMC) for ensuring compliance of
environmental laws by the Units found to be violating the same with impunity.
Resolution No. 2
Committee unanimously endorsed the Report on Human Resources & Infrastructure
issues in the KSPCB.
Resolution No.3.
The committee resolved to depute Mr.Jacob.v. Lazar, Mr.Purushan Eloor and
Mr. M.Asokan to attend the meeting organized by the Pollution Control Board on the eve
of World Environment day celebrations. Dr.Claude Alvaris, Member , Supreme Court
Monitoring Committee may be invited to Kochi for attending the meeting convened to
discuss the problem of Bone meal units on 6-6-05.
64th meeting held on 06-06-2005, Monday at 11.30 am at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution no. 1
This meeting is being convened to discuss the odour nuisance of Bone meal units in
Eloor-Edayar belt. Dr.Claude Alvaris , Member ,Supreme Court Monitoring Committee
was the special invitee. Chairman, Adv.P.K.Ibrahim welcomed the Chief guest Dr.Claude
Alvaris . He briefed about the various steps taken by LAEC and emphasized the need for
proper guidance to various Bone meal units to transform them as a model for such
industries elsewhere.
Dr.Claude Alvaris stressed the need for modernizing the bone meal units in the context of
changes taking in all fields of human activity . He promised all assistance including
expert advise to the units ready for change. He stressed the need to arrest the odour
nuisance within the outer limit of three months failing which he cautioned that the
defaulting units will have to face closure order.
The Bone meal units agreed to bear the expenses for getting the assistance from expert
and requested LAEC to take initiative for arranging experts for technical advice.
784
65th meeting held on 10-06-2005, Friday at 5.30 p.m at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
The committee discussed the lab report of the samples taken from Merchem Ltd, Eloor
on 01.06.2005. The samples taken from the pit near Hazardous Storage Place, from the
rear side of Canteen, Polishing pond (the tank to store treated effluent) and of Raw
Effluent Tank A, show the parameters of BOD,COD,SS,TDS,Iron,Chlorides, Sulphate
etc all beyond the tolerable limits. Lab Report is attached.
According to the reliable source of information, the unit is not taking the entire trade
effluent into evaporator for treatment. It takes raw effluent in to the polishing tank and
under the guise of reusing the treated effluent of the polishing tank; the effluent from the
polishing tank is discharged into the open land. The zero discharge clamed by the unit is
thus made a mockery. The lab reports of the sample collected from pit and polishing
tanks substantiate this information.
It may be recalled that the unit was issued with a closure order after having caught redhanded for discharging untreated effluent into Kuzhikandom thodu by deceptive
operation of effluent treatment system. Right from the trial of the company, there is
complaint from public against the unit for discharging untreated effluent. The unit has
successfully managed to overcome all the action against it by taking some actions to
make it appear that it has rectified irregularities. All such measures taken by the unit has
been proved without any earnestness. There is total lack of bonafides.
The claim of zero discharge has now relieved the company from obtaining consent under
the Water (Prevention and Control of Pollution) Act 1974. The company is now
discharging a major quantity of raw effluent into the open land maintaining the effluent
treatment system for zero discharge for a minimum quantity of effluent only so as to
make it appear that the company is observing zero discharge .The officer deputed in the
company for monitoring by the PCB is found to be ineffective.
The new system introduced by the company needs to be closely monitored continuously
round the clock at least for two months. By such monitoring alone, one can assess the
total physical quantity of the product, the total quantity of the effluent generated each
day, the total capacity of the Effluent treatment system of zero discharge and the total
quantity of sludge generated each day in order to assess whether the Zero discharge
system is functional and financially feasible so as to avoid clandestine discharge of
untreated effluents.
To undertake this exercise, one must admit that the PCB has no sufficient staff strength
on its roll. LAEC is of the opinion that 6 persons (at the rate of 2 persons per 8 hours)
have to be engaged for supervising and monitoring the unit for two months under its
785
supervision. This should be in addition to the monitoring of the Board. Appropriate order
can be issued in the light of the monitoring report of this unit by LAEC.
The company, having adopted ETP of zero discharge as claimed by it, simultaneously
should be asked to execute a bank guarantee of Rs 10 lakhs for being forfeited in the
event of resorting to any illegal discharge of untreated effluent into open land. It appears
that companies claiming zero discharge resort to discharge of raw effluent with impunity.
The instances of M/s.Sree Sakthi Paper Mills and Merchem Ltd. are pointer to this fact.
From the experience of LAEC, it is felt that companies claiming zero discharge must be
bound by bank guarantee for observing zero discharge failing which they will make the
regulatory machinery a mockery.
LAEC requests for immediate action against Merchem Ltd, Eloor taking into account the
track record of this unit.
Source : Merchem,Eloor.
Date of sample collection: 1-6-05; Ref. No. LAEC/CL/05
Date of Sample Report : 10-6-05.
Sample No: LAEC 195(Premises near the TSDF (discharge on grass)),LAEC 196(Drain
from FACT and IRE inside merchem compound),LAEC 197(Polishing pond),LAEC
198(Raw tank No.A),LAEC 199(Effluent near canteen outlet.),
Name of the Lab : Central Laboratory, Gandhi Nagar.
Sl.
No.
1
2
3
4
5
6
7
8
9
10
11
12
Determinant
pH
BOD
COD
SS
TDS
Zinc
Iron
Chlorides
Sulphates
Manganese
Phenolic Compounds
Colour
Unit
mg/l
hazen
LAEC
195
6.5
90
960
977
9872
ND
174
300
4000
165
1.2
640
Value
Sample No.
LAEC LAEC LAEC
196
197
198
5.6
9.3
12.8
12
108
568
96
1232
7120
196
132
664
792
1896
9970
ND
ND
ND
11.8
1.4
18.7
140
120
1400
550
750
700
39
ND
ND
ND
2.3
2.5
20
40
3200
LAEC
199
8.6
198
2400
825
4690
ND
42.6
2000
450
ND
1.5
2000
786
Resolution No.2
Resolved to approve the reports of the following Units.
1.
2.
3.
4.
5.
6.
Periyar Polymer Products, Edayar
Neelima Chemicals, Edayar
SS Chemicals, Edayar.
Milton Rubbers, Edayar
Mark Rubber Products, Edayar
Mark Polymers, Edayar.
7. Mark Pre-treads, Edayar
8. Chemi tech Engineers
66th meeting held on 14-06-2005, Tuesday at 7.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
Resolved to approve the report on Merchem Ltd, Eloor.
67th meeting held on 16-06-2005, Thursday at 6.45 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
The LAEC members Mr. Asokan and Mr. Purushan Eloor along with the officials of
Pollution Control Board Smt.Chitrakumarri.D,EE, Mr.K.S.Soman. AEE, Mr.Shanvas,
AES, and Mr.Baburaj .P.K, AEE and Smt.Vandana Babu, AE inspected M/s Sree Sakthi
Paper Mills on 9-6-2005.
During the inspection the team found a person pumping hot raw effluent into the pits
seen dugged in its premises. The ETP was not functional. The untreated effluent was
pumped using flexible hose. Simultaneously, through different PVC pipeline effluent was
being discharged in to the open land from where it flowed through a concealed pipe into
the drain of a public road ultimately reaching in Periyar.
The pumping was abruptly stopped seeing the inspecting team. The scene was
photographed for recording the state of affair noted by the team. The inspecting team has
collected samples from various pits and is given for lab analysis. The report is awaited.
The inspecting team prepared a mahazar of the scene noted by them at the time of
787
inspection that is signed by the Works Manager of the unit Mr.Jayakumar. The
incinerator found in the unit is totally inadequate and seems to be not complying the
norms of the PCB. The house keeping is thoroughly poor. Paper pulp is seen scattered
everywhere, inhibiting one to walk through. The concealed PVC pipes laid across the
premises which is said to be for draining storm water is suspicious. . It is believed that
these pipeline is used for discharging trade effluent.
The unit is not having consent under Water(Prevention and Control of Pollution)Act 1974
. The boiler ash is kept openly and is likely to carry by the wind or through water .
It may be recalled that in the previous two inspections by the LAEC in this unit on 22-112004 and 17-4-2005, the unit was found indulging in the similar illegal activity and the
unit was warned with dire consequences if such activity is found repeated.
Sree Sakthi Paper mill is a unit that claims to have zero discharge effluent treatment
system. Under the pretext of the said claim the unit has not obtained any consent under
the Water (Prevention and Control of Pollution)Act 1974.The unit has forfeited the
confidence of the committee for the reason of having violated its promises made at the
time of detecting such illegal activity.
The unit is a medium scale industry. It consumes huge quantity of water. The effluent is
also in huge quantities. The
Effluent treatment system that claims to attain zero
discharge is found not operating at all occasions of LAEC’s inspection. By discharging
untreated effluent, the unit has violated Environmental Protection Act and Water
(Prevention and Control of Pollution) Act 1974.
The letter dated 10.06.05 addressed to the chairman, the unit has tacitly
admitted that the zero discharge system of the unit is not functional and the
unit must be given two months time “to eliminate the irregularities” and that
the unit has “appointed a consultant namely M/s. Enviro cum Laboratories,
Kalamassery”. And that “they are preparing a detailed scheme to overcome
the irregularities noted I the zero discharge system and to make the same
more effective”.
Having regard to the repeated instances of illegal discharges by the unit and
found violating the provisions of the Environmental Protection Act and the
fact that the unit is not having an adequate system to treat the effluent, the
unit should be directed to bring down its production forthwith and be
permitted to function in a phased manner only subject to following
conditions.
Assess the capacity and efficiency of the ETP now available in the unit
and depending on its efficiency allow the unit to run to take such
quantity of production that generate effluent proportionate to the
capacity of the existing ETP.
The unit should be asked to execute a Bank Guaranty of Rs 5 lakhs
and an undertaking that it shall not discharge untreated effluent in to
the open land.
788
The unit should be directed to make zero discharge system functional
within 45 days.
The unit should be allowed to take full production only after it
establishes effective zero discharge system.
The unit should be asked to furnish bank guarantee of Rs.5 lakhs
which shall be forfeited in the event of illegal discharge after the
operation of ETP of zero discharge.
The unit should install an incinerator conforming the norms of the
Pollution Control Board.
The unit should be directed to dismantle the PVC pipe used for rain
water drainage and asked to provide an open drainage.
The Unit should keep boiler ash in a confined area protecting it from
wind and rain.
The ash generated by the burning of plastic waste in the incinerator
should be removed to secured landfill.
At present the plastic waste are kept in open land near Periyar
without confining to any particular room with a roof, protecting it from
being escaped into the river Periyar .
The Unit has to improve its house keeping.
Green belt not seen provided. The units should be directed to grow
fast growing and long lasting trees all along its boundary.
