BINANI ZINC LIMITED EDAYAR - People's Union for … (ZnO.Fe 2 O 3). Leaching of Calcine is carried...

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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

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.

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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 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.

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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.

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.

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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. 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.

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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 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

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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.

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Consented Parameters and limits

Consented parameters under Water(Prevention and Control of Pollution)Act 1974.

SL.No Characteristic Unit Tolerance

limit 1 pH 6-8.5 2 Suspended Solids mg/l 30 3 Total Dissolved Solids ,, 2100 4 Sulphide ,, 2 5 Fluoride ,, 2 6 Sulphate ,, 1000 7 Cadmium (as Cd) ,, 0.2 8 Zinc (as Zn) ,, 5 9 Mercury(as Hg) ,, 0.01 10 Copper(as Cu) ,, 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 : Binani Zinc Limited, Edayar Date of sample collection : 2-12-04. Sample Identification No :LAEC 45(Raw effluent tank)

LAEC 44(Authorized outlet) LAEC 48(Unauthorized outlet).

Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl.No

Unit Raw effluent tank

Authorized Outlet

Unauthorized outlet

Tolerance limit as per consent

1 pH 3.4 6.8 4.2 6-8.5 2 SS mg/l 180 8 17 30 3 TDS 13588 784 268 2100 4 Zinc 550 0.19 11.0 5 5 Iron 170 ND 8.4 --- 6 Mercury 0.1 ND ND 0.01 7 Cadmium 4.88 ND ND 0.2 8 Copper 13.1 ND 0.01 2 9 Fluorides 3.27 0.57 ND 2 10 Sulphates 5000 600 125 1000 11 Sulphides ND ND ND 2

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Source : Binani Zinc Limited, Edayar Date of sample collection : 30-12-04. Sample Identification No : LAEC 39(River sludge near unauthorized outlet of Binani

Zinc Limited) Name of the Lab : Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No

Determinant Unit River sludge near unauthorized outlet of Binani zinc Limited

1 pH 4.43 2 Zinc mg/kg 581.3 3 Iron 440.4 4 Lead 195 5 Mercury 0.102 6 Cadmium 14.7 7 Copper 72.9 8 Nickel 41.9 9 Arsenic ND 10 Flouride ND 11 Chlorides 2000 12 Sulphate 245 13 Sulphide ND 14 Manganese 436.5 Source : Binani Zinc Limited, Edayar Date of sample collection : 2-12-04. Sample Identification No :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)

Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No

Determinant Unit 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

1 pH 3.5 5.1 5.7 6.3 3.8 2 Zinc mg/kg 573.5 585.1 609.4 587.5 486 3 Iron 56880 3505 1090 89400 110985 4 Lead 3616 3400 3820 2950 196 5 Mercury 0.05 0.06 0.08 0.02 0.02 6 Cadmium 373.9 662 723.6 355.3 70.3 7 Copper 212.9 165.8 196.4 114.1 60.8 8 Nickel 8.7 269.7 809.6 22.4 53.7

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Source : Binani Zinc Limited ,Edayar Date of sample collection : 2-12-04. Sample Identification No :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.)

Name of the Lab : Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit LAEC 21

LAEC 22

LAEC 23

LAEC 24

LAEC 25

1 pH 4.2 9.1 8.7 5.1 5.1 2 Zinc mg/kg 304 597.3 399 439.1 5000 3 Iron 31920 37140 56430 131050 49350 4 Lead 57 1063 233 443 430 5 Mercury ND 0.04 0.03 0.05 0.16 6 Cadmium 6.6 405.5 9.3 23.7 8.6 7 Copper 25 202.8 60.3 90.8 4.5 8 Nickel 12.7 58.4 64.4 36.2 39.7 Source : Binani Zinc Limited .Edayar Date of sample collection : 2-12-04. Sample Identification No :LAEC 26(Near bamboo forest, inside the compound wall)

LAEC 27(Soil inside the compound, southern side of bamboo forest near the motor shed).


