NGT - Env Compensation From IOCL Panipat 26112019

702
703
704
705
Annexure-A 706
Comment-NS/CPCB/09082018
Comments on the Draft report circulated by Nodal Officer, HSPCB, for

finalizing the Report
A. The damage and cost of restoration w.r.t Oxygen depletion

and Pollution caused to the surface water due to illegal
discharge of effluent submitted to Hon’ble NGT by two
members earlier in the interim report needs to be updated as
explained earlier, to make it technically and legally correct , if
challenged. Pls note no change has been made in the number
of days i.e 120 days as decided by two members of the
committee for interim reports. Only correction has been made
in one formula and unit price of one component has been
updated citing Reference. Therefore, it is requested to include
the following details appropriately in the final report.
=============================================
Responsibility of assessment of damage and cost of restoration was assigned by the

Joint Committee as under:
1. Assessment of damage and cost of restoration w.r.t Oxygen depletion and

Pollution caused to the surface water due to illegal discharge of effluent (CPCB
Member)
2. Assessment of damage caused to public health & environment (CSIR-NEERI

Member)
3. Assessment of damage caused to ground water and cost of restoration (CGWB

Member)
1. Assessment of damage and cost of restoration w.r.t Oxygen depletion

and Pollution caused to the surface water due to illegal discharge of
effluent:
The tentative cost of restoration towards the damage caused w.r.t Oxygen depletion
and Pollution caused to the surface water due to illegal discharge of effluent, as
submitted to Hon’ble NGT in the Interim Report by two members of the committee
was Rs. 17.31Crores. Since some of the numbers considered while calculating the
tentative cost of restoration earlier were estimated figures and it was also observed
that minor correction was also required in a formula used for calculation, CPCB
member revisited the assessment done earlier and the updated assessment of the
damage and cost of restoration w.r.t oxygen depletion and pollution caused to the
surface water due to illegal discharge of effluent, after incorporating the references
used for arriving at the final figure, is submitted before the Hon’ble NGT as under:
Page 1 of 7
707
Environmental Damage due to Illegal Discharge of BOD:
The environmental Damage on account of oxygen depletion due to illegal discharge

of BOD into the Thirana Drain from PTA Plant, as calculated by the Joint Committee
is as follows:
Total Volume of Effluent from PTA Plant through ETP-III (A): 255 m3/h i.e. 255 x 24:
6120 m3/day
Biochemical Oxygen Demand (BOD) of the Effluent (B): 170 mg/l i.e. 0.17 Kg/m3
Total BOD discharged in the Thirana Drain/day (C): A x B: 6120 x 0.17 = 1040.40 Kg/day
Total Period of Non Compliance as decided by two members of the Committee (D): 120 days
Total BOD discharged in the Thirana Drain during entire period of non-Compliance (E): C x
D: 1040.40 x 120 = 124848 Kg
Amount of Oxygen required for stabilizing BOD (F):
C6H12O6 + 6O2 = 6CO2 + 6H2O
Thus, the theoretical oxygen demand would then be:
Oxygen demand = (Gram of oxygen used) / (Gram of carbon oxidized) =
192 / 72 = 2.67 g O2/g of carbon
Total Oxygen required to stabilize total BOD Load discharged in the Thirana Drain (G): E x F
i.e. 124848 x 2.67 = 333344.16 Kg
Estimated Cost of Oxygen (H): Rs. 25/ Kg.
Total Environmental Damage in Monetary terms due to depletion of Oxygen

on account of illegal discharge of Effluent in the Thirana Drain: G x H i.e.
333344.16 x 25 = Rs 8333604 (C1)
Environmental Damage due to Illegal Discharge of COD:

The BOD discharge calculated above is the BOD3 estimated in the laboratory, in the
samples collected by the Joint Committee. However, BOD5 is only 60% of the Ultimate
BOD i.e BOD20, and the remaining 40% of the BOD ( i.e difference of BOD20 and BOD3)
which is although biodegradable but not reflected in the BOD3 tests conducted in the
laboratory, contributes towards COD. This 40% of the BOD, which is reflected as COD,
also depletes oxygen when discharged in the Environment. Therefore, Joint
Committee decided to estimate the damage caused to the environment due to this
biodegradable component of the COD as follows:
Page 2 of 7
708
BOD3 of the effluent discharged in the Thirana Drain (A): 170 mg/l
(This BOD3 is the only 60% of the Ultimate BOD i.e BOD20)
Remaining 40% portion of the BOD which is reflected as COD: (100/60 x A)-A i.e
(100/60 x 170)-170 = 113 mg/l i.e 0.113 Kg BOD /m3
Total Volume of Effluent from PTA Plant through ETP-III (A): 255 m3/h i.e. 255 x 24:
6120 m3/day
Total Biodegradable COD (Difference of BOD20 and BOD3) discharged in the Thirana Drain/day
(C): A x B: 6120 x 0.113 = 691.56 Kg/day
Total Period of Non Compliance as decided by two members of the committee(D): 120 days
Total BOD discharged in the Thirana Drain during entire period of non-Compliance (E): C x
D: 691.56 x 120 = 82987.2Kg
Amount of Oxygen required for stabilizing BOD (F):
C6H12O6 + 6O2 = 6CO2 + 6H2O
Thus, the theoretical oxygen demand would then be:
Oxygen demand = (Gram of oxygen used) / (Gram of carbon oxidized) =
192 / 72 = 2.67 g O2/g of carbon
Total Oxygen required to stabilize total BOD Load discharged in the Thirana Drain (G): E x F
i.e. 82987.2 x 2.67 = 221575.82 Kg
Estimated Cost of Oxygen (H): Rs. 25/ Kg.

on account of illegal discharge of Effluent in the Thirana Drain: G x H i.e.
221575.82 x 25 = Rs 5539395 (C2)
Environmental Damage due to Discharge of Untreated Effluent in Cass

Pool:
The untreated effluents was found to be discharged in an area measuring 250 mtr x
8 mtr. The environmental damage on account of this activity was calculated as follows:
Average BOD of the Untreated Effluent in Cess Pool as reported earlier in the report of the
Joint Committee (A): 1050 mg/l i.e 1.5 Kg/m3
Total Volume of Effluent in Cess Pool as per Report of the Joint Committee (B): 250 x 8 x 2.5
mtr=5000 m3
Total BOD Discharged (C): A x B i.e. 1.5 x 5000 = 7500 Kg
Oxygen required to stabilize BOD: 2.67 g O2/ g of carbon
Page 3 of 7
709
Total Oxygen required to stabilize total BOD Load discharged in Cess Pool: 7500 x 2.6 =
19500 Kg
Estimated Cost of Oxygen: Rs. 25 /Kg

on account of illegal discharge of Effluent in the Cess Pool: 19500x 25 = Rs.
487500 (C3)
Total Cost of Environmental Damage by IOCL, Panipat Refinery: C1 + C2

+ C3 i.e. Rs 8333604+ Rs. 5539395 + Rs. 487500 = Rs.
14360499 (Rs. 1.44 Crores)
Cost of Restoration of the Environment damage on account of

Oxygen depletion:
Joint Committee was of the view that a part of the Environmental damage caused due
to depletion of Oxygen may be restored by generating equivalent amount of oxygen
through tree plantation. In view of this, the Joint Committee calculated the cost of
restoration of Environment as follows:
Amount of Oxygen depleted by Discharging untreated effluent (BOD) in Thirana Drain:

333344.16 Kg
Amount of Oxygen depleted by Discharging untreated effluent (BOD) in Thirana Drain:
221575.82 Kg
Amount of Oxygen depleted by Discharging untreated effluent in Cess Pool: 19500 Kg

Total Amount of Oxygen depleted (A): 333344.16 + 221575.82 + 19500
=574419.98 Kg O2
Average amount of Oxygen generated by a fully grown tree/annum (B): 118 Kg
Total Number of Forest trees required to generate depleted Oxygen (C): A/B: 574419.98
/118 =4868 Trees
Survival rate of the Forest Trees (D): 60%
Total number of trees required after considering 60% survival rate (E): 100/D x C i.e.
100/60 x 4868 = 8113 Trees
Average Time required for maturity of Forest Trees (F): 10 years

Total Number of Trees considering maturity Period (G): E x F i.e. 8113 x 10 = 81130 trees
Page 4 of 7
710
The joint committee is of the view that the damaged caused by the Unit in four months should
be restored in seven months to ensure timely justice to the environment.
Number of Trees required for Restoration of Damage in 4 months (H): G x (12/7)
i.e. 81130 x 12/4 = 243390 Trees
Estimated average price of 6-8 Ft Forest Tree (I): Rs. 100 (Reference: India Mart. The price was
found to be ranging between Rs. 50-250/Tree)
Total Cost of Restoration: H x I: 243390 x 100 = Rs. 24339000 (Rs. 2.43 Crores)
This cost of restoration is just enough to restore the damage caused by the Unit by
depleting the Oxygen from the Environment. As directed by Hon’ble NGT, it is
extremely necessary to make this deterrent so that such acts of polluting the
environment are not repeated in the future. Therefore, Joint Committee proposes
to impose Environmental Damage cost equivalent to 2 times of the Cost of
Restoration.
Therefore, the proposed cost of Restoration should be: Rs. 2.43 Crores x 2
= 4.86 Crores (C4)
Cost of Damage due to Discharge of TDS in Thirana Drain and

Compensation:
The Industry is not permitted to discharge effluent in the Thirana Drain. Apart from
discharging high BOD, the Unit has also been discharging high TDS in the Thirana
Drain instead of recycling and reusing the effluent as per conditions of the Consent
granted by Haryana State Pollution Control Board. Joint Committee was of the view
that by Discharging TDS in the Thirana drain, Industry has tried to save the treatment
cost and hence in this case, Environmental compensation should be equivalent to
atleast Cost of Prevention, which may be utilized for monitoring and planning of
restoration of ground water quality. The cost of prevention estimated by the Joint
Committee is as under:
Total Volume of Effluent from PTA Plant through ETP-III (A): 255 m3/h i.e. 255 x 24: 6120
m3/day
Total period of Non Compliance as decided by two members of the Committee (B): 120 days
Estimated minimum cost of Treatment (Including partial ZLD) for recycling the effluent (C):
Rs 150/m3 (Reference: CPCB Guidelines on Techno-Economic Feasibility of Implementation of Zero Liquid
Page 5 of 7
711
Discharge (ZLD) for Water Polluting Industries . The O&M cost of ZLD Indicated in the Guidelines if Rs. 300-350
for ZLD. Since the consent of operate granted to the Unit is for “Recycle and Reuse”, the cost of ZLD taken by
Joint Committee is Rs. 150/m3 )
Total Cost of Prevention: A x B x C i.e. 6120 x 150 x 120 = Rs. 110160000

(Rs. 11.02 Crores )
Joint Committee is of the view that keeping the cost of restoration just equivalent to
the cost of prevention may not serve as a deterrent for preventing the Unit to do such
act of non-compliance of the conditions of Consent to operate granted by HSPCB and
hence keeping in view the fact the unit has remained non-compliant for more than 6
months, it is proposed to impose Environmental Restoration Cost equivalent to 2 times
of cost of prevention.
Therefore, the proposed cost of Restoration should be: 11.02 x 2 = Rs.