68th meeting held on 18-06-2005, Saturday at 3.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
LAEC during its surprise inspection at Binani Zinc Ltd on 2nd December 2004 detected
an illegal outlet in the premises of Binani Zinc Ltd. A report of the said inspection was
forwarded to Pollution Control Board recommending the action to be taken against the
said the company. Among the recommendation include direction to dismantle the
illegaloutler provided underground and direction to remove the sludge collected at the
point of outlet and got accumulated in the surrounding land.
The unit has come forward with a sketch and plan of the outlet and has requested for
regularizing the outlet exclusively for discharging rain water. The route of the drain as
seen in the sketch is passing through the side of jerosite pond. The jerosite pond is not
provided with any roof. During rainy season this pond which is like a lagoon may flood
and the supernatant is likely to escape to the land by overflowing .According to the
company the supernatant during rainy season will be discharge only after treatment .
Assessing the capacity of the ETP it is very hard to believe that the entire supernatant in
the jerosite pond could be treated before discharge. Be that as it may the company’s
request for regularizing the outlet as drain water cannot be brushed aside. However while
regularizing the drain as rain water outlet sufficient safeguard must be taken to ensure
789
that the outlet is used for any illegal activity including for the discharge of untreated
effluent and the supernatant from jarosite pond.
The drain provided by the company for rain water discharge has no delay pond .
Therefore there is no mechanism to ascertain whether the water discharged is rain water
or pollutant effluent . The company should therefore be directed to provide a delay pond
of minimum 2.5 metre height to hold the water discharged through the drain. The water
to the delay pond should be discharged through a bend pipe up to the length touching
the bottom of the delay pond
The sewage drain connecting to the drain water drain should also be provided with a
delay pond before it is taken to join the rain water drain at the down stream of the delay
pond of the rain water drain.
The delay pond should be emptied during non-rainy season. Granite rubles may be put up
to 3/4th height of the delay pond. The rainwater drainage shall not be allowed to be used
for discharge of any other effluent.
The company should be directed to execute a bank guarantee of Rs.10,00000/-(10 lacs) to
be forfeited in the event of discharging effluent containing pollutant through the rain
water drain .
Resolution No.2
Resolved to approve the reports of the following industries.
1.
2.
3.
4.
5.
6.
7.
Sterling Industrial Chemicals and Allied Industries Pvt. Ltd, Edayar
Sri Srinivas Roller Flour Mills Pvt. Ltd., Edayar.
Shalimar Polysacks, Edayar.
New Kerala Rubber Udyog. & New Kerala Polymers , Edayar.
Macfield Beverages (India ) Pvt. Ltd
Kunnath Chemicals Pvt Ltd, Edayar.
Kumarsons wire products, Edayar
69th meeting held on 25-06-2005, Saturday at 1.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
The LAEC discussed the modalities for environmental audit to be conducted
at FACT. FACT has three units in the Eloor Area viz., a Complex Fertilizer
Unit, Petrochemical Division and Ammonia Plant
Mr. P.K. Ibrahim, Chairman solicited the views of all the members and after
detailed deliberations it was unanimously resolved as under:
1. Environmental audit at FACT is an onerous task considering the size of
FACT and the complex nature of its operation / production processes.
790
2. Environmental Audit incl. Mass balance at FACT requires assistance of
experts from the fertilizer industry over and above the Panel of Experts
/ officials of PCB assisting the LAEC. It was therefore decided to seek
the assistance of experts from the Fertilizer Association of India (FAI)
or such other institutions / agencies.
3. The cost towards this shall be borne by FACT.
4. LAEC along with the officials of PCB shall initially inspect FACT and
draw out a terms of reference for the external expert from the fertilizer
industry to advise LAEC.
Resolution No.2
It is brought to the notice of LAEC that there is some delay in reaching the
reports of LAEC at all concerned offices of the Pollution Control Board which
cause delay in taking action on the reports. Taking note of this aspect, which
is brought note to the notice of LAEC by the Convenor, the committee
resolved to send copies and the reports to head office and also to Regional
office Ernakulam simultaneously while forwarding the reports to SCMC.
Resolution No.3.
Sigma Fertilizers is a bone meal unit under closure order. This unit may also
be given three months time further to implement pollution control measures
as in the case of other similar units that are permitted to continue its
operation as per the time schedule of the Supreme Court Monitoring
Committee. The committee resolved to recommend to the PCB to keep in
abeyance the closure order till then.
Resolution No.4
Sulfiyath N.P who was appointed as engineering assistant in the office has been relieved
from duty with effect from 31-5-05. In the consequent vacancy the application of Miss.
Prathibha. V.Nair. Who has worked as a graduate apprentice with Pollution Control
Board during 2002-2004 has been considered by the Chairman LAEC. She was asked to
join office with effect from 21st June 2005. Miss. Pratiba. V.Nair.has been appointed on a
consolidated pay of Rs. 4500 per month. Her appointment is purely provisional. The
decision of the Chairman stand endorsed by the committee. Miss. Pratiba. V.Nair shall be
required to attend the office on holidays as and when requested and at times even beyond
office hours depending on the urgency of works.
Resolution No.5
791
Resolved to approve the reports on following Industries.
1. Pazhumadathil paints, Edayar
2. Thamarachalil Polymers,Edayar.
3. Surya Rubbers, Edayar
4. Alwaye Fibre Industries,Edayar
5. Lakshmi Chemical Industries, Edayar.
6. Welcome Enterprises, Edayar.
7. Microtrol Sterilisaton Services Pvt.Ltd, Edayar
8. Eminent Composites Pvt Ltd, Edayar
9. Harisree Technically Specified Block Rubber Pvt. Ltd, Edayar.
10. Cochin chemicals Industries
70th meeting held on 29-06-2005, Wednesday at 6.30 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution no. 1
Mr. Purushan Eloor, Member LAEC reported that an incident of fugitive emission on 266-2005 at Eloor Vadakumbagam where a public sector undertaking namely FACT
Udyogamandal situate. Huge white smoke spread around the area caused severe
discomfort for breathing, throat irritation and vomiting sensation to the residents of
Kanjirakuzhi and its northern area of Eloor Panchayat.
The fugitive emission is believed to be from FACT and, by the description of discomfort
felt to the people, the fugitive emission contained sulphur dioxide and sulphuric acid
mist. The smoke burned even the leaves of the trees. Some residents were treated in the
Primary Health Center, Eloor.
The reported fugitive emission was duly informed at the office of the Pollution Control
Board Ernakulam. LAEC members Mr. Purushan Eloor, Jacob.V.Lazar and official of
Pollution Control Board Mr. K.S.Soman AEE inspected the affected area and took
statements from the residents on the incident. The report of the inspection is read over in
the meeting and is made part of this proceeding.
The committee deliberated on various aspects of the incident and expressed its anxiety on
the lack of arrangements for attending to such incidents, which is part of the
comprehensive chemical disaster management. The committee has been alerted on the
fact that despite Eloor-Edayar industrial belt being an area with number of chemical
industries dealing in hazardous chemicals, a program for chemical disaster management
is indispensable and the same is yet to be evolved.
The district administration, Factories and Boilers and Pollution Control Board should
evolve a scheme for chemical disaster management for Eloor - Edayar and periodical
792
review is to be made. The residents of Eloor –Edayar should also be educated and
necessary training be given.
Committee resolved to approach the district collector and seek his indulgence for
constitution of such a body. Mr. Purushan Eloor and Mr.Asokan are authorized to meet
the collector and to follow up the matter.
Resolution No. 2
Resolved to approve the reports of the following industries.
1.
2.
3.
4.
Valiyaparambath Industries
V. J. Rubber Industries.
Cochin Rubber Complex
Njavallil Latex Pvt. Ltd.
71st meeting held on 30-06-2005, Thursday at 4.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
This meeting was arranged to take stock of the actions taken on various reports of the
committee forwarded to the Board. Chairman Mr. Raj Mohan was a special invitee to the
meeting. Chairman Adv.P.K Ibrahim briefed the inspection conducted by the committee
in bone meal industries and stressed the need for enforcing environment laws on bone
meal industries which cause serious concern to the environment also. Responding to the
briefing Mr. Raj Mohan chairman PCB assured the committee that the Board will stick to
the time frame of the Supreme Court Monitoring Committee and the bone meal industries
on being failed to implement adequate pollution control measures the Board will issue
closure orders.
Chairman Mr. Raj Mohan instructed Convenor Mr. Farook Sait that if the units against
which closure order have been served are still functioning,steps to enforce the order must
be taken immediately.
Regarding the directions to Merchem Ltd Eloor to open the Kuzhikandam thodu to
public by demolishing the compound wall, he stated that as soon as directions from
SCMC in this regard reach the board, the board would promptly act. The chairman also
issued instructions to the Convenor to make the facilities available for resuming air
monitory by LAEC.
The chairman LAEC handed over the compilation of the reports finalized after
SCMC’s visits in may 2005.
72nd meeting held on 9-7-2005, Thursday at 3.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
793
Resolution No.1
LAEC members as part of the stack monitoring inspected FACT, Udyogmandal along
with the officials of PCB viz., Mr. K.S. Soman, Asst. Environmental Engineer; Mr. K.V.
Shanavas, Asst. Scientist on 8th July, 2005 at 12:30 p.m.
The inspecting team before arriving at FACT had received complaints from local people
including industrial workers regarding suffocation, chest congestion etc., as a result of
serious fugitive emission, which was found visible in areas near Sud-Chemie, Binani
Zinc Ltd., Njavallil Latex and other areas in the Edayar industrial belt. A survey
conducted by the inspecting team in these areas revealed that the source of emission is
from FACT, Udyogamandal and people have been suffering such discomforts for the past
few days. It may be recalled that a large scale emission, which caused serious
apprehension in the minds of the people by the fugitive emission happened on
26/06/2005 was taken note of and this Committee had resolved to request PCB for
necessary action against FACT, Udyogamandal, being the culprit of fugitive emission.
Mr. Baburaj, Asst. Environmental Engineer of PCB joined the inspecting team at 1:30
p.m. at FACT, Udyogamandal. FACT, Udyogamandal Acid Plant was inspected by the
team as the concern of the team was to find out the source of SO2 & SO3 (Sulphur
dioxide and sulphur tri-oxide) emission. The FACT claims to have on-line recorder for
stack monitoring. The said system for stack no. 15 (Acid plant) was found to be
operational. The needle of the recorder is found remaining at the maximum point viz.,
1000 ppm, which is equivalent to 2617 mg/nm3 as against the permissible concentration
of 1500 mg/nm3.
