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Charter for Water Recycling & Pollution Prevention in Pulp & Paper Industries

Working Group-III Recommendations for Monitoring Protocol for Charter Implementation9th August 2014Working Group : Developing Monitoring Protocol for Charter ImplementationWorking Group with following members were formed to develop monitoring protocol for the proposed charterMr C S Kashikar, Head EHS, Bilt (Chairman)Prof. Dharm Datt, Dept of Paper Technology, IIT, RoorkiDr Nitin Endlay, Scientist, EMD, CPPRIMr Satyajit Mohanty, DGM, Env, JK Paper LtdMr P G Mukundan, Secretary General, IARPMDr Chhaya Sharma, Associate Professor, IIT, Roorki

Draft Monitoring Protocol was discussed with all members and also with various industry associations like IPMA, IARPMA and suggestions were considered

Final draft is prepared and being circulated to all members for their suggestions and comments.

Stakeholders of the ProgrammePulp & Paper Mills

Pulp & paper Mills Associations

Experts & Resource Institutes

CPPRI

SPCBs

CPCB

MoEF

Pulp & Paper Mills Submission of Self assessment & planning reports to Third Party/ SPCB for evaluation & validationSelf monitoring & reporting: Daily ETP effluent sampling, analysis & maintenance of log booksSubmission of progress/ performance reports to SPCB/ Third Party on quarterly basisSetting up of infrastructure facilities and creation EMC Participation in quarterly review meetings with SPCB/ Third Party/ CPCB Self assessment & planning: Preparation of inventory, ETP Adequacy assessment report, and Action plans to implement the Charter Resource Planning Roles & Responsibilities i) Implementation of the approved action plans and submission of quarterly progress reports to Third Party/ SPCBThird PartyThird PartiesResource Planning Roles & Responsibilities ii) Central Pulp & Paper Research Institute (CPPRI)Indian Paper Manufacturers Association (IPMA)Indian Agro & Recycled Paper Mills Association (IARPMA)South India Kraft Paper Manufacturer Association, ChennaiPaper Unit Chapter, Kumaun Garhwal Chamber of Commerce and Industry (KGCCI)Paper Manufacturer Association (PMA), Uttar PradeshGujarat Paper Mills Association, VapiAndhra Pradesh Paper Mills association, RajahmundryAurangabad Paper Mills AssociationIndian Recycle Paper Association (Mr Rastogi)Indian Agro & Recycled Paper Mills Association (IARPMA) / Gujarat Chapter Ahmadabad Note : All third parties representing industries should be registered body.Mills will have option to select any one as the Third Party from the above list Third PartyInventory, upgradation requirements and action plan for process upgradationResource Planning Roles & Responsibilities Work plan by mills for reduction in water consumption/ effluent generationii) Preparation of list of experts/ Institutions(To facilitate Mills in preparation of self assessment & planning reports)ETP adequacy assessment report , design / drawings and proposed augmentation/ upgradation plan as per CharterNote : Cost of engaging third party/expert will be borne by the millEngagement of Expert Institutions like IITs/ NEERI/ NPC/ EPTRI /any other laboratory / environmental consultant or setting up of Expert Committee for Evaluation & Validation of following reports Submitted by the participating Mills Third Party Resource Planning Roles & Responsibilities Quarterly Activities

Verification of progress reports submitted by participating mills

Compilation of Implementation Status Report for Submission to SPCBs/ CPCB

Compilation of ETPs performance report for submission to SPCBs/ CPCB

ii) Organising Quarterly review meetings with participating mills/ SPCBs/ CPCB Organising training / workshops programmes, if requiredNote : Cost of engaging third party / expert will be borne by the millExperts/ Institutions,If requiredProvide technical support to mills/ Third Parties in implementation of Charter Preparation / Validation of assessment reports, action plan for process & ETP upgradation, effluent analysis etc Resource PlanningRoles & Responsibilities Note : Cost of engaging experts will be borne by the participating mill/ third partyiii) SPCBsResponsible for monitoring and surveillance activities to ensure environmental complianceTo take appropriate actions under the Water/ Air Acts/ E(P)Act in case of any serious/ significant violation of prescribed normsTo ensure proper implementation of the Charter by the individual millsResource Planning Roles & Responsibilities Quarterly review meetings of Mills, Third Parties & CPCB to facilitate mills in timely implementation of the Charter Participation in evaluation /validation of the status assessment reports, action plan for Charter implementation/ process/ ETP upgradation iv) SPCBsInventory, upgradation requirements and action plan for process upgradationResource Planning Roles & Responsibilities Work plan for reduction in water consumption/ effluent generationiv) ETP adequacy assessment report , design / drawings and proposed augmentation/ upgradation plan as per CharterConstitution of Expert Committee for Evaluation & Validation of following reports directly submitted by the participating Mills (if any) to SPCBs Note : Mill has to decide where to submit the report, either to association or to SPCB.SPCBs Resource Planning Roles & Responsibilities Surveillance Activities

Verification of progress reports (on quarterly basis in case directly submitted by participating mills, and on random basis in case of submission through Third Party)

Compilation of Implementation Status Report for Submission to CPCB on Quarterly basis

Surprise monitoring

iv) Organising Quarterly Review meetings of participating Mills, Third Parties & CPCB to assess status of implementation of Charter and environmental compliance by mills. CPCB Resource Planning Organising Six Monthly review meetings of participating mills/ third parties/ SPCBs to review the progress of the Charter implementation programme

Participation in review meetings organised by third parties/ SPCBsv) To supervise, co-ordinate and support to stake holdersTo take necessary actions namely modification in the Charter/ Action Plan/ roles & responsibilities of participating agencies.Plan of Activities: Facilitation of Charter ActivitiesAction By Time Formation of experts group / selection of experts Third Party3 months