22.04 Crores (C5)
So, Total cost of restoration on account of damage caused due to

oxygen depletion and pollution of surface water: C4 + C5 i.e
4.86+ 22.04 = Rs. 26.90 Crores
============================================
B. The following may also be incorporated in the

Conclusion Section
The environmental compensation (EC) calculated by the Joint team is as under:
i) EC for Oxygen depletion and Pollution caused to the surface water due to illegal
discharge of effluent: Rs. 26.90 Crores
ii) EC for damage caused to public health & environment : Rs. 92.59 Crores
iii) EC on account of damage caused to ground water : Rs. 540 Crores
Total Environmental Compensation as calculated by the Joint team is :

26.90 + 92.59 + 540 = Rs. 659.49 Crores, out of which IOCL has already
deposited Rs. 17.31 Crores, as interim compensation in compliance of Hon’ble
NGT Order.
Therefore, balance environmental compensation to be deposited is:

659.49-17.31 = Rs. 642.18 Crores, if approved by Hon’ble NGT.
Page 6 of 7
712
Water stored in multiple lagoons/ponds inside the plant should be treated and recycled
before lining the lagoon to make them impervious.
No untreated water will be stored in the lagoons/ponds except in the tanks, which are
components of effluent treatment plant.
Looking into the potential of one industry to cause such a huge environmental
damage, the Joint Committee is of the view that mode of discharge of treated
industrial effluents must be decided and permitted only and only after evaluating the
carrying capacity of receiving environment. This factor becomes extremely important
in view of the fact that the cost & time required for restoration is much higher than
the cost of damage & period of polluting activity and the damage caused to the
environment may not be reversible in most of the cases.
C. Pls also note that the following statements were submitted

by two members in the interim report:
“The profit made by the PTA plant per day can be calculated only
after submission of profit earned by the unit from its PTA plant.
This information was requested by the Joint Committee from the
Unit on 27/03/2019 and is yet to be received.”
“ The unit may be directed to submit the amount of profit earned
by him per day from the PTA Plant, so that total amount of profit
earned by the unit from the production made without complying
with the environmental norms could be calculated during non-
compliance period”
“However, once the assessment of environmental damage to public
health and Ground water is concluded with the assistance of Co-
opted Experts and the details of the profits earned by the Unit from
the production made by violating the environmental norms, the
Joint Committee may further enhance the deterrent effect for
continuous and long term violations made by the unit by proposing
the Cost of Restoration/Environmental Compensation on
exponential basis”
You may like to add something w.r.t above in the Final
Report, to avoid any adverse observation by the Court.
Page 7 of 7
713
Annexure -B
Environmental damage cost assessment due to discharge pollutants

from effluent treatment plant beyond the permissible limits into
Thirana drain by IOCL Refinery, Panipat and cess pool
The Effluent from IOCL refinery, Panipat was found to be discharged beyond
the CPCB prescribed standards into storm drains and open land. The discharge of
polluted effluent into thirana drain ultimately reaches river Yamuna causing
environmental oriented damages such as the depletion of aquatic life, water supply
suspenirion, toxicity, damage to biological life etc. Pollutant discharged into open land
has resulted in ground water contamination and disamenity due to odor due to
stagnation of the effluent for a longer period forming a cess pool. This illicit
exploitation and significant damages to the environment are valued on a monetary
basis in this report. The monetary assessment was carried out using shadow pricing
nrethodusing the figures in table LShadow pricing or avoided cost refers to those
damage cost that can be avoided if efficient treatment procedure is incorporated to
reduce the pollutant Concerlation before the l'jnal discharge.
Table l: Damage cost value for each pollutant[ I i

Pollutant Damage in Euro per Kg (2010)
Suspended Solids 0.005
Biological Oxygen Demand 0.033
Chemical Oxygen Demand 0.098
Economic assessrnent cost on the environment due to the discharge of

pollutant is calculated taking CPCB discharge standards as base docurnentl2l.The
breached pollutant load in comparison with CPCR permissible limit is considered for
analysis and damage cost for a non-complying period of 506 days was calculated
using the figures suggested bV [11. The estimation of damage cost is done on 2010 -
2019 average inflation basis i e.,18.30o/o [3] and Euro to INR exchange rate fbr the
year 2010 (l Euro: 60.59)14'l.
Table 2 shows the pollutant concentration of effluent being discharged. It can
be observed that all the discharge pollutant concentration breaches the standard set by
CPCB for Petroleum oil refinery industries. Table 3 shows the non-complying
duration for the effluent discharge. IOCL operates 3 Effluent treatment plants. The
capacity of ETP's are ETP-I 8. ETP-2 is 400 mjlhr each and that of ETP-3 is 275
rn3/lrr. The treated effluents from ETP-1 & ETP-2 is taken directly into the process
and treated effluent from ETP-3 is discharsed into thirana drain.
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Table 2: Concentration of pollutants discharged into Thirana drain and cess
Pollutants Discharge Discharge CPCB discharge
concertation in concertation in standard (mg/l)
T'hirana drain open land/cess pool (EP,2008)
'(me/l)
(me/l)
Biological oxygen 170 I 200 l5
demand (BOD)
Chemical oxygen 460 5472 t25
Demand (COD)
Total suspended t42ls] 552 20
solids flSS)
Table 3: Duration for which pollutants are emitted from ETP-III to Thirana drain
From To Total Number of Davs

1311112017 3111212017 49 days
UU20l8 3Ut2l20l8 365 days
Uv20r9 21412019 92 days
TOTAL 506 davs
Table 4: Environmental damage cost due to Excess BOD discharge in Thirana drain
Duration BOD value of Excess BOD Damage
treated effluent discharged cost
being discharged breaching the (Lakhs,
(me/l) standards (15 me/l) INR)
l3-ll-201'7 to3l-12- t70 r55 I .78
2017
0 f -01-2017 to 3l -12- 170 155 t3.3l
201 8
0 f -01-2019 to 02-04- 170 r55 3.35
2019
Total 18.46 ----
(A)
Table 5: Environmental damage cost due to Excess COD discharge in Thirana drain
Duration COD value of Excess COD Damage
treated effluent discharged cost
being discharged breaching the (Lakhs,
(mg/l) standards (125 rNR)
me/l)
l3-1 | -2017 to 3l-12- 460 335 n.47
2017
0l-01-2017 ro3l-12- 460 335 8s.48
201 8
Environmental damage cost assessment due to discharge pol

plant beyond the permissible lirnits into Thirana drain by IO
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0l-0l-201 9 to 02-04- 460 335 21.54

2019
Total 1r8.50 --
(B)
Table 6: Environmental damage cost due to Excess TSS discharge in Thirana drain
Duration COD value of Excess COD discharged Damage
treated effluent breat:hing the starrrdards (125 cost
being discharged mg/l) (lakhs,
(me/l) INR)
13-11-2017 142 t22 0.21
13-11-2017 142 122 I .58
13-11-2011 142 t22 0.40
Tota 2.20 -- (c)
Table 4,5,6 shows the environmental damage cost due to the discharge of
pollutants such as Biological oxygen demand (BOD), Chemical oxygen demand
(Cod) and total suspended solids (TSS) respectively at a concentration higher than the
perrnissible value set by CPCB.
Therefrrre,
Total environmental damase cost due to discharse into thirana drain: A+B+C
18,46,339+ 1,18,50,503+
2.20.189
-- 1,39,17,032 INR (Rs. 1.39 Cr)
i.e. Rs I Crore in an year (2018)
Some of the water from the plant is directly discharged on land which has lead
to creation of Cess Pool. The water quality analysis on the cess pool showed BOD:
102, 1200,880,900 in mg/I, COD: 306, 3580, 2812, 5412in mg/l and TSS: 194, 124,
552,252, 156 in mg/l[fiJ. As a purpose of valuation worst case scenario was
considered, where higher concentration for each pollutants analysed was taken for
assessment. The total volume of cess pool was 5000m1(250 x 8 x 2.5 mts)[6]and the
same was used to calculate the loading rate, considering 2017 as discharge year. This
cess pool water is stagnant in nature and must be percolating in the ground water.
Since no direct valuation rnethod is available to assess the environmental, damage,
water risk monetiser is used to determine the damase value in the fbrm of risk.
The idea used is to understand the amount of freshwater which will be

required to dilute the water to attain water quality discharge standa
Environrnental damage cost assessrlrent due to discharge pollutants fi-orn effluent tfeatrnent
plant beyond the permissible lirnits into Thirana drain by IOCL Retinery, Panipat and cess pool
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E,rrvironnrental
Engineering
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Table 6: Environmental damage cost due to direct discharge of effluent into cess pool
Durafion Raw effluent Average Raw

parameters effluent
concentration
(ms/l) *
l3-11-2017 COD 3058
t3-tt-2017 BOD 770
t3-11-2017 TSS 256
Direct discharge of raw effluent into open land has stagnated the effluent over
the area forming a cess pool. The stagnated effluent in order to be discharged needs to
meet the CPCB set standard (i e., BOD : 15 mg/l). Hence a dilution with fresh water
need ro be made before the discharge. The fresh water required for dilution is 250
Million titres and is calculated using the Eq (1). The Cost for dilution is valuated
using willingness to pay method (WTP) which is considered as damage cost incurred
due to release ofraw effluent.
Cvx Caoo * Dvx Deoo: (Cv + Dv) x Feoo Eq (l)

Where.
C.v: Volume of cess pool (m3)
Ceoo: BOD concentration in cess pool (mg/l)
Dv: Volume of dilution water (ml)
Dsoo: BOD of dilution water (mg/l) (Deoo: I mg/l)
Feoo: Final BOD to be achieved (i e', 15 mg/l)
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The damage caused by cess pool water, when considered for discharge, will lead to an
impact worth approximately Rs 59 Crore as given in the figure above. For USD to
INR, Rs 68 is used as the conversion f'actor
Health damage cost due to air pollutants

Air pollutants emitted frorn industrial stacks can have severe adverse health
impacts on human wellbeing. Major pollutants that need to be fbcused are PMro,
PMz s, NOz& SOz as these have high risk of mortality and morbidity impacts on
human. In this report, the data provided by Medical officer, CHC Daldana, Panipat
regarding air borne cases as mentioned in Table 7 is used to evaluate health damage
due to air pollutants. There exists an uncertainty, when it comes to source of
pollutants that has resulted in air borne disease. In order to avoid the ambiguity,
ambient air quality rnonitoring over the refinery area needs to be carried out. In thrs
report, for the purpose of damage assessment, all the mentioned air borne cases are
assumed to be due to pollutants emitted frorn industrial stack.This is based on the
reason that respiratory problems generally happens because of air pollution. Further,
there is hardly any other industry in the l0 km radius of CHC Daldana hence the air
pollution can be attributed to only Panipat plants.
The darnage cost due to air pollution is evaluated using cost of illness
approach. The study carried out by fil in Mumbai region is taken as reference
document. The COI due to respiratory diseases is estimated for Panipat region
considering the base estirnate reported bV 171 using per capita income of both cities as
shown in Eq (2). The values are then inflated fbr the required years.
Table 7: Water & air borne diseases details

Year Water borne diseases Respiratory diseases
2015 r98 19ll
2016 60 2449
20t7 436 505
20t8 388 11s7
2019 205 2495
Colran,par : COlvon,oo t * Y33L Eq

INC MUMDAL
(2\
COleanipar: Cost of illness per person in Panipat area
COll,lun,uui: Cost of illness per person in Murnbai area (INR 14,378 as of I 991) 1:,11
Incpun;oo1 : Per capita income of Panipat fbr the year 20ll-2012 (INR 109230) | ltl
IncMun'boi :Per capita income of Mumbai for the year 2011 -201 2(INR I 5 I 608X91
Environrnental dama_qe cost assessrrent due to discharge polhrtanrs florn effluent treatnlenl
pLant beyond the permissible lrrnits into Thilana drain by IOCL Retinely, Panipat and cess pool
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CSIR-National
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COlvu.uuivalue is inflated to 201l, as no per capita income of both cities for the year
1997 was available. The inflated value is used to determine the COlponipol for the
year
2011 using Eq (2). Further the determined COlpunipat volues are inflated for the
required years. Total health damage cost incurred due to respiratory diseases as an
impact of air pollutant is shown in Table 8. The total health damage cost incurred due
to air pollution is 322.6 million INR (Rs' 32.2 Crore)'
Table 8: Health damage cost due to respiratory diseases

Year Cost per person (COf) Total Cases Total cost (INR)
2015 34546.12 l9l 66017635
2016 36730.81 2449 89953900
2017 37550.12 505 l 89628 I 0
20r 8 39052.14 l 157 45183325
2019 4l 100.35 2495 10254s373
Average (Rounded) 64532600 i.e. Rs.
6.45 Crore
Water damages are not valued as diseases can happen due to many reasons and cannot
be directly attributed to Panipat plants.
is:
Hence total impacts caused by the refinery I .39 + 59 + 32.2: Rs. 92.59 Crore
In an year, refinery has caused damage of : 1 + 6.45 + 59 (assuming all cess Poll
water is released in an year): Rs. 66.45 Crore
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plant beyond the permissible limits into Thirana drain by IOCL Retinery, Panipat and cess pool
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References
ill Hern6ndez-Sancho.F., Molinos-Senante, M.,'Sala-Garrido, R. (2010). Economic

valuation of environmental benefits from wastewater treatment processes: an
empirical approach for Spain.Sci Total Environ- 408(4), 953-7
tll URL 0l: http:llcpc6.nic.inluploads/Industry-Specific-Standards/Effluent/03

petroleum-oil-refinery.pdf. Accessed on 12-06-2019
[.1] URL 02:
value'?amount:1 . Accessed on 12-06-2019
[4] URL 03:

annual-exchange-rate/. Accessed on 12-06-2019
[5] URL 0a: Accessed on
12-06-20t9
[6] Report of the Joint Committee constituted by as per Hon'ble NGT Order
dated
l5llll20l8 in OA No.738/2018, in the matter ofSatpal Singh & Others Vs IOCL,

panipat Refinery in Compliance ofFlon'ble NGT Order dated 01.03.2019. Accessed
on 12-06-2019
i7l Srivastava, A. and Kumar, R. (2002). Economic valuation of health impacts of air
pollution in mumbai. Environ. Monit. Assess. 75:135-143'
05:
[S] URL . Accessed on27-06-2019
iel URL 06:
I 3:eng.pdf. Accessed on 27 -06-2019

in Urban Delhi,
[10] Dasgupta, P. "Valuing Health Damages from Water Pollution
India: A Health Production Function Approach." Institute for Economic GroMh:
Delhi,India
lr rl URL 07: htt siindi
Accessed on 27-06-2019
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1.7
Environmental damage cost assessllent due to discharge pollutants from effluent treatment
plant beyond the permissible lirnits into Thirana drain by IOCL Retrnery, Panipat and cess pool
720
Annexure-C1
Report on Environmental Compensation for Ground Water
Contamination by Panipat Refinery as per Hon’ble NGT Order
dated 15/11/2018 in OA No.738/2018, in the matter of Satpal Singh &
Others Vs IOCL, Panipat Refinery in Compliance of Hon’ble NGT
Order dated 01.03.2019
During the hearing of the case OA No. 738/2018 titled Satpal Singh and
Others Vs Indian Oil Corporation Limited, Panipat Refinery before Hon’ble NGT on
01.03.2019, the following directions were issued by the Hon’ble Tribunal:
“In the light of findings recorded in the spot inspection report, we

consider it necessary to require the joint Committee constituted by this
Tribunal vide order dated 15.11.2018 to make a realistic assessment of the
damage caused to public health and environment and immediate measures
for stoppage of polluting activity. Such report may be furnished within one
month by email at [email protected]. The Committee is at liberty to take
any expert opinion or co-opt any other expert. The compensation proposed
must be adequate to meet the cost of restoration of environment and public
health and deterrent against the polluter so that such action is not repeated”.
Accordingly, the committee constituted by Hon’ble NGT, co-opted a member from