The emission through the stack being highly in excess of the permissible limit, which is
even beyond the comprehension of the installed on-line recorder was detected as a
serious lapse causing very grave concern to the environment and local community. The
complaints of the local community and from the nearby industrial community stands
vindicated by the above findings of LAEC. The inspecting team asked the Company to
furnish the statement of on-line recorder for previous 7 days on-line monitoring. The
company refused to provide the same on the plea that they have a Chemical Analysis
Report of Manual analysis of checking concentration of pollutants. The inspecting team
then asked as to how a manual analysis is conducted. The company confessed that the
manual analysis is not done from the stack inspection duct by climbing at the sample
point. According to them, the ladder provided for climbing is rusted and not safe enough
to use the same. The sample is therefore collected from a pipe connected to the duct of
the chimney. When confronted by the LAEC, as to how samples were taken from pipe
can give the pressure of the emission, the company admitted the faulty nature of manual
analysis. The laboratory reports of the manual analysis furnished to the LAEC is thus
found to be unreliable. Despite insisting for the on-line recorder statement, the same has
not been furnished.
794
The company is not having adequate system to control the fugitive emission and even the
system provided for recording the emission is found totally inadequate. The Company
has not provided necessary arrangement even to the regulatory machinery to monitor the
Stack. The provisions of the Air Act and the conditions of the Consent issued to the
Company is thus found violated with impunity.
During the inspection, Mr. Dandapani, Plant Manager was present throughout. After the
inspection, the inspecting team also met Mr. Asokan, General Manager and appraised
him of the situation and the concern of the LAEC.
After the inspection, Chairman, LAEC had a telecon with the General Manager, FACT in
the evening to inform him that any future complaints on fugitive emission from the locals
would be seriously viewed and that the company should immediately arrest the emission
beyond the consent parameters.
Mr. Asokan, General Manager, FACT assured that
necessary precautionary steps will be taken up.
Despite these warnings, the Company could not control fugitive emission and as a result
at around 10:30 p.m., Chairman, LAEC was informed by members of LAEC, Mr. Asokan
and Mr. Jacob Lazer that they are patrolling in Eloor / Edayar belt on information that
there is huge smoke in the entire area and some unit is on fire. The workers in the
industrial belt was found panicky. LAEC members, surveilled the entire area and found 3
fire force engines, police force and the Eloor Panchayath President, Smt. Subaida Hamsa
were all moving in the Industrial area to identify the source of wide spread white smoke.
LAEC members, local community and industrial workers felt suffocation. The major
source of this emission was ultimately found to be from FACT, Udyogamandal.
In the above circumstances, LAEC resolved to recommend that the operation of the Acid
Plant of FACT, Udyogamandal be directed to stop production forthwith and be allowed
to re-start production only after ensuring that the Unit makes adequate and fool-proof
pollution control measures to the satisfaction of LAEC and PCB.
Emergency meeting held on 10-7-2005, Thursday at 3.00 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution No:- 2 1 or 2
The reports of the following Units were approved by the LAEC:
1.
2.
3.
4.
5.
6.
Pananghat Polymer Packaging Pvt. Ltd.
Millennium Poly Packs & Processors Pvt. Ltd, Edayar
Periyar Polyfilms, Edayar
Periyar Plastics, Edayar
Unipack India Pvt. Ltd., Edayar
Silver Stream Polymers
795
7. Al Arafa Plastics
8. Vinayaka Industries
9. Gijas Rubbers, Edayar
10. Transel Wires
11. SM Industries
12. Alwaye Smithy Workshop
13. Simla Wood Industries, Edayar
14. Ajit Carbons & Pigments Ltd
15. Jonarin Chemicals
16. Travancore Ammonia Pvt. Ltd
17. Manchester Chemicals, Edayar
18. Manswill Chemicals Pvt. Ltd.
19. Galilea Chemicals
20. Solvay Chemicals.
73rd meeting held on 11-07-2005, Monday at 6.00 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Chairman invited the attention of the members to the news item appeared in the Hindu
under the caption “PCB fails to trace source smoke at Eloor, Edayar” and expressed his
unhappiness and disapproval over the contents of the news item published. He also
informed the committee that Ms.Chithra Kumari Environmental Engineer, PCB raised
her concern over the said news. Appreciating the concern of the PCB officials deputed to
LAEC the Chairman assured her that he would speak to the correspondent. He disowned
any responsibility for the offending news item. Chairman told that the press release of
LAEC appeared on the same page and is the true version of the LAEC which is in
conformity with the resolution passed.
The resolution of LAEC has not made any observation or found fault with PCB much
less accusing them for failure to detect source of smoke at Eloor. The chairman called the
correspondent Mr. G. Krishna Kumar of the Hindu newspaper over phone and expressed
his displeasure. Chairman also told the correspondent that such news item will only strain
the relationship of LAEC with PCB and that will not promote any public interest. He
requested the correspondent to be careful in future. Mr. G. Krishna Kumar expressed his
regret and explained that the caption was done at the desk and that he only authored the
news regarding the past events, which reflected in the proceedings of LAEC. However, as
regards certain portions in the news (those do not form part of LAEC proceedings), Mr.
Krishna Kumar did not divulge the source.
The committee appreciated the suo motu and the timely action taken by the Chairman of
LAEC on such a sensitive issue
796
Resolution No: 1
The Committee being concerned about the frequent incidents of fugitive emission in
Eloor, Edayar belt and considering the practical difficulty of undertaking stack
monitoring for want of proper maintenance of sampling facilities by the Companies, the
Committee decided to request PCB to move the Mobile Ambient Air Monitoring system
to Eloor, Edayar Area. It is noted with great pain that this mobile unit has not been fully
utilized in spite of huge investments being made for procuring the unit.
Mr. Farook Sait, Convenor, brought to the notice of the Committee that the unit requires
calibration and that there is no Annual Maintenance Contract existing. Annual
Maintenance Contract has also to be made for ensuring uninterrupted working of the
equipment. According to him, the maintenance of the vehicle is very costly.
LAEC applied its mind to the various aspects raised by the Convenor. Though, the
problems raised by him are genuine it is not un-resolvable. The cost of Ambient Air
Monitoring can be met from the factories, who have failed to make adequate
arrangements for stack monitoring by the PCB and have failed to adhere to the
parameters under the consent orders. The Board shall raise the necessary funds from the
Units having stacks, which are found to be causing environmental pollution.
In any case, PCB being a regulatory body to monitor the industries cannot be justified
for their inaction on the plea of lack of funds. It is to be noted that the system is capable
to monitor Sulphor dioxide (SO2 ) Hydrogen sulphide (H2S), Carbon monoxide (CO),
Hydrocarbons, Methane, Particulate matter, Mercaptans etc. In fact these are all the
common gases / substances found in the ambient air in the area, raising significant
complaints from the public.
In the above circumstances, LAEC resolved to recommend to the PCB to make the
Mobile Ambient Air Monitoring System fully functional and may be taken to Eloor,
Edayar for ambient air monitoring without further delay.
Resolution No. 2
The Committee place it on record its appreciation for the work done by Mr. Purushan
Eloor, Member, LAEC and Mr. K.V. Shanavas, Asst. Scientist, who have followed up to
the application for the allotment of land to establish a permanent River Monitoring
Station at Eloor Ferry. They have reported to LAEC that an area of 11.250 cents of land
has been earmarked in Eloor Ferry and the concerned Tahsildar & Village Officer have
submitted their recommendations for the assignment of this land in favour of PCB. The
process is now almost in the final stage. What remains is only an order from the District
Collector considering the recommendations of the Tahsildar & Village Officer for
allotment of the said land in favour of PCB. A letter addressed to the District Collector
797
enclosing copies of the recommendations of the Village officer & Tahsildar may be sent
and the Committee shall meet the District collector for the said purpose at the earliest.
The Committee also resolved to appraise the Collector for the constitution of the
Comprehensive Chemical Disaster Management Plan as mandated under the Chemical
Accidents (Emergency Planning, Preparedness & Response) Rules, 1996.
Resolution no. 3
Inspection at FACT, Udyogamandal, Petrochemical Division & Ammonia Plant, which is
pending, has to be expedited. Committee felt that during the inspection of the above
units, it is necessary to involve the Inspector of Factories & Boilers, apart from the PCB
officials from the Regional Office in addition to the other officials of PCB deputed to
LAEC. A letter to this effect shall be sent to concerned department and seek their
participation on the inspection scheduled to begin from 16th July 2005.
Resolution no. 4
On the matter of providing water to the affected community in Eloor Panchayat viz.,
Ward nos. 1, 2, 3, 4 & 17, the Committee resolved to constitute a sub-committee
comprising Mr. Purushan Eloor and Mr. Asokan to conduct a survey of these wards and
prepare a list of affected community, for whom the drinking water is to be provided by
the defaulting companies.
The sub-committee shall engage a maximum of 10 persons ie, 2 nos per ward to collect
datas specified in the Proforma. The sub-committee shall prepare a Proforma and submit
before the LAEC in the next meeting for approval. The sub-committee shall also
undertake random sampling of well water in these areas to assess the impact of
contamination. The entire survey will be completed on or before 25th July 2005. On
obtaining the survey report of the sub-committee, LAEC shall hold a meeting of the
defaulting companies and discuss with them the modalities for providing water under the
supervision of PCB, as per directions of SCMC in the matter.
Resolution no. 5
Mr. G. Anand, Member of LAEC will make all arrangements including resource persons
to conduct a pilot cleaning process of Kuzhikandam Thodu to assess the various impact
before undertaking the restoration of Kuzhikandam Thodu. He will identify the expert in
the field and report to the committee at its next meeting. On receipt of Mr. Anand’s
report, the committee shall place it before the Chairman,PCB for appropriate action,
including arrangements for their inspection.
798
Resolution no. 6
Chairman, LAEC brought to the notice of the committee members the order
issued by the Chairman, PCB that the Board has decided not to allow any
new bone meal units in Ernakulam district. The Committee also feels that
the decision is in the right direction, having regard to the environmental
damage that is being caused by the present units who failed to implement
pollution control measure.
Resolution no. 7
Resolved to approve the following reports:
1. TMV Natural Oils & Extracts Pvt. Ltd.
2. Nini Crepe Mills
Resolution no. 8
Chairman, LAEC sought endorsement of the committee appointing Ms.Thanu Mol K.A.
as Administrative Officer in the vacancy of Mr. Josemon, who got relieved from this
office from 30th June 2005. Ms. Thanu Mol K.A. joined office by the order of the
Chairman from 27th June 2005 onwards. An amount of Rs. 5,000/- per month has been
fixed as honorarium for the service of Ms. Thanu Mol K.A.
