Report of the Court Commission for Visiting the Industrial Areas of Balotra, Jasol and Bithuja and the Effluent Management System Including CETP and Effluent Disposal Areas (HRTS)
With Reference to Order of Hon’ble National Green Tribunal, Principal Bench dated 5th may 2018 in Original Application No. 34(THC)/2014 Digvijay Singh Vs. State of Rajasthan and oths; along with several other tagged matters
(Solar Evaporation Pond at Balotra)
Dr. Ajay A. Deshpande May 2018
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Report of the Court Commission for Visiting the Industrial Areas of Balotra, Jasol and Bithuja and the Effluent Management System Including CETP and Effluent Disposal Areas (HRTS) A. SCOPE OF COMMISSION
1. Hon’ble NGT in its order dated 5th may 2018 in Original Application No. 34(THC)/2014 Digvijay Singh Vs. State of Rajasthan and oths; along with other tagged matters has appointed undersigned as Court commissioner. The relevant portion of the daily order dated 5th may 2018 is reproduced for clarity. “In view of the aforesaid submissions and counter submissions made by the Learned Counsels for the respective parties and the fact that present condition at the site has been disputed by them, we deem it justify and proper to appoint a Court Commissioner who shall visit the site and submit a report, in the light of the aforesaid directions passed by the Tribunal on 04th October, 2017. In this regard, we request Dr. Ajay A. Deshpande, Former Expert Member of NGT, to visit the site and submit the report, as to whether there is any breach in the HRTS facility or flow of treated and untreated affluent into the river Luni and the RO discharge has been properly transferred from CETP to HRTS facility or not.” The Tribunal further directed that “The Learned Court Commissioner is also requested to see as to whether the establishment of HRTS is proper and in accordance with law or not.” 2. It is also necessary to mention that the court in the order of 5th May 2018 has referred to the 4th Oct 2017 order when certain issues were flagged and specific directions was given to the authorities. As the court has referred order Dated 4th Oct 2018 and also a copy of the same has also been ordered to be communicated to undersigned, it is necessary to refer to this order of 4th October 2017 to clearly understand the scope of the Commission. The order states “Presently, our consideration is confined to the following issues raised by the Applicant:- 1. The breach in the HRTS facility 2. The non-functioning of the CETP consequent to which unchecked discharge of affluent into River Luni. 3. Frequent breach in the HRTS Wall.”
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“For the purpose of ensuring that there is no frequent instance of breach in the HRTS facilities or flow of treated or untreated effluent into the river Luni and to ensure that RO discharge is properly transferred from the CETP to HRTS facility. CPCB and SPCB shall conduct joint inspection periodically once in three months and if they find breach of any of the conditions issued they may file report in the Tribunal.” 3. In view of this order of the Hon’ble Tribunal, undersigned visited the area under reference i.e. Balotra, Jasol and Bithuja on 9-10th May 2018 and carried out commission. The Broad scope of the commission was outlined to all the stakeholders in the initiation meeting held at SDM, Balotra’s office on 9th May 2018 which was agreed to by all the stakeholders. The list of officials and other participants in this meeting is enclosed at Annexure-1. The broad scope of commission was outlined as under; a. Visit to all CETPs and observe the treatment and disposal practices of effluent b. Visit to HRTS areas and understand the rationale and design of HRTS to assess its performance c. Visit to the sites of alleged breaches of HRTS wall and the leakage/seepage in the river bed, as claimed by the Applicant’s.
B. BACKGROUND
4. Balotra is a city in Barmer district, about 120 km from Jodhpur. The industries at Balotra are situated in three main industrial clusters namely; Balotra, Jasol and Bithuja. The Jasol industrial area is located across the Luni River opposite Balotra town. Bithuja industrial area is located about 4 to 5 kilometers in the upstream of the river Luni from Balotra. The textile industries are reported to be in operation in this area since last more than 60 years. These industries are mainly involved in washing, dyeing and printing of the gray cloth received from various industries located in Maharashtra and Tamil Nadu. After the processing, the coloured cloth is sent back again for manufacturing garments. During the meeting, it was informed that there are about 400 industrial textile industries located at Balotra. Many of these industries were earlier in operation from the Balotra city; however, these industries were shifted to the industrial area developed by RIICO. At Jasol industrial area, there are about 112 industries and they are mainly located on the private lands. However, as most of these units are located along the road and in vicinity of each other, a common effluent collection
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and treatment system was possible. The Bithuja industrial area accommodates about 214 industries which are involved in only caustic washing besides de-sizing and mercerizing activities. The textile industries are categorized in ‘Red’ category of industries and generate large quantities of wash water, which is polluting both the water and soil in the area. There is no clear information whether some industries have shifted to acid use for washing required for polymer clothing.
Location map of the Balotra, Jasol and Bithuja CETP and HRTS
5. Balotra Water Pollution Control & Research Foundation Trust was established during September 1995 for the purpose of construction, operation and maintenance of the Common Effluent Treatment Plant (CETP) in the territorial jurisdiction of Balotra Municipal Board. It was also mentioned that these industries are facing legal actions since 1990. Initially, 6 MLD CETP was made operational somewhere in 1999 which was further upgraded to a new additional CETP of 12 MLD capacity in 2006. Additionally another CETP of 18 MLD was commissioned in 2014 for which environmental clearance was granted in June 2009. However surprisingly this EC neither prescribe the quantity of the effluent be treated in CETP nor the required discharge standards and effluent disposal mode. Similarly, Jasol 2.5 MLD CETP was established in 2004 and its augmentation with new CETP of 4 MLD was commissioned in 2012. Bithuja 30 MLD capacity CETP was established in 2006.