Determinant Unit Near bamboo forest inside the compound wall

Soil inside the compound, southern side of bamboo forest near the motor shed

1 pH 5.5 5.3 2 Zinc mg/kg 321.8 597.5 3 Iron 18750 18050 4 Lead 120 90 5 Mercury 0.02 0.06 6 Cadmium 5.1 3.5 7 Copper 2.7 274.7 8 Nickel 13.3 14.2

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Source : Binani Zinc Limited .Edayar Date of sample collection :3-8-05 Sample Identification No :LAEC 261(Storm water drain outlet) Name of the Lab : Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Storm water drain outlet Tolerance limit

1. pH 3.5 6-8.5 2 SS mg/l 223 30 3 TDS ,, 736 2100 4 Zinc(as zn) ,, 25 5 5 Iron ,, 20 - 6 Mercury(as Hg) ,, ND 0.01 7 Cadmium ,, ND 0.2 8 Copper(as cu) ,, ND 2 9 Fluorides ,, 0.3 2 10 Sulphates ,, 625 1000 11 Sulphides ,, ND 2

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MERCHEM LIMITED, ELOOR

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 : 385 MT/Yr 2. Acetone : 176 ,, 3. Carbon disulphide :275 ,, 4. Industrial Methylated Spirit :83 KL 5. Caustic Soda Lye : 385 MT/Yr 6. Sulphuric Acid : 110 ,, 7. Hydrochloric Acid : 20 ,, 8. Toluene : 22 ,, 9. Soda Ash : 10 ,, 10. Trichloroethylene : 25 ,, 11. Chlorine : 66 ,, 12. Hydrogen peroxide : 40 ,, 13. Hexachlorobenzene : 45 ,, 14. Sodium Sulphide : 35 ,, 15. Sulphur : 110 ,, 16. Elasto 245 oil : 2 ,, 17. Sodium Sulphite : 6 ,, 18. Ferric Chloride : 4 ,, 19. Mixed Sulphate Salt : 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

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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.

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.

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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 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.

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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 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.

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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 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.

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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.

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.

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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.

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.

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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.

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.

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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 4-2-2005 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 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)

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.

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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.

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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 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.

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

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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.

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

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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.

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 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.

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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.


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

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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 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.

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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.

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

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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. 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.

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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 . 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.


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.

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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 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.

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Source : Merchem Limited ,Eloor. Date of sample collection :1-6-05 Sample Identification No :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.)

Name of the Lab :Central Laboratory, Gandhi Nagar. Sl. No.


LAEC 196

LAEC 197

LAEC 198

LAEC 199


1. pH 6.5 5.6 9.3 12.8 8.6 5.5 – 9.0 2 BOD mg/l 90 12 108 568 198 30 3 COD 960 96 1232 7120 2400 -- 4 SS 977 196 132 664 825 100 5 TDS 9872 792 1896 9970 4690 -- 6 Zinc ND ND ND ND ND 5.0 7 Iron 174 11.8 1.4 18.7 42.6 -- 8 Chlorides 300 140 120 1400 2000 -- 9 Sulphates 4000 550 750 700 450 -- 10 Manganese 165 39 ND ND ND -- 11 Phenolic

Compounds 1.2 ND 2.3 2.5 1.5 1.0

12 Colour hazen 640 20 40 3200 2000 --

Consented Parameters and Limits.


SL.No Characteristic Unit Tolerance limit

1 pH 5.5-9 2 Suspended Solids mg/l 100 3 BOD(3Days at 270 C) ,, 30 4 Oil and Grease ,, 10 5 Zinc ,, 5.0 6 Phenolic Compounds ,, 1.0 7 Sulphides(as S) ,, 2.0

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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 : Merchem Limited, Eloor. Date of sample collection : 9-12-04. Sample Identification No :LAEC 35(Sludge from hazardous waste storage tank)

LAEC 36(Dyke of MBTS Storage tank). Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No

Determinant Unit Sludge from hazardous waste storage tank

Dyke of MBTS Storage tank.

1 Zinc mg/kg 578.5 82.3 2 Iron 57750 1300 3 Lead 128 6 4 Cadmium 8.2 3.9 5 Copper 99.1 7.4 6 Nickel 46.6 30.9 7 Arsenic ND ND 8 Total Chromium 173.3 ND 9 Manganese 457 12.9 Source : Merchem Limited, Eloor Date of sample collection : 9-12-04. Sample Identification No :LAEC 72(Raw effluent collection tank)

LAEC 73(Retention tank) LAEC 74(Authorized outlet.)