74th meeting held on 15-07-2005, Friday at 3 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No.1
Resolved to pass the following reports
1. M/s Shepherd Plastic Extrusion Pvt. Ltd.
2. M/s Bright Pigments.
3. M/s Joyce welfare Mahila Samajam (New Jyothi Foods).
4. Navin Engineering Industries.
5. GEM Enterprises.
6. W-Electro Chemicals
7. Thachavallath Industries.
8. Abin Granites
9. Thottakkattu Distilleries
10. Parur Powerloom Co-op Society Ltd.
11. Barath Polymers.
12. Spectrum Regulates and Chemicals.
13. Payyappillys Glossy granites.
799
14. Classic.
15. D.L. Engineering.
16.Jagadamba Containers.
Resolution No. 2
The committee deliberated the draft inspection reports Power Controls Edayar. The unit
is found to be violating many environmental laws. The lab report is shocking. Having
regard to the seriousness of the pollution from this units, the committee decides to call the
occupier of the industry in to the meeting of LAEC for a personal hearing .The chairman
LAEC talked to Mr. Joseph the occupier of the unit over phone and he is being asked to
appear before the committee with all relevant records including lab reports if any
tomorrow at 3pm ie 17th July. The report will be further discussed after hearing the
occupier.
Resolution No.3
It is brought to the notice of the committee that the meeting of LAEC held on
10-7-05 has not been noted in the meeting register. Being Sunday the staff
of the committee was not available and the members left the register to be
signed latter. The omission to sign the register by the members on the
meeting held on 10- 7- 05 has been discussed .The committee resolved to
mark the presence of the members attended the meeting on 10-7-2005
immediately after the attendance marked of the today’s meeting. This
resolution will be separately noted in the meeting book as a special note.
75th meeting held on 22-07-2005, Friday at 4 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
This meeting is convened to discuss the problems relating Merchem India Pvt
Ltd and Merchem Ltd Edayar. The meeting was attended by Mr. Eldos P.
Kauma, Deputy Plant Manager of both the concerns accompanied by Dr
Jayapalan who claims to represent Merchem group namely Merchem LtdEloor, Merchem Ltd-Edayar and Merchem India Pvt Ltd - Edayar, being the
Deputy General Manager(R&D) of all these companies. They have been
authorized by the Managing Director Mr. George to attend this meeting.
Mr. Eldo P. Kauma to the question put to him as to whether the unit has
adequate pollution control measures, replied that the system is perfectly in
order and there is no defect in the system and that they have not observed
any type of non-conformities with the environmental laws.
The representative made available the lab reports of the effluent discharge
from the common ETP. According to company representatives, Merchem Ltd
Edayar and Merchem India Ltd Edayar have a common treatment plant. Both
800
the industries situate in the adjacent plots. The raw effluent from Merchem
India Pvt Ltd Edayar is taken to Merchem Ltd Edayar in a separate pipeline.
Similarly the raw effluent of Merchem Ltd Edayar is taken through another
pipe line to the common treatment plant..
The representatives claimed that the COD in the raw effluent is only between
1000-1200mg/l, TDS around 1500,BOD 180-220, zinc 3-5ppm and chloride
60%of TDS. According to the representatives, the toxicity of effluent can be
found only by toxicity studies (bio-assay test), which they have admittedly
not done. The lab report furnished by them is that of a private lab which
show the parameters of the discharge effluents meeting the prescribed
parameters. The unit at present has no water consent and the application is
pending before the PCB from September, 2004.The unit has valid air
consent.
The discharge point of the effluent of Merchem India under the consent order
is Periyar. It is shocking that the unit has not tested the toxicity of the trade
effluent when it is discharged to Periyar. It was highly obligatory to ensure
that the discharged water contains no toxicity.
The representatives were told of the alarming state of well water in the lab
report of the sample. Chairman LAEC expressed total dissatisfaction in the
manner the company is being operated.
The representatives of the company sought one week’s time from today
undertaking that they will assess the plant and in the assessment if any
failure mode is detected, they will come out with proposal to improve the
system.
The representatives of the company have admitted that samples taken by
them simultaneously with the LAEC on their inspection was analyzed
internally and the reports are available which they undertook to produce
before committee. Having regard to the request of representatives and the
common consensus of the committee, a week’s time is given to set their
house in order and rectify the failure of the system.
It is made clear to representatives that fresh surprise inspections will be
undertaken and samples will be collected from premises and in the event of
lab reports confirming the alarming reports of the samples already the
committee would recommend for closure without further notice.
Resolution No.1
Mr. Farook sait Convenor assured that steps will be initiated for getting
concrete pillars to lay in industrial area for blocking road leading to Periyar at
safe distance to prevent vehicles to river Banks. This shall be done within two
weeks from today.
76th meeting held on 26-07-2005, Tuesday at 7 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
801
Resolution No.1
This meeting was called in the wake of Fugitive emission from various
industries in Eloor Edayar causing serious air pollution to the people living on
the southern side of Pathalam Bridge. The smoke prevalent in the air was
thick blocking the vision. The residents felt discomfort in breathing. They
described the smell as those of burned hair. Some people point towards FACT
and some against Merchem Edayar and some under total confusion. The
smell was of combination of smokes from various factories and for that
reason no one could specifically accuse any particular industry by name. But
the fact is that the emission of smoke was beyond all parameters.
The committee has occasion to deal such complaints in earlier occasions also. In one of
such occasion, the emission was identified as that of FACT. In another occasion it was
from Merchem Eloor. Having regard to the frequent incidents of such complaints from
the locality the committee resolved in one of its meeting requesting PCB to take its
Mobile Ambient Air Quality Monitoring Unit to Eloor Edayar belt to monitor the
ambient air quality.
The incidents of fugitive emissions have caused health hazard to people of the locality
and many were admitted in hospital for primary treatments. The concern expressed by the
committee against the indiscriminate discharge of emissions causing serious air pollution,
unfortunately has not been taken serious note of by the PCB. The committee takes strong
exception to this and is constrained to say that the Board is negligent. The failure to
Monitor Air Quality by the PCB is a serious lapse deserved to be condemned. LAEC
resolved to request the Board to take immediate action to bring under control the
alarming Air Pollution in Eloor Edayar Belt.
The incidents of such dangerous emissions from industries as and when brought to the
notice of LAEC, the committee in turn, has alerted the officers of the Board in the
regional office. The site office of PCB at Eloor Edayar which was directed to be made
functional round the clock with sufficient staff and infrastructure remains still on paper.
The committee note this fact as a serious failure on the part of the Board. The committee
while assessing the situation cannot ignore the failure of the government in addressing
this issue which is directly linked with the peoples Right to Live. It is high time that the
government arm the Board with sufficient staff to make it functional for discharging its
statutory obligations.
The committee call upon the State of Kerala and PCB to realize its constitutional and
statutory obligations to the people and take immediate measures to bring the Pollution
related problems in the Eloor Edayar industrial belt under control.
802
Resolution No.2
Mr. Jayathilakan, Hon’ble member of LAEC explained to the committee that the practical
difficulty highlighted by the Convenor that the Mobile Ambient Air Quality Unit unless
kept stationary at some place, its apparatus will get easily damaged, is not a matter
unresolvable. According to Mr.Jayathilakan there is M/s Accurate Instrumentations and
Control Engineers Pvt Ltd, Valanjambalam is a competent institutions locally available
who can attend to any complaints of mobile unit. The committee requested
Mr.Jaythilakan to take initiative to ensure this mobile unit made operational and is taken
to Eloor Edayar belt taking follow-up actions with PCB.
77th meeting held on 2-08-2005, Tuesday at 6.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Mr. Purushan Eloor placed before the committee five bound volumes of
survey reports conducted for the purpose of identifying the persons for
providing water in Eloor Panchayath.The work was complete in record time,
the committee express its appreciation to the members of the sub committee
Mr. Asokan and Purushan Eloor and also the volunteers who have been
associated with the survey .The committee requested the sub committee a
list of the beneficiaries after going through the survey reports and submit
within 7 days. Place this matter for further follow-up on 7-8-05 at 3 pm.
As per the directions of the SCMC five copies of Interim report has been handed over to
Mr. Farook Sait, Convenor for transmission to Chairman PCB. Chairman PCB has been
directed to SCMC to sent these copies to five LAEC with his forward note. The
Convenor may report the follow-up in the next meeting.
The committee discussed the action taken by PCB in the matter relating to of cut open the
wall enclosing kuzhikandom thodu by the Merchem Eloor.It is reported that the notice
issued by PCB has been served on the unit 21-7-05.The time granted for demolishing
wall is seven days which expired on 28-7-2005.The board is therefore take further action
for demolishing the wall which the com has so far not taken .The Convenor of the LAEC
being not present today he may be asked to report the committee the development in the
matter on Thursday in the next meeting.
The committee considered the request of Mr. Jerson the office assistant for increasing his
salary. The committee resolves to increase an amount of Rs 500 from July 2005.
78th meeting held on 4-08-2005, Thursday at 5.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
803
LAEC during its inspection found certain units in Eloor Edayar being closed and remains
non- functional for long time.
The lists of such units are given below: 1. Nexa Condinents (P) Ltd., Edayar
2. Kripa Foods Pvt Ltd
3. Sevana Industries
4. Techno Flex Cables Pvt. Ltd
5. Maruthi Foam.
6.Larzen and Toubro Ready Mix Concrete Plant, Edayar.
And list of other units finalized.
1. Best Electricals & Engineers.
2. Excel Electricals
3. Glass Tech.
4.Chavara Pipe
5.Sarala Industries.
The committee discussed the need for consulting PCB before allotment of land in
Industrial belt. The committee is of the opinion that PCB should write to DIC Ernakulam
seeking information whether proceedings for re- allotment of any defunct units have been
initiated. The DIC should also be requested to give information to the Board as and when
land is re-allotted or resumed by the department. Board should also write to the occupier
of the units by registered post with acknowledge due informing that as and when the units
re-opens, it should intimate the Board failing which unit should be asked to close
satisfying the Board with all pollution control measures.
The Committee discussed the notice issued by PCB to Merchem India
Ltd Eloor. Mr. Farook Sait Convenor apprised the committee that the Merchem Ltd Eloor
has not demolished the wall as directed in the notice. They have given a reply to the
Board with copy marked to regional office Ernakulam stating that once the wall is
demolished the public will make unauthorized entry into their premises. Mr. Sait stated
that the Member Secretary, PCB asked for his comment and he has already written to the
board that the reason stated by the company is totally unsatisfactory and that their
contention that “ the authorized person of the board can enter the Kuzhikandom thodu
through a manhole.” Is not acceptable. According to him further actions including
demolition of wall will be initiated at cost of the company, immediately on getting
direction either in oral or in writing from Chairman or Member Secretary. The committee
fully appreciated the stand of Farook Sait.
