What ails STPs in India — An open submission to the Hon. NGT

 

FOREWORD : 

 

In July of 2019, I was appointed as the “Subject Expert -  Wastewater Management” by the Karnataka State Pollution Control Board (KSPCB), in the Monitoring Cell constituted by KSPCB,  pursuant to an Order OA No: 606/2018 dt. 24 April 2019 issued by the Hon. National Green Tribunal (NGT), Delhi.

 

This got me to think – Why only Karnataka?  The sorry state of health of STPs across India, in major cities such as Mumbai, Pune, NCR, Chennai, Hyderabad and many others is quite similar. This begs the question – What are the root causes for this failure? I wish to submit my thoughts in this note for the consideration of the Hon. NGT.  

 

The primary reason I find is lack of adequate Education, Knowledge, Competence, Expertise, Experience and Skill of various stakeholders in the chain of events which gives birth to an STP.  

 

And therefore, I take this liberty to write this note, a white paper, if you will for the Hon. NGT to take note and if found proper and useful, to take necessary and appropriate steps to action the plans on a MISSION MODE. This note is also for the benefit of concerned Citizens to understand the issues our Nation faces and the first substantive steps for the way forward.

 

For the benefit of a wider audience, I would also like to reproduce here selected Sections from the Water (Prevention & Control of Pollution) Act, 1974 for maintaining or restoring of wholesomeness of water, which mandate the role and responsibilities of State PCBs.

 

Section 17(1) (e)   To collaborate with the Central Board in organizing the training of persons engaged or to be engaged in programmes relating to prevention, control or abatement of water pollution and to organize mass education programmes relating thereto;

 

Section 17(1) (h)   To evolve economical and reliable methods of treatment of sewage and trade effluents, having regard to the peculiar conditions of soils, climate and water resources of different regions and more especially the prevailing flow characteristics of water in streams and wells which render it impossible to attain even the minimum degree of dilution;

 

And in the event of a non performing Treatment plant, the remedy thru rectification :

 

Section 30 (2)   If the person concerned fails to execute the work as required in the notice referred to in sub-section (1), then, after the expiration of the time specified in the said notice, the State Board may itself execute or cause to be executed such work.

 

Section 30 (3)   All expenses incurred by the State Board for the execution of the aforesaid work, together with interest, at such rate as the State Government may, by order, fix, from the date when a demand for the expenses is made until it is paid, may be recovered by that Board from the person concerned, as arrears of land revenue, or of public demand.

 

The Mission on which I propose that all stakeholders embark upon, is in perfect consonance and conformity with the letter and spirit of the above Sections in the said Act of 1974.

 

 

A. THE MISSION

 

A broad outline of the mission and its components, timelines for execution etc, may be summarized as below :

 

1.     OBJECTIVE :  

 

- To set right all existing STPs and ETPs which are dysfunctional to various degrees in

  various states of India

 

- To ensure that all the future STPs and ETPs to be set up in various states are Designed,

   Engineered, Executed, Operated and Maintained to meet prescribed treated water Quality

   standards.

 

2. SCOPE :  

 

- Major Cities and Towns in India, in respect of STPs.

- Major industrial clusters, standalone industries for ETPs and STPs.

 

3. TIMELINE :     

 

- Three to Five years for existing units.

- Immediately for proposed New plants

 

4. MILESTONES :  

 

  • Set percentage of total number of treatment plants to be covered and successfully turned around Year on Year, within a 3-5 year timeline and continuously monitor the progress on a monthly basis.

 

5. OUTCOME :

 

  • Monitor the improvement in quality of surface waters and ground water in the vicinity of the project areas covered in this mission, which will in turn indicate the success and also the success rate of the Mission.

 

As the First step towards implementation of the Mission, it is imperative that, key stakeholders  who directly or indirectly contribute to the success of the mission, be equipped with necessary knowledge, skill and expertise to understand their respective roles in this mission and to act responsibly and diligently for the success of the mission.

 

 

 

B. STAKEHOLDERS,  RESPONSIBILITIES, ACCOUNTABILITY

 

Key stakeholders identified for success of the Mission are :

 

1. State PCB and all its Officers  In every regional office of the State, at all levels from Regional Officer to Assistant Environmental Officer (AEO), Assistant Engineer (AE), including even non technical support staff in the PCB.

 

The Primary responsibility is to strictly enforce provisions of law, consent conditions etc.,  without fear or favour.

 

Shall be made directly accountable in case of failure to monitor and control pollution in their areas.

