Editorial

Amidst COVID-19 Pandemic Mask Disposal Advisory Indispensable

27th March 2020

According to an advisory issued by the Directorate General of Health Services, Ministry of Health and Family Welfare, Govt. of India, there is no scientific evidence to show health benefit of using triple layer masks for members of public. In fact erroneous use of masks or continuous use of a disposable mask for longer than 6 hours or repeated use of same mask may actually increase risk of infection further.

Suspect/ probable/confirmed cases of influenza should use Triple layer surgical mask. The care provider in home care settings should use triple layer mask. Close family contacts of such cases undergoing home care should also use Triple layer surgical mask. Triple layer mask should not be re-used. Masks used by patients / care givers/ close contacts during home care and should be disinfected using ordinary bleach solution (5%) or Sodium Hypochlorite solution (1%) or appropriate concentration of Quaternary Ammonium household disinfectant and then disposed off either by burning or deep burial.

Th advisory also states that disposal of used masks should be considered as potentially infected medical waste. In the hospital setting it should be disposed off in the identified infectious waste disposal bag/container. In community settings where medical waste management protocol cannot be practiced, it may be disposed off either by burning or deep burial. This deliberates on mask management related to medical ground, which is very much managed under the scope of Bio-Medical Waste (BMW).

Notwithstanding the fact that there is a widespread use of mask by the general public there is no clear advisory on its use, management and disposal. Unnecessary usage will increase load in solid waste management, the cycle of garbage collection and plastic recycling. And, improper disposal may lead to serious consequences to our health and environment. Those who are not nCoV infected, but have some other airborne diseases may cause health impact on the safety of municipal workers and ragpickers. According to a tweet, New Delhi Municipal Corporation (NDMC) has provided all Personal Protection Equipment (PPE) and essential devices to each member of the work force of sanitation and other staff, while working to sanitize Parliament House, Safdarajng Hospital, NDMC's buildings and all Public Toilet Utilities, and many other premises in New Delhi area. The home page of the website of NDMC has also provided information on COVID-19. However, there was no trace of mask disposal in it. The South Delhi Municipal Corporation and North Delhi Municipal Corporation did not display any information regarding COVID-19. The website of East Delhi Municipal Corporation was placed with a copy of notice dated 21.03.2020 pertaining to to closure of non-essential service in the wake of COVID-19. This was also not that visible.

It is important that the governments, including the municipal bodies, issue advisory and share information on the use, management and disposal of mask. The public must also behave responsibly, and not throw it just anywhere.

Treatment of coronaviruses in wastewater

23rd March 2020

The outbreak of respiratory illness, known as #COVID19, continues to spread around the world. India is no exception. In India, the number COVID confirmed cases is increasing alarmingly. As a preventive measure, the hospitals are also trying to keep COVID positive patients away from other patients. Therefore, it is becoming imminent to create temporary medical centers.

With this, a question arises, whether COVID-19 can be transferred via wastewater? On wastewater treatment, WHO has stated that there “is no evidence to date that the COVID-19 virus has been transmitted via sewerage systems with or without wastewater treatment”.

The United States Environmental Protection Agency (USEPA) said wastewater treatment plants do treat viruses and other pathogens and that the virus is "particularly susceptible to disinfection".

No COVID-19-specific protections are recommended for employees involved in wastewater management operations, said the Water Environment Federation (WEF). Workers should follow routine practices to prevent exposure to wastewater. However, the WEF added that COVID-19 may be transmitted through the faecal-oral route. The virus RNA was detected in patient stool after scientists noticed that some patients infected with the COVID-19 virus experienced diarrhea in the early stages of infection instead of a fever, the latter being more common. Many experts say that there have been no reports of faecal-oral transmission of COVID-19 to date.

According to USEPA. the wastewater treatment plants treat viruses and other pathogens. COVID-19 is a type of virus that is particularly susceptible to disinfection. Standard treatment and disinfectant processes at wastewater treatment plants are expected to be effective.

Nevertheless, the USEPA has added that the decentralized wastewater treatment (i.e., septic tanks) do not disinfect, EPA expects a properly managed septic system to treat COVID-19 the same way it safely manages other viruses often found in wastewater. Additionally, when properly installed, a septic system is located at a distance and location designed to avoid impacting a water supply well.

Thus, the temporary medical centres, which are connected with sewer lines may be a better choice. In the case of non-availability of such arrangements, it seems to be prudent to avoid use of the water sourced from borewell or any groundwater adjacent to the septic tank disposing the wastewater from a temporary medical centre or camp.

