1. 1 When Environment Protection Causes Problems! October 2019
When Environment Protection Causes Problems!
Can mere strictly adhering to compliance to the norms be considered as a bad thing? Well,
seems difficult to digest at first glance, but, maybe. Read on.
First of all, we must understand what is pollution? The presence of anything beyond a
typical quantity at the wrong time, at the wrong place is pollution. Take a bucket full of
fresh water. It is a resource for you. The moment you throw this water on a heap of food
grains, the food grains get polluted. Salt is common ingredient for many foodstuffs. Can
you use it while making sweets? No. Water is must for all. Milk is also necessary for the
growth of kids. However, you add a spoonful of milk in a glass of water, and the water
becomes unsuitable for discharge -it has become polluted.
For the purpose of law enforcement and governance, pollutants must be avoided as far as
possible. To achieve this, various norms have been prescribed time to time. But, can the
approach to follow these too seriously all these result in problems? Let us evaluate a
typical case.
I visited a factory some time back. The factory was really a big one, and was using nearly
1000 KLD (kiloliter per day) water to produce different products. Some water was being
consumed during manufacturing and remaining nearly 850 KLD was being discharged from
their process.
The discharge was having a BOD (Bio-Chemical Oxygen Demand) of around 700-750. This
is very high and such effluent cannot be discharged without proper treatment. For the
same the mill had installed a complete effluent treatment plant. Now the effluent
treatment plant was working well, and the mill was getting BOD in the range of 22-26.
The mill owner informed that the norms for discharge for his sector were 100 BOD if the
effluent is used for irrigation and 30 BOD if effluent has to be discharged in any water
body such as a lake, river, drain or sea. There was no water body near the factory, and all
the water was being used for irrigation in nearby agricultural fields.
However, the authorities did not accept the claim, saying that how can they ensure that
the water does not go to any water body, and the unit has to comply with the 30 BOD
mandate. Luckily, the mill had already installed a bigger effluent treatment plant, and
could maintain these norms.
Some time later, there were verbal instructions that the government is planning to reduce
the BOD from 30 to 20. As per many environmental experts, maintaining lower BOD
becomes more complicated as we reduce the final BOD limit, and the unit had to increase
the ETP capacity to double just to meet the new norms.

2. 2 When Environment Protection Causes Problems! October 2019
On a rough estimate, this needed an investment of nearly 80-85 lakhs, with an increased
electricity consumption bill of 40-42 lakhs annually. The mill manager informed about the
option with cost figures to the mill owner. The mill owner gave his permission to go for it
almost immediately.
As an energy conservation expert, I strongly opposed the mill owners decision. Being a
close friend of the mill owner, I asked, why he was wasting so much money, resources and
electricity. He needs to maintain 30 BOD, and is already achieving 20-25, isn't that
enough?
His version was something beyond imagination. He said, "In case of a non-compliance, the
officers sometimes order to shut the plant operations without even giving a prior show
cause notice. In 90% of the cases, a show cause notice is issued, but in some 10% cases,
the closure order is issued. A closure order is revoked only after 2-3 months or more.
Now, the norm is 30 BOD, but, in some of the guidelines, a 20 BOD norm is mentioned.
The officers are saying that the 20 BOD norms may be notified any time. Once it is
notified, we might not get sufficient time to upgrade our plants for the same. For you, it is
a matter of 80-85 lakhs or 40-50 lakhs annual cost increase; for you this might be a crime
to waste electricity and capital cost on this unnecessary approach of over compliance. For
me, this is an insurance to avoid unnecessary future problems. Tell me, why should I not
be allowed to follow the norm of 100 BOD as per the standards? And now, if I am being
forced to follow the 30 BOD mandate, why should I not remain prepared for 20?"’
As a businessman, as an industrialist, his points are valid. As a common man, the less is
the BOD, the better it is. However, should someone be fanatic to achieve better, better
and better than the mandate norms, that too at the cost of other important resources-
capital cost and energy?
I am confused.
Please share your views.