ICC MPCB Workshop on RC Proceedings - Report

ICC-MPCB ONE-DAY WORKSHOP FOR TOP MANAGEMENT ON RESPONSIBLE CARE

MR. N. SATEESH BABU, DIRECTOR, ICC DELIVERING THE WELCOME ADDRESS.

A

delegation from ICC comprising Mr. Ravi Goenka, Mr. Yogesh Kothari, Mr. B. Vivek Shetty and Mr. Sateesh Babu met Dr, Anbalagan, Member Secretary and Mr. P.K. Mirashe, Asst.

Secretary, MPCB, on September 22, 2016, wherein it has been decided to organise One-Day Workshop jointly

by ICC and MPCB on Responsible Care and utilise the same platform to discuss on environmental matters concerned to chemical industries.

Accordingly, the Indian Chemical Council (ICC) and the Maharashtra Pollution Control Board (MPCB) jointly organized a One Day Workshop for Top Management on Responsible Care in Vivanta by Taj President, Mumbai on November 11, 2016.

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Mr. N. Sateesh Babu, Director, ICC welcomed the dignitaries and the participants for this unique occasion that is aimed at bridging gap between the industry and regulatory Board for concerted and coordinated efforts towards sustainable development through Responsible Care Programme, which seeks compliance to Codes of Practices i.e. i) Process Safety Code; 2) Employee Health & Safety Code; 3) Pollution Prevention Code; 4) Emergency Response and communication Code; 5) Distribution Code; 6) Product Stewardship Code. In addition, Security Code is also being brought under the scope for sound management of chemicals in their entire life cycle.

MR. B. VIVEK SHETTY, CHAIRMAN, WESTERN REGION – ICC ADDRESSING THE DELEGATES.

Dr. Amar Supate, Acting Member Secretary, MPCB; Mr. P. K. Mirashe, Asst. Secretary, Prof. B. N. Thorat,

INAUGURATION OF THE FUNCTION BY LIGHTING THE TRADITIONAL LAMP. THE DIGNITARIES (FROM L TO R) ARE: MR. H. S. KARANGLE, MR. N. SATEESH BABU, DR. NANDKUMAR GURAV, MR. P. K. MIRASHE, DR. AMAR SUPATE, MR. VIVEK SHETTY, PROF. B. N. THORAT AND MR. UMESH TAYADE.

PROF. B. N. THORAT ADDRESSING THE DELEGATES.

DR. AMAR SUPATE, ACTING MEMBER SECRETARY, MPCB, ADDRESSING THE PARTICIPANTS

ICT, Mumbai; Sh. Vivek Shetty, Chairman-Western Region, ICC; Mr. Umesh Tayade, President, Addl.

Ambarnath Mfrs. Association; Mr. Harsharaj and Mr. H. S. Karangle, Director General ICC addressed gathering in the Inaugural Session.

Mr. B. Vivek Shetty emphasized the pivotal role that chemical industry is playing in supporting ever-increasing demand for quality and comforts of life. This imperative needs to be sustainable, for long-term growth with increased acceptance to the public and mother nature. He also welcomed the participants to discuss on various Maharashtra related environmental concerns with the Officers of MPCB for better understanding and to work hand in hand.

Prof. Thorat highlighted the need for environmentally compatible development and need for changing the perception of the public at large by demonstrating best examples and by pursuing sustainability initiatives such as Responsible Care. Currently CETPs are not functioning well demanding discipline operations. The suvival of the medium scale batch processing industries is on the scale of operation, hence expansion as

per market needs is imperative for survival. Overall, Responsible Care is the way forward for chemical industry before the time crushes on industry.

Mr. Supate explained several pressures including the NGT for environmentally compatible and responsible operations by the industries. He also mentioned that MPCB has taken series of measures to introduce transparency in the system. He has also mentioned that relative ease of doing business rating of MPCB is significantly high i.e. more than 90 against DIPP

MR. P. K. MIRASHE, ASST. SECRETARY, MPCB, ADDRESSING THE DELEGATES

CHEMICAL NEWS DECEMBER 2016 z 11

PANEL DISCUSSION IN PROGRESS

scale. He also said that MPCB is committed to promote Responsible Care programme in Maharashtra and asked the industries to adopt the same for compliance and beyond.

As such, he announced fast-track mechanism for clearances and processing to all those RC logo-

holding industries and will take some visible measures for promotion of sustainability initiatives such as Responsible Care.