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C. SITE VISIT
6. On 9th May 2018, a stakeholder meeting was held at the office of Sub-divisional magistrate (SDM) Balotra wherein the stakeholders including SDM, officers of RPCB, RIICO, representatives of Balotra, Jasol and Bithuja CETP and original Applicant Mr Digvijay Singh were present. However, no representatives of CPCB were not present though due intimation of the commission was given to CPCB by RO, RPCB Balotra. RIICO representatives only participated in meeting and did not accompany during the site visits.
7. The CETP office bearers informed about the effluent management system including the CETP and disposal arrangements. They also informed about proposed up gradation including ZLD scheme approved under Govt of India scheme. They further pointed out that there are more than 100 industrial units which have obtained the consent with zero liquid discharge condition and they are not members of the CETP. These industries manage effluent treatment and disposal themselves and it is apprehended that many of these industries are not complying with norms and may be contributing to the river and the groundwater pollution. The SDM informed that the industries have now proposed a zero discharge up gradation and moreover, government has recently allotted about 750 bighas of land on lease (new HRTS site). He further informed that they have already been allotted to 278 bighas of land for the solar evaporation ponds (Old HRTS site).
SDM further informed that some complaints regarding the unauthorized discharge of the effluent from the CETP and its disposal Area into adjoining lands were received and the complainants and the CETP have mutually resolved these complaints by compensating for the losses after duly verifying each of the complaint. He clarifies that the administration is not involved in such negotiation and settlement. A statement submitted by CETP management shows that there are 14 cases of compensation settled from 3/10/2017 to 19/04/2018 totaling to Rs. 9,18000/-. However, there are no details how much land is affected and how the compensation amount has been calculated. Mr. Digvijay Singh informed about the regular breach, leakage and seepage from CETP and HRTS areas and stated that the entire ground water has been polluted. He also referred to NPC report which was commissioned by Govt of Rajasthan and stated that the report has not been implemented so far.
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D. CETP
8. There are 6 total CETP in Balotra, though only 3 are in operation now. Their details and capacity is as under: • Balotra- 6 mld (1999-note operational), 12 MLD (2006-not operational ) and 18 MLD (2014) • Jasol-2.5mld (2004-not operational), 4 MLD (2012) • Bithuja-30 mld (2006)
The CETP Association informed that the 18 MLD CETP at Balotra is operating at 6-8 MLD effluent intake in order to achieve the consented discharge standards. It was also informed that they are upgrading the CETP to ZLD status with the scheme approved by Govt. of India. In the meantime, the present RO system of 6 MLD designed for 12,000 mg/lt TDS (Total Dissolved Solids) will be upgraded to 20,000 TDS using imported filters. This up gradation will be complete by 31st May 2018. They further informed that 4 MLD CETP plant at Jasol is also operated at 40% capacity with 2.5 MLD existing RO plant. An additional 2 MLD RO unit is being installed. CETP at Bithuja will be upgraded for ZLD and caustic recovery is also proposed there.
9. It is an admitted fact that the CETPs at Balotra, Jasol and Bithuja are being operated at lower hydraulic capacity in view of the high concentration of the TDS in the incoming effluent and inadequacies of existing CETPs to deal with such high concentration influent. CETP management is regulating the influent intake from industries association through SCADA operation. RPCB officials could not confirm whether RPCB or CPCB has issued any such specific directions to reduce the effluent generation or production levels in consonance with the CETP operational capacity. In absence of such statutory directions, it is only operational directives from the CETP authorities.
10. According to RPCB, there is no CETP influent design criteria specified for TDS , however, during discussions CETP management mentioned that they expected @4-5000 TDS in the incoming effluent. Whereas the present inlet TDS concentration is reported to be ranging from 15,000 to 20,000 mg/lt. CETP office bearers present during the site visit attribute such high concentration of TDS to the very high TDS in the groundwater which is used as raw material in manufacturing process. RPCB officials presented the data of the ground water quality which indicates that the TDS concentration in ground water in the
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surrounding areas ranges from 3000 to 20,000 mg/lt. The highest concentration of TDS is found to be within the Balotra industrial area. RIICO also supplies the ground water to some industries with TDS of about 5000 to 8000 mg/lt which itself is high. The present RO systems provided at the CETP are designed for TDS of about 12000 mg/lt and therefore, practically most of the effluent is cannot be treated in the RO. CETP management informed that recent notification of MoEFCC dated 1.1.2016, on CETP discharge standards takes into account the high TDS in water used by industries and gives flexibility to SPCBs to revise the standards accordingly. They further informed that they have already received necessary clarification from MoEFCC and have requested RPCB to revise the TDS standards which is under consideration.