Joining all mills to Industry association to facilitate the charter implementation and coordination Third Party3 months

National level workshop for sharing charter details and roadmap to all shareholdersCPCB1 month before charter notificationNote : CPCB should give authority letter to industry associations for coordination of charter implementationPlan of Activities: Facilitation of Charter Plan of Activities: Facilitation of Charter Plan of Activities: Technological & Process ImprovementsActivitiesAction By Time Self Assessment: Inventory of existing process technologies & practices, identification of upgradation requirement and preparation of action plan for upgradation with supporting document & pert chart Mills / consultants6 months

Third Party Evaluation & Validation: Evaluation/ validation of the reports on inventory, up-gradation requirements and action plan Third Party4 months

Implementation of action plan envisaged as per document of individual mills MillsAs per scheduleSubmission of monthly progress reports to Third Party/ SPCB Mills monthlyVerification of progressThird Party/ SPCBsQuarterlyRegulatory review: Verification of the progress

SPCBsPeriodicActivitiesAction By Time Installation of sealed flow meter and running hours meter on bore wells and inlet pipe line of different process section i.e. pulp mill, paper machine , boiler etc

Mills Three Month Installation of online flow meter/ V notch to monitor final effluent discharge Mills Three Month Colour coding of pipe lines carrying recycled process water and fresh process waterMillsOne year Provision of water reservoir and supply of process water from reservoir only Mills Six Month Maintenance of log book to record daily water drawl from borewell and water consumption unit wise after installation of meterMillsDaily basis Plan of Activities: Water Conservation & Water RecyclingActivitiesAction By Time Self Assessment: Preparation of report of existing water consumption- section wise, reuse/ recycle practices; Preparation of work plan to achieve fresh water requirement targets Mill/ Consultant Six MonthsThird party Evaluation & Validation: Evaluation/ validation of the work plan for implementation of water consumption standards Third Party/ SPCBs4 monthsImplementation of action plan Mills As per scheduleSubmission of progress reports MillsMonthly Verification of the progressThird Party/ SPCBsQuarterly Regulatory review: Verification of the progressSPCBs PeriodicPlan of Activities: Water Conservation & Water RecyclingActivitiesAction By Time Self Assessment: Preparation of ETP adequacy assessment report; and proposed augmentation and up-gradation plan, design/ drawing, along with monthly PERT Chart Expert / Mill 3 monthsThird Party Evaluation & Validation: Evaluation/ validation of adequacy, and proposed augmentation/ up-gradation plan, design/ drawingsThird Party/ SPCBs4 monthsImplementation of action plan Mills As per time scheduleSubmission of monthly progress report to Third Party/ SPCBs MillsMonthly

Verification of the progressThird PartyQuarterlyRegulatory review: Verification of the progressSPCBs Periodic Plan of Activities: Assessment, augmentation and up-gradation of ETPs for improved environmental performanceActivitiesAction By Time Self Monitoring & Reporting:ETP performance monitoring by individual Mills and maintenance of Log Book as per the prescribed format

Mills Daily Submission of the performance report of individual mill to third party/ SPCBs

MillsMonthlyReview meetings of Mills/ third party & SPCBs to help mills to improve ETP performance & sample analysis qualityThird Party/ SPCBQuarterlyPlan of Activities: Monitoring & Surveillance of Environmental ComplianceActivitiesAction By Time Regulatory Monitoring: Periodic/ Surprise monitoring and review meetingsSPCBsPeriodically/Quarterly Dismantling/ removal of digesters/ pulp washing lines, etc. in agro based mills operating in Ganga River Basin (UP/UK) not having operational CRPs/ CCRPs SPCBs ImmediateOrganisation of training programmes on process technology, best practices, ETP operation & maintenance, Sample analysis etc Third Parties/ SPCBs / CPCBPeriodicallyPlan of Activities: Monitoring & Surveillance of Environmental Compliance

Plan of Activities: Strengthening of infrastructure facilities1. Setting up of lab facility at Paper Mills for Effluent Analysis

Minimum Analysis Facilities for pH, TSS, TDS, BOD, COD and ColourAppointment of ETP Manager, one Chemist and three operators in shift with appropriate qualificationTraining of the Staff at all level to be carried out compulsorily every year. Frequency of the Analysis

Plan of Activities: Strengthening of infrastructure facilities2. Operation & Maintenance of ETP

Key guidelines for Operation & Maintenance Ensure proper and optimum conditions as per the designed specification and manufacturers instruction. Avoid fluctuation in effluent flow and pollution load so as to reduce the shock load to biomass and the system as a whole. Ensure proper addition of nutrientsMaintain required level of MLSS/MLVSS concentration during biological treatment. Maintain desired level of DO in the aeration tank (1-2 mg/l).Ensure periodic & timely withdrawal of sludge from the clarifiers.Proper maintenance of electric motors and pumps etc.

Documentation Fresh water consumption, effluent discharge, effluent analysis , and ETP chemical & utility (like steam and power) consumption to be properly recorded

Plan of Activities3. Creation of Environmental Management Cell

Duties of Environmental Management Cell

Weekly meeting on a designated day to review the water consumption, measures taken and identify the areas for water conservation, resource recovery & pollution reduction.

Recording of minutes of the decisions taken, its circulation to all members of EMC and in-charge of various process operations and follow up of the decisions to be monitored by the Unit Head & ETP in-charge.

Review/ discussion in case of non compliance by any department

Internal audit to be done by the EMC on monthly/ quarterly basis

EMC will arrange for external environmental audit on annual basis