Zero Liquid Discharge

18th March 2020

Zero Liquid discharge, well known as ZLD is not a new term to many practicing environmental professionals. ZLD technology has been available and mandated in industries in Europe since the 1980s. The implementation in India has gained success in some industries, such as distilleries and also did not result any good in many others, for example pulp and paper. Some experts blame that the definition of ZLD is not very clear. The Central Pollution Control Board (CPCB) defines ZLD as installation of facilities and system which will enable industrial effluent for absolute recycling of permeate and converting solute (dissolved organic and in-organic compounds/salts) into residue in the solid form by adopting method of concentration and thermal evaporation. ZLD will be recognized and certified based on two broad parameters that is, water consumption versus waste water re-used or recycled (permeate) and corresponding solids recovered (percent total dissolved / suspended solids in effluents). This definition is often misunderstood. Many regulators in India have also twisted the requirement of ZLD, which has diluted the need and perception. In simple terms ZLD means 100% recycle or reuse of treated wastewater in manufacturing and allied processes or in domestic usages. However, use of treated wastewater in watering greenbelt is not considered as ZLD.

A close look at the Environment Statement for the Financial Year 2018-19 submitted by Aditya Aluminium, Lapanga to the Odisha State Pollution Control Board, shows that the company claims zero disposal of wastewater. Under Part-C, the water pollution discharged to the environment per unit of output has been stated as “Nil”, as against water consumption of nearly 32802 KLD (process+cooling+domestic). There is no statement regarding RO reject characterization and disposal. Further, the treated wastewater from Sewage Treatment Plants of capacity 600 KLD +300 KLD is disposed of onto the land for watering greenbelt. This disposal falls under regulation and is a part of the water pollution pertaining to the industry's activities. Therefore, this pollution, RO reject should have been accounted for. The Odisha State Pollution Control Board, the Zonal Office of the Central Pollution Control Board, and also the Regional Office of the Ministry of Environment, Forest, and Climate Change should act on this. All these authorities must have received copies of the statement, as per applicable legal requirements. There might be several cases like this in India.

Another important factor is that ZLD systems are associated with significantly high capital investments and even higher operating expenses. There is a need to find various options to reduce the ZLD CAPEX and OPEX. Although currently the industry is looking at it as a challenge and a sunk cost, in long term ZLD has the potential to provide tangible as well as intangible benefits to the companies. Apart from this in some cases this cost can be offset by the resource recovery i.e. salt and other chemicals which can be again reused in the process. In textile industry for example there is enough scope to recover salts and brine solution which can be reused in the manufacturing process and reduce the impact of treatment cost on the overall cost of production. Nevertheless, there are several industries, such as; pharmaceutical industries and food industries, where implementation of ZLD seems to be highly impractical or needs to be designed very carefully.

The ZLD mandate has helped increase the focus of the industry to water which has traditionally been an underpriced resource.


This opinion has been published on the print version of Enviro Annotations on 18th March 2020 issue.

Suggestions to incoprorate in EIA Notification 2020

11th March 2020

The new EIA notification proposed by the Ministry of Environment, Forest and Climate Change (MoEF&CC) has been prepared very diligently. Sharing of power or responsibility with the State Pollution Control Boards (SPCBs) and Union Territory Pollution Control Committees (UTPCCs) to carry out inspections and monitoring of compliance with regard to the conditions laid in environmental clearance (EC) is meaningful. Taking the NGT order with regard to OA No. 639/2018 into account, the responsibility sharing step by the MoEF&CC will be eco-friendly too. The projects could be reviewed both for consent and EC compliance in one go by the officials deputed for inspection. If executed properly, it could be very resultant, as the MoEF&CC was not able to review many projects after grant of EC. Nevertheless, it is well known that the level of environmental degradation attained, despite availability of water act since 1974, air act since 1981 and hazardous waste management and handling rules since 1989. Also, there is a significant increase in environmental activism pertaining to the matters handled by the SPCBs and UTPCCs. Therefore, it is a concern from a national perspective as to how things will yield.