11. Still however, at Balotra CETP, presently RO rejects which is about 60% to 65% of the total effluent is discharged in the evaporation ponds with TDS of about 30,000 mg/lt. This was confirmed by CETP authorities though RPCB data on treated effluent quality do not indicate such segregation of effluents and their high TDS concentrations. This effluent is taken to the sump near the old HRTS system from where it is pumped in the evaporation pounds. The supernatant with TDS of about 4000-6000 mg/lt is available for industrial use but many of the industries do not take this water for reuse in their manufacturing process due to the high cost of treated water. Therefore, even the treated effluent is partly coming back to the evaporation ponds, defeating the very purpose of providing the RO system. It is not known what regulatory interventions have been taken or made by RPCB to either convince the industries to reuse the RO treated effluent or to ensure that the industries are directed to reuse such a treated RO water. It would also be worth to explore whether RIICO can provide additional water with lower TDS. This will not only reduce the effluent reaching to the evaporation ponds but also ensure cost economic operation of CETP which is essential for sustained effluent management.
12. During the visit it was observed that the CETP treated effluent and RO rejects at Balotra are taken to solar evaporation ponds through a closed HDPE pipeline via sump which is located near the ponds. Mr. Digvijay Singh informed that earlier the CETP effluent was brought through open storm water drain. Some effluent was found to be stagnant in this open drain which CETP authorities agreed to lift immediately. CETP authorities informed that due to laying of underground effluent collection conveyance pipelines, there is significant variation in the hydraulic inlet levels and thereby in hydraulic retention capacity
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Bithuja: Use of Mechanical Foggers: water is sprayed for increasing evaporation.
Effluent Stored At Bithuja CETP Evaporation Ponds, Just Next To River Bed
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of various unit processes which they are trying to optimize with balancing the CERTP operations.
13. Other major concern which was observed during the visit to CETPs is handling of hazardous waste. Due to the high TDS and also high pH due to use of caustic soda, the sludge generation at CETP is very high. Particularly, in Bithuja, where only caustic effluent is reaching CETP from washing operations, this problem is more serious. The photographs attached shows that large quantity of the hazardous waste is accumulated in the dried evaporation ponds and similarly huge quantity of the sludge is stored along the ponds. Similar conditions prevail at Balotra and Jasol too, where the coloured sludge which indicates presence of chemicals and more particularly the heavy metals, is generated in significant quantities. CETP has recently installed some centrifuge to reducing the water content of the sludge. This sludge is then solar dried in unscientific and crude manner resulting in very high moisture retention (45-55% as informed) in this sludge before it is sent to common hazardous waste disposal facility. The CETP needs to evolve innovative techniques to handle this large quantity of hazardous waste in order to ensure that the moisture content in the sludge is reduced. One of the alternatives is use of the solar energy. As this area has abundant sunshine and also sunny days, the solar energy options for drying of the waste seems to be practical and economically attractive. This will not only reduce the sludge quantity but also reduce the cost of the waste disposal making the CETP operations sustained.
Hazardous Waste at And Near The Evaporation Ponds At Bithuja CETP
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Hazardous Waste Unscientifically Being Handled At Jasol CETP
CETP Sludge Being Handled and Stored At Balotra CETP
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14. In this entire background, the role of regulatory authorities of RPCB and CPCB becomes very crucial. RPCB has the mandate not only of regulatory nature, but also, more importantly of facilitation and research oriented approach towards waste management under section 17 of Water (P &CP) Act, 1974. Similarly, CPCB has a very important scientific and coordination role as specified in Section 16 of Water (P&CP) Act, 1974. As per information received from RPCB, there is no research or performance evaluation studies conducted for individual ETPs or CETPs or its unit processes, making entire enforcement dependent on the claims of the industries. This litigation has a very chequered history of more than a decade, mainly revolving around efficient and sustained operations of CETP; and therefore, both these organisation should have played a more proactive scientific and technical role in addressing the complex issues, rather than strictly following the regulatory approach which is evident from the consent management and directions issued to various industries on regular basis.
15. It is manifest from the above that though the CETPs have been installed at all three places i.e. Balotra, Jasol and Bithuja, admittedly; they have been installed after a substantial time gap after commissioning of Industries. The operational CETPs are not adequate to meet the desired standards even for reduced hydraulic intake capacity than the designed one. The RO rejects which have very high TDS of @ 30,000 mg/lt are disposed for solar evaporation, at the evaporation ponds which are not lined. The entire CETP development and augmentation efforts seem to be in reactive mode in response to regulatory or court orders. It is necessary to take a holistic view in design, operation and maintenance of entire effluent management including CETP, disposal and reuse of effluent. Even now, new augmentation is planned to achieve ZLD that would involve huge expenditure. As huge money has already been spent on CETPs, it would be worth to conduct a thorough appraisal and performance studies through reputed organizations like NEERI or IIT.