Mr. P. K. Mirashe, presented status of chemical industries in Maharashtra in respect of red, orange and green categories. He

MR. TRIMBAK HOTE, DR. M.V. REGE AND MR. ALOK CHANDRA MAKING THEIR PRESENTATIONS

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has also mentioned the current challenges being faced by the industries including the CETPs, their limitations. He has emphasized that change in ethics due to Responsible Care is the key for successful operation of the CETPs, as member industries are discharging the

MS AMRUTHA RANADE, MR. R. N. IYER AND MR. NAMITESH ROYCHOUDHARY PRESENTING THE CASE-STUDIES

effluents without considering the treatability of the common treatment facility. He emphasized that MPCB is committed for promoting sustainability initiatives and RC in particular for chemical industries.

Mr Umesh Tayade, presented environmental challenges being faced by Maharashtra industry including from NGT and emphasized need for concerted efforts for solving the issues together in place of shifting the responsibility from one department to other.

Mr. Karangle proposed a vote of thanks by specific mention of Dr. Anbalagan, for his complete support in organizing the Workshop, while he was on leave due to family rituals. He also mentioned that MPCB officers shared ownership for successful accomplishment of the Workshop and thanked all the delegates for the participation and welcomed for active discussions.

A panel comprising Dr. Supate, Mr. Mirashe, Dr. Nandkumar Gurav from MPCB and Mr. B. Vivek Shetty and Mr. Sateesh Babu from ICC deliberated on number of questions raised by the participants. A precise complication of the issues discussed and opined is placed in Appendix – I hereunder.

In the post lunch Session, ICC experts precisely explained the code-specific expectation from

the industry; i.e. Mr. Trimbak Hote covered product stewardship & process safety; Dr. M. V. Rege presented employee health protection aspects under various codes; Mr. Alok Chandra Covered Distribution and emergency response Codes; and Mr. Sateesh Babu covered Pollution Prevention Code.

Subsequently, Case studies were presented by Ms. Amrutha Ranade from M/s. Galaxy Surfactants; Mr. R.N. Iyer from M/s. Alkyl Amines Chemicals Ltd.; and Mr. Namitesh Roychoudhary from M/s. Lanxess India Pvt. Ltd. The approach followed for implementation from the starting stage of signing the commitment for RC guiding principles to the obtaining RC logo have been explained through cases studies, which have demonstrated how transformation takes place from the raw stage to enlightening stage, wherein the costs of compliance and eventualities dwarfs substantially making the things cost-saving and satisfaction of doing right thing, and beyond that respect for the organization and professional working in such groups.

The presentations are very well received by the delegates and many have expressed their desire to associate with this programme and to pursue the same, as it explores and drives the industry towards safe and healthy culture that consider

every expect for improvement to the acceptable levels, and thus is an imperative for long term sustenance of the business and operations.

Mr. R. R. Gokhale presented vote of thanks to all the dignitaries, panelists, presenters, ICC Team that facilitated the programme including hotel management for making the programme a remarkable success.

The delegates opined it as a breakthrough programme that has facilitated exchange of views and opinions between the environmental regulators and the industry on various long and short pending issues through panel discussions and during breaks, besides driving the synchronized efforts towards promoting Responsible Care, a sustainability drive being promoted

by ICC, by the industry and also by the regulatory authorities by offering soft incentives for the special efforts being put forward by the RC logo holding industries in comparison to other industries. The programme has been concluded with special thanks to Mr. Ravi Kapoor, President, Mr. Vijay Sankar, Vice President, Mr. B. Vivek Shetty and ICC Team for organizing the Workshop, and opined to have such frequent interactions to avoid apprehensions among the industries and to realize the priorities of the Government.

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A PART VIEW OF THE DELEGATES

Appendix - I

PANEL DISCUSSION POINTS AND VIEWS 1. MR. SATEESH BABU PRESENTED THE COMMON ENVIRONMENTAL CHALLENGES, TO SET THE FOCUSED DISCUSSIONS. z Change in product mix z No/inadequate representation of Industry in decisionmaking process on the premise of conflict of interest etc. z Revised COD limit for deep sea discharge through authorized diffusers z Implementability of "Zero Liquid Discharge (ZLD) Scheme" for restoration of river water quality z Implementing liabilities for environmental damages due to spillage/ fire/ illegal disposal of hazardous waste and penalty – (Ref. CPCB document) z Consolidated views of the ICC on draft Environmental Laws (Amendment) Act, 2015 z Proposed Standards for Sewage Treatment Plants z CGWA Guidelines 2015 z CETPs – Operational challenges z Others