The validity of EC to projects except Mining, River Valley or Irrigation projects or Nuclear power projects shall be 10 years, which was earlier for 7 years. With the EIA Notification 2006, some projects come back to authorities for expansion/modification of EC within 2 years, or even less time from the date of EC grant, which is much before the expiry of validity. Such projects could be observed as improperly planned. Many such projects have come back with extremely high increase in pollution load. And, sometimes with proposal of lesser greenbelt area. Obviously, this brings additional workload on the appraising authorities. On the other hand, there is a cost involved in the part of the government to appraise an application seeking EC. But there is no fee involved in the EC process. It is important to impose a significant amount of fee in the cases, which seek expansion/modification within EC validity with a high degree of pollution load. However, projects needing expansion because of national interest should be exempted.

The penalty clause for defaulters in compliance reporting is a welcome step. There were many projects going to sleep mode after obtaining EC. It is also a need to incorporate a generic structure and a list of enclosures to support the EC compliance reporting. The reports should also be prepared by professionals with appropriate knowledge and experience. The condition regarding the availability of only the latest compliance reports on the project proponents’ (PP) websites needs to be reviewed. As many times the government sites either found not accessible or don’t provide adequate information, the compliance reports must be made available at least for 3 years on the PP’s website. This is certainly not going to cause any hurdle in their ease of doing business. Further, the notification should also incorporate a clause regarding the revocation of EC in case of a project’s regular and consistent failure in complying with the conditions outlined in it. The decision should be reserved by the MoEF&CC.

Dealing with the violation cases seems to be in need a review. If a project has been issued Consent to Operate (CTO) without prior-EC or prior-EP, the same should come to cease, once it is found to be in violation. Secondly, most of the violation cases practically fall in B1 and B2 category. Such projects fall under the SEIAA AND UTEIAA. As the SPCBs and UTPCCs are now going to be involved in the post EC monitoring, they should be given the responsibility to evaluate the applicability of EIA notification at the time of granting CTO. Further, there should be a provision that the projects under violation should compulsorily undergo public consultation, irrespective of its type and category.


This opinion has been published on the print version of Enviro Annotations on 11th March 2020 issue.

Thermal Power Plants: A curse to the environment?

4th March 2020

Early in February, in her budget speech, the Finance Minister, Smt. Nirmala Sitharaman expressed concerns about environment and clean air. She also said that the Central government will advise closure of utilities running thermal power plants, which are old and have higher carbon emissions. By the end of February, the Chief Justice of India also said he wanted all thermal plants in the country shut to prevent further environmental pollution. “You cannot destroy the ecology. You can consider keeping it out of ecologically fragile areas,” the Chief Justice said.

The total installed capacity of thermal power in India, as on 31st January 2020 stands to be 230,189 MW, against the total installed capacity of 368,689.82 MW. This means installed capacity of thermal power in India is above 62% of the total installed capacity. Moreover, coal based power has a share of 55.6%, which is 204,724.5 MW. The greenhouse gas (GHG) emissions from electricity generation (2017) 2,194.74 metric tons of carbon dioxide equivalent.

China, with the world’s largest thermal fleet of 981 GW capacity, about 55 % of its total electricity generation mix, revolutionized its highly polluting coal power sector to tackle the problem of air pollution. Emissions from coal plants contributed to around 40% of PM(2.5) emissions in China (China Power Team, 2016). The Chinese Ministry of Environmental Protection reported that since 2012, Sulphur Dioxide emissions from coal-based plants decreased by 38%, while Oxides of Nitrogen emissions declined by 42%.

According to a 2019 publication “India’s Energy Transition: The Cost of Meeting Air Pollution Standards in the Coal-fired Electricity Sector” Srinivasan et al. (2018) and Ramanathan (2017) identify costs of the various pollution-control technology on a normalized basis per MW of installed plant capacity. The costs are subject to change, based on improvements in technology, the economies of scale achieved over large number of installations and most importantly, plant- or unit-level constraints. For example, the cost of a wet flue gas desulphurization system was as low as Rs. 19 lakhs per MW, in a recent bid. However, this was an outlier, and the average cost, as suggested by technology providers and the literature they reviewed, is Rs. 50 lakh per MW.

In an editorial opinion, the Economic Times on 17th February 2020 has deliberated that the renewable energy sector, which has witnessed the vast bulk of private funding in power in the last six years, now faces the real threat of transforming into non-performing assets (NPAs) due to lax payment for power supplied, never mind if it’s ‘green’. The powers that be clearly need to proactively address mounting non-payment; otherwise, India’s target to have 175 GW of renewable capacity will simply not see the light of day by 2022, or ever. The article further articulates that the Finance Minister has, rightly, flagged the issue of ‘financial stress’ in state power distribution companies, or discoms, due to rampant non-payment of user charges and widespread revenue leakage.