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E. HRTS (SOLAR EVAPORATION PONDS)
16. Considering the special mandate given for the present commission, specific query was raised with RPCB about the design criteria of this ‘HRTS system’ and was also discussed with CETP authorities. As per RPCB, the present HRTS (solar evaporation) was established in 2012 after the directions by Hon’ble Rajasthan High court for no discharge in river. CETP authorities and office bearers informed that they are newly elected and as per their information, HRTS was first mooted by NEERI in the feasibility report, a copy of which shared with undersigned. On close review of this document (Basic Engineering package for CETP at Bithuja- September 2003) , it is manifest that NEERI has clearly mentioned that detailed design and cost of treatment for removal of TDS have not been worked out, considering high cost. NEERI further, advised industries to regulatory agencies, in view of high TDS and non-feasibility of centralized TDs treatment. NEERI then mentions HRTS, plantation/horticulture one of the option in the feasibility report of 2003 for the treated effluent disposal. However, it was not the only or even recommended option for treated effluent disposal. Further, no specifications or detailing of such scientific HRTS system has been provided by NEERI nor any further inspection or guidance has been given by NEERI. One document on internet shows TERI has given some advisory services on CETP up gradation of the HRTS system. However, no details could be made available.
17. NEERI, whose reference was quoted during the site visit, has described the High rate transpiration system (HRTS) on their website (http://www.neeri.res.in/content/high-rate-transpiration-system-hrts) as having following characteristics;
• HRTS involves the use of dynamic, multicomponent soil system as a live filtration device to renovate the wastewater through adsorption, ion exchange, precipitation and stabilization of pollutants through microbial degradation • HRTS is a land application system wherein the wastewater is applied in especially designed field layouts with wide ridges and furrows. In ridges, trees are planted having much higher transpiration capacity, while wastewater is allowed to flow through the furrows • The high transpiration capacity of plants grown on soil matrix enables the system to serve as a biopump
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• The soil system works in close conjunction with plants on it that provide a bio-pump through their high transpiration capacity through stomatal network. As all the wastewater is utilized in this process, the ground water pollution problem is obviated • In addition to this, artificial filter media and leaf fall from standing plants provide thick mat and forms a filter bed, which is responsible for retention and assimilation of colour bodies • Thus, the treatment and disposal of wastewater through HRTS provide cost effective and environmentally acceptable solution to manage the problem of coloured wastewaters
18. As per information hosted by NEERI on its website, the high rate transpiration system for treatment and disposal of wastewater works on the following principles:
• Transpiration of large amount of water through stomatal network • Waste renovation using soil as a physico-bio chemical reactor • Assimilation of colour in filter media
Phytoremediation (‘phyto’ means plant) is a generic term for the group of technologies that use plants for remediating soils, sludge, sediments and water contaminated with organic and inorganic contaminants. Phytoremediation can be defined as “the efficient use of plants to remove, detoxify or immobilize environmental contaminants in a growth matrix (soil, water or sediments) through the natural biological, chemical or physical activities and processes of the plants”.
19. Interestingly, RPCB has issued consents to these CETPs in a very inconsistent manner. Firstly, separate consent to operate exist for multiple CETPs existing in the same complex (like Balotra), though these CETPs share much of the infrastructure. Secondly there is a variation in waste disposal conditions, TDS standards etc. Consent is given only under Water act, though CPCB has already advised all the SPCBs to give common consent under Water and Air Acts, along with HW authorization to enable a focused and simplified enforcement of regulations. The table below presents such discrepancies;
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CTE CTO Date Disposal TDS Date Disposal TDS standards standards mg/lt mg/lt Balotra 11.7.201 ZLD, no Reuse and 8.5.2018 HRTS Not 18 MLD 1 discharge recycle specified Balotra 25.3.04 HRTS IS: 2470 6.1.18 Land, agriculture 2100 12 MLD Balotra 11.10.13 Land, agriculture 2100 6 MLD Jasol 4 6.7.10 In river 2100 27.10.15 2500 cum recycle, Not MLD 1500 evaporation specified Bithuja 26.5.14 On land for Not 30 MLD agriculture/ specified horticulture/ other use. Install RO and ZLD
20. On physical inspection of all the so called HRTS areas, it was observed that al all the places including Balotra, Jasol and Bithuja there is no HRTS system that has been provided for disposal of treated waste waters from CETP. In fact, there are only solar evaporation ponds for drying of the treated effluent. Over the years, CETP has installed mechanical foggers/sprinklers to enhance the evaporation rates by sprinkling waste waters. The CETP authorities and also, RPCB officials agreed to this finding that there is no HRTS system but only solar evaporation system for treated effluent.
21. The fact that there is no plantation or agriculture as a part of HRTS, is not unknown to RPCB and CPCB as numerous visits have been paid to the site by all these authorities over all these years. However, in spite of this proven and established fact that there is neither HRTS system nor any plantation provided for disposal of treated effluent at Balotra, Jasol and Bithuja, all these authorities are still continuing to call the present arrangement of solar and forced evaporation of effluent as HRTS, which is rather surprising and a matter of grave concern. A clarification as to why such arrangement was referred as HRTS was called from RPCB. As CPCB did not participate in the visit, in spite of information communicated by RPCB, this information could not be called from CPCB. Being the technical and scientific regulatory authorities, it was rather necessary for RPCB and more essentially for CPCB, to put the correct picture before NGT, that
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there is neither HRTS system nor plantation/agriculture but only, combination of solar and forced evaporation of mostly untreated effluent. More interestingly, even the regular consent to operate renewal for these CETPs was also granted with waste disposal through HRTS and/or plantation/agriculture, while there was clear knowledge that such systems do not exist at site.