The committee unanimously however feels that the order of the Board is self-operative in
the sense that if the unit fails to comply by its direction, the Board should initiate action
to demolish the wall at the cost of the company. The copy of the order marked to the
804
regional office Ernakulam, has specifically asked the said office to take follow-up action
for compliance.
Mr. Farook Sait assured the committee that he would take up this matter with the Board
and regional office and will ensure the execution of the order on receipt of further orders
from the chairman or member secretary as the case may be.
Chairman PCB and the Chairman LAEC discussed the matter over phone regarding the
implementation of SCMC directions. The Chairman PCB was categorical that the Board
is committed to implement SCMC directions and will not sit on judgment over it. He
instructed Convenor Mr.Farook Sait over phone to implement the direction of SCMC
with immediate effect.
Mr. Farook Sait informed the committee that the board proposes to hold a meeting of the
industries namely FACT, HIL, Merchem and IRE to discuss the cleaning up of the
Kuzhikandom thodu. According to him the view of the companies’ will be clear in the
said meeting. Chairman LAEC expressed surprise over such a move without taking
LAEC into confidence. The meeting proposed is to discuss Kuzhikandom thodu and the
issue being important, the presence of LAEC members (being the delegated authority of
SCMC) is necessary .On this Mr. Farook Sait assured that LAEC will be called to the
proposed meeting and its presence will be its ensured. The step for cleaning up process
has to be expedited. The pilot project of cleaning, the place of final disposal, the resource
persons to be involved, the conveyance to be arranged, the finance etc are the matters yet
to be sorted out. The Board is therefore requested to take speedy measures for finalizing
these aspects failing which it would be difficult to complete the cleaning within the time
stipulated by the SCMC.
79th meeting held on 6-08-2005, Saturday at 4 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No: 1
The Chairman called the attention of the members the necessity to complete the
inspections of the remaining industries and finalization of the reports without further
delay. Chairman suggested that a subcommittee could look into the reports and finalize
the same to avoid delay. The suggestion was accepted and the committee authorized
Chairman to constitute the Sub-committee. Accordingly Chairman constituted a sub
committee consisting of Mr.Purushan Eloor and Mr. Jacob Lazer, in his absence
Mr.Jayathilakan, as members with himself as Chairman of the subcommittee to finalize
the reports .The sub-committee will complete the reports on or before 22-8-2005 and will
proceed further with the review of actions taken by PCB .The sub-committee will prepare
a flow chart of actions suggested and the measures taken thereon by PCB. The actions
will be reported to the LAEC on 25-8-2005.
805
Resolved to approve the reports of the following industries.
1. South Indian Fertilizers, Edayar.
2. Tecccap electronics pvt ltd, edayar
3.Shalimar inks and chemicals Edayar.
4.R.S compound Edayar.
5.Excel enterprises, edayar
6.Nath spun pipes Edayar
7.Filco polymers Edayar
8.Tecman capacitors pvt ltd, edayar
9.Laksmi acetylene Edayar.
10.Atchuth nitrous company Edayar.
11.Manifold industries Edayar.
12.Malayalam chemicals pvt ltd Edayar.
13.Spectrum chemicals.
14.Wires and nails Edayar.
15.Rahul flourmills Edayar
16.Starrefinery Edayar.
17.Amma food products pvt ltd
18.Pneumahydraulics Edayar
80th meeting held on 7-08-2005, Saturday at 4 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No: 1
The Committee considered the direction of the SCMC to the Board in the matter of
demolishing the wall constructed across the Kuzhikandom thodu by Merchem ltd Edayar.
The SCMC had directed the Board to issue orders to Merchem Ltd to remove the wall
within the period of 1 week of their communication and to ensure removal of the wall at
the cost of the company on their failure. The SCMC issued the said direction by their
letter dated 12- 7- 2005 addressed to the chairman PCB.
In compliance of the said direction, the member secretary of the Board on 18-7-2005
issued a direction to the Merchem Ltd Eloor directing them to demolish the wall within a
period of seven days and report compliance to the Board. The said direction has been
served on the Merchem Ltd Eloor on 21-7-05 and the time specified to demolish the wall
expired on 28-7-2005.
The LAEC in its meeting held on 4-8-05 and 6-8-2005 discussed the issue. Convenor of
LAEC Mr. Farook Sait brought to the notice of the committee that the unit after receipt of
the direction has written two letters dated 22-7-05 and 6-8-05 informing that demolition
of wall would lead to unauthorized entry of the public into their premises and that the
company is prepared to provide a grilled gate of 1.5 m width dimension and a key of the
grilled gate can be entrusted with the Board for their access to inspect the Thodu. Mr.
806
Farook Sait made available a copy of the second communication for reference of the
committee.
The said letter was read in the meeting and the members expressed their
strong view on it. Mr. Jacob Lazer member LAEC expressed that the attempt
of the company is to overreach the direction of the SCMC and the reason
stated is highly flimsy in as much as the company can stop any unauthorized
entry to their premises by fencing with barbed wire at a length of 150 m all
along the side of the Kuzhikandom thodu.
Mr. Purushan Eloor has stated that Kuzhikandom thodu is public creek which
carry rain water and the industrial effluent of companies such as FACT,
Merchem, HIL IRE etc and that this thodu has been used for discharging
highly toxic pollutants from these industries ever since Merchem Ltd blocked
access of the public to this thodu by constructing a wall across the thodu,
that these companies have been indulging in illegal activities without the fear
being caught by the public, that PCB has failed to monitor the thodu and stop
discharging hazardous wastes by these companies. According to him it is in
this circumstance, the demand for demolition of the wall by the public was
attended to by LAEC and that the safety and security of the thodu being
abused by the companies, the public should have direct access to monitor
the thodu. The reply of the company virtually leave the cat out, when it
refuses to demolish the wall for the fear of public inspection.
Mr. Asokan took strong exception to the reply of the company and hoped
that the Merchem Ltd Eloor will comply by the direction of the SCMC on
getting the reply from the Board that its suggestion are not acceptable to it.
Mr. Anand on being informed about the developments on this issue had
expressed that LAEC should not hesitate to ensure the implementation of the
directions of the SCMC. He has specifically asked the Chairman to place his
view in the Committee. Mr.Jayathilakan could not be contacted to know his
view.
Chairman, LAEC to refresh the proceedings of the committee read its
resolution passed in the of 62nd meeting held on 3-6-05 which reads thus:
“The premises of Merchem Ltd. situate adjacent to Kuzhikandom
thodu, which is on its southern boundary. Of the two sides of the thodu, one
side is having the compound wall of HIL. The other side remains open
without any compound wall separating the Kuzhikandom thodu and Merchem
premises. However, on the western side of Merchem boundary, the Unit has
constructed a wall across the thodu thereby preventing access to that portion
of Kuzhikandom thodu, which is on the southern boundary of Merchem Ltd.
By constructing this wall, both public and the Pollution Control Board have
lost direct access to Kuzhikandom thodu and to enable the PCB to take
samples from different points of Kuzhikandom thodu situate on the southern
boundary of Merchem Ltd, without entering the compound of Merchem Ltd.
807
This has helped this Unit to go Scot-free and perpetuate their illegal activity
from the sight of public as well as regulatory agencies. The complaint of the
public regarding the construction of wall blocking their access to the
Kuzhikandom thodu remains unattended despite various instances of
dumping of raw effluent containing hazardous waste being noticed by the
Board. In order to have an effective monitoring of the thodu and protect it
from dumping hazardous waste for the future, the Committee is of the
opinion that Merchem Ltd., Eloor should be directed to forthwith demolish the
wall constructed across the Kuzhikandom thodu in its western boundary and
allow access to the public and regulatory agencies for inspection of the thodu
flowing on the southern side of Merchem Ltd. The access to the thodu all
along its full length is necessary for removing the hazardous waste already
dumped by various units and for its remediation.”
The SCMC has issued various directions for the remediation of the thodu, which includes
cleaning up the decontamination of the thodu and nearby areas of hazardous waste. The
SCMC has directed the Board to carry out rehabilitation of the thodu within 6 months
that is by December 2005, with active involvement of LAEC Kochi. SCMC has directed
that since effluent from FACT IRE and HIL and Merchem are involved the cost for of the
cleaning up should be recovered from these units. The further direction of SCMC to
ensure the demolition of wall by Merchem Ltd Eloor is treated as part and parcel of the
clean up of hazardous waste lodged in the thodu over the past several years.
On appreciating all these facts and also bearing in mind various directions of Hon’ble SC
on 14-10-2003 which includes the concern of the Hon’ble Supreme Court not to allow
discharge of any hazardous waste in open dumps which it emphasized taking note of the
report of the high-powered committee which has reported thus:
“Hazardous waste found dumped in open environment have been wide spread cause of
pollution creating draught like situation in areas traditionally not lacking in water
supplies.’’
The dumping of the hazardous waste into Kuzhikandom thodu has rendered the areas
near Kuzhikandom thodu causing a draught like situation that was traditionally an area
depending on well waters. SCMC having concern for the lack of drinking water caused
by the contamination of well water, have directed the aforesaid companies to provide
sufficient water to the residents at their cost.
The area to which public access has been denied is the real dumping site of hazardous
waste by the companies. To ensure that these companies do not further indulge in
dumping hazardous waste, public should be give free access to the thodu.
In the public interest and safety of the Kuzhikandom thodu, the thodu should be open to
the use of public and no private person should be allowed to restrict their entry for
perpetuating their nefarious activities.
808
LAEC therefore unanimously resolve to request the Board to demolish the wall engaging
sufficient personnel forthwith and recover its cost from the company as directed by
SCMC. The delay will give company to scuttle the direction, by resort to various
delaying tactics including even abuse of the process of law.
81st meeting held on 28-08-2005, Sunday at 3 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution –1
The committee discussed the report of the sub-committee constituted for
conducting survey of the families, who lost their water source by the contamination
underground water, to provide water. The committee found 2143 affected families in
ward numbers 1 to 4 and 17 in Eloor Panchayath. There were 1250 wells out of which
926 were contaminated by the industrial pollution. . These families now wholly depend
the public tap facility to meet their water requirement. In view of the fact that the people
depend tap water, owing to the contamination of their wells by industrial pollution, the
committee unanimously resolved to request the Board to initiate appropriate action
directing the companies, namely Merchem, HIL, IRE, and FACT to provide drinking
water to these families at the rate of 500 litres/day free of cost. Each family should be
provided with separate meter connections and consumption of water in excess of 500
litres should be directed to be born from the respective families.
SCMC has directed that these companies should be asked to provide water to the affected
families as the pollution source is from these companies. In compliance of the said
direction, LAEC has completed the survey and identified the affected families. Further
action from the Board is now awaited. LAEC request the Board to call a joint meeting of
the companies, LAEC and Board to finalize the modalities for providing drinking water.