In such a juncture, whether, India can bear such a mammoth financial burden towards technology change or shutting down of thermal power plants? It is extremely necessary to carry cost-benefit analysis to phase out the polluting industrial processes. Renewable energy is a good option. However, there is a need for detailed impact analysis on the questions being raised against Photovoltaic Cells in solar energy sector. It is well understood that it can’t be attained in a very short time. But the good sign for the nation’s environment is that air pollution issues are being seriously considered. Late better than never. Now, solid action is a necessity. Defaults must not be tolerated.


This opinion has been published on the print version of Enviro Annotations on 4th March 2020 issue.

MoEF&CC proposes Amendments to Battery Waste Management Rules

26th February 2020

Year 2020 has been described as a Super Year for Environment. The Ministry of Environment, Forest and Climate Change has brought several proposals to amend existing rules. The latest one being the Battery Waste Management Rules 2020, vide S.O. 770(E) dated 20th February 2020. Earlier, the Batteries Management and Handling Rules were notified in 2001 and amended in 2010.

The earlier rules were considering only lead acid battery. The 2020 rules incorporate all types of batteries; such as non-rechargeable and rechargeable batteries, regardless of their shape, volume, weight, material composition or use. Under the new rules 'battery' or “accumulator” means any source of electrical energy generated by direct conversion of chemical energy and includes disposable primary (Alkaline/Mercury/Silver oxide/Zinc Carbon) batteries or rechargeable secondary (Lead Acid/Lithium Ion/Lithium Metal/Nickel Cadmium) batteries or any other battery which is a source of electrical energy and contains (or may produce at end of its life) potassium hydroxide or sodium hydroxide or ammonium chloride or zinc chloride or sulfuric acid or pressurized sulfur dioxide gas or thionyl chloride or magnesium bromide or magnesium perchlorate or mercury or zinc or cadmium or nickel or lithium chloride or any other hazardous material as defined in Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Schedule-I of the new rule has listed all batteries including alkaline batteries, and lead acid batteries. It will become applicable to every manufacturer, producer, collection center, importer, re-conditioner, re-furbisher, dismantler, assembler, dealer, recycler, auctioneer, vehicle service center, consumer and bulk consumer involved in manufacture, processing, sale, purchase, collection, storage, re-processing and use of batteries or components thereof including their components, consumables and spare parts, which make the product operational; all appliances into which a battery is or may be incorporated.

The new regulations do not apply to batteries used in (1) equipment connected with the protection of the essential security interests such as arms, ammunition and war material, and intended specifically for military purposes; (2) equipment designed to be sent into space (space exploration); (3) emergency and alarm systems; (4) emergency lighting; and (5) Medical Equipment.

The definition 'bulk consumer' has also changed, and it means a consumer such as Central Government, Railways, Defense, Telecom, Posts and Telegraph, departments of State Government, public sector undertakings, Boards, banks, educational institutions, multinational organizations, international agencies and public or private companies that are registered under the Factories Act, 1948 and Companies Act, 2013 and health care facilities, which have turnover of more than 1 crore or have more than 20 employees and other agencies or companies who purchase hundred or more than 100 batteries per annum.

What are the responsibilities of a consumer and bulk consumer? Consumers shall be required to ensure that used batteries are not disposed of in any manner other than depositing with the seller or in demarcated areas form whom the consumer has bought the new battery. The consumer shall obtain proper GST invoice in respect of new battery purchased from the dealer. Additionally, the consumer shall receive an invoice, along with payment voucher from the dealer in respect of every used battery sold, as per CGST Act, 2017.

The new rule has proposed bulk consumer to get registered with State Pollution Control Board (SPCB), which was not required earlier. The bulk consumer shall ensure that that scrap batteries are not disposed off in any manner other than depositing it to registered recyclers. Previously, the scrap batteries were considered under hazardous waste regulation. The bulk consumer shall file annual return in Form 1, which is yet to be finalized, to the SPCB. Further, bulk consumer shall provide data of new batteries purchased and old batteries sold with their tariff heading and GSTN. The rules have provisions for the bulk consumers or their user units that may go to contract or auction for used batteries to registered recyclers only. Bulk consumers are also required to keep a record of valid license of registered recyclers with whom scrap batteries are being deposited.


This opinion has been published on the print version of Enviro Annotations on 26th February 2020 issue.