Determinant Unit Raw effluent Collection tank

Retention tank

Authorized outlet


1 pH 8.8 7.7 7.9 5.5 - 9 2 BOD mg/l 410 0.2 2 30 3 COD 3600 4 8 -- 4 SS 15 12 7 100 5 TDS 7704 68 64 -- 6 Zinc ND ND ND 5.0 7 Chlorides 1100 20 8 -- 8 Sulphate 3000 12 ND -- 9 Phenolic Compounds 0.4 ND ND 1.0 10 Oil & grease ND ND ND 10

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Source : Merchem Limited, Eloor Date of sample collection : 13-12-04 Sample Identification No :LAEC 76(Authorized Outlet)

LAEC 77(By pass line to outlet) LAEC 78(Storm water drain) LAEC 80(Flare stack water seal sample).

Name of the Lab : Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No

Determinant Unit Authorized Outlet

By pass line to outlet

Storm water drain

Flare stack water seal sample

Tole-rance limit

1 pH 7.1 9.4 6.6 11.2 5.5-9 2 BOD mg/l 2.0 210 12.4 200 30 3 COD 24 7640 64 10800 -- 4 SS 8 48 62 20 100 5 TDS 398 13840 494 8808 -- 6 Chlorides 80 1630 40 5000 -- 7 Sulphates 12 10000 200 375 -- 8 Sulphides ND ND ND 2000 2.0 9 Phenolic

compounds ND 1 0.1 250 1.0

10 Oil & grease ND ND ND 2.2 10 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 ))


Determinant Unit Sludge near storm water drain

NAMBT process sludge

Sludge western side of polishing pond

Sludge near collection tank

Sludge near creek (stagnant)

1 pH 3 6.1 5 5.8 7.1 2 Zinc Mg

/kg 40 265 640.8 590.8 1024.8

3 Iron 21780 6235 463.5 218.5 6080 4 Lead 82 84 168 198 252 5 Cadmium 4.8 4.6 6.2 22.8 43.2 6 Copper 7.2 10.3 86.8 200 24 7 Nickel 596.6 18.2 32.6 63.7 66.6 8 Arsenic ND ND ND ND ND 9. Chloride 40000 2000 2500 3000

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10 Sulphates 21400 127 2000 2300 16500 11 Sulphides ND ND ND ND ND 12 Magnesium 2000 ND 2000 3000 3000 13 Total

Chromium 13.8 9.2 286.8 95.4 13.8

14 Manganese 837.5 69.8 352 948.5 593 Source : Merchem Limited, Eloor Date of sample collection : 7-2-05. Sample Identification No :LAEC 18(Recycling water- sample pumped from the sump

near NMBTS pumped to equalization tank) LAEC 29(Treated effluent from secondary settling tank)


Determinant Unit Recycling water- sample pumped from the sump near NMBTS pumped to equalization tank

Treated effluent from secondary settling tank

Tolerance Limit

1 pH 7.6 4.4 5.5-9 2 BOD mg/l 130 180 30 3 COD 3440 8160 -- 4 SS 35 196 100 5 TDS 1740 3700 -- 6 Chlorides 400 1350 -- 7 Sulphates 120 400 -- 8 Phenolic Compounds 1 200 1.0 Source : Merchem Limited, Eloor -Sludge Date of sample collection :10-2-05 Sample Identification No :LAEC 52(Inside plant-New Recovery plant) Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No

Determinant Unit Inside plant-New Recovery plant

1 pH 6.22 2 Chlorides mg/kg 300000 3 Sulphate 66470 4 Organo Chlorine

compounds 55.76

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Source : Merchem Limited, Eloor Date of sample collection :10-2-05 Sample Identification No :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)

Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Kuzhikandam Thodu - Downstream of HIL outlet

Outlet Raw effluent

Effluent after chemical Treatment

Bio tower outlet

Tolerance limit

1 pH 6.5 6.6 10 6.3 6.8 5.5 - 9 2 BOD mg/l 160 90 205 200 190 30 3 COD 800 480 2960 2720 1680 -- 4 SS 2983 72 112 121 153 100 5 TDS 836 3012 4700 4528 6888 -- 6 Chlorides 300 1380 1250 3200 3380 -- 7 Sulphate 375 1125 750 450 1375 -- 8 Phenolic

Compounds ND 9.6 16 8 5.6 1.0

9 Oil & grease 10 ND ND ND ND 10 Source : Merchem Limited, Eloor Date of sample collection :10-2-05 Sample Identification No :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).