Central Ground Water Board for taking up ground water pollution studies around the
Panipat Refiner to assess the areal impact of pollution caused by Panipat Refinery
both laterally and vertically (Depth wise). Sh. S.K. Mohiddin, Sr. Hydro geologist,
Central Ground Water Board (CGWB), North West Region, Chandigarh has been
nominated by CGWB for this study.
CGWB has takenup the detailed study around the Refinery and collected 31 ground
water samples around the Refinery to assess the ground water contamination.
Groundwater sampling and analysis was done by Sh. Dhan Prakash, Sc ‘B’ CGWB
during May and June, 2019. Apart from these 31 samples, the data collected by the
721
HSPCB during the preliminary study was also used for estimation of environmental
compensation.
2. Hydrogeological condition around the Panipat Refinery: The Refinery is
located adjacent to Western Yamuna Canal (Delhi Branch). The area is flat alluvial
plain underlain by arid brown soil. The geological formation comprises
unconsolidated alluvial deposits. The principal aquifer system comprises of fine to
coarse sand and sand associated with kankar. A number of aquifers are present in
the area as per the exploratory data of CGWB (CGWB data revealed that the
existence of . The aquifer which is fine to coarse sand are intercalated with thin clay
layers. It is observed that first sand layer is present from 10.00 m to 27.00 mts below
ground level (bgl), second layer is present between 31.00 m to 35.00 m bgl, third
layer present between 44.00 to 48.00 m bgl, fourth layer is between 82.5 m bgl and
fourth layer is present between 95 to 130 m bgl. Within these aquifers also, there are
few clay layers of 2-3 m thick which are not of much importance as far as
hydrogeology is concerned because of lateral extension of these aquifers are very
limited and the major aquifers are interconnected in the area. It is observed that most
of the shallow tubewells are of the depth 30 m to 80 m depth with discharges varying
between 8 to 14 Litres per Second (LPS). Depth to water level around the vicinity of
Refinery and Western Yauna Canal is shallow i.e. 5.00 to 6.00 m bgl. Away from the
canal, depth to water level is about 18.00 m to 20.00 m bgl. Piezometric head i.e.
water level of deeper aquifer is also 18.32 m bgl in Baholi piezometer and 16.81 m
bgl in Khandra.
3. Ground Water Quality:

Ground water samples from 31 shallow handpumps and deep tubwells are collected
for analysis and data collected by HSPCB, Haryana, are also taken into
consideration for demarcation of area of contamination. The data and interpretation
along with the maps are at Annexure-1.
4. Demarcation of Contaminated area: A number of parameters are
considered for demarcation of contaminated zone. Important parameters considered
are Electrical Conductivity, COD and Iron Concentration. Based on the distribution
of various parameters the contaminated zone has been demarcated. The E.C. value
contour of 600 micro-siemens/cm has been is considered for demarcation of polluted
zone and shown in Figure-1. The ambient and in-situ ground water quality in the
722
area is of less than 600 ms/cm which is reported by the ground water samples
collected away from the Refinery. The ground water within the vicinity of refinery is
having EC values more than 600 ms/cm. The ground water samples collected from
nearby refinery are also having COD ranging from 7.20 mg/lt to 40.80 mg/lt. The
COD in ground water samples should be zero. This also depicts that the ground
water is contaminated in the vicinity of refinery. Higher concentration of iron is also
reported from the ground water around the refinery. The Total Organic Carbon
(TOC) is also present in the ground water which should be zero. The presence of
TOC shows that ground water is contaminated with organic pollution. This TOC is
mainly by the uncontrolled disposal of effluents from the Refinery into the cess pools
and the drains. Considering all the above parameters it is estimated that ground
water in about 75 Sq.km area around the refinery is contaminated.
The depth upto which the contamination has also been arrived at based on
these parameters. The depth of the tubewells where contamination is identified are
about 46 m bgl. It is inferred that aquifers upto the depth of about 50 m depth are
contaminated. Considering the average water levels of about 7 to 8 m bgl and clay
zones of 12 m thick, about 30 m thick aquifer zones filled with fresh water have been
contaminated.
5. Estimation of total quantum of water contaminated:
The area contaminated = 75 Sq.km
The thickness of aquifer contaminated = 30 m thick
Specific yield of aquifer zone = 12% i.e. 0.12
Thus total quantum of water contaminated = 75 Sq.km * 30 m * 0.12 = 270 Million
Cubic Meters of fresh water has been contaminated.
Estimation of Environmental Compensation: As per the Central Ground Water
Authority notification vide S. O. No. 6140(E) dated 12th Dec., 2018, the water
conservation fee recommended for industries drawing more than 5000 Cu.mt per
day in Over-exploited areas is Rs 20/- per cubic meter. The matter was discussed
with CPCB representative of the committee and based on his observations, the
water conservation fee of Rs 20 is taken into consideration. Thus Taking into
consideration of this fee, the dewatering of affected/contaminated water will be:
Cost of dewatering contaminated water = 270 MCM * Rs 20
= 270000000 * 20 = Rs 540,00,00,000
723
i.e Rs: 540 Crores
Environmental Management Plan proposed: Dewatering and refilling of

contaminated aquifers is proposed in this management plan. It is suggested that for
dewatering of 270 MCM of water, 170 tubewells need to e constructed which are
yielding about 36 Cu.mt/hour. These tubewells need to be pumped 24 hours
throughout the year for a minimum period of 5 years to dewater contaminated water
of 270 MCM. At the same time, surface water from the Western Yamuna Canal need
to be recharged through the same number of tubewells so that the aquifers will be
filled with fresh and non-contaminated water. The de-watered 270 MCM of water
can be put to irrigational requirements in the surrounding areas and partly can be
used for industrial requirements in Panipat Refinery. Environmental compensation
amount collected from the refinery can be used for this purpose.
724
Annexure-1
Ground Water Quality in and around Panipat Refinery
The quality of shallow/deep ground water in the surrounding area distance of at least
10km. of Panipat Refinery plant has been evaluated on the basis of 31 no’s of water
samples collected from shallow/deep aquifers during pre-monsoon season i.e. May,
2019. All the collected samples were analyzed by adopting standard methods of
analysis (APHA). Chemical analysis data of samples are given in Annexure-2. Apart
from these, chemical data of water samples collected from the HSPCB is also
utilised for interpretation purpose. The HSPCB data is at Annexure-3. The Total
Organic Carban data is at Annexure-4. The summarized results of ground water
samples are given in Table-1 given below.
Table: 1 Ground Water Quality of analysed samples:

S.No. Parameters Permissible Ranges No. of Percentage
limit Samples %
1 Sp. Conductance - <600 17 54.83

(µs/cm at 25oC) 601-2250 07 45.16
2 Chloride 250-1000 <250 31 100
(mg/l)
3 Fluoride 1.50 mg/l <1.00 11 35.48
(mg/l) 1.01-1.50 11 35.48
>1.50 09 29.03
4 Nitrate 45 mg/l <45 29 93.54
(mg/l) 46-100 02 6.45
pH
In Panipat Refinery plant and surrounding area villages pH values of ground water
ranges between 7.15 to 8.24.
Specific Conductance
Majority of samples (54.83%) are found to have specific conductance less than 600
µS/cm at 25 oC hence the ground water is fresh and potable. About 45.16% of the
725
samples have values which are neary by the refinery area are having Sp.
Conductance between 600- 2250 µS/cm respectively. The specific conductance min
310 µS/cm at 25oC at Vill-More Majra Bus stand. and max 1325 µS/cm Vill-
Kutana,Gurunanak spare parts.
Chloride Concentration
The concentration of Chloride in all samples is less than 250 mg/l. Chloride
concentration in most of the samples is within the maximum permissible limit of BIS
for drinking water purpose.
Fluoride Concentration
Fluoride is an important parameter for evaluating ground water quality. The

concentration of fluoride in majority of the samples (71.00 %) is less than 1.50 mg/l
and remaining 29.03% which are near by the plant area are above the permissible
limit i.e. 1.5 mg/l. The min Fluoride Concentration 0.36 mg/l at Vill-Khandra, Govt.
middle school, bus stand, and max 2.60mg/l at Beshwal road, Ramesh Malic, new
construction.
Nitrate Concentration
Nitrate is also an important parameter for evaluating ground water quality. The all
samples having concentration of nitrate is less than 45 mg/l, Nitrate is an
anthropogenic pollutant and plays an important role to evaluating ground water
quality for various applications.
Total Hardness
The total hardness concentration min 83 mg/l at Vill-Singhpura,Satpal sarpanch

dera,Babadargha and max 347 mg/l at Vill-Dharamgarh,vardha ashram,bus stand.
Classification of Hardness
This classification is based on the value of total Hardness. Ground water may be
classified in to four type’s soft, moderate hard, hard and very hard.
726
Table: 2 Ground water samples summarised as per classification of Hardness

S.N District Nos of Soft Mod. Hard Hard Very Hard
o Samples (0-60 (61-120) (121-180) more than
mg/l mg/l mg/l 180 mg/l
1 Panipat 31 00 04(12.90%) 09(29.03%) 18(58.06%)
Refinery plant
As per the classification, the majority of Ground water is hard and very hard. None of
the sample of in the study area are belongs to Soft category.
Sulphates (SO4)
The sulphate content of ground water ranged between 1.0 mg/l to 201 mg/l at (Vill-
Khandra, Govt. middle school, bus stand.)
Heavy Metals NGT case Panipat Refinery:
Ground water samples are analyzed for six heavy metals viz Iron, Cadmium,
Copper, Lead, Zinc and Manganese. The concentration of heavy metals is given in
Annexure-4. The maximum and Minimum values are as follows:
Minimum and maximum values:
Parameters Maximum permissible Minimum (mg/l) Maximum (mg/l)