F. LEAKAGE/SEEPAGE OF EFFLUENT INTO THE RIVER
22. In order to verify that whether there are any discharges of effluent from the ponds to the river, the present arrangements were evaluated on primary basis for following safeguards. a. Adequate capacity of the ponds, which needs to be decided based on hydraulic flow reaching the ponds, Solar evaporation rate in the area b. Inside Lining of the tanks c. Structural strengthening of the dyke wall along the river length.
23. The primary method of waste disposal at Bithuja and Balotra is solar evaporation ponds installed whereas in Jasol, solar evaporation ponds are smaller and part of CETP due to higher capacity of RO plant. As per the information received from RPCB, the status of these solar evaporation ponds is as under;
No. Of ponds Total No. of No. of mechanical completely lined/ Area Ha ponds and total blowers installed and HDPE-Concrete and area in m2 their rated capacity total area m2 Balotra Old 44.68 5 Nos. 2 Nos. 13 Nos. HRTS 216012.02 sqm 71700.00 sqm 20 KL/hr. each Balotra 37.04 7 Nos. 7 Nos. 10 Nos. New HRTS 109000.00 sqm 109000.00 sqm 30 KL/hr. each Proposed (applied for electricity connection) Jasol ------Bithuja 6.96 4 Nos. 5 Nos. 57096.39 sqm 20 KL/hr. each
24. Be that as it may, it would be necessary to assess the adequacy of Evaporation ponds in order to ensure that there is no discharge of effluent in the river bed. It is necessary to note here that the ponds at Bithuja and Balotra CETP (old HRTS)
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are located next to the river bed. In fact, it is a grievance of the complainant that a major part of Bithuja evaporation ponds is located inside the river bed and he relies on the marking made by revenue department and has produced photograph of the same. However, as this is not part of the Commission, the issue has not been dealt here and the same can be addressed by revenue department independently. Ingress of effluent from CETP and evaporation ponds can be possible in four different scenarios
a. Seepage from the ponds b. Overflow from the ponds c. Leak/breach of ponds d. Any intentional discharge
25. In order to understand the above issues, it would be necessary to understand the local environmental setting for weather conditions, geography and ground water table. The published data on above parameters is presented below; a. The solar evaporation rate in Jodhpur is reported to be min. 2366 mm and max. 3518 mm and the trend of evaporation rate are ‘decreasing’. (Recent Variations and trends in Pan Evaporation in India, I.J. Verma and V.N. Jadhav, Indian Meteorological Department, Pune, Mausam, 3rd July, 2008, 347-356). Now considering the high concentration of TDS in treated wastewaters and also, the coloured effluent, the actual evaporation rate would be substantially lower than the above referred values. And therefore, while assessing the adequacy of solar evaporation ponds, it would be necessary to have an realistic assessment of the evaporation rate considering the high TDS from 12000-30000 as observed in treated effluent and RO rejects. This TDS concentration is bound to increase as the more and more evaporation happens in evaporation ponds. It is an admitted fact that the present capacity of the ponds is not even adequate for the reduced operating capacity of CETP at all the three locations namely; Balotra, Jasol and Bithuja. In view of this, the CETP management has now proposed two pronged approach, firstly, they are constructing a new series of ponds at newly allotted site near CHWTSDF and secondly, they are augmenting the evaporation by increasing use of the mechanical foggers.
b. Climate and Rainfall: Barmer the district experiences arid type of climate. Mean annual rainfall (1971-2005) of the district is 281.8 mm whereas
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normal rainfall (1901-1971) is lower than average rainfall and placed at 277.5 mm. Almost 90% of the total annual rainfall is received during the southwest monsoon, which enters the district in the first week of July and withdraws in the mid of September. As the district lies in the desert area, it faces extremes of heat in summer and cold in winter. Both day and night temperatures increase gradually and reach their maximum values in May and June. The temperature varies from 48 degree in summer to 2 degree in winter. Atmosphere is generally dry except during the monsoon period. Humidity is at its highest in August with mean daily relative humidity of 43%. The annual maximum potential evapotranspiration in the district is 1850 mm and it is highest (260 mm) in the month of May and lowest (77 mm) in the month of December. 3.0 Geomorphology and Soil Types Geographically, the area as a whole forms a part of the Great Indian Desert. Apart from a small offshoot of the Aravalli hills in the east, the area is a vast sandy tract. The country west of Luni River represents sandy plain dotted with bold hills. A well-defined valley is observed along Barmer- Gadra road to the east of Kharin. Pachpadra, Sanwarla and Thob are the major salt lakes in the district. A salt lake 3 locally called Rann is located east of Redana village. The surface elevation of the district varies from 70 above mean sea level (mamsl) at Sindhari to 457 mamsl at Ghonia village. The only major drainage course in the area is Luni River, which flows from Samdari, passing through Balotra. The river is ephemeral, flowing only in response to heavy precipitation. In the year of drought there is no run off.