Determinant Unit Effluent after primary settling

Secondary settling tank outlet

Outlet of final settling tank

Inlet water from the sump NAMBT

Tolerance limit

1 pH 7.2 5.1 5 5.1 5.5-9 2 BOD mg/l 240 120 - 168 30 3 COD 3120 800 - 880 -- 4 SS - 99 - 31 100 5 TDS - 5544 - 1944 -- 6 Chlorides - 4000 - 500 -- 7 Sulphate - 575 - 500 -- 8 Phenolic

Compounds - 12 - 16 1.0

9 Oil & Grease - ND - ND 10

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Source : Merchem Limited, Eloor. Date of sample collection :11-2-05 Sample Identification No :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)).


Determinant Unit Mixing water from the sump near the main plant to the second sump

Flare stack water seal sample

Sample from the final sump

Sample from the equalization tank inlet (sample 1)

Sample from the equalization tank inlet (sample 2)

Tolerance limit

1 pH 8.4 10.9 9.1 9.1 9.1 5.5-9

2 BOD mg/l 500 2800 244 560 440 30 3 COD 5360 25280 2880 8720 5440 -- 4 SS 329 285 272 29 61 100 5 TDS 6310 8540 3500 3390 3460 -- 6 Chlorides 650 250 1600 1300 750 -- 7 Sulphide ND 1248 ND ND ND 2.0 8 Phenolic

Compounds 1.25 2.5 0.8 0.88 0.6 1.0

9 Oil & grease ND 10 ND ND ND 10 Source : Merchem Limited, Eloor. Date of sample collection :11-2-05 Sample Identification No :LAEC 53(Sludge-Final pumping sump). Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Sludge-Final pumping sump

1 Cyanides mg/kg BDL 2 Phenolic Compounds BDL 3 Organo Chlorine

Compounds 62.25

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Source : Merchem Limited, Eloor. Date of sample collection :14-2-05 Sample Identification No :LAEC 97(Aeration tank outlet)

LAEC 98(Bio tower inlet) LAEC 99(Bio tower outlet) LAEC 100(Raw effluent) LAEC 101(Final Outlet).


Determinant Unit Aeration tank outlet

Bio tower inlet

Bio tower outlet

Raw effluent

Final Outlet

Tolerance Limit

1 pH 7 3.9 6.5 11.3 5.8 5.5-9 2 BOD mg/l 108 436 330 996 52 30 3 COD 880 1600 960 2720 240 -- 4 SS 2256 983 81 304 46 100 5 TDS 5548 5120 5784 7760 1968 -- 6 Chlorides 2900 1200 2000 1400 600 -- 7 Sulphate 600 900 900 750 1250 -- 8 Sulphide ND ND ND ND ND 2.0 9 Phenolic

compounds 0.93 0.22 0.2 1.1 ND 1.0

10 Zinc ND ND ND ND ND 5.0 Source : Merchem Limited, Eloor. Date of sample collection :19-2-05 Sample Identification No :LAEC 32(Raw effluent)

LAEC 37(Sump near Caustic Scrubber). Name of the Lab : Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Raw effluent Sump near Caustic Scrubber

Tolerance limit

1 PH 6.0 5.5 5.5-9 2 BOD mg/l 108 200 30 3 COD 1920 2400 -- 4 SS 444 120 100 5 TDS 3608 5444 -- 6 Zinc ND ND 5.0 7 Iron 100 250 -- 8 Lead ND ND -- 9 Cadmium ND ND -- 10 Copper ND ND -- 11 Nickel ND ND -- 12 Arsenic ND ND -- 13 Chlorides 1000 2000 -- 14 Sulphate 2300 1100 -- 15 Cyanide ND ND -- 16 Sulphide ND ND 2.0 17 Phenolic Compounds 1.22 .410 1.0 18 Titanium ND ND --

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Source : Merchem Limited, Eloor. Date of sample collection : 23-2-05 Sample Identification No :LAEC 153(outlet) Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Outlet Tolerance limit

1 pH 5.6 5.5-9 2 BOD mg/l 50 30 3 SS 61 100 4 COD 480 -- 5 TDS 6008 -- 6 Free Chlorine ND -- 7 Zinc ND 5.0 8 Iron ND -- 9 Nickel ND -- 10 Chlorides 800 -- 11 Sulphate 1375 -- 12 Sulphide ND 2.0 13 Magnesium 30.49 -- 14 Phenolic Compounds ND 1.0 15 Hexa chromium ND -- 16 Total Chromium ND -- 17 Manganese ND -- 18 Oil & grease ND 10 Source : Merchem Limited, Eloor. Date of sample collection :25-4-05 Sample Identification No :LAEC 183(Kuzhikandam thodu)

LAEC 184(Raw effluent) LAEC 185(Treated effluent).