The survey report is forwarded to the Board for further follow up actions which LAEC
expect the Board to finish urgency.
Resoulution-2
The committee discussed the Writ petition No.14051-2005 filed by the Edayar
Small Scale Industries Association before the High Court. Chairman read the interim
order dated 9-8-2005-. The committee takes strong exception to the manner in which the
Board has conducted the case. The observation of the Court that the counsel has no
instruction “though writ petition was admitted on 18-5-05.” gives an indication as to
how negligent the Board was in defending the case.
The Writ Petition was admitted by the Hon’ble High Court on 18-5-05 and the
matter came up for orders on interim prayer only on 9-8-05. Board did not file any
statement producing the order of the Hon’ble Supreme Court restraining all the High
809
Courts from entertaining any writ petition challenging any proceedings issued by the
Board or other authorities as part of the implementation of the order of the Supreme
Court dated 23-10-03.
LAEC in its 56th meeting requested the Board to bring to the notice of the
Hon’ble High Court, in all the cases pending and also in fresh matters coming for
admissions challenging the Board’s action issued pursuant to the recommendations of the
SCMC, the order of the Supreme Court dated 9-5-05 by way of an affidavit and petition.
The Board was requested to instruct the counsel to do the same promptly and get the
orders vacated by securing the dismissal of the Writ petitions.
The Board has a standing counsel in High Court. The standing council was also
aware of the Hon’ble Supreme Court order dated 9-5-05 as he had occasion to produce
the said order in an earlier case. The standing council however failed to bring the order to
the notice of the Court .His submission that he did not get instruction in matter made the
situation further worse.
From the submission of the counsel, the Board’s knowledge of the Writ Petition
cannot be disputed. One can understand if the counsel had sought time to file the counter
or to produce the order of the Hon’ble Supreme Court. But that is not what happened.
The Board owes an explanation to this strange submission of the counsel.
The writ pet filed by the Association is pertains to the an order issued by the
Board on the recommendation of SCMC which was constituted to implement the
directions of the Hon'ble Supreme Court dated 23-10-03.The order of Hon’ble Supreme
Court, (namely “Having heard learned counsel and perused the records we direct
that no court or authority shall take cognizance or entertain any challenge
connected with the implementation of the order passed by this Court on
14.10.2003”) is therefore squarely applicable on the facts of the case. The Board was
legally under an obligation to bring to the notice, the order of the Supreme Court at the
admission stage itself and if by any reason it could not do so, at least by filing an affidavit
and petition producing the said order, of Hon’ble High Court. The Board however did not
do so which has caused embarrassment to the SCMC .The indifference of the Board to
instruct the counsel on the matter is a serious failure of its duty.
LAEC in an earlier occasion sought to conduct an enquiry when it was brought to
its notice that the Counsel made a submission in the court against the official stand of the
Board. That was a case relating to the Merchem Ltd, Eloor. It is also brought to the notice
of the committee that the instances of passing interim order by the High Court for want of
instructions from the Board are many, even after adjournments. If the Board is not keen
to defend itself when its orders are challenged, why orders are issued to trouble the
industries. LAEC does not understand the logic. Having regard to the importance of the
issue, LAEC is of the opinion that a proper enquiry should be conducted in all case where
Hon’ble High Court passed interim orders for want of instructions during the tenure of at
least the present standing counsel who has happened to make such submissions in the
court and take action against those found negligent in conducting the cases in the court.
LAEC in the aforesaid circumstance resolve to report this matter to the SCMC requesting
810
that the Board to explain its conduct and order further enquiry into the conduct of cases in
High Court.
The Hon’ble High Court at the instance of LAEC was pleased to modify its earlier
order dated 9-8-2005 and directed that the nominee of the Petitioner Association need be
included in the LAEC “only with the permission of SCMC.” The Petitioner Association
was directed to produce the copy of the order to LAEC and thereupon LAEC has been
asked to forward to SCMC for orders. So far Petitioner Association has not submitted the
copy of the order. It will be forwarded as soon as the same is received.
Resolution-3
Cleaning up of Kuzhikandom thodu is a task entrusted to the Board for
being undertaken by involving LAEC.A pilot cleaning is necessary to assess
the impact and determine the mode of disposal to the secured land fill. The
committee felt necessary to involve experts in the field of hazardous waste
management. In pursuance to the earlier resolution of the committee, Mr.
Anand contacted some of the experts in hazardous waste management and
has furnished their names. LAEC has already discussed this matter with the
Chairman PCB when he attended LAEC meeting on 30-6-2005. Chairman
Pollution Control Board has agreed to invite the experts identified by LAEC
.In the aforesaid circumstances, committee recommends the following
names.
1.Dr R.Gopichandran, Centre for Environment Education, Ahmedabad.
2.Dr.A.A Khan, Emritus scientist, Indian Institute of Chemical Technology, Hyderabad.
3.Dr Devota, Director, NEERI.
Phone numbers :
Dr R.Gopichandran –09825409031
Dr.A.A Khan- 09246505819 / 040 27193139 / 27193626
Res: 040 23553962
Resolution-4
Resolved to pass the reports of all these industries:
1.
2.
3.
4.
5.
Cee Jee Lubricants, Edayar.
Cube India Rubbers Pvt Ltd, Edayar.
Green Field Chemicals and Foot ware.
Jyothi Chemical Industries, Edayar.
Jyothi Industries.
811
6. Alwaye Techno Engineering Pvt Ltd, Edayar.
7. Jansons Balers, Edayar.
8. M.G.R.Idustries.
9. Carmel Threads.
10. Star Mark.
11. Chemmannur G.R.Pvt Ltd.
12. Pigment India Ltd.
13. Asiatic Products.
14. Kochi Castings and Manufacturing Pvt Ltd.
15. Body Gear International Pvt Ltd, Edayar.
16. Buena Vista International Pvt Ltd, Edayar.
17. Chilton Refrigeration Pvt Ltd, Edayar.
18. Sarson Polymers, Edayar.
19. Gama Paints.
20. Enviro Designs and Equipments.
21. Excel Threads.
22. Success Spinning Pvt Ltd.
23. Pasafic Packagings.
24. Popular Mega Motors (I) Ltd.
25. Meeram Acids Pvt Ltd, Eloor.
26. Agar Agar Manufacturing Unit.
27. Kingston Polymers.
28. Jaysons Industries Edayar.
29. Steel Arc Rods and Wires.
30. Pneumo Hydraulics Pvt Ltd.
31. Cee Gee Engg Works.
82nd meeting held on 8-09-2005, Thursday at 3.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution-1
Merchem Ltd, Eloor along with the profoma submitted to the
LAEC has described its typical hazardous waste (black coloured paste like
substance) as follows:
1.
2.
3.
4.
5.
Mercaptobenzothiazole (MBT):0. 73%
Aniline: 10.04%
Benzothiazole (BT): 19.59%
Dibenzothiazyl disulphide (MBTS): 45.36%
Other Sulphur containing organics: 24.28%
812
This black coloured tarry substance generated by the company admittedly is a hazardous
waste. The company has therefore obtained authorization under the Hazardous Waste
(Management and Handling) Rules 1989 for its storage and safe disposal. The Board is
empowered to cancel the authorization if in its opinion the authorized person has failed to
comply with any of the conditions of the authorization or with the provisions of the Act
and the Rules made under the Act. While packaging, labeling and transporting the
hazardous waste, the occupier shall prepare six copies of the manifest in Form-9
comprising the following colour code, all signed by the transporter.
Copy 1 (White)
-to be forwarded by the occupier to the State Pollution Control
Board or Committee.
Copy 2 (yellow)
-to be retained by the occupier after taking signature on it from the
transporter and rest of the four copies to be carried by the transporter.
Copy 3 (pink)
-to be retained by the operator of the facility after signature.
Copy 4 (Orange)
accepting waste.
-to be returned to the transporter by the operator of facility after
Copy 5 (Green)
-to be returned by the operator of the facility to State Pollution
Control Board or committee after treatment and disposal of wastes.
Copy 6 (Blue)
-to be returned by the operator of the facility to the occupier after
treatment and disposal of wastes.
Further as per Section 7 of the hazardous waste Rules, the occupier is required to follow
the provisions of Motor Vehicle Rules and other guide lines issued by the Central
Government from time to time in the matter of transporting the Hazardous goods.
The occupier is also required to provide to the transporter with relevant information in
form 10 regarding the hazardous nature and measures to be taken in case of emergency.
No transporter shall accept hazardous waste from an occupier for transport unless it is
accompanied by copy numbers 2-5-colour code manifest in form 9.
Under Rule 8, the occupier is responsible for identifying site for disposal of hazardous
waste. Under Rule 16, the occupier shall be liable for damages caused to environment
resulting in improper handling and disposal of hazardous waste. The occupier shall also
be liable to restore destroyed or damaged environment at his cost. The occupier shall also
be liable to pay fine as levied by the State Pollution Control Board with the approval of
Central Pollution Control Board (CPCB).
Merchem Ltd Eloor is found responsible for dumping hazardous waste (black coloured
tarry substance) in 15 barrels of 200 litre capacity at kundelil padam in Thiruvallor of
Alangad Gram Panchayath .These barrels were found on 27 –8-05 by Mr. Jayakrishanan,
813
the Sub Inspector Police, Binanipuram Station on information from an anonymous
source. The Sub Inspector of Police have made investigation and questioned Mr. Vinod
who transported this hazardous waste to kundelil padam. LAEC members informed the
Board on 29-8-2005 and requested to take action.
On being questioned, Mr.Vinod stated that these barrels of tarry substance have been
brought from Merchem Ltd Eloor. The transporter did not have any document for
transporting hazardous waste. On examination of site where the barrels were found, tarry
substance of the similar nature is seen discharged into land by heating up the barrels.
The transporter produced a tax invoice for purchasing the 15 barrels of “benzothiozol
(5%).” The tax invoice produced is dated 29- 8-05. Mr. Vinod explained that these
barrels were kept in the Kundelil Padam for being taken to Tamil Nadu whereas the
invoice discloses a nearby place, Chalakudy.
The barrels used for transporting the tarry substance were barrels used for storing
Morpholin, which is an imported raw material of Merchem Ltd Eloor. The label on the
barrels also therefore confirms the source.
On 29-8-05 itself, the Board officials took samples from 15 barrels and sample from the
land where it is discharged .The barrels were thereafter shifted to Binanipuram Police
station for safer custody. The next day, ie.30-8-05 the Board also took Statutory Samples
from these barrels. These samples have been sent to Central Lab Cochin for ascertaining
whether the goods seized is the same hazardous waste (tarry subtance0 generated out of
the manufacturing process of the MerchemLtd, Eloor. The lab analysis confirmed that the
tarry substance contained in 15 barrels and the one discharged in to the land are of the
hazardous wastes of Merchem Ltd. Neither the transporter nor occupier could produce
form 9 and 10 under the Hazardous Waste (Management and Handling) Rules 1989.