limits as per BIS standards
(mg/lt)
Iron 0.3 0.013 7.205
Cadmium 0.003 0.002 0.007
Copper 1.5 BDL 0.017
Lead 0.01 BDL 0.030
Zinc 5 to 15 BDL 1.890
Manganese 0.3 BDL 0.450
Iron Concentration
The 48.38% of samples having Iron concentration more than 0.30 mg/l. Iron
concentrations in these samples are beyond the norms setup by BIS for drinking
water purpose. The Iron concentrations min 0.013 mg/l sample no-3(M/S Gulsan
Garment Noorwala, gas godown, Panipat town) and max 7.205 mg/l at (Vill-
Singhpura, In the residence of Satpal sarpanch dera, Babadargha).
727
Cadmium
Most of the samples (87%) having the concentration of cadmium within desirable
limits i.e.0.003mg/l. The cadmium concentration min 0.002 mg/l sample no-27(Vtsav
garden, GT road, Gagbad-vill.) and max 0.007mg/l at (Mahinder singh S/O Shri
Sadhuram,CISF colony, Baholi.).
Copper
In majority of samples, having copper concentration less than 0.05 mg/l. copper
concentrations in these samples are within the norms setup by BIS for drinking water
purpose.
Lead
The most of the samples (84%) having lead concentration less than 0.010 mg/l. Only
five samples having lead concentration more than 0.01 mg/l. The max 0.03mg/l
concentration of Lead has been found in sample no-1 at (Vill-Nizampur,shiva
temple.).
Zinc
The all samples have Zinc concentration within acceptable limit i.e.5 mg/l. None of
the sample has Zinc value above the permissible limit.
Manganese
The most of the samples having manganese concentration within permissible limit
i.e.0.30 mg/l. Only one sample has manganese value above the permissible limit
i.e.0.45mg/l (Vtsav garden, GT road Gagbad-vill.).
Bacteriological Contamination: Ground water samples from the Panipat refinery
surrounding areas were collected by HSPCB and analysed for various parameters.
The data is given in Annexure-3. As per the data, the COD values ranges between
7.20 mg/lt to 40.80 mg/lt. As per the BIS standards, drinking water should not have
BOD and COD and thus the concentrations should have been zero. The presence of
COD in ground water shows that the ground water is contaminated around the
refinery area. The parameter COD has als been taken into consideration for arriving
at the area and aquifers contaminated by the effluents of Panipat Refinery.
Total Organic carbon: Total Organic Carbon values range between 1.18 mg/lt to
82.60 mg/lt. All the samples collected around the refinery are having the TOC. TOC
for the ground water to be sued for drinking purposes should be zero. Presence of
TOC shows the organic contamination of ground water.
728
Annexure-2
*
S. Location Sour Depth EC in
No ce in mts µS/cm TH *as
pH* HCO3 Cl* SO4 NO3 F* PO4 Ca* Mg* Na K SiO2
at 250 CaCO3
C
mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l
1 Vill- S.B. 46 7.63 450 268 36 6 0 0.61 0 8 50 23 2.9 12
Nizampur,shiva
temple. 225
2 Radha swami S.B. 38 8.08 425 281 21 2 0 1.21 0 8 27 60 1.9 9
sat sang beas,
sec-18. 133
3 M/S Gulsan T.W. 46 7.97 435 293 28 5 0 2 0 21 22 67 2.3 8
Garment
Noorwala, gas
godwon 143
4 Beshwal road, T.W. 76 7.74 330 232 29 8 1 2.6 0 16 17 58 1.3 10
Ramesh Malic,
new
construction 112
5 Krishana filling S.B. 76 7.94 670 330 43 90 7 1.6 0 4 55 90 3.1 15
station,Sanoli
road. 235
6 M/S R.K. T.W. 24 8.02 770 293 43 149 0 1.3 0 4 47 116 2.6 12
industry,Bapoli
road,Nimbori. 204
7 Ishwer Singh, T.W. 76 7.8 690 317 28 115 0 0.37 0 8 55 80 2.7 7
nearby Samadh,
vill-chajpur. 245
8 Vill-Dahar,New T.W. 91 7.91 550 317 43 6 20 1.4 0 8 40 73 3.1 5
balaji veshno
dhaba,Gohana
road. 184
9 Vill-Dadlana, H.P. 36 7.96 450 232 50 3 3 0.49 0 8 35 45 4.6 8
near water tank. 163
10 Vill- T.W. 106 7.72 325 232 28 1 5 2.4 0 16 17 58 2.2 11 112
729
Dadlana,PHE,
T.W.
11 Mahinder singh H.P. 33 7.84 890 598 43 4 9 1.4 0 4 35 187 4 13
S/O Shri
Sadhuram,CISF
colony,Baholi. 153
12 Mahinder singh S.B. 35 7.89 990 683 57 15 17 1.2 0 8 30 241 5 16
S/O Shri
Sadhuram
,CISF,colony,Ba
holi. 143
13 Naphtha H.P. 30 7.62 590 220 113 7 2 1.1 0 12 55 40 8.1 16
creeker, glycol
road nursery. 255
14 Ravi kumar S.B. 40 7.65 840 403 113 94 11 1.7 0 4 62 148 11 15
ranga,KBPL
gate,Phool singh
dera. 265
15 Pawan s/o Pale H.P. 27 7.74 895 647 92 11 9.2 1.53 0 4 55 249 5.2 12
ram, near
railway
line,Baholi. 235
16 Munsiram,sohan H.P. 30 7.92 590 281 43 2 6 2.3 0 4 22 90 3.3 13
lal dera,Inside
Raily
line,Baholi. 102
17 Vill- H.P. 46 8.01 950 464 43 20 20 2.2 0 17 10 183 3 14
Singhpura,Satpa
l sarpanch
dera,Babadargh
a 83
18 Vill- H.P. 23 7.65 310 159 21 2 2 1.3 0 25 20 10.3 2.3 12
Singhpura,NC
plant
6km,Rotashpal
sweet. 143
19 Vill- H.P. 21 7.74 1240 586 43 18 15 2.9 0 8 35 189 4 10
Baljatan,sachin 163
730
beauty salon.
20 Vill- H.P. 46 7.47 1190 366 99 89 33 1.16 0 8 80 78 5.1 9
Dharamgarh,var
dha ashram,bus
stand. 347
21 Vill-Khandra, H.P. 46 7.57 1090 195 156 201 29 0.36 0 20 50 161 6 7
Govt. middle
school, bus
stand. 255
22 Vill-Munak,Bus H.P. 36 7.5 885 488 21 9.6 12 0.86 0 8 27 145 4 2
stand. 133
23 Vill-Rer H.P. 34 7.75 1030 488 57 47 1 0.65 0 12 37 157 5.2 9
Kalan,Shiva
temple. 184
24 Vill- H.P. 27 7.54 1325 549 121 48 25 0.86 0 4 62 193 6 5
Kutana,Gurunan
ak spare parts. 265
25 Vill- Begampur, H.P. 34 7.52 1050 515 99 10 50 1.51 0 4 55 172 5.5 11
Shiva temple. 235
26 Vill- S.B. 46 7.15 920 281 142 46 58 0.35 0 8 72 95 5.4 12
Gudoh,Kashyap
chopal. 317
27 Vtsav garden, S.B. 34 7.41 510 244 85 37 19 0.71 0 4 60 52 6 8
GT
road,Gagbad-
vill. 255
28 Filling junction, S.B. 50 7.32 690 171 149 31 19 0.77 0 16 55 58 6 7
Babarpur,G.T
road. 265
29 Vill- S.B 56 8.17 590 305 14 29 12 0.4 0 45 30 32 5.2 13
Ballaa,Gaoushalla
. 235
30 Vill-More Majra SB 30 8.24 310 134 14 6.5 15 1.32 0 33 12 7.6 2.7 10
Bus stand. 133
31 Vill-More Majra TW 91 7.89 575 207 43 54 18 1.2 0 45 30 30 4 12
,Water works. 235
731
Annexure-3
732
733
734
Annexure-4
Pollution studies around Panipat Refinery, Panipat-Heavy metals analysis (concentrations in mg/lt)
S. Location Source
Cd Cu Mn Pb Zn Fe
No
Vill-Nizampur,shiva T.W.
0.003 0.003 BDL 0.030 0.032 0.540
1 temple.
Radha swami sat sang T.W
0.005 BDL BDL 0.022 0.017 0.240
2 beas, sec-18.
M/S Gulsan Garment T.W.
BDL BDL BDL 0.020 0.098 0.013
3 Noorwala, gas godwon
Beshwal road, Ramesh T.W.
BDL BDL BDL 0.014 0.012 BDL
4 Malic, new construction
Krishana filling S.B.
5 station,Sanoli road.
M/S R.K. T.W.
industry,Bapoli BDL BDL BDL 0.013 0.008 BDL
6 road,Nimbori.
Ishwer Singh, nearby T.W.
0.005 BDL BDL BDL 0.010 BDL
7 Samadh, vill-chajpur.
Vill-Dahar,New balaji T.W.
veshno dhaba,Gohana BDL BDL BDL BDL 0.018 0.113
8 road.
Vill-Dadlana, near H.P.
BDL BDL BDL BDL 0.264 0.524
9 water tank.
Vill-Dadlana,PHE, T.W.
0.006 BDL BDL BDL BDL 0.264
10 T.W.
Mahinder singh S/O H.P.
Shri Sadhuram,CISF 0.007 BDL BDL 0.007 0.159 1.877
11 colony,
Baholi.
Mahinder singh S/O T.W.
Shri Sadhuram BDL BDL BDL 0.009 BDL 0.043
12 ,CISF,colony,Baholi.
Naphtha creeker, glycol H.P.
13 road nursery.
Ravi kumar T.W
ranga,KBPL gate,Phool BDL BDL BDL 0.006 BDL BDL
14 singh dera.
Pawan s/o Pale ram, H.P.
near railway BDL BDL BDL 0.001 BDL 4.985
15 line,Baholi.
Munsiram,sohanlal H.P.
dera,Inside Raily BDL BDL BDL BDL BDL 0.031
16 line,Baholi.
Vill-Singhpura,Satpal H.P.
sarpanch BDL 0.011 BDL BDL 0.021 7.205
17 dera,Babadargha
Vill-Singhpura,NC H.P.
plant 6km,Rotashpal BDL 0.007 BDL BDL BDL 1.848
18 sweet.
Vill-Baljatan,sachin H.P.
BDL 0.008 BDL BDL 0.092 1.187
19 beauty salon.
735
Vill- H.P.
Dharamgarh,vardha BDL 0.014 BDL 0.010 0.577 1.239
20 ashram,bus stand.
Vill-Khandra, Govt. H.P.
middle school, bus BDL 0.007 0.164 0.005 0.053 1.180
21 stand.
22 Vill-Munak,Bus stand. H.P. BDL 0.005 BDL BDL BDL 0.178
Vill-Rer Kalan,Shiva H.P.
BDL 0.003 BDL 0.009 BDL 1.311
23 temple.
Vill-Kutana,Gurunanak H.P.
BDL 0.002 BDL 0.006 BDL 1.642
24 spare parts.
Vill- Begampur, Shiva H.P.
BDL 0.003 BDL 0.016 1.890 2.284
25 temple.
Vill-Gudoh,Kashyap T.W.
BDL 0.002 0.165 BDL BDL 2.925
26 chopal.
Vtsav garden, GT T.W
0.002 0.001 0.451 BDL 3.175 BDL
27 road,Gagbad-vill.
Filling junction, T.W.
28 Babarpur,G.T road.
29 Vill- Ballaa,Gaoushalla. T.W BDL 0.004 BDL BDL BDL 0.164
Vill-More Majra Bus T.W
BDL 0.017 BDL BDL BDL 0.104
30 stand.
Vill-More Majra ,Water TW
31 works.
736
TOC data of ground water samples

around Panipat Refinery Annexure-5
S. No Unique District Location Source TOC
ID (NPOC)
mg/l
1 1TOC Panipat Vill-Dadlana, near water tank. H.P. 15.35
2 2TOC Panipat Vill-Dadlana,PHE, T.W. T.W. 2.270
Panipat Mahinder singh S/O Shri H.P.
52.26
3 3TOC Sadhuram,CISF colony,Baholi.
Panipat Mahinder singh S/O Shri Sadhuram Tubewell
,CISF,colony,Baholi. 82.60
4 4TOC
5 5TOC Panipat Naphtha creeker, glycol road nursery. H.P. 21.25
Panipat Ravi kumar ranga,KBPL gate,Phool Tubewell
singh dera. 37.64
6 6TOC
Panipat Pawan s/o Pale ram, near railway H.P.
0.72
7 7TOC line,Baholi.
Panipat Munsiram,sohanlal dera,Inside Raily H.P.
2.19
8 8TOC line,Baholi.
Panipat Vill-Singhpura,Satpal sarpanch H.P.
47.11
9 9TOC dera,Babadargha
Panipat Vill-Singhpura,NC plant H.P.
46.45
10 10TOC 6km,Rotashpal sweet.
Panipat H.P.
31.04
11 11TOC Vill-Baljatan,sachin beauty salon.
Panipat Vill-Dharamgarh,vardha ashram,bus H.P.
44.19
12 12TOC stand.
Panipat Vill-Khandra, Govt. middle school, bus H.P.
stand. 45.51
13 13TOC
Panipat Vill-Munak,Bus stand. H.P.
1.18
14 14TOC
Panipat H.P.
1.33
15 15TOC Vill-Rer Kalan,Shiva temple.
737
738
739
740
741
742
743
744
745
Annexure -C2 746
Report on Environmental Compensation for Ground Water

Contamination by Panipat Refinery as per Hon’ble NGT Order
dated 15/11/2018 in OA No.738/2018, in the matter of Satpal Singh &
Others Vs IOCL, Panipat Refinery in Compliance of Hon’ble NGT
Order dated 01.03.2019
During the hearing of the case OA No. 738/2018 titled Satpal Singh and
Others Vs Indian Oil Corporation Limited, Panipat Refinery before Hon’ble NGT on
01.03.2019, the following directions were issued by the Hon’ble Tribunal:
“In the light of findings recorded in the spot inspection report, we

consider it necessary to require the joint Committee constituted by this
Tribunal vide order dated 15.11.2018 to make a realistic assessment of the
damage caused to public health and environment and immediate measures
for stoppage of polluting activity. Such report may be furnished within one
month by email at [email protected]. The Committee is at liberty to take
any expert opinion or co-opt any other expert. The compensation proposed
must be adequate to meet the cost of restoration of environment and public
health and deterrent against the polluter so that such action is not repeated”.
Accordingly, the committee constituted by Hon’ble NGT, co-opted a member from