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2. MR. P. K. MIRASHE, DURING HIS PRESENTATION PRECISELY EXPLAINED THE STATUS, NON-COMPLIANCE ISSUES, MEASURES THAT ARE TAKEN INCLUDING POSSIBLE EXEMPTION THAT HAVE BEEN SOUGHT FROM GOVERNMENT OF INDIA TO FACILITATE INDUSTRIAL GROWTH AND EXPANSIONS. HE HAS EXPLAINED THE FOLLOWING: z There are around 5500 chemical industries in the state 14 z CHEMICAL NEWS DECEMBER 2016

of Maharashtra out of these 1100 fall in large-scale category.

The SSI and MSI units can’t afford to have full-fledged treatment system for effluent & HW. The Govt. has facilitated by providing CETP & CHWTSDF for the treatment of effluent & HW generated from these units.

The Govt. has developed different zone in Maharashtra for sitting of Chemical industry, so as to tackle the environmental issues effectively.

Most of the chemical zones are located along the bank of seashore for easy and safe disposal of treated effluent.

Maharashtra Industrial Development Corporation declares chemical zone & sells the plots to the Industries. After getting the plot the MSME’s Entrepreneur has to go to get an Environment Clearance and consent from the M.P.C.Board.

MPCB has started issuing Auto Renewal of consent for fast disposal of consent application Status of CETPs :

Total No. of CETPs 24 (Mostly located in Chemical &

Textile Industrial Cluster in MIDC Area Total Design Capacity 201.35 MLD Present Load 174.13 MLD

z State Level Co-ordination Committee for CETPs • “State level Coordination Committee under

chairmanship of Hon'ble Chairman MPCB for monitoring performance of CETP’s” is formed.

• In regard to improve the performance Of CETPs reviews were taken on 02/07/2015, 01/08/2015, 10/08/2015, 02/02/2016, 18/05/2016 & 08/06/2016. z Status of C.H.W.T.S.D.F. - 4 Nos. Location Capacity in Tonnes 1 Taloja (MWML) 2 TTC 3 Ranjangaon, Pune 4 Buti Bori, Nagpur

120,000 (landfill+Incineration) 25,000 60,000 (landfill); 25,000 (Incin) 60,000 (landfill); 25,000 (Incin)

z Challenges being faced by Chemical Industry • It is fact that Maharashtra Industries growth was increasing only because of MSME/SME manufactures participation.

• 58% -60% belongs to MSME/SME and balance 40% to LSM. • Maharashtra Industrial Development Corporation declares chemical zone & sells the plots to the Industries After getting the plot the MSME’s Entrepreneur has to go to get an Environment Clearance.

• At some places, Industries face problem for disposal of treated effluent on land for irrigation purpose including sea. In this regard, relocation/alternate arrangement gets better solution to the problem.

• Since the Chemical, process generates mainly toxic waste, which needs substantial cost towards its treatment and disposal. Hence, minimum production scale needs to be ascertained so that they can afford the cost of treatment facility.

• MPCB encourages adopting Best Available Technology (BAT) towards manufacturing and waste minimization as adopted in advanced countries. z Action taken by MPCB in recent past: • MPCB had filled criminal cases against CETP’s governing body due to failure in meeting the

environmental standards.

• As per Hon’ble Court directives no new industry / expansion in existing unit is allowed in the area where CETP performance is not satisfactory.

• Apart from these many industries have been issue directions towards compliance of the environmental norms, after giving opportunity of hearing under natural justice they are being allow to operate by giving time limit for compliances z Actions taken to improve CETPs performance • Directions issued to CETPs, Member Industries and MIDC towards improving CETPs performance: • CETPs to install online monitoring systems including SCADA system • All effluent generating units 100 M3/Day and above to install online flow, pH, along with SCADA system and separate electric meter for the pollution control systems • Highly pollution potential industries to segregate high and low COD effluent and treat separately.

• MIDC to curtail daily water supply by 25% of member industries in the areas of Dombivali, Ambernath, Tarapur, Taloja, Kagal and Icjalkaranji.

• Vigilance squads are formed in non-complying CETP areas.