The occupier is therefore found guilty for breach of the provisions of the Hazardous
Waste (Management and Handling) Rules 1989 and also the conditions of authorization
issued to it.
The company has reported that 24-tonne/year tarry wastes are generated for the
production rate of 3 tonne/day. But the company is actually producing 6 metric tones
per day generating 48 tones tarry substance per year. It should therefore necessarily
possess 336 tonnes of hazardous tarry substance in its temporary disposal facility over
the past seven years of its production. The company is therefore liable to account for so
much quantity generated over these years.
LAEC on inspection could find only a layer of tarry substance in their temporary disposal
facility. The tarry substance generated over the last even one year is not seen in the TSDF
and the company could not explain where it has been disposed off.
The company was compelled to install evaporator and RO to treat its toxic effluent only
in April 2005 that is after LAEC recommended closure of this unit. The company has
814
been dodging the Kerala State Pollution Control Board with an ETP, which was capable
to treat only Organic Effluent, which was totally inadequate to treat inorganic waste of
heavy toxicity of the company. The complaint of the public residing near by
Kuzhikandam thodu has thus been found vindicated. These are all facts documented and
now available with PCB for reference
In the above facts and circumstances, the authorization issued to the company under
Hazardous Waste (Management and Handling) Rules 1989 is liable to be cancelled for
violating the provisions of the Hazardous Waste (Management and Handling) Rules 1989
and conditions of authorization issued to it. The company is also liable for fine. The
company has been served with a series of closure order and show cause notice by the
Pollution Control Board ever since its operation started in 1997.
.
In the circumstance the LAEC unanimously resolve to recommend the following action
from KSPCB.
1. Cancel the authorization issued under Hazardous Waste (Management and
Handling) Rules 1989 to the Merchem ltd Eloor forthwith as this unit has been
found operating not only in breach of the said Rule but also the orders issued by
the Hon’ble Supreme Court with impunity.
2. Impose fine based on the quantity of the hazardous waste not accounted by the
company especially the tarry substance generated over these years.
3. The company should be allowed to restart its operation only after it account for
the waste generated by it over these years especially the tarry substance which is
calculated as 336 tonne at the rate of 6 metric tonn /day production and on the
payment of the fine imposed by the Board.
4. The board shall approach the Central Pollution Control Board giving a brief
history and detailing the track record of the company along with the closure
orders, show cause notices and other actions taken against the company over these
years.
This resolution passed unanimously is forwarded to SCMC and to the Board. SCMC
may issue necessary orders taking stock of the whole situation.
83rd meeting held on 10-09-2005, Saturday at 10.30 am at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
Resolution No: 1
Resolved to approve the reports on the following:
1. M/S BSES Kerala Power Ltd Udyogamandal.
815
2. Lime unit owned by Mr.Suresh
3. Ashan Exports, Edayar (Tallow unit)
4. Tallow unit of Mr.Siraj.
5. Juno Industries of Mr.Jaison, Edayar. (Tallow unit)
6. Winner Seals Pvt Ltd, Edayar.
7. Durocoats Paints Pvt Ltd, Edayar.
8. Krishna Engineering Works, Edayar.
9. Alba Polymers, Edayar.
10. Panakkal Polymers, Edayar.
11. New Plastic Industries, Edayar.
12. R.K Cartons, Edayar.
84th meeting held on 13-09-2005, Tuesday at 5 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolved to approve the report on Hindustan Insecticides Ltd, Eloor.
85th meeting held on 19-9-2005, Monday at 4.30 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No: 1
Chairman brought to the notice of the committee that the two of the
members of LAEC Mr.G.Anand and Mr.Ashokan have sought his permission to
demit the office. Considering the fact that reports of some units inspected by
these members are yet to be finalized Chairman requested them not to demit
office until reports of those units are finalized and sought their cooperation to
continue until the final report, which is being finalized, is submitted to the
SCMC. Chairman sought the opinion of the LAEC on his view requesting these
members to continue till the report is submitted to SCMC.The members
concurred with the view of the chairman and pointed out that a new member
will be hardly of any use at the fag end of finalizing the environmental audit
report .The committee hence resolved to request Mr. Anand and Mr. Asokan
to continue their cooperation until LAEC submit its report to SCMC.
Resolution no: 2
The committee resolved to submit its final report on 1st October 2005 subject to the
convenience of the SCMC .The committee decided to finalize report on or before 29-92005.Chairman made a telecon with Dr Claude Alvares to find out whether 1st Oct 2005
could be suitable for SCMC members to visit Kerala to submit the report to it. .
Dr.Claudes has tentatively agreed to the said date which he assured to confirm by
tomorrow or will suggest another convenient date. On getting confirmation from him
816
communication to PCB Chairman should be sent fixing the date of submission of final
report to SCMC.The details of the function shall be worked out in the subsequent
meetings.
Resolution-3
Mr. Purushan raised the question as to what action has been taken by the
PCB on the resolution passed by the committee recommending certain
actions against Merchem Ltd Eloor after being caught red-handed for
transporting hazardous waste in violation of Hazardous Waste (Management
and Handling) Rules 1989 and the conditions of authorization issued to the
company. Mr Farook Sait convener being absent in the meeting today, this
matter will be discussed in the next meeting.
Resolution-4
Resolved to approve the reports of the following industries:
1. Falcon Infrastructure, Eloor.
2. Copper Blues.
3. General Chemicals and Polymers.
4. Varkeys Industries.
5. East Hill Rubbers.
6. Southern marketing Associates.
7. Anaswara Fibre Industries.
8. M/s Kingston Packings.
9. M/s Mampad Rubber Manufacturing Co.Ltd.
10. Associated Chemicals, Edayar.
11. Southern Composites.
86th meeting held on 22-09-2005, Thursday at 4 pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No: 1
The committee discussed the inspection of bone meal units in Edayar to
assess the improvements made pursuant to the direction of the SCMC .The
committee opined that the units have failed to achieve arrangements for
boiling the raw bones brought to the units on the same day and to processes
the same on first come first basis. The committee resolved to issue the
following notice to all units mentioned hereunder and take a decision on the
merits of each units after hearing them.
1. Sigma Fertilizers.
817
2.
3.
4.
5.
6.
7.
National fertilizers
AES industries.
Cochin bone meals
Kaveri bone meals.
Yeoman Bone and Allied products.
Nelkadir Bone
Show Cause Notice
LAEC during its inspection of your unit on various dates, have found the
pollution control measures totally inadequate. The committee have even called a meeting
of the all bone meal units and directed to take necessary measures to control odour
nuisance. The consent order issued to your unit has stipulated a condition that all the raw
bones brought to the units must be boiled on the same day and be kept in different
compartments for being processed by first come first lot principle. SCMC issued
directions for closure of all the bone meal units on failure to implement adequate odour
control measures by 30th August 2005.
LAEC made visit to your unit recently to satisfy the measures taken by your unit to
control the odour nuisance. The committee found to its shock that you have not enhanced
the capacity of boiling the fresh bones brought to the unit daily. This obviously causes
backlog which is a major source of nuisance .The committee also find no improvement in
the process.
Your unit is also have been found processing tallow illegally which is yet another
nuisance. LAEC in the above circumstances is constrained to recommend closure of your
unit for being found violating the environmental laws. However in the interest of justice
before making such recommendation, the committee resolved to give an opportunity to
you to explain adequacy of measures taken by your unit with factual details.
You are therefore requested to submit your explanation and show cause why the
committee should not recommend closure of your unit to Pollution Control Board (PCB).
Your explanation should reach the office on or before 27- 9-05.
87th meeting held on 25-09-2005, Sunday at 10 am at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Chairman briefed the committee the details about the discussion he had with the Nini
Creep Mills, Edayar. Mr. Niyas Rasheed Managing Partner, Mr Sukku Kassim Partner
Mr. Irshad.P.Y Partner Nini crepe mills attended the meeting scheduled to discuss the
problem relating to the unit .The occupier requested for time to prepare a detail report on
the pollution control measures to be implemented and sought time to consult a competent
consultant. Time is granted upto 30-9-05 for submission of detailed report and action
taken on pollution control measures. The committee will finalize the report on Nini Creep
Mills after 30-09-2005.
818
Resolution No: 1
The committee resolved to approve the following reports.
1.Travancore Cochin Chemicals, Eloor.
2.Sud Chemie India Pvt.Ltd
88th meeting held on 27-09-2005, Tuesday at 4.30pm at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
Resolution No: 1
Bone meal units of Edayar.
1.
2.
3.
4.
5.
6.
7.
Sigma Fertilizers.
National fertilizers
AES industries.
Cochin bone meals
Kaveri bone meals.
Yeoman Bone and Allied products.
Nelkadir Bone
This meeting was convened to assess the improvements made by the Bone meal units,
pursuant to the time granted for implementing pollution control measures. All the units
submitted their explanation to the show cause notice. The units have assured that they
would not keep backlog of raw bones and will ensure strict compliance of the conditions
that may be imposed. A form containing undertaking from the bone meal units to be
submitted to Pollution Control Board (PCB) has been finalized as follows. The unit will
submit the form after duly filled before LAEC on or before 1-10-2005.
Before the Environment Engineer, District Office, Kerala State
Pollution Control Board, Gandhi Nagar, Ernakulam, Kochi-20.
1. Name of the industry
:
2. Name and address of the owner
:
3. Nature of the industry
:
4. Daily intake of raw bones
:
819
5. Intake of raw bones during festival seasons :
6. Intake of raw bones during sundays/holidays :
7. Capacity of the boiler
(Give details about the vessel and
Quantity of bones boiled per batch)
:
8. No: of vessels used for boiling
(Give details of its size and
Quantity of bones boiled per batch)
:
9. Time required for boiling per batch
:
10. Frequency of boiling per day.
:
11. Number of compartments available for
keeping daily boiled bones
(give size of the carpet area of each
compartment)
:
12. The normal time taken for processing the
boiled bones
:
13. The materials used for spraying to control
the odour
:
14. Quantity of the consumption of spray
used per day
:
15. Whether tallow is processed except the
tallow derived by steaming the raw bones
:
16. Quantity of waste water generated during :
steaming per batch(Give details of disposal)
17. The quantity of tallow derived by steaming :
the raw bones per day
18. The person to whom the tallow is disposed off:
Undertaking
The information furnished above are true and correct. I undertake that the
unit will not indulge in tallow extraction except by what is derived by
steaming raw bones. I undertake to process the raw bones brought to the
820
unit on the same day and a register will be kept for daily intake. The details
furnished above and the undertaking given hereby will be strictly followed. In
case of any violation, the unit hereby agree to the forfeiture of bank
guarantee that may be furnished.