c. A per the literature available, soils of the district are classified as follows: 1. Desert soil: Desert soil area is occupied by alluvium and wind-blown sand, yellowish brown, sandy to sandy loam, loose, structure less, well drained with high permeability and lies in northern, western and central parts of the district. 2. Sand dunes: These are non-calcareous soil, sandy to loamy sand, loose, structure less and well drained. Sand dunes lie in northern, western and central parts of the district. 3. Red desertic soil: These are pale brown to reddish brown soils, structure less, loose, and well drained. Texture varies from sandy loam to sandy clay loam. These soils occupy eastern and southeastern parts of the district. 4. Saline soil of depressions: This type of soil is found in salt lakes. They are dark grey to pale brown, heavy soils with water table very near to the surface and are distinctly saline. 5. Lithosols & Regosols of hills: This type of soil is found in isolated hills as lithoslopes. These soils are shallow with gravels very near
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to the surface, high textured, fairly drained, reddish brown in colour and lie in southeastern part of the district.
d. Central Ground Water Board periodically monitors the National Hydrograph Network Stations (NHNS) stations in the Barmer district, four times a year i.e. in January, May 6 (Premonsoon), August and November (Postmonsoon). Balotra - Pre-monsoon water level in m bgl 22.05; Post- monsoon water level in m bgl min 4.10 max 38.07 and variation in m 2.05. As per CGWB report, unconsolidated formation includes Quaternary alluvium that is most extensive, forms the potential aquifer and covers Balotra block of district. The exploration drilling data indicate that alluvium is composed of heterogeneous sequence of sand, silt, clay and kankar with occasional tongues and lenses of gravel and cobbles. The thickness of alluvium varies generally from 40 to 100 m. This information is important as this nature of soil prevent in the area would indicate the high percolation rate of the treated effluent disposed on land, leading to possibility of ground water pollution. CGWB has estimated the fresh ground water resources (as on 2009) for Balotra block (Excl. Saline) Total Net Annual Existing Existing Existing Allocatio Net G.W. Stage of Category annual Ground Gross Gross Gross n for availability G.W. replenish- Water Ground G.W. Draft Ground Dom. & for future Develo able Availability Water for Dom. Water Ind. irrigation pment, resource cum Draft for & Ind. Draft for Require- Dev.,cum % cum Irrigation, Use, cum all uses, ment, cum cum cum
22.1580 20.3290 24.3504 6.9387 31.2891 7.0519 0.0742 153.91 OVER- EXPLOITE D
e. A paper ‘Analysis Of Dyeing And Printing Waste Water Of Balotra Textile Industries’ By Pallavi Mishra* And Rajshri Soni , Department Of Chemistry, J. N. Vyas University, Jodhpur (Raj.) India has following finding. The textile effluents containing dye, printing and processing waste water of Balotra region were collected to study the concentration levels of different salts and metal ions in the effluents. Water samples were collected from ten different locations of Balotra region and various parameters were analysed viz pH, EC, TDS, COD, The concentration of Na+, Ca2+, Mg2+, Cl−, NO3 −, F− and the heavy metals (Cu, Fe, Cr, Ni, Zn, Pb Cd), which reveals that effluent discharge from the dyeing and printing textiles has great impact on the quality of water. The results show extreme variation from the standard WHO specifications. The samples were found to contain pH
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and electrical conductivity in the range 7.1 to 8.7 and EC from 2000 to 9000 μmhos/cm, respectively. The concentrations of biological oxygen demand (BOD) and chemical oxygen demand (COD) were found unexpectedly very high. A higher concentration of heavy metals was also detected. The concentration of nitrates and fluorides were very high from the limit set by WHO. f. One more report which is not authenticated indicates Calorific values of CETP sludge at Balotra as 4100 KL/kg and 8650 KJ/kg. it also shows presence of heavy metals concentration in textile sludge, particularly: Cu, Cd, Zn, Ni, Co, Cr-Vi, CR-III, and Pb in large quantities.
26. During the site visit to evaporation ponds at all the three locations; it was observed that the evaporation ponds are filled nearly up to the full capacity, more particularly at Bithuja and Balotra (Old HRTS). Though it was informed that 2 ponds at Balotra old site are lined; actually only one pond at Balotra is effectively lined up as the other pond of 150m x 150m, though lined up, is already submerged in a larger unlined pond. All the ponds are protected by embankments of wide sand bunds. These sand bunds do not have water retaining capacity nor have significant stability to function as water retaining structure. They are highly prone for breach/seepage.
27. These ponds are located along the river length and any accidental discharge will directly reach the river. The Oct 2017 incident also was of similar nature. The storage of such high TDS effluent in these unlined ponds, pose a serious risk of ground water pollution. The only positive factor naturally available is existence of an impermeable gypsum layer at 6-7 feet below the ground which exist in this area. However, any breakage of such natural layer can pose serious risk to lower aquifers. None the less, these ponds are constructed at higher level than the ground and therefore natural gradient flow of seepage through sandy soil will lead towards river. During the visit, oozing of effluent in small quantity was observed from one pond at old HRTS site at Balotra. The external walls/ embankments of these ponds are unprotected and needs to be secured to avoid any mishap. The newly constructed ponds at newly allotted site near CHWTSDF are being lined, though the construction works needs to be more scientific and third party inspections are necessary to ensure proper construction of these ponds.