Determinant Unit Kuzhikandam thodu

Raw effluent

Treated effluent

Tolerance limit

1 pH 6.4 10.9 6.7 5.5-9 2 BOD mg/l 30 280 128 30 3 COD 368 3360 1184 -- 4 SS 480 628 98 100 5 TDS 1396 12536 9304 -- 6 Iron 378 468 9.4 -- 7 Chlorides 400 700 900 -- 8 Sulphide ND ND ND 2.0 9 Phenolic Compounds 0.14 1.32 0.4 1.0 10 Colour hazen 40 480 200 --

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Source : Merchem Limited ,Eloor. Date of sample collection :1-6-05 Sample Identification No :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.)

Name of the Lab :Central Laboratory, Gandhi Nagar. Sl. No.


LAEC 196

LAEC 197

LAEC 198

LAEC 199

Tolerance limit

1. pH 6.5 5.6 9.3 12.8 8.6 5.5 – 9 2 BOD mg/l 90 12 108 568 198 30 3 COD 960 96 1232 7120 2400 -- 4 SS 977 196 132 664 825 100 5 TDS 9872 792 1896 9970 4690 -- 6 Zinc ND ND ND ND ND 5.0 7 Iron 174 11.8 1.4 18.7 42.6 -- 8 Chlorides 300 140 120 1400 2000 -- 9 Sulphates 4000 550 750 700 450 -- 10 Manganese 165 39 ND ND ND -- 11 Phenolic

Compounds 1.2 ND 2.3 2.5 1.5 1.0

12 Colour Hazen 640 20 40 3200 2000 -- Source : Merchem Limited, Eloor. Date of sample collection :30-7-05 Sample Identification No : 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)



LAEC 96

LAEC 95

LAEC 18

LAEC 41

1 pH 8.5 8.3 7.1 6.5 8.3 2 BOD mg/kg 266 20 1.0 1.2 508 COD ,, 8320 800 80 80 11920 4 SS ,, 15 68 10 210 38 5 TDS ,, 9889 10334 100 143 15824 6 Zinc ,, ND ND ND ND ND

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7 Iron ,, 15.4 14.7 0.07 0.16 36 8 Lead ,, ND ND ND ND ND 9 Chlorides ,, 1200 1000 4 5 2600 10 Nitrates ,, ND ND ND ND ND 11 Phospates ,, ND ND ND ND ND 12 Sulphates ,, 7184 8220 30 25 10524 13 Sulphides ,, ND ND ND ND ND 14 Phenolic

compound ,, 1.9 0.08 0.035 0.02 0.93

15 Hexa Chromium

,, ND ND ND ND ND

Source : Merchem Limited, Eloor. Date of sample collection :30-7-05 Sample Identification No : 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));



LAEC 27

LAEC 92

LAEC 235

LAEC 342

1 pH 8.7 12.5 8.2 12.6 9.4 2 BOD mg/kg 548 490 286 526 502 COD ,, 15040 13800 9040 12630 12800 4 SS ,, 268 35 48 126 76 5 TDS ,, 16987 26246 16613 26990 20050 6 Zinc ,, ND 0.1 ND 0.11 ND 7 Iron ,, 25.6 22.8 1.3 14.15 20.7 8 Lead ,, ND ND ND ND ND 9 Chlorides ,, 5200 5400 1200 10600 7000 10 Nitrates as N ,, ND ND ND ND ND 11 Phospates ,, ND ND ND ND ND 12 Sulphates ,, 6255 15224 8112 5575 5958 13 Sulphides ,, 232 ND ND ND ND 14 Phenolic

compound ,, 0.25 1.9 2.7 2.5 1.14

15 Hexa Chromium

,, ND ND ND ND ND

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Source : Merchem Limited, Eloor. Date of sample collection : 30-7-05 Sample Identification No :LAEC EV(Effluent before entering RO) Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Effluent before entering RO

1 pH 8.2 2 BOD mg/kg 272 3 COD ,, 10240 4 SS ,, 296 5 TDS ,, 8303 6 Zinc ,, ND 7 Iron ,, 1.5 8 Lead ,, ND 9 Chlorides ,, 1100 10 Nitrates as

N ,, ND

11 Phospates ,, ND 12 Sulphates ,, 6003 13 Sulphides ,, ND 14 Phenolic

compound ,, 1.79

15 Hexa Chromium

,, ND

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COCHIN MINERALS AND RUTILE LTD, EDAYAR 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 71 88 FerricChloride 42 92 Ferrous Chloride 43 91 Avg. t/day Raw materials :Ilmenite 125 Coke 13 Hydrochloric Acid 175 FuelOil 10 KL Chlorine 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.