 

2. Project Proponents – Builders, Developers, Industrialists, Entrepreneurs etc.

 

The Primary responsibility is to ensure that all aspects of pollution from their respective projects are well appreciated, understood and conveyed in full and truthfully to person / persons /agencies appointed by them to control pollution    

 

Shall be made directly accountable to their constituents/ Govt. agencies to demonstrate satisfactory Performance of pollution control measures over a long period, say 3-5 years. Responsible also for correcting any deficiencies, defects, lacunae in pollution control systems executed by them.

 

3. Architects, Consultants, Vendors – As specialist, experienced and professional consultants and advisors to Project Proponents, their primary responsibility is to acquire necessary and sufficient knowledge, skill and expertise to correctly advise their clients in a technically and professionally competent and ethical manner.

 

Shall be made Accountable to their clients for any deficiencies, defects, lacunae in the Pollution Control Systems designed and /or executed by them. Repeated failures must mandatorily result in blacklisting of such Architects / Consultants / Vendors.

 

4. Ultimate Users, Management Committees – As ultimate users and long term owners of Pollution Control Systems and responsible for its day to day operation & maintenance.

 

Their primary responsibility is to do due diligence / audit of the STP or ETP before taking over Physical Possession of the Waste Water Treatment Plant from the STP/ETP builder. The Responsibility also is not only to take over physical possession of the plant, but also to collect all the documents related to the plant starting from the CFE/CFO/ EC application filed by the Builder with the PCB / SEIAA.  In addition it is also their Responsibility to get the plant rectified by the Builder / PCB under Section 30 of The Water (Prevention and control of Pollution) Act, 1974, even before taking over, should such rectification be found to be necessary.

 

 

They shall be made Accountable thereafter to the Community and to the PCB to ensure that the plant is operated and maintained to enable recycle and reuse of treated water for secondary purposes, such as toilet flush, irrigation and for car wash, common areas washing, etc as mandated by respective state pollution control Boards. 

 

Further, under the new mandate of the Hon. NGT to control Total Nitrogen to less than 10 PPM, even ground water recharge could become a very beneficial reuse option , if so permitted by the Hon. NGT.

 

5. Facility Managers must put ethics and professionalism above narrow business interests and shall refuse to serve those clients and sites, which have defective Treatment Plants. Otherwise they run a serious risk of aiding and abetting a criminal Act.

 

6.  NGOs, Environmental Activists, Apartments and Builders Federations – As watchdogs, counselors for their respective constituents.

 

- the Primary responsibility shall be to educate, create awareness of the enormous Advantages and Benefits accruing from well designed, well engineered, well executed and well operated & maintained treatment plants.

 

  • Ensuring Water Security of the community upto 50-60 % of their requirement.

  • Economic benefits from savings in purchase costs of fresh water

  • Conservation of a precocious natural resource.

  • Protection and preservation of the Environment.

 

At present there does not seem to be any accountability that could be reasonably attached to these stake holders. They may be considered more as facilitators and support systems, as also conscientious watchdogs, constantly monitoring acts of omission and commission of the other stakeholders and ensuring that they to perform their duties diligently and with utmost professionalism, honesty and transparency.

 

7. STP, ETP Operators/ Agencies – They are the final cogs in the wheel which ultimately run the plants on the ground: The best designed plants will fail in the absence of Trained, Disciplined and Dedicated operators.

 

- Their Primary responsibility is to understand their role, their duties and work as laid out in the Standard Operating Procedure (SOP) for the plant. They need to carry out the work assigned to them in a diligent manner and take full ownership of the plant.

 

- Shall be made Accountable to the Community for non performance and non delivery of good quality treated water.

 

8.  Print and Electronic Media – The most vital channel to assiduously gather ground realities, facts, verify, validate and then report, disseminate to the larger public on the State of the Environment, on a regular basis and not just during a crisis as Breaking News. Investigate and report Acts of omission and commission by various stakeholders that have in the past, and could in future harm the Environment. To expose without fear or favour the guilty and equally to highlight good work done in the field by the few albeit in an insignificant minority, to be showcased as an example and a model for others to emulate.

 

C. STAKEHOLDERS AWARENESS CREATION AND EDUCATION

 

As the first and most critical exercise in accomplishing the mission, I recommend that appropriate education and training be imparted to the various stake holders to fulfill their responsibilities as follows :

 

1. State PCB and all its Officers

 

  • Training on Various STP Technologies – Design, Engineering, Execution and Operation & Maintenance.

  • Training on scientific methodology for inspection, assessment and audit of STP to determine efficacy of treatment system.  A tried, tested and proven Methodology and Template is available with us and can be shared with the PCBs.