Central Ground Water Board for taking up ground water pollution studies around the
Panipat Refiner to assess the areal impact of pollution caused by Panipat Refinery
both laterally and vertically (Depth wise). Sh. S.K. Mohiddin, Sr. Hydrogeologist,
Central Ground Water Board (CGWB), North West Region, Chandigarh was
nominated by CGWB for this study.
CGWB has takenup the detailed study around the Refinery and collected 31 ground
water samples covering an area of about 500 Sq.km around the Refinery to assess
the ground water contamination. Groundwater sampling and analysis was done by
Sh. Dhan Prakash, Sc ‘B’ CGWB during May and June, 2019 (Annexure-I & II). Apart
from these 31 samples, the data collected by the HSPCB during the preliminary
study was also used for the study. Effluent water quality before treatment and after
747
treatment as well as the cess pool samples and stagnant water samples from the
ponds of Refinery were collected and analysed by HSPCB and given in Annexure-3.
2. Hydrogeological condition around the Panipat Refinery: The Refinery is

located adjacent to Western Yamuna Canal (Delhi Branch). The area is flat alluvial
plain underlain by arid brown soil. The geological formation comprises of
unconsolidated alluvial deposits. The principal aquifer system comprises of fine to
coarse sand and sand associated with kankar. A number of aquifers are present in
the area as per the exploratory data of CGWB. The exploratory drilling data of
CGWB reveals that fine to coarse sand aquifers are intercalated with clay layers
giving rise to multiple aquifer system with confining conditions. The aquifer which is
fine to coarse sand are intercalated with thin clay layers. It is observed that first sand
layer is present from 10.00 m to 35.00 mts below ground level (bgl), with clay
intercalation at 18.00 m to 21.00 m bgl and 27.00 m to 31.00 m. A consistent clay
layer of about 9 m thickness is present from 35.00 m to 44.00 m bgl. This is followed
by aquifer present between 44.00 to 82.5 m bgl underlain by thick clay layer which
extends upto 95.00 m bgl. The second aquifer is present between 95 to 130 m bgl. It
is observed that most of the shallow tubewells are in the depth range of 30 m to 46
m with discharges varying between 8 to 14 Litres per Second (LPS). Depth to water
level around the vicinity of Refinery and Western Yauna Canal is shallow i.e. 5.00 to
6.00 m bgl. Away from the Western Yamuna canal, depth to water level is about
18.00 m to 20.00 m bgl. Depth to piezometric head i.e. water level of deeper aquifer
is also 18.32 m bgl in Baholi piezometer and 16.81 m bgl in Khandra.
3. Ground Water Quality:

Ground water samples from 31 shallow handpumps and deep tubwells were
collected for analysis. Data collected by HSPCB, Haryana, are also taken into
consideration for demarcation of area of contamination. The data and interpretation
along with the maps are at Annexure-1.
4. Demarcation of Contaminated area: A number of parameters are

considered for demarcation of contaminated zone. Important parameters considered
are Electrical Conductivity, Chemical Oxygen demand (COD), Total Organic Carbon
(TOC) and Fluoride concentrations and heavy metals Iron and Zinc. Presence of all
748
the above parameters are examined against the BIS Standards prescribed for
drinking water quality.
The threshold value for Electrical Conductivity is taken as less than 1000
ms/cm from shallow ground water which is also acceptable limit for drinking water
quality. Thus the ambient and in-situ ground water quality in the area is of less than
1000 ms/cm which is reported by the ground water samples collected away from the
Refinery. The acceptable limits of Electrical Conductivity for drinking water is 1000
ms/cm (Total Dissolved Solids – 500 mg/lt) and 3000 ms/cm is permissible if any
alternative source of drinking water is not available (TDS is 2000 mg/lt). In shallow
ground water, the Electrical Conductivity values ranges between 840 ms.cm to 1240
ms/cm within the vicinity of refinery and well within the permissible limits of drinking
water quality if alternate sources are not available. But the increased value of
Electrical Conductivity within the vicinity of refinery shows contamination and mixing
of effluents with shallow ground water as also indicated by other constituents. The
water samples of cess pool water, stagnate water, ETP outlet waters and other
surface water samples where effluents are being released are having Electrical
Conductivity values varying between 1491 to 5070 ms/cm (Annexure-3). Thus
seepage of this water and mixing with ground water is causing the ground water
around the refinery contaminated and increase in the Electrical Conductivity. The
E.C. value of contaminated ground water is also less than 2000 ms/cm which is the
permissible limits for drinking water.
Chemical Oxygen Demand (COD) is another parameter which is considered

for demarcation of polluted zone. The water samples of cess pool water, stagnate
water, ETP outlet waters and other surface water samples where effluents are being
released are having COD values varying between 120 mg/lt to 5472 mg/lt. Thus the
very high value of COD in effluents released on surface is causing the contamination
of ground water resulting in increase in COD in ground water. COD in shallow
ground water varies from 7.2 to 76.8 mg/lt. The data analysed by HSPCB was used
for interpretation of COD.
Iron is another parameter which is obtained in higher concentrations in
effluent water stored in cess pool etc. Iron concentration in stored effluents water
varies from 0.4 mg/lt to 5.6 mg/lt. Iron concentration in shallow ground water is
749
morethan 1.0 mg/lt around the refinery complex. The permissible limit of iron in
dinking water is 0.3 mg/lt. Presence of iron at higher concentrations shows the
contamination of shallow ground water because of effluent water released on the
surface.
Another parameters considering for study of ground water contamination by

the effluents is Total Organic Carbon due to contamination by petroleum
products/effluents. Total Organic Carbon values range between 1.18 mg/lt to 82.60
mg/lt in the samples analysed. All the samples collected around the refinery are
having the TOC. This TOC is mainly by the uncontrolled disposal of effluents from
the Refinery into the cess pools and the drains. No limit has been prescribed by BIS
for TOC in drinking water. Presence of TOC shows the organic contamination of
ground water.
Heavy metals like Copper, Zinc, Nickel, Chrome, Lead and Cadmium have
been analysed from the effluent water stagnating around the refinery. Out of these
parameters, only zinc is found beyond permissible limit in the effluent samples. All
other parameters are below detectable limits. In ground water heavy metals
parameters like cadmium, copper, manganese, lead and zinc are analysed. All these
elements are below permissible limits prescribed for drinking water.
Based on the distribution of various parameters the contaminated zone has

been demarcated. Considering all the above parameters it is estimated that ground
water in about 72 Sq.km area around the refinery is contaminated by one or more
than one parameters as discussed above.
The depth upto which the contamination has also been arrived at based on
hydrogeology and presence of these parameters. The maximum depth of the
tubewells where contamination is identified are about 45 m bgl. Depth of most of the
tubewells are 21 m bgl to 36 m bgl which are tapping the first aquifer of 35.00 m
depth. There is a thick clay layer of 9 m thick between the two aquifers. This thick
clay layer of 9 m thick is acting as good attenuation layer and restricting the pollution
plume movement to the deeper aquifers. Considering the general depth of the most
of the tubewells and hydrogeological conditions and aquifer disposition, it can be
inferred that aquifers upto a depth of 35 m bgl are contaminated. Considering the
750
average water levels of about 7 to 8 m bgl and clay zones of 7 m thick, about 20 m
thick aquifer zones have been contaminated.
5. Estimation of total quantum of water contaminated:
The area contaminated = 72 Sq.km

The thickness of aquifer contaminated = 20 m thick
Specific yield of aquifer zone = 12% i.e. 0.12
Thus total quantum of water contaminated = 72 Sq.km * 20 m * 0.12 = 172.8 Million
Cubic Meters of fresh water has been contaminated which is not fit for drinking water
purposes.
6. Drinking water supply in the villages around the refinery
It is estimated that about 173 MCM of total quantum of shallow ground water
is contaminated with one or more than one parameter in the shallow aquifer down to
a depth of 35 m bgl. The water supply in all the villages surrounding the Panipat
refinery are based on ground water from deeper aquifers which is being supplied by
PHED Department of Government of Haryana. As the ground water of deeper
aquifers are meeting the standards prescribed by BIS (ISO10,500 of 2012) which is
being supplied for drinking and domestic water requirements by piped water system.
751
Annexure-1
Ground Water Quality in and around Panipat Refinery
The quality of shallow/deep ground water in the surrounding area upto a distance of
about 10km. of Panipat Refinery plant has been studies and 31 no’s of water
samples were collected from shallow/deep aquifers during pre-monsoon season i.e.
May, 2019. All the collected samples were analyzed by adopting standard methods
of analysis (APHA) in the Regional Chemical Lab of CGWB. Chemical analysis data
of samples are given in Annexure-2. Apart from these, analysis data of water
samples collected from the HSPCB is also utilised for interpretation purpose
(Annexure-3). The Total Organic Carbon content in the ground water samples is
presented at Annexure-4. The summarized results of ground water samples are
given in Table-1 given below.
Table: 1 Ground Water Quality of analysed samples:

S.No. Parameters Permissible Ranges No. of Percentage
limit Samples %
1 Sp. Conductance - <600 17 54.83

(µs/cm at 25oC) 601-2250 07 45.16
2 Chloride 250-1000 <250 31 100
(mg/l)
3 Fluoride 1.50 mg/l <1.00 11 35.48
(mg/l) 1.01-1.50 11 35.48
>1.50 09 29.03
4 Nitrate 45 mg/l <45 29 93.54
(mg/l) 46-100 02 6.45
pH
In Panipat Refinery plant and surrounding area villages pH values of ground water
ranges between 7.15 to 8.24.
752
Specific Conductance
Majority of samples (54.83%) are found to have specific conductance less than 600
µS/cm at 25 oC hence the ground water is fresh and potable. About 45.16% of the
samples located around the refinery area are having Sp. Conductance between
600- 2250 µS/cm respectively. The specific conductance varies between 310 µS/cm
at 25oC at Vill-More Majra Bus stand and 1325 µS/cm (Vill-Kutana).
Chloride Concentration
The concentration of Chloride in all samples is less than 250 mg/l which is within the
maximum permissible limit of BIS for drinking water purpose.
Fluoride Concentration
The concentration of fluoride in majority of the samples (71.00 %) is less than 1.50
mg/l and remaining 29.03% located around the plant area show fluoride
concentration above the permissible limit i.e. 1.5 mg/l. The min Fluoride
Concentration of 0.36 mg/l is observed at Vill-Khandra and maximum concentration
of 2.60mg/l is observed at Beshwal road.
Nitrate Concentration
All the samples show nitrate concentration less than 45 mg/l, Nitrate is an
anthropogenic pollutant.
Total Hardness
The total hardness concentration in the ground water varies from 83 mg/l at Vill-
Singhpura, and 347 mg/l at Vill-Dharamgarh.
Classification of Hardness
This classification is based on the value of total Hardness. Ground water may be
classified in to four type’s soft, moderate hard, hard and very hard.
753
Table: 2 Ground water samples summarised as per classification of Hardness