Name of occupier/authorized agent:
Address:
Phone No:
Signature
Place :
Date
Occupier/authorized agent:
:
89th meeting held on 28-09-2005, Wednesday at 4.30 pm at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
The meeting was called to discuss the problem relating to Cochin Rubber Industries .
The unit sought one month time to implement the pollution control measures.
Considering the fact that the unit has initiated actions to implement certain control
measures the committee resolved to grand time of one month.
90th meeting held on 1-10-2005, Saturday at 12.30 am at Local Area Environmental
Committee Office, Kaloor Towers, Kaloor.
The meeting was convened to discuss the follow up actions on various recommendations
made by the committee. Member Secretary Pollution Control Board was specially invited
to attend the meeting. Chairman invited his attention to the following issues upon which
recommendation have been forward for appropriate action.
1. Seizing of barrels containing Hazardous waste illegally handled by Merchem Ltd
Eloor in violation of conditions of authorization.
2. The proposal to establish for chemical check post in Eloor-Edayar belt to monitor
the movement of hazardous waste and transportation of other chemicals.
3. The matter relating to the erection of concrete post across the road to block entry
of the tanker and other lorries to Periyar river.
4. To remove the illegal road block caused by certain units resulting to
inconvenience for inspection of the industrial units.
5. Water supply scheme to be ensured to the people of Ward Nos. 1 to 5 and 17 of
Eloor Panchayath.
821
6. Cleaning up of Kuzhikandam thodu.
7. The findings of the committee on Cochin Chemicals and Merchem Edayar.
8. River monitoring Station at Eloor Ferry.
9. Mobile Air Monitoring unit.
10. A district level office at Eloor Edayar.
Member Secretary assured action against Merchem Limited Eloor on the
recommendation on the committee. Regarding the proposal to establish Chemical check
post Member Secretary stated that necessary action involving departments such as Motor
Vehicle, Industries Dept. etc will be initiated. He instructed convenor Farook Sait to call
a meeting of the district officials of these Departments to discuss and finalize the
modalities for establishing chemical check post. As regards the erection of concrete wall
is concerned he informed the committee that the secretary of the govt. departments of
Industries have already issued orders for blocking the road to prevent access to tanker and
other lorries to the Periyar river bank. He instructed convenor Farook Sait to follow up
the matter. It was decided that LAEC will call a meeting of the four companies namely
Merchem limited Eloor, IRE, FACT and HIL involving PCB officials on 7-10-2005 to
finalize the modalities including contribution of fund to meet the expenditure of the
water supply. Member Secretary informed the committee that FEDO has been asked to
study the cleaning up of Kuzhikandam thodu and suggested that the experts named by the
LAEC could be associated with the FEDO as consultants. The Member Secretary
expressed his displeasure over the inhibition of the PCB officials to prepare even a draft
report of Cochin Chemicals. According to him the report has to be prepared without
bearing in mind any fear or favour. He also asked the committee to finalize the report on
Merchem Limited Edayar which is found to be in operation without a proper ETP to treat
inorganic effluent of Toxic nature. The land after being allotted in favour of PCB
necessary action would be initiated to setup a river monitoring station at Eloor Ferry. On
Mobile Air monitoring unit Memebr Secretary asked convenor to entrust the work at the
Regional Office for appropriate action. Member Secretary informed the committee that
the site office will be upgraded as district office and sufficient officers will be soon
posted.
Member Secretary agreed to get the consent of Hon’ble Minister for Health to inaugurate
the function to organize for submission of the Environment Audit Report. He confirmed
the appointment even before the conclusion of the meeting.
Resolution No: 1
Resolved to approve the reports on the following units
1. Power Control, Edayar
2. Ultra Tiles,Eloor
3. Cochin Chemicals ,Eloor
822
91st meeting held on 5-10-2005, Wednesday at 9.30 am at Local Area
Environmental Committee Office, Kaloor Towers, Kaloor.
The committee deliberated the seizure of hazardous waste of Merchem Ltd, Eloor and
took note of the following aspects and resolved to send the following concern of the
Committee to PCB and SCMC.
Resolution No1
“Merchem Ltd, Eloor has described its typical hazardous
waste as black coloured paste like substance. This black coloured tarry
substance generated by the company admittedly is a hazardous waste. The
company has therefore obtained authorization under the Hazardous Waste
(Management and Handling) Rules 1989 for its storage and safe disposal.
Under Rule 8, the occupier is responsible for identifying site for
disposal of hazardous waste. Under Rule 16, the occupier shall be liable for
damages caused to environment resulting in improper handling and disposal
of hazardous waste. The occupier shall also be liable to restore destroyed or
damaged environment at his cost. The occupier shall also be liable to pay
fine as levied by the State Pollution Control Board with the approval of
Central Pollution Control Board (CPCB).
As per Section 7 of the hazardous waste Rules, the occupier is required
to follow the provisions of Motor Vehicle Rules and other guide lines issued
by the Central Government from time to time in the matter of transporting
the Hazardous goods. The occupier is also required to provide to the
transporter with relevant information in form 10 regarding the hazardous
nature and measures to be taken in case of emergency. No transporter shall
accept hazardous waste from an occupier for transport unless it is
accompanied by colour code manifest in form 9 of the Hazardous Waste
(Management and Handling) Rules 1989.
Merchem Ltd Eloor is found responsible for dumping hazardous waste (black
coloured tarry substance) in 15 barrels of 200 litre capacity at kundelil
padam in Thiruvaloor of Alangad Gram Panchayath on 27.08.2005. .These
barrels were found by Mr. Jayakrishanan, the Sub Inspector Police,
Binanipuram Station on information from an anonymous source. On
examination of site where the barrels were found, tarry substance of the
similar nature is seen discharged into land by heating up the barrels. The
Sub Inspector of Police have made investigation and questioned Mr. Vinod on
29.08.2005 who transported this hazardous waste to kundelil padam.
On being questioned, Mr.Vinod stated that these barrels of tarry
substance have been brought from Merchem Ltd Eloor. The transporter
produced a tax invoice for purchasing the 15 barrels of benzothiozol. The tax
invoice produced was dated 29- 8-0, whereas the barrels were found on
823
27.08.2005. Mr. Vinod explained that these barrels were kept in the Kundelil
Padam for being taken to Tamil Nadu whereas the invoice discloses a nearby
place, Chalakudy. The barrels used for transporting the tarry substance were
barrels used for storing Morpholin, which is an imported raw material of
Merchem Ltd Eloor. The label on the barrels also therefore confirmed the
source.
On 29-8-05 itself, the Board officials took samples from 15 barrels and
sample from the land where it is discharged .The barrels were thereafter
shifted to Binanipuram Police station for safer custody. The next day, ie.308-05 the Board also took Statutory Samples from these barrels. These
samples were sent to Central Lab Cochin for ascertaining whether the goods
seized is the same hazardous waste (tarry subtance0 generated out of the
manufacturing process of the MerchemLtd, Eloor. The lab analysis confirmed
that the tarry substance contained in 15 barrels and the one discharged in to
the land are of the hazardous wastes of Merchem Ltd.
Neither the transporter nor occupier could produce form 9 and 10
under the Hazardous Waste (Management and Handling) Rules 1989. The
occupier is therefore found guilty for breach of the provisions of the
Hazardous Waste (Management and Handling) Rules 1989 and also the
conditions of authorization issued to it.
The company has reported that 24-tonne/year tarry wastes are generated for the
production rate of 3 tonne/day. But the company is actually producing 6 metric tones
per day generating 48 tones tarry substance per year. It should therefore necessarily
possess 336 tonnes of hazardous tarry substance in its temporary disposal facility over
the past seven years of its production. The company is therefore liable to account for so
much quantity generated over these years. LAEC on inspection could find only a layer of
tarry substance in their temporary disposal facility. The tarry substance generated over
the last even one year is not seen in the TSDF and the company could not explain where
it has been disposed off.
The company was compelled to install evaporator and RO to treat its toxic effluent only
in April 2005 that is after LAEC recommended closure of this unit. The company has
been dodging the Kerala State Pollution Control Board with an ETP, which was capable
to treat only Organic Effluent, which was totally inadequate to treat inorganic waste of
heavy toxicity of the company. The complaint of the public residing near by
Kuzhikandam thodu has thus been found vindicated. These are all facts documented.”
The committee sought action taken report from Member Secretery, PCB on 1-102005 on the report of the LAEC on Merchem Ltd which was found to have dumped
Hazardous wastes in violation of authorization. The Board however is seen totally
negligent in taking proper action against the unit. The committee takes strong exemption
to the attitude of the Board. The committee reminds the Board that the very purpose of
constituting monitoring committee is to ensure enforcement of the provisions of the
Hazardous Waste (Management and Handling) Rules 1989 and ensure the compliance of
824
the various directions issued by the Hon’ble Supreme Court of India. The inaction on the
part of the Board is nothing but amounts to flouting the Supreme Court directions. The
Committee therefore reminded the Board its consequences of inaction and hope that the
Board will wake up from its inaction and would exercise its power as expected from a
statutory authority.
Resolution No.2
The committee passed the following reports;
1. Indian Rare Earths Ltd,
2. Indian Aluminuim Company- Extrusion Division
3. Indian Aluminium company- Smelter Division
4. Akshay gases
5. Prax air Carbondioxide
6. Merchem India Pvt. Ltd
7. Merchem Limited Edayar
8. Binani Zinc
9. Kemo Gravures
10. A.K.Chemicals
11. Ria Enterprises
12. FACT- UD
13. FACT-PD
14. Periyar Chemicals
15. Masters Multipack
16. Southern Gase
Resolution No 3
The representatives of Cochin Chemicals namely Vinodkumar , Balagopal Ramanandan ,
Prathabachandran and Manikandan on taking prior appointment with chairman LAEC
came to office at about 3 pm . They explained that the unit is not processing any
chemicals and that the premises is issued only as a transits point to transport the waste
ferrous chloride effluent. According to them the excess effluent will be stored in the
premises.
They could not answer how excess effluent would come if it is only a transits point.
Chairman also asked why the unit did not disclose to PCB that it has stopped processing
any chemicals.
The representatives admitted that there is discharge of effluent and that the unit is
prepared to undertake remedial measures .
Chairman expressed his displeasure over the irresponsible conduct of the unit which is
being owned by none other than a stallwart in the environmental consultancy. Chairman
825
asked representatives to place concrete proposals on remedial measures proposed by the
unit.
The unit sought time to get back to LAEC with an action plan to remedy environmental
damage already committed.
Time upto 17th October 2005 is granted .
The committee resolved that the issue will be further discussed after knowing the
concrete proposal from the unit .