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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 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 31-12-2004 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) -3.9 high concentration of Iron - 2005 mg/l Lead -1.14 mg/l Manganese -16.46 mg/l

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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 . 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.

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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 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

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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 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 .

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pH -4.4 Suspended Solids -1410 mg/l Zinc -2.01 mg/l Iron -12238mg/l Lead -4.29 mg/l Chlorides -33500 mg/l Manganese -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 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

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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. 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

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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. 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


SL.No Characteristic Unit Tolerance limit

1 pH 6-8.5 2 Suspended Solids mg/l 30 3 Oil and Grease ,, 10 4 Hexavalant Chromium (asCr) ,, 0.1 5 Total Chromium (asCr) ,, 2 6 Manganese ,, 2 7 Nickel ,, 2 8 Titanium (asTi) ,, 5 9 Copper ,, 2 10 Zinc ,, 5 11 Cadmium ,, 0.2 12 Mercury ,, 0.01 13 Lead ,, 0.1 14 Cyanides ,, 0.2 15 Total Heavy metals ,, 7

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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 Minerals and Rutile Ltd., Edayar Date of sample collection :26-11-04 Sample Identification No :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)).


Determinant Unit

Soil near equalization tank

Lime slurry collec-tion tank

Solid collec-tion yard

Block of soil from riverside (near pump house)

Soil from the storm water drain

Sludge from the CMRL premises (backyard of cochin fertilizers)

1 Zinc mg/kg

130.9 415.0 424.2 135.8 70.2 322.5

2 Iron ,, 2494.7 2696.3 2425.1 2587.0 2336.1 2895.5 3 Lead ,, 70.0 127.0 206.0 93.0 67.0 133.0 4 Mercury ,, 0.01 0.02 0.02 0.03 ND ND 5 Cadmium ,, 2.8 6.4 6.5 4.9 1.5 1.8 6 Copper ,, 21.5 22.3 63.8 14.7 10.0 124.0 7 Nickel ,, 60.4 67.0 69.6 24.9 24.3 53.6 8 Total

Chromium ,, 74.9 208.3 830.0 173.7 408.6 94.9

9 Manganese ,, 560.9 877.6 460.6 124.5 62.2 71.4 10 Hexavalant

chromium ,, 3.5 18.1 185.6 7.2 80.5 3.6

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Source : Cochin Minerals and Rutile Ltd.,Edayar` Date of sample collection : 26-11-04 Sample Identification No :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)).


Determinanat Unit Autho-rised 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

1 pH 6.8 9.6 7.5 3.3 3.9 6-8.5 2 SS mg/l 8 20 22 15 35 30 3 Zinc ND ND 0.77 0.6 0.15 5 4 Iron ND ND 1.28 13.79 2005 -- 5 Lead 0.62 ND ND 0.1 1.14 0.1 6 Mercury ND ND ND ND ND 0.01 7 Cadmium ND ND ND ND 0.03 0.2 8 Copper 0.07 ND ND 0.04 0.07 2 9 Nickel 0.17 0.02 ND 0.11 0.35 2 10 Cyanides ND ND ND ND ND 0.2 11 Hexa.

Chromium ND ND ND ND ND 0.1

12 Total Chromium

ND ND ND ND 0.04 2

13 Manganese 0.072 ND ND 0.6 16.46 2 14 Oil and Grease ND ND ND ND ND 10 15 Titanium ND ND ND ND ND 5 Source : Cochin Minerals and Rutile Ltd., Edayar Date of sample collection : 21-12-04 Sample Identification No :LAEC 37(Hazardous waste from CMRL used for brick

making) LAEC 38(Hazardous waste mixed with clay for making brick).