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28. Mr. Digvijay singh also showed several locations along the river length from Bithuja to Tilwada which is @ 10 km downstream of Balotra and showed various locations where coloured effluent marks are present and moreover, in certain stretch of river, water is pooled in the otherwise dry river bed. At one location near Rani temple the stagnant water pooled in river bed shows high TDS of about 69000 mg/lt which could be due to evaporation and concentration. The CETP authorities submitted that the entire area near Tilwada where second largest cattle fair is organized in every April-May, the age old phenomenon of getting the potable water at some depth in the river bed is well known. However, according to Mr. Digvijay Singh, the water now found is unpotable. During the visit, the one of the old pond at Balotra was found to be provide stone pitching and it was informed that there was a breach earlier and now the entire length has been strengthened. A continuous seepage from the stretch was observed which is meeting the river. Photographs of this seepage are attached.
29. The apprehension of seepage from solar evaporation ponds in the river bed is strengthened by the fact that the river just @ 1km upstream of Bithuja is completely dry, and even some excavation carried out there as shown in photographs is dry. However, near Bithuja and in downstream section, the river has several spots where traced of coloured effluent is found and also, at some places, water is stagnant, along with coloured hazardous waste dumped in river bed.
30. After October 2017 incident, there are at least two incidents of leakage/breach of effluent from these ponds which are on record of RPCB, first one is of 5.3.2018 while second one is of 17.4.2018. Both these incidents have been investigated by RPCB and legal action has been recommended to RPCB HQ. The investigations of 5.3.2018 revealed that at Bithuja there was a breach on the bund on the right side of HRTS and effluent had reached some lands in adjoining area. The incident on 17.4.2018 is more serious as effluent bypass arrangements involving buried underground pipe was observe d by RPCB vigilance team. Moreover, there are at least 3 cases in 2018 where CETP has paid compensation to farmers though exact details of damage are not available.
31. Another important concern is that the Effluent collection and conveyance pipelines from Jasol industrial area as well as Gandhipura areas of Bithuja CETP are passing through the riverbed. The photographs attached show that the pipelines are passing through the riverbed which is not a good environmental
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practice. In fact, one of the issues raised by Mr. Digvijay Singh is that the rising main provided for about 20 to 24 industries at Gandhipura to take their effluent to Bithuja CETP regularly ruptures and untreated waste water is directly released in the river. He has also highlighted certain photographs to show such incidences. RPCB officials, during the visit, confirmed such incidences and informed that they received several complaints and after receipt of such complaints, they immediately inform the CETP office bearers and instruct them to take corrective action. On specific query, it was informed that the industries in that area never inform about such breakage or rapture of the pipeline and only after RPCB instructions, follow up action is taken. On enquiry, it was informed the consent granted to industries does not have any specific condition to inform any accident or incident which results in excessive or unauthorized pollutant discharge to RPCB and District Administration. It would be a good environmental practice to include such condition of informing the incidents or accidents resulting in excessive discharge of pollutants in the environment to all the concerned authorities so that necessary preventive and corrective measures can be comprehensively taken immediately.
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Effluent seeping in River Luni near Evaporation Ponds (HRTS) at Bithuja
Water accumulated in the River bed across Balotra CETP Evaporation ponds. The Jasol Industrial area can be seen on other side of River.
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Hazardous waste dumped in the River Luni downstream of Balotra Evaporation pond (old HRTS)
Effluent Seepages from the evaporation pond (Old HRTS) where the breached section has been strengthened by stone pitching
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A View: Down Stream Of The Seepage Leading To River Bed
Water/Effluent Accumulated In River Bed Down-Stream Of Balotra Evaporation Ponds (Old HRTS) Near Khed. Stagnant Water, But The Sand Mining Indicates Limited Stretch Of Water
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New Evaporation ponds being constructed at New site near CHWTSDF (new HRTS site) with HDPE lining
River Luni upstream of Bithuja from Bridge along Balotra By-pass (Completely dry, even excavation is dry)
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Open Pipelines Carrying Effluent from Industries To CETP Through The River Bed
Stagnant Water in the River across Balotra CETP. Industries seen are from Jasol Industrial Area
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G. SUMMARY 32. The commission visit observations can be summarized as follows; a. CETP: i. CETPs at Balotra, Jasol and Bithuja are not adequate to treat the consented effluent generation from the respective catchment area and hence, are being voluntarily operated at reduced hydraulic capacity. Even after this, the total effluent is not able to be treated as per consented norms, for TDS. ii. The CETPs are being upgraded with addition of RO plants and more mechanical foggers/sprinklers but the exact time frame for such up gradation is still not finalized. Such upgradation needs to be holistically examined in order to ensure the long term efficient operations of the plant. iii. The RO rejects along with partially treated effluent from CETP is taken to solar evaporation ponds in closed HDPE pipe line now. CETP has also laid down HDPE effluent collection pipeline network with SCADA system for better management of incoming effluent. This has reduced the leakage, seepage and storm water mixing significantly. iv. Large quantities of hazardous waste are stored in CETP areas, which requires speedy disposal. The ponds at Balotra are full of effluent and it cannot be seen how much HW is accumulated at the bottom of these tanks. The Hazardous waste handling needs to be improved by effective drying practices and also, proper characterization and regular disposal.