 

2. Project Proponents

 

  • Training on Various STP Technologies – Design Engineering, Execution and Operation & Maintenance.

  • Selection of most suitable, most appropriate Technology for their specific Projects.

 

3. Architects, Consultants, Vendors

 

  • Training on Various STP Technologies – Design, Engineering, Execution and Operation & Maintenance.

  • Training on scientific and methodical inspection, assessment and audit of STP’s designed by them to validate and obtain feedback on their designs for continual improvement.

 

4. Ultimate Users, Management Committees, Facility Managers

 

  • Training on Various STP Technologies – Design, Engineering, Operation & Maintenance.

  • Process for due diligence in selection of service providers for STP O&M.

 

5.  NGOs, Environmental Activists, Apartments and Builders Federations

 

  • Training on Various STP Technologies – Design, Engineering, Execution and Operation &  Maintenance.

 

6. STP, ETP Operators / Agencies  

 

  • Training on standard operation & maintenance process and procedures in the plant,as per SOP provided.  

 

It is noteworthy from the above Awareness creation and Education program that, the common thread of information and knowledge gap that runs across all stakeholders is education and training on various STP technologies and the ability to select the best technology for the intended application and purpose.

 

I therefore recommend that every State Pollution Control Board shall undertake and organize such awareness, education and training programs, in the first instance, as the starting point in the mission to improve Wastewater management in their respective States. I will be more than happy to undertake this task on a war footing.

 

The sessions may be scheduled for 2 Hours in the morning on mutually convenient dates. These sessions can start with the PCB officers, followed by other stakeholders in the same sequence as stated in this report, which is also in the order of importance of different roles played by the stakeholders in this mission.

 

Once this basic task is accomplished, we will see a significant improvement in performance of a vast majority of new Wastewater Treatment Plants.  Also failure rate of new STPs and ETPs will see a drastic reduction from the current high levels, generally estimated to be around 80-85%.

 

D. RECTIFICATION, RESUSCITATION OF DYSFUNCTIONAL PLANTS

 

At Ecotech, over the last two decades, we have successfully turned around defective, dysfunctional, defunct treatment plants of various hues and colour.  Such treatment plants include those that employed Anaerobic Technology, SBR, MBBR, MBR and even poorly designed and engineered Extended Aeration Activated Sludge (EAAS) systems. The total of such plants rectified by us runs to over 60 in number, with a 100 % success rate in the surgeries carried out.  In all these CASES, without exception, the surgery entailed conversion to the Tried, Tested, Proven and Robust Classical EAAS system, now scientifically redesigned and reengineered. The ultimate proof of the pudding also comes from a guaranteed demonstration of satisfactory performance of the upgraded Treatment Plants: A long term Operation & maintenance Contract which ensures responsibility and accountability for the works carried out.

 

The Process and Procedure for undertaking such Upgradation of dysfunctional Treatment plants is now well established in our Company via a thorough technical audit of the delinquent unit.  A standard format / Template for an audit has been developed. which we have used successfully over the years.  

 

The Audit Report consists of our Observations followed by recommendations for suitable, appropriate and optimal upgradation of the Treatment plant to meet quality standards of treated water on a sustained basis over the long term. 

 

We should be happy to conduct training programs to develop such auditors and audit capabilities in various cities and states of India. These reports then could be actioned either directly by the user or with help and financial assistance from the Urban Development Ministry / Department of the States and the Development agencies under the Ministry.

 

Finally it is once again my humble submission to the Hon. NGT to consider the views contained in this note and if thought fit, take necessary and appropriate action as the Hon. NGT may deem fit.

 

 

Dr. Ananth S. Kodavasal

July 04, 2020

Ecotech

 

 

FOOTNOTE : We are well aware that any good Policy, Program  or Plan is only as good as how well it is implemented.   And past experience in India shows that, well meaning plans have also to be implemented with a carrot and stick approach.  And therefore this additional note to the Powers that be. 

 

Attendance in the proposed awareness and education training for 

 

1) Consultants. 

2) Developers. 

3) STP Vendors

 

shall be made mandatory. This will instil a sense of discipline, responsibility and accountability among these stakeholders while designing and building new Treatment Plants.  And in the event, their STPs fail on account of non adherence to Guidelines prescribed by the PCB, they may be penalized once, twice in monetary terms, as per current norms of the CPCB /NGT. 

 

On the third recurrence of faulty STP (Even where only one of the three agencies are involved in the third instance of default) all Agencies involved in the Consortium shall be summarily blacklisted and prohibited from conducting business related to STP, based on the universally well recognized and accepted principle of Professional Malpractice.

 

 

 

 

 

 

     

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