Determinant Unit Hazardous waste from CMRL used for brick Making

Hazardous waste mixed with clay for making brick

1 pH 5.1 4.1 2 Zinc mg/kg 493.1 176 3 Iron 352250 548.1 4 Lead 190 142

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5 Mercury 0.03 0.02 6 Cadmium 8.3 5.6 7 Copper 56.4 48.1 8 Nickel 61.1 48.9 9 Total chromium 277.9 152 10 Manganese 714 328 Source : Cochin Minerals and Rutile Ltd., Edayar Date of sample collection : 28-12-04 Sample Identification No :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),

Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar.

Sl. No.

Determinant Unit 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

1 pH 6.5 4.7 2.1 1.9 6.5 6-8.5 2 BOD mg/l 6 10.0 20 16.0 2.0 -- 3 COD 26 560 480 64 17.2 -- 4 SS 8 215 460 8 8 30 5 Chlorides 2600 18800 1750 31200 2750 -- 6 Cynide ND ND ND ND ND 0.2 7 Sulphide ND ND ND ND ND -- 8 Phenolic

Compounds 0.1 1.4 0.08 0.5 0.08 --

9 Total residual Chlorine

ND ND ND ND ND --

10 Oil & grease ND ND ND ND ND 10 11 Hexa

chromium ND ND ND ND ND 0.1

12 Zinc ND ND ND ND ND 5 13 Iron ND 106.5 225 280.8 ND -- 14 Lead ND 0.4 0.03 0.45 ND 0.1 15 Mercury ND ND ND ND ND 0.01 16 Cadmium 0.023 0.321 0.052 0.243 0.03 0.2 17 Copper 0.171 0.85 0.028 0.906 0.053 2 18 Nickel ND ND ND ND ND 2 19 Manganese ND ND 8.2 ND 2.1 2 20 Titanium ND ND ND ND ND 5

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Source : Cochin Minerals and Rutile Ltd., Edayar Date of sample collection : 26-1-05 Sample Identification No : LAEC 19(Final outlet point in Periyar river). Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Final outlet point in Periyar river

Tolerance limit

1 pH 5.8 6-8.5 2 SS mg/l 2100 30 3 TDS 12400 -- 4 Chlorides 6515 -- 5 Cyanides ND 0.2 6 Oil & Grease ND 10 Source : Cochin Minerals and Rutile Ltd., Edayar Date of sample collection : 26-1-05 Sample Identification No : LAEC 26(Metals). Name of the Lab : Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Metals Tolerance Limit

1 Zinc mg/l 1.697 5 2 Iron 1881 -- 3 Cadmium 2.263 0.2 4 Copper 0.235 2 5 Nickel 0.501 2 6 Total Chromium 1.087 2 7 Manganese ND 2 8 Titanium ND 5 9 Lead 2.2 0.1 10 Mercury ND 0.01 11 Arsenic ND -- 12 Hexa Chromium ND 0.1

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Source : Cochin Minerals and Rutile Ltd., Edayar Date of sample collection : 1-1-05 Sample Identification No :LAEC 81(Sample taken by Solidarity from final discharge

point of CMRL in River) Name of the Lab :Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.

Determinant Unit Sample taken by Solidarity from final discharge point of CMRL in River

Tolerance limit

1 pH 4.4 6-8.5 2 SS mg/l 1410 30 3 Zinc 2.01 5 4 Iron 12238 -- 5 Lead 4.29 0.1 6 Mercury ND 0.01 7 Cadmium 0.192 0.2 8 Copper ND 2 9 Nickel ND 2 10 Chlorides 33500 -- 11 Cyanides ND 0.2 12 Hexa chromium ND 0.1 13 Total Chromium 0.41 2 14 Manganese 11.2 2 15 Oil & grease ND 10 16 Titanium ND 5 Source : Cochin Minerals and Rutile Ltd., Edayar Date of sample collection : 1-4-05 Sample Identification No : LAEC 178 (outlet) Name of the Lab : Central Laboratory, K.S.P.C.B, Gandhi Nagar. Sl. No.


Tolerance limit

1 pH 9.5 6-8.5 2 SS mg/l 8 30 3 Zinc ND 5 4 Lead 2.92 0.1 5 Cadmium ND 0.2 6 Copper 0.03 2 7 Nickel 0.08 2 8 Cyanides ND 0.2 9 Hexa chromium ND 0.1 10 Total Chromium ND 2 11 Manganese 0.3 2 12 Oil & grease ND 10 13 Titanium ND 5

BINANI ZINC LIMITED EDAYAR - People's Union for … (ZnO.Fe 2 O 3). Leaching of Calcine is carried...

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