b. HRTS: (Evaporation ponds) i. There is no HRTS system or any plantation/agriculture for disposal of treated effluent. ii. The solar evaporation ponds at Bithuja, Jasol and Balotra (old HRTS site) are unlined except one (1) pond. The other lined pond is subsumed by a larger unlined pond. There are reasonable chances that the stagnant effluents at these ponds contribute to seepage/leakage of effluents to adjoining river. iii. As the existing ponds are not adequate to cater even the present reduced effluent, additional area has been allotted by the solar
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evaporation ponds being developed at new location at Khed near CHWTSDF which are being HDPE lined. c. Effluent in river: i. Some of the effluent collections and conveyance pipelines leading to Jasol and Bithuja CETP are passing through the river bed, which are open and prone to any damage resulting in effluent discharge in river. It is necessary to immediately reroute them, may be along the road. ii. There are symptoms of effluent and hazardous waste presence in the River at certain locations at detailed in Report. RPCB needs to issue directions to lift this effluent and hazardous waste for necessary treatment and disposal. iii. There was continuous seepage from the ponds near the stone pitched section of old HRTS entering in the river, which needs to be diverted back for treatment. iv. There are at least two reported incidents of 5.3.2018 and 17.4.2018 where RPCB has observed breach/bypass resulting into discharge of effluent in river. d. There is a huge gap of scientific and technology based regulatory interventions from RPCB and CPCB, in terms of characterization of CETP influent and effluent, CETP unit process performances, HRTS Vs Solar evaporation ponds, consent conditions, reuse of RO supernatant for industrial purposes, issuance of directions for reduced hydraulic capacity of CETP, hazardous waste handling and characteristics.
33. Way forward; Thought scope of commission is very specific, following points would be helpful for improving overall environmental management in the industrial areas. a. The entire industrial water use in this area is based on ground water. The This area is already a critical area from ground water availability point of view. It is necessary to make it mandatory to reuse the RO supernatant for industrial purposes as it has reduced TDS of 3-5000 mg/lt against 8000- 20000 in the natural ground water. This will not only reduce groundwater extraction but also, reduce the effluent sent for solar evaporation, besides making CETP operations more viable.
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b. Individual industries need to segregate their effluent for separating very high TDS streams like silicate streams, which can be separately treated by CETP to reduce TDS load on CETP and RO plants. c. Individual industries who have installed own ETP and not the members of CETP need to be regulated effectively by conducting surprise audits of their claims for effluent disposal by solar evaporation. There are more than 100 units and they are important part of environmental management of the industrial area. Previously, stringent action including closure has been taken by RPCB against many of these units. d. It is necessary to check the stability of the ponds through a structural safety audit urgently and take suitable strengthening measures. In the mean time an electronic surveillance along with watch and ward shall be in place to identify any breach and leakages. e. The construction of ponds at new site near CHWTSDF shall be expedited and put into use after necessary approvals. The existing unlined ponds at Balotra shall be gradually discontinued simultaneously. RPCB needs to assess the adequacy of ponds using the solar evaporation rates for the particular type of effluents rather than a straight jacket formula. f. ZLD plant up gradation shall be expedited and till that time the CETPs may be operated even at lower capacity in proportion to the solar evaporation pond capacities. g. A holistic appraisal of the entire effluent management in the industrial area including treatment, disposal and reuse shall be undertaken to ensure that proposed up gradation is sustainable in long term. One option for examination could be to treat this industrial effluent along with domestic wastewater of Balotra. h. RPCB has a skeleton staff and infrastructure at Balotra. There is no full- fledged laboratory and samples are sent far away to Kota. RPCB needs to strengthen their scientific manpower and infrastructure at Balotra on priority. RPCB need to have an enforcement policy of the RPCB with a focus on scientific appraisal and evaluation of the pollution control systems and status of environment for taking science based informed regulatory decisions.
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Annexure I List of people participated in the visit.
1- Mr. Ajay A. Deshpande, Former Expert Member NGT and Court Commissioner 2- SDM, Balotra 3- Mr. Ashok Kumar Gupta, SEE. RSPCB, Jaipur 4- Mr. Jagdish Singh, RO RSPCB, Balotra 5- Mr. Vikram Parihar, SO RSPCB, Balotra 6- Mr. Sunil Kumar, JSO RSPCB, Balotra 7- Mr. Pawan Chouhan, JEE RSPCB, Balotra 8- Mr. Subhash Mehta, Chairman Trust 9- Mr. Manoj Chopra, Member Secretary Trust 10- Mr. Digvijay Singh, Petitioner 11- Mr. Tulsaram, Farmer 12- Mr. Kanaram, Sarpanch 13- Mr. Om Prakash Soni, Press Reporter 14- Mr. Dhanraj Chopra, Trustee 15- Mr. Mahendra Golechha Chairman BLUM & Trustee 16- Mr. Jaswant Gogar, Secretary BLUMS & Trustee 17- Mr. Sudheer Mathur, Plant Manager Trust 18- Mr. Rajesh Vyas, Civil Engineer Trust
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References 1. Ground water information Barmer district Rajasthan central ground water board, June 2013 2. CPCB publication on ‘Industrial Pollution Due To Small Textile Printing And Dyeing Units At Jodhpur , Pali And Balotra In Rajasthan’ 3. CPCB report on ‘ Information For Study Visit Of The Department - Related Parliamentary Standing Committee On Science & Technology, Environment & Forest To Udaipur & Mount Abu From 28th June To 1st July, 2016’ 4. CAG compliance audit report on CETPs in Rajastan
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