S.N District Nos of Soft Mod. Hard Hard Very Hard
o Samples (0-60 (61-120) (121-180) more than
mg/l mg/l mg/l 180 mg/l
1 Panipat 31 00 04(12.90%) 09(29.03%) 18(58.06%)
Refinery plant
As per the classification, the majority of Ground water is hard and very hard. None of
the sample of in the study area are belongs to Soft category.
Sulphates (SO4)
The sulphate content of ground water ranged between 1.0 mg/l to 201 mg/l at Vill-
Khandra.
Heavy Metals
Ground water samples are analyzed for six heavy metals viz Iron, Cadmium,
Copper, Lead, Zinc and Manganese. The concentration of heavy metals is given in
Annexure-4. The maximum and Minimum values are as follows:
Minimum and maximum values:
Parameters Maximum permissible Minimum (mg/l) Maximum (mg/l)

limits as per BIS standards
(mg/lt)
Iron 0.3 0.013 7.205
Cadmium 0.003 0.002 0.007
Copper 1.5 BDL 0.017
Lead 0.01 BDL 0.030
Zinc 5 to 15 BDL 1.890
Manganese 0.3 BDL 0.450
Iron Concentration
The 48.38% of samples are having Iron concentration more than 0.30 mg/l which is
beyond the standards prescribed by BIS for drinking water purpose. The Iron
754
concentrations varies between 0.013 mg/l sample no-3 (M/S Gulsan Garment
Noorwala, gas godown, Panipat town) and 7.205 mg/l (Vill-Singhpura)
Cadmium
Most of the samples (87%) are having the concentration of cadmium within desirable
limits i.e.0.003mg/l. The cadmium concentration varies between 0.002 mg/l sample
no-27(Vtsav garden, GT road, Gagbad-village.) and 0.007mg/l at (in the residence of
Mahinder singh, opp. To CISF colony, Baholi.).
Copper
In all samples, copper concentration is less than 0.05 mg/l. copper concentrations in
these samples are within the standards by BIS for drinking water purpose.
Lead
The most of the samples (84%) having lead concentration less than 0.010 mg/l. In
five samples, lead concentration more than 0.01 mg/l is observed. The maximum
0.03mg/l concentration of Lead has been found in sample no-1 at Village Nizampur
which is within the prescribed limit as per BIS.
Zinc
The all samples have Zinc concentration within acceptable limit i.e.5 mg/l. None of
the sample has Zinc value above the permissible limit.
Manganese
The most of the samples having manganese concentration within permissible limit
i.e.0.30 mg/l. Only one sample has manganese value above the permissible limit
i.e.0.45mg/l (Vtsav garden, GT road Gagbad-vill.).
Bacteriological Contamination: Ground water samples from the Panipat refinery
surrounding areas were collected by HSPCB and analysed for various parameters.
The data is given in Annexure-3. As per the data, the COD values ranges between
7.20 mg/lt to 40.80 mg/lt. As per the BIS standards, drinking water should not have
BOD and COD and thus the concentrations should have been zero. The presence of
COD in ground water shows that the ground water is contaminated around the
refinery area.
Total Organic carbon: Total Organic Carbon values range between 1.18 mg/lt to
82.60 mg/lt. All the samples collected around the refinery are having the TOC.
However, no limit has been prescribed by BIS fr TOC in drinking water. Presence of
TOC shows the organic contamination of ground water.
755
Annexure-2
*
S. Location Source Dept EC in
No h in µS/cm TH *as
pH* HCO3 Cl* SO4 NO3 F* PO4 Ca* Mg* Na K SiO2
mts at 250 CaCO3
C
mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l
1 Vill- T.W. 45 7.63 450 268 36 6 0 0.61 0 8 50 23 2.9 12
Nizampur,shiva
temple. 225
2 Radha swami T.W 38 8.08 425 281 21 2 0 1.21 0 8 27 60 1.9 9
sat sang beas,
sec-18. 133
3 M/S Gulsan T.W. 45 7.97 435 293 28 5 0 2 0 21 22 67 2.3 8
Garment
Noorwala, gas
godwon 143
4 Beshwal road, T.W. 76 7.74 330 232 29 8 1 2.6 0 16 17 58 1.3 10
Ramesh Malic,
new
construction 112
5 Krishana filling D.T.W 76 7.94 670 330 43 90 7 1.6 0 4 55 90 3.1 15
station,Sanoli
road. 235
6 M/S R.K. T.W. 24 8.02 770 293 43 149 0 1.3 0 4 47 116 2.6 12
industry,Bapoli
road,Nimbori. 204
7 Ishwer Singh, D.T.W 76 7.8 690 317 28 115 0 0.37 0 8 55 80 2.7 7
nearby Samadh,
vill-chajpur. 245
8 Vill-Dahar,New D.T.W 91 7.91 550 317 43 6 20 1.4 0 8 40 73 3.1 5
balaji veshno
dhaba,Gohana
road. 184
9 Vill-Dadlana, H.P. 36 7.96 450 232 50 3 3 0.49 0 8 35 45 4.6 8
near water tank. 163
756
10 Vill- D.T.W. 106 7.72 325 232 28 1 5 2.4 0 16 17 58 2.2 11

Dadlana,PHE,
T.W. 112
11 Mahinder singh H.P. 33 7.84 890 598 43 4 9 1.4 0 4 35 187 4 13
S/O Shri
Sadhuram,CISF
colony,Baholi. 153
12 Mahinder singh T.W. 35 7.89 990 683 57 15 17 1.2 0 8 30 241 5 16
S/O Shri
Sadhuram
,CISF,colony,Ba
holi. 143
13 Naphtha H.P. 30 7.62 590 220 113 7 2 1.1 0 12 55 40 8.1 16
creeker, glycol
road nursery. 255
14 Ravi kumar T.W. 40 7.65 840 403 113 94 11 1.7 0 4 62 148 11 15
ranga,KBPL
gate,Phool singh
dera. 265
15 Pawan s/o Pale H.P. 27 7.74 895 647 92 11 9.2 1.53 0 4 55 249 5.2 12
ram, near
railway
line,Baholi. 235
16 Munsiram,sohan H.P. 30 7.92 590 281 43 2 6 2.3 0 4 22 90 3.3 13
lal dera,Inside
Railway
line,Baholi. 102
17 Vill- H.P. 45 8.01 950 464 43 20 20 2.2 0 17 10 183 3 14
Singhpura,Satpa
l sarpanch
dera,Babadargh
a 83
18 Vill- H.P. 23 7.65 310 159 21 2 2 1.3 0 25 20 10.3 2.3 12
Singhpura,NC
plant
6km,Rotashpal
sweet. 143
757
19 Vill- H.P. 21 7.74 1240 586 43 18 15 2.9 0 8 35 189 4 10

Baljatan,sachin
beauty salon. 163
20 Vill- H.P. 45 7.47 1190 366 99 89 33 1.16 0 8 80 78 5.1 9
Dharamgarh,var
dha ashram,bus
stand. 347
21 Vill-Khandra, H.P. 45 7.57 1090 195 156 201 29 0.36 0 20 50 161 6 7
Govt. middle
school, bus
stand. 255
22 Vill-Munak,Bus H.P. 36 7.5 885 488 21 9.6 12 0.86 0 8 27 145 4 2
stand. 133
23 Vill-Rer H.P. 34 7.75 1030 488 57 47 1 0.65 0 12 37 157 5.2 9
Kalan,Shiva
temple. 184
24 Vill- H.P. 27 7.54 1325 549 121 48 25 0.86 0 4 62 193 6 5
Kutana,Gurunan
ak spare parts. 265
25 Vill- Begampur, H.P. 34 7.52 1050 515 99 10 50 1.51 0 4 55 172 5.5 11
Shiva temple. 235
26 Vill- S.B. 45 7.15 920 281 142 46 58 0.35 0 8 72 95 5.4 12
Gudoh,Kashyap
chopal. 317
27 Vtsav garden, T.W. 34 7.41 510 244 85 37 19 0.71 0 4 60 52 6 8
GT
road,Gagbad-
vill. 255
28 Filling junction, D.T.W. 50 7.32 690 171 149 31 19 0.77 0 16 55 58 6 7
Babarpur,G.T
road. 265
29 Vill- D.T.W 56 8.17 590 305 14 29 12 0.4 0 45 30 32 5.2 13
Ballaa,Gaoushalla
. 235
30 Vill-More Majra T.W 30 8.24 310 134 14 6.5 15 1.32 0 33 12 7.6 2.7 10
Bus stand. 133
31 Vill-More Majra D.T.W 91 7.89 575 207 43 54 18 1.2 0 45 30 30 4 12
,Water works. 235
758
Annexure-3
759
760
761
Annexure-4
Pollution studies around Panipat Refinery, Panipat-Heavy metals analysis (concentrations in mg/lt)
S. Location Source
Cd Cu Mn Pb Zn Fe
No
Vill-Nizampur,shiva T.W.
0.003 0.003 BDL 0.030 0.032 0.540
1 temple.
Radha swami sat sang T.W
0.005 BDL BDL 0.022 0.017 0.240
2 beas, sec-18.
M/S Gulsan Garment T.W.
BDL BDL BDL 0.020 0.098 0.013
3 Noorwala, gas godwon
Beshwal road, Ramesh T.W.
4 Malic, new construction
Krishana filling T.W.
5 station,Sanoli road.
M/S R.K. T.W.
industry,Bapoli BDL BDL BDL 0.013 0.008 BDL
6 road,Nimbori.
Ishwer Singh, nearby T.W.
0.005 BDL BDL BDL 0.010 BDL
7 Samadh, vill-chajpur.
Vill-Dahar,New balaji T.W.
veshno dhaba,Gohana BDL BDL BDL BDL 0.018 0.113
8 road.
Vill-Dadlana, near H.P.
BDL BDL BDL BDL 0.264 0.524
9 water tank.
Vill-Dadlana,PHE, T.W.
10 T.W.
Mahinder singh S/O H.P.
Shri Sadhuram,CISF 0.007 BDL BDL 0.007 0.159 1.877
11 colony, Baholi.
Mahinder singh S/O T.W.
Shri Sadhuram BDL BDL BDL 0.009 BDL 0.043
12 ,CISF,colony,Baholi.
Naphtha creeker, glycol H.P.
13 road nursery.
Ravi kumar T.W
ranga,KBPL gate,Phool BDL BDL BDL 0.006 BDL BDL
14 singh dera.
Pawan s/o Pale ram, H.P.
near railway BDL BDL BDL 0.001 BDL 4.985
15 line,Baholi.
Munsiram,sohanlal H.P.
dera,Inside Raily BDL BDL BDL BDL BDL 0.031
16 line,Baholi.
Vill-Singhpura,Satpal H.P.
sarpanch BDL 0.011 BDL BDL 0.021 7.205
17 dera,Babadargha
Vill-Singhpura,NC H.P.
plant 6km,Rotashpal BDL 0.007 BDL BDL BDL 1.848
18 sweet.
Vill-Baljatan,sachin H.P.
BDL 0.008 BDL BDL 0.092 1.187
19 beauty salon.
762
Vill- H.P.
Dharamgarh,vardha BDL 0.014 BDL 0.010 0.577 1.239
20 ashram,bus stand.
Vill-Khandra, Govt. H.P.
middle school, bus BDL 0.007 0.164 0.005 0.053 1.180
21 stand.
22 Vill-Munak,Bus stand. H.P. BDL 0.005 BDL BDL BDL 0.178
Vill-Rer Kalan,Shiva H.P.
BDL 0.003 BDL 0.009 BDL 1.311
23 temple.
Vill-Kutana,Gurunanak H.P.
BDL 0.002 BDL 0.006 BDL 1.642
24 spare parts.
Vill- Begampur, Shiva H.P.
BDL 0.003 BDL 0.016 1.890 2.284
25 temple.
Vill-Gudoh,Kashyap T.W.
BDL 0.002 0.165 BDL BDL 2.925
26 chopal.
Vtsav garden, GT T.W
0.002 0.001 0.451 BDL 3.175 BDL
27 road,Gagbad-vill.
Filling junction, T.W.
28 Babarpur,G.T road.
29 Vill- Ballaa,Gaoushalla. T.W BDL 0.004 BDL BDL BDL 0.164
Vill-More Majra Bus T.W
30 stand.
Vill-More Majra ,Water TW
31 works.
763
TOC data of ground water samples

around Panipat Refinery Annexure-5
Sample Unique District Location Source TOC
No ID (NPOC)
mg/l
9 1TOC Panipat Vill-Dadlana, near water tank. H.P. 15.35
10 2TOC Panipat Vill-Dadlana,PHE, T.W. T.W. 2.270
Panipat Mahinder singh S/O Shri H.P.
52.26
11 3TOC Sadhuram,CISF colony,Baholi.
Panipat Mahinder singh S/O Shri Sadhuram Tubewell
,CISF,colony,Baholi. 82.60
12 4TOC
13 5TOC Panipat Naphtha creeker, glycol road nursery. H.P. 21.25
Panipat Ravi kumar ranga,KBPL gate,Phool Tubewell
singh dera. 37.64
14 6TOC
Panipat Pawan s/o Pale ram, near railway H.P.
0.72
15 7TOC line,Baholi.
Panipat Munsiram,sohanlal dera,Inside Railway H.P. 2.19
16 8TOC line,Baholi.
Panipat Vill-Singhpura,Satpal sarpanch H.P.
47.11
17 9TOC dera,Babadargha
Panipat Vill-Singhpura,NC plant H.P.
46.45
18 10TOC 6km,Rotashpal sweet.
Panipat H.P.
31.04
19 11TOC Vill-Baljatan,sachin beauty salon.
Panipat Vill-Dharamgarh,vardha ashram,bus H.P.
44.19
20 12TOC stand.
Panipat Vill-Khandra, Govt. middle school, bus H.P.
stand. 45.51
21 13TOC
Panipat Vill-Munak,Bus stand. H.P.
1.18
22 14TOC
Panipat H.P.
1.33
23 15TOC Vill-Rer Kalan,Shiva temple.
764
Sample No District Block Location Source COD

mg/l
Panipat Panipat
9 Vill-Dadlana, near
water tank. H.P. 14
Panipat Samalkha Mahinder singh S/O
Shri Sadhuram,CISF
11
colony,Baholi.
H.P. 20
Panipat Samalkha Naphtha cracker,
13 glycol road nursery.
H.P. 40.8
Panipat Samalkha Ravi kumar
ranga,KBPL
14 gate,Phool singh
dera.
H.P. 7.2
Panipat Samalkha Pawan s/o Pale ram,
15 near railway
line,Baholi. H.P. 8.8
Panipat Samalkha Munsiram,sohanlal
16 dera,Inside Raily
line,Baholi. H.P. 24.4
Panipat Madlauda Vill-
Singhpura,Satpal
17
sarpanch
dera,Babadargha H.P. 12.8
765
Fig 1: Location Map of Sampling points

766
Fig 2: Electrical Conductivity (E.C.) of Ground water

767
Fig 3: Concentration of Iron

768
Fig 4: Concentration of Zinc

769
Fig 5: Concentration of Chemical Oxygen Demand (COD)

770
Fig 5: Concentration of Total Organic Carbon (TOC)

771
Fig 6: Demarcation of ground water contaminated zone around Panipat

Refinery Complex based on Electrcal Conductivity, Iron and Total Organic
Carbon
772
Annexure-D 773
Rajesh Garhia <[email protected]>
Re: EIL report in the matter of IOCL, Panipat Refinery, Panipat.