• Top non - performing Industries were identified and following actions initiated against Industries located in the CETP areas during last year 2015-16. z Reforms taken By MPCB: • Reduction in time line for grant of Consent from 120 days to 60 days • Introduced Randomized Risk based inspection & sampling (RRBIS) module-Resulting total transparency and eliminates discretions - benefitting 62,677 industries through NO INSPECTION • Started uploading of visit report on Board’s IMIS system within 24 hours • Scheme of Auto-Renewal of Consent based on self-certification for Red, Orange & Green Category industries- incentivizing complying industries • Introduced Web Portal (ecMPCB) for accepting online applications- Savings @4,878 mandays/ annum • Introduced Simplified Consent Application form for Green Category industry (8 pages to 2pages) • Grant of Renewal of Consent to Operate for a minimum period of 5 Yr for Large/ Medium scale and a minimum period of 3Yr for SSI ind excluding Sugar industries • Uniform Integrated Enforcement Policy for Consent Management - First in Maharashtra • Enforced online monitoring facility for 17 categories of critically polluting industries.

• MPCB has topped with 92% score among Dept. the State of Maharashtra in implementing Ease of CHEMICAL NEWS DECEMBER 2016 z 15

Doing Business (as envisiged by DIPP) and will be complying reform 100% in a months time.

3. SPECIFIC ISSUES THAT WERE DELIBERATED IN THE PANEL DISCUSSION SESSION While discussions went on for over 90 minutes, some specific points captured for facilitating the reader are given below: i) When a waste can be utilized by others as a raw material, why I should undergo procedures under HW Rules • As per new HW Rules, if a by-product or waste is intended to be reused, then CPCB is to certify the technology.

• It is a matter of interpretation of utility i.e. by-product or waste.

• Agreement between seller and buyer copy with justification is sufficient to permit by-product exchange • The Rules are intended to curb the unauthorized disposal and improper disposal issues. Genuine cases will be cleared, as it reduces net waste generation from different operations. ii) Whether any preferential treatment is being considered for RC Logo holding industries?

• Applications from complying and RC logo holding industries will be cleared on priority • In future, monitoring frequency will be reduced • Third party supervision relieves partially the pressure on MPCB and hence is encouraged to have RC Logo • Already prolonged consent periods are being considered i.e. 5 years, there are many industries seeking us to reduce the duration, as the consent fee for all the years is to be paid in advance.

Therefore, 5 years period is a reasonably long period for consent. iii) Why two difference treatments and different standards?

• The provision is being prescribed to ensure dilution alone is not being explored for disposal without any treatment • It is true that the treatability increases in biological treatments if sewage is directly added, in such cases, as per law, stringent of the both standards will apply.

• Upon deliberations on the issue of cost-effective treatment and net benefit due to mixing, MPCB agreed to consider case-by-case merit of such mixing for consideration. iv) Change in product mix and Eco sensitive areas are becoming a bottleneck • Eco-sensitive areas are decaled by the Govt. of India.

• However, MPCB is taking up the issue with the 16 z CHEMICAL NEWS DECEMBER 2016

Government to exempt certain cases from the purview of the notification such as no wastewater generating industries, ZLD industries, members of CETPs, which are complying etc. in order to offer benefit tot eh industries. v) MPCB is asking MIDC to certify no pollution and MIDC says that it has no manpower to do so and the industries are suffering in the process • NGT Directives are being followed by the respective departments • MPCB has taken bold steps in favor of industry, but to be seen whether NGT endorses them vi) How many CETPs are not complying?

• Out of 24 CETPs, 17 are complying. 7 CETPs are facing non-compliance and of them 3 are marginally exceeding limits and 4 are not complying on various accounts include inadequate treatment capacity. Therefore, imposing restrictions on water consumption so that the industries comply with the quantitative limits, until CETP capacity is expanded.

• In many cases, inlet norms are not being met.

• Where there limits are not complying, some form of technical committees including ICC may help in resolving the issues, besides state level technical committee. vii) Whether warehouses require consent?

• If the warehouses are storing any hazardous materials beyond prescribed thresholds, require permission, same is the case for isolated storages. viii) Whether any measures are being taken to restrict land use conflicts around industrial estates?

• It is noted that restricting the land-use around industrial areas is a necessity, despite having several safety measures being taken to minimise the consequences of events.

• While giving clearances to the new industrial estates are possible, whereas in existing ones, only policy decisions at central Govt. can drive the change. ix) As Maharashtra is having maximum number of chemical industries, MPCB shall have a member from ICC • Board constitution is dealt by the Maharashtra Government and hence, ICC may represent to the Government directly for such nomination.

ICC STAND TRUE TO THE COMMITMENT OF THE INDUSTRY FOR A SAFE AND HEALTHY WORLD.