1 message
Narender Sharma <[email protected]> Wed, Nov 20, 2019 at 7:09 AM

To: hspcbsrscientist <[email protected]>
Cc: ms kumar <[email protected]>, [email protected], Deputy Commissioner Panipat <[email protected]>, ADC
Panipat <[email protected]>, mohiddin sk <[email protected]>
Confidential and For Circulation to only and only Members of the Joint Committee and Expert
Members
Dear Sir,
Pls refer to the MOM signed by you, DC and ADC, Panipat asking for comments on EIL Report from the
Expert Members ( Copy Attached). Pls note that clarifications sought by other committee members have
already been explained technically by the CPCB Member during the meeting but unfortunately not included
in the Minutes of meeting.
As mentioned in my previous email that we are not supposed to give comments on the draft observations of EIL on the
reports of the Experts engaged by the Joint Committee constituted as per orders of Hon'ble NGT in this matter. It is like
helping someone to prepare a report against the report of the Joint Committee prepared for submission to the Hon'ble
NGT. Pls note that EIL has been/is involved in providing Engineering, Procurement and Construction Management
(EPCM) services to refineries and recently been awarded a contract of 30 Crores by IOCL for its expansion
activities. EIL is an intereseted party and there could be conflict of interest and whole committee should not be
held accountable in case of any dispute, at any stage. As explained during the meeting it will be highly unethical
on our part to share and discuss the confidential reports of the experts with a consultant of the Industry against
whom the investigation is going on, under the supervision of Hon'ble NGT and that too before submitting the
report to NGT, which is ready for the past few months. It will be even more serious concern if we influence our
report by considering the observations of the consultant of the industry and it may be seen as serious violation of
NGT's Order. The reports have been prepared by individual experts ( CPCB, CSIR-NEERI and CGWB) as
required by Joint Committee , based on reports of the Joint Committee comprising members of District
administration, HSPCB and CPCB), past data and the information provided by HSPCB, IOCL and District
Administration , additional data generated by collected samples of ground water and scientific evaluation. These
reports can be defended by these agencies if required to do so by Hon'ble NGT but not by EIL. However, as
requested by CGWB expert in the trailing email , you may kindly provide approval of Hon'ble NGT for seeking
observation of the Consultant of IOCL, before submission of the Report to Hon'ble NGT.
You may mention in the final report that comments were asked on EIL's Observations from CPCB
Member and he has replies as under ( Pls reproduce my views as explained above)
--
With regard to finalization of the report for submission to Hon’ble NGT, you are requested to kindly refer to the MOM of the
Joint Committee dated 20/9/2019 and your letter to DC, Panipat dated 13/9/2019, which clearly say that:
Draft report was circulated to members on August 6, 2019 and CPCB member submitted his comments acceptance of the report
subject to incorporation of the comments on August 9, 2019; The CPCB Member is in agreement with the conclusions of CSIR-
NEERI and CGWB; The final Draft report circulated by Nodal Officer was accepted by CPCB Member on 13/8/2019; Nothing is
pending with CPCB Member which could delay the submission of the Report to NGT.
CPCB Still stand by his report and the report circulated by the Nodal Officer and hence no further comments are required.
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However, during meeting on 14/11/2019 in the Office of DC, Panipat , it was desired by the Committee to elaborate some
points to strengthen the final report and accordingly the following should be included in the conclusion part of the Final
Report:
Grab Samples were collected by HSPCB Team under Water Act as per Law under the direct supervision of Joint Committee
constituted in this matter as per orders of Hon’ble NGT, by issuing proper notice to the representatives of the Industry.
This is to emphasize here that firstly it was illegal discharge without any consent to operate for such disposal in the thirana drain and
secondly no industry could be allowed to discharge beyond prescribed limits in water body even for short duration since the loss to
water life is irreparable, one done by such act. It may also be noted here that effluent in thirana drain was being discharged from the
storage tank after the ETP and not directly from ETP which itself shows that average values of parameters were on much higher side
that prescribed beside being illegal discharge.
It may also be noted that the industry was discharging effluent not only from this point reported in the Ist report of the Joint
Committee but two other points i.e one directly in the thirana drain and another into the Drain No 2 leading directly to Yamuna drain.
The flow of effluent considered is 255 m3/h. Flow of Effluent was also estimated from pipe size and was coming to much higher side
and hence was restricted to the volume indicated in the water balance/Consent of the Industry, for calculation of the damage. Diameter
of three pipe lines which were found to be used for discharging were 8 inch, 6 inch and 18 inch.
OCEMS installed in the Industry was studied in detail by the Joint Committee and the finding of the Joint Committee as reported in
the Ist Report of the Joint Committee to Hon’ble NGT is reproduced as under: “The Online Continuous Emission Monitoring System
(OCEMS) installed for real time monitoring was checked for its accuracy by using a standard reference solution of known COD of 70
ppm. The OCEMS system installed by Panipat Refinery showed value of 69.5 ppm for the sample of known COD of 70 ppm and
hence found be accurate and calibrated. However, the samples collected for analysis from the outlet of ETP and from Thirana Drain
were found to be non-complying with the prescribed norms which indicate that effluent streams used for online monitoring may not
be the same as the final outlet of ETP. Therefore, sensors of Online Continuous Effluent Monitoring system need to be installed
directly and immediately into the final discharge rather than taking one small pipe line to a room for OCEMS as presently being
done by the Unit, to prevent tempering of the representative discharge sample. The State Pollution Control Board needs to issue
directions to the Unit in this regard.”
It was also concluded by the Committee that “the Online Analyzers provided by the unit for monitoring of treated effluent quality and
for air emission was found in working condition and transmitting real time data to CPCB / HSPCB server. However, the samples
collected for analysis from the outlet of ETP and from Thirana Drain were found to be non-complying with the prescribed norms
whereas results of the stream diverted to OCEMS in a room was found to be complying with norms as per values recorded in
OCEMS, which indicates that effluent stream used for online monitoring may not be the same as the final outlet of ETP. Therefore,
sensors of Online Continuous Effluent Monitoring system needs to be installed directly into the final discharge rather than taking one
small pipe line to a room for OCEMS as presently being done by the Unit, to prevent tempering of the representative discharge
sample.” In view of this, the joint Committee decided not to consider historical data of OCEMS.
Legal samples collected by the Joint team were analysed by notified Board’s analysis. There is also a provision in the Act, which
permits the Industry to request for one parallel sample drawn by the HSPCB Team sealed, for getting it tested from approved
Laboratory through State Pollution Control Board. The industry could have done it at that point of time. They were asked by the Joint
Committee while issuing notice but Industry didn’t opt for this. Similarly, villagers were also asked by the Joint Committee if they
want to send the parallel hand pump samples to another lab but they also didn’t opt this option.
It was informed during the meeting of the Joint Committee held on 14/11/2019 that HSPCB has now granted permission to IOCL for
discharging effluent in the thirana drain which ultimately, meets the Yamuna River. This means that Illegal discharge of Effluent in the
thirana drain as reported by Joint Committee comprising members of HSPCB, DC, Panipat and CPCB, has been legalized. The
HSPCB may be asked to share the study done to establish the environmental carrying capacity of thirara drain and Yamuna river to
ensure the water and air ecosystem are not affected from discharge of industrial effluent of PTA plant which not only contains BOD
and COD but heavy metals as well. This becomes more important in view of the fact that the water from the Yamuna river is not only
used for crops but also for growing vegetable which are eaten raw by human population.
The HSPCB should get the “ZLD” or “Recycle & Reuse” implemented in true sence as per definition approved by Hon’ble NGT.
Effluent used for plantation/irrigation can not be considered ZLD or Recycle & Reuse. For using effluent which are hazardous in
nature and contains heavy metals, the carrying capacity of the soil, ground water and crops must be conducted before allowing use of
such effluents for plantation of irrigation.
Lastly, the damage caused to the public health and ground water was attributed to Panipat without considering the need of Source
apportionment on account of the following reasons: No other industry exists in the affected area ; No industry in the affected area is
discharging effluents illegally in the drain for years; Industry has created earthen lagoons covering hectares of land for storing treated
and untreated waste water without arrangement of capturing VOC, No arrangement has been made to prevent release of VOCs in the
775
Environment; OCEMS installed for treatment was found to be mastered, No dilution is available in the open thirana drain were
industry is discharging effluent and so on.
My apologies for typo errors, if any. I'll correct that same in the final report, if shared by Nodal Officer
before submission to Hon'ble NGT.
Regards
Narender
From: "mohiddin sk" <[email protected]>

To: [email protected], "ms kumar" <[email protected]>, [email protected], "Deputy Commissioner
Panipat" <[email protected]>, "ADC Panipat" <[email protected]>, "Narender Sharma" <[email protected]>
Sent: Tuesday, November 19, 2019 11:28:18 AM
Subject: Re: Fwd: EIL report in the matter of IOCL, Panipat Refinery, Panipat.
Sir,
The decision regarding seeking the comments of EIL on experts reports of CPCB, NEERI and CGWB has been taken by
the committee constituted by the Hon'ble NGT. If so in which meeting this decision has been taken and please forward the
minutes of the said meeting. Whether the decision to seek the comments on experts report from EIL is put before the
Hon'ble NGT.
The above clarifications may be forwarded immediately to take a decision to prepare clarifications on EIL report.
S K Mohiddin,
Sr. Hg (Scientist), CGWB, Chandigarh.
On 11/16/19 04:05 PM, Rajesh Garhia <[email protected]> wrote:
As per the the meeting of the the joint committee held on 15 11 2019 in the the office of deputy commissioner
Panipat the observations of the the Engineers India Limited are hereby forwarded to you for your valuable
comments on the Damage assessment reports of cpcb member , CSIR -NEERI member and CGWB member
with in two days so that report may be finalized accordingly and submitted to Honable NGT.
---------- Forwarded message ---------

From: Rajesh Garhia <[email protected]>
Date: Fri, 15 Nov 2019, 1:46 pm
Subject: EIL report in the matter of IOCL, Panipat Refinery, Panipat.
To: Narender Sharma CPCB <[email protected]>
Please find the attachment.
--
Rajesh Garhia, Sr. Scientist,
Haryana State Pollution Control Board (HQ),
Panchkula
--
With Regards,
S K Mohiddin,
Scientist, CGWB
Ministry of Water Resources, RD & GR
West Block-2, R.K. Puram, New Delhi
Ph: 011-26175316; Fax: 011-26175369
email: [email protected],
http://www.cgwb.gov.in
776
Annexure-E 777
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781
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784
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Date: 22.10.2019
IOCL’s Panipat Refinery & Petrochemical Complex (PRPC) is located in Baholi village of Panipat
district. A complaint was sent by Sarpanchs of Gram Panchayats (vide letter dated 4.9.2018) to the
Hon’ble National Green Tribunal (NGT) related to air and water pollution in surrounding villages due
to PRPC operation. While acting upon the complaint, NGT vide its order dated 15.11.2018 directed
constitution of the Joint Committee comprising representatives of CPCB, HSPCB and Deputy
Commissioner, Panipat to visit the site and furnish an Action Taken Report (ATR). The Hon’ble NGT
also appointed HSPCB as the nodal agency.
In compliance to the direction of Hon’ble NGT, the Joint Committee visited PRPC & surrounding
areas during 4th to 7th December, 2018 for carrying out inspection for air and water quality and
consequently, submitted its interim report to the Hon’ble NGT on 15.1.2019. The Joint Committee’s
report inter-alia specified that the treated effluent quality from PRPC was not as per prescribed
standards. The team also reported the odour and irritation in eyes. The ground water samples were
also reported to be exceeding certain parameters prescribed by drinking water standards IS 10500
(2012).
Taking cognizance of the observations made by the Joint Committee report dated 15.1.2019, the
Hon’ble NGT vide its order dated 01.03.2019 considered it necessary to require the Joint Committee
to make a realistic assessment of the damage caused to public health and environment and
immediate measures for stoppage of polluting activity. The joint committee was directed to submit
its report on the same within one month. The joint committee was allowed to take any expert
opinion or co-opt any other expert.
Keeping in view the time frame given by the Hon’ble NGT, the joint committee proceeded with the
exercise without a third party expert member and inspected the unit again on 27.3.2019. The joint
committee observed that IOCL has made some progress but yet to make complete compliance of all
the observations made earlier by the joint committee. The joint committee was also of the opinion
that outside experts in the area of Environment and Ground Water are required to conclude the
assignment. As the assignment including engagement of experts was expected to take time, the joint
committee decided to send its interim report (based on visit dated 27.3.2019) to Hon’ble NGT.
Accordingly, the joint committee submitted its report to Hon’ble NGT on 22.4.2019.
Subsequently, the Joint Committee co-opted experts from Central Ground Water Board (CGWB) and
National Environmental Engineering Research Institute (NEERI) for assessment of damage caused to
ground water, public health & environment. The meeting of Joint Committee along with co-opted
expert members was held on 26.4.2019. The co-opted expert members sought certain details and
time for completing the study. It was decided by the committee to assess the environmental damage
and propose preliminary compensation and cost of restoration based on the existing details and
Engineers India Limited Page 1 of 14

786
submit the report to Hon’ble NGT before next date of hearing. The committee submitted its report
to Hon’ble NGT on 9.5.2019. The report included tentative cost of restoration, further stating that
the updated cost of restoration would be submitted after concluding the assessment of
environmental damage to public health and ground water.
The assessment of the damage was divided into three components by the committee and the same
was assigned to CPCB member, CGWB member and NEERI member as per details given below:
A). Assessment of damage and cost of restoration w.r.to oxygen depletion and pollution caused
to the surface water due to illegal discharge of effluent (CPCB Member)
B). Assessment of damage caused to ground water and cost of restoration (CGWB Member)
C). Assessment of damage caused to public health & environment (NEERI Member)
It is reported that the interim report was submitted by the CPCB member on 9/5/2019 and final
report was submitted on 9/8/2019. Interim report was submitted by the CGWB member on
8/8/2019 and modified report was submitted on 5/9/2019. The report was submitted by the NEERI
member on 2/8/2019. These reports were submitted to the Joint Committee for finalization before
submission to the Hon’ble NGT.
Simultaneously, M/s IOCL also engaged The Energy and Research Institute (TERI) to assess the status
of air, water and soil quality in order to quantify the environmental damage, due to operational
activities of IOCL-PRPC. TERI submitted its report in June, 2019.
DC, Panipat vide its Letter No. 5183/MB dated 27.09.2019 sought EIL’s expertise to evaluate the
CGWB & NEERI reports proposed to be submitted to Hon’ble NGT shortly. The reports were to be
evaluated in terms of contextual veracity and also with reference to impact assessment on public
health, environment and remedial measures. A meeting was held with ADC, Panipat on 30.09.2019
wherein EIL desired that all relevant reports in this regard may be shared for study. Accordingly, the
following reports were furnished to EIL by ADC, Panipat office:
 Joint Committee Report dated 15th January, 2019 submitted to Hon’ble NGT (copy attached
as Appendix-I)
 Joint Committee Report dated 22nd April, 2019 submitted to Hon’ble NGT (copy attached as
Appendix-II)
 Joint Committee Report dated 9th May, 2019 submitted to Hon’ble NGT (copy attached as
Appendix-III)
 Reports (2 Nos.) of Central Ground Water Board (CGWB) (copies attached as Appendix-IV)
 Report of National Environmental Engineering Research Institute (NEERI) (copy attached as
Appendix-V)
 Report of TERI prepared for IOCL-PRPC (report available with ADC’s office)

787
EIL have studied all the reports (including reports of Joint Committee, CGWB, NEERI and TERI) to
review the matter in totality. EIL’s observations are presented in this report.
We understand that CPCB’s interim report dated 9.5.2019 is the same report which is Joint
Committee’s report dated 9.5.19 above, and no separate report was submitted by CPCB. Also, we
did not get copy of final report as reported to be submitted by CPCB on 9/8/2019. As such, our
observations are based on Joint Committee/CPCB’s report dated 9.5.2019.
Based on review of above mentioned reports, it is observed that the Joint Committee (including
reports of CGWB & NEERI) have broadly identified following key problem areas which have caused
pollution to the environment:
1. IOCL PRPC does not have permission to discharge treated effluent (from PX-PTA) in the
Thirana Drain
2. The treated effluent (from PX-PTA) being discharged to Thirana Drain does not meet the
prescribed discharge standards
3. The treated effluent (from PX-PTA) being discharged to Thirana Drain and Cess Pool water
have polluted the surface and ground water
4. VOC emissions from PRPC is polluting the ambient air quality in the surrounding villages
5. Stagnant effluent (cess pool) due to accidental leakage of untreated effluent have polluted
the ground water
EIL have reviewed all the above referred reports and their content in details. EIL have following
observations on each of the identified key problem area:
1. IOCL PRPC does not have permission to discharge treated effluent (from PTA) in Thirana Drain
In Joint Committee’s report dated 15.1.2019, it is stated that the complex does not have
permission to discharge its treated effluent to Thirana Drain. Whereas it is also mentioned in the
same report that the representatives of IOCL-PRPC have claimed that they have permission to
discharge treated effluent to Thirana Drain. In order to get clarity on the issue, EIL requested
ADC, Panipat office to furnish a copy of various EC/NOC/CTO granted to IOCL-PRPC by
MoEF&CC/HSPCB till date. Copy of the same was furnished to EIL by ADC, Panipat office vide its
email dated 15.10.2019. Based on review of these documents, the following were observed:
 Original Environmental clearance (EC) for Integrated Paraxylene and Purified Terephtalic
Acid (PX-PTA) was granted by MoEF & CC vide its letter No. J-11011/52/2000/IA II dated
30.4.2001. As per the EC granted, IOCL was required to undertake maximum recycle/reuse
of the treated effluent for process purposes in addition to green belt development.

788
Additionally, IOCL was allowed to discharge maximum of 255 m3/h of treated effluent from
petrochemical complex to Thirana Drain.
 Subsequently, Environmental Clearance (EC) dated 26th March 2018 granted by MoEF&CC
to IOCL for its BS-VI fuel quality up-gradation & expansion of PX/PTA plant (point no 11 (iii))
stated that in case of PX/PTA expansion project, there shall not be any increase in effluent
discharge and the treated effluent of 255 m3/h shall continue to be discharged to the
existing Thirana drain.
 Latest Consent to Operate (CTO) dated 25/7/2019 granted by HSPCB to IOCL (specific
condition point no 5) stated that the unit will not discharge any effluent inside or outside the
premises except 255 m3/h effluent of the treated effluent from PX-PTA plant into Thirana
drain.
Further, specific condition point No. 6 stated that the unit will conduct the feasibility study
of Zero Liquid Discharge (ZLD) from PX-PTA plant within the period of 18 months as per
undertaking of the unit and will submit the technical feasibility report accordingly to achieve
the ZLD from PX-PTA section.
As per the Joint Committee’s report dated 15.1.2019, we understand that the committee took a
stand that IOCL does not have permission to discharge treated effluent (from PTA) to Thirana
Drain based on compliance statement given by IOCL, which states that the unit is reusing the
treated effluent from PTA-ETP (ETP-III) as make-up to cooling towers and balance for irrigation in
green belt. However, we could not find any amendment to EC/CTO or any other document to
establish that the permission to discharge 255 m3/h of treated effluent to Thirana Drain granted
as per original EC letter no. J-11011/52/2000/IA II dated 30.4.2001 have been withdrawn or
suspended by MoEF&CC/CPCB/HSPCB.
Even the HSPCB’s CTO as latest as 25/7/2019 allows discharge of 255 m3/h of treated effluent
from PX-PTA plant into Thirana drain.
Hence, as per EIL’s understanding, IOCL Panipat do have permission to discharge 255 m3/h of
treated effluent to Thirana Drain.
2. The treated effluent (from PTA) being discharged to Thirana Drain does not meet the
prescribed discharge standards
Effluent samples were collected by the Joint Committee & its team from the outlet of ETP-I, ETP-
II, ETP-III & ETP-IV. The effluent samples were also collected from the green belt around the unit
and from the Thirana Drain. The effluent samples were collected during 4th to 6th December,
2018. The committee got all the collected samples analysed in HSPCB laboratory located in
Panchkula during 5th to 9th December, 2018.

789
 In their report dated 12.01.2019, the joint committee reported that results of the ETP-I, ETP-
II and ETP-III treated effluent were found exceeding the prescribed limits for parameters viz
TSS, BOD, COD, Oil & Grease, and TDS. Results of ETP-IV treated effluent were found to be
within prescribed limits. Results of surface water being discharged in Green Belt area were
found exceeding in parameters TSS, BOD, COD, Oil & Grease, and TDS. The unit was found to
be non-complying by the joint committee w.r.to parameters prescribed for treated effluent
discharge.
 It is observed that analysis of one sample of effluent was under taken & analysed by HSPCB,
which became the basis for all further conclusions by the Joint Committee and the expert
agencies (including CGWB & NEERI). It is not clear from the report whether a grab sample
(average of three samples) or composite sample (24 hourly) were collected by the team. No
data of flow measurement was available in the report. Committee has considered 255 m3/h
discharge limit as flow to the Thirana drain.
EPA gazette notification 18th March 2008 states... quote“ Quantum of pollutant shall be
calculated on the basis of daily average of concentration values (one 24 hourly composite
sample or average of three grab samples as the case may be)average flow of the effluent
during the day and crude throughput capacity of the refinery.” Unquote.
 It is reported by the joint committee that PRPC also have OCEMS (Online Continuous
Emission Monitoring System) installed for real time monitoring of treated effluent and the
same was found to be accurate and calibrated as per their report dated on 22.04/2019. The
real time data is also online transmitted to central server of CPCB/HSPCB. However, no
historical records of the OCEMS data were found in the report. Further, the records of
OCEMS data were not taken into cognizance by the Joint Committee.
 In case there were variations in the OCEMS data and the lab analysis results, it would have
been prudent to take multiple samples at each locations and get them analysed at different
labs to eliminate the chances of error (human and/or monitoring/ analysis equipment) in
effluent sampling and lab analysis. This has become even more imperative as further
assessment of damage to environment as drawn by CPCB and other expert agencies (CGWB
& NEERI) including cost of environmental restoration is based on the results of this single lab
analysis carried out by HSPCB.
EIL is of the view that in order to have reached at logical conclusion in terms of non compliance
by IOCL, the committee should have compared the OCEMS data and the data of treated effluent
samples as per gazette notification requirement. Also, past data which might have been taken by
HSPCB/CPCB/MOEF&CC as a part of routine environmental compliance monitoring should also
be complimented.

790
3. The treated effluent (from PTA) being discharged to Thirana Drain & Cess Pool water have
polluted the surface and ground water
It has been reported that ‘Discharge of effluent in Thirana Drain’ and ‘Discharge of untreated
effluent in Cess Pool’ have contaminated the surface water and ground water, for which damage
to the environment and cost of environmental restoration have been assessed by the Joint
Committee. Additionally, outside experts from CGWB and NEERI were co-opted by the joint
committee to estimate damage to ground water and public health. The assessment of the
damage was divided into three components and the same was assigned to CPCB member, CGWB
member and NEERI member as per details given below:
It was considered in the report that the effluent discharged to Thirana Drain and Cess Pool
having BOD results in the depletion of oxygen equivalent to the amount required for
stabilization of BOD. Oxygen demand was calculated @ 2.67 g O2/g of Carbon based on
formula (C6H12O6 + 6O2 = 6CO2 + 6 H2O). Further, the cost of oxygen @ Rs. 25/kg was
considered for estimating environmental damage in monetary terms.
 The committee has estimated that the unit was not complying with the treated effluent
discharge standards for a total period of 120 days (i.e. from 4/12/2018 to 2/4/2019).
Accordingly, joint committee has estimated that total 7,34,400 m3 (= 255 m3/h x 24
hours x 120 days) of off-specifications treated effluent was discharged in the Thirana
Drain. This effluent (having 170 mg/L BOD as measured by HSPCB) is calculated to be
contributing to 124848 kg of BOD, which is estimated to be equivalent to 333344.16 kg
of oxygen.
 Cess pool area was measured to be 250 m x 8 m. Accordingly, it was estimated that total
5,000 m3 (250 m x 8 m x 2.5 m stagnant effluent depth in cess pool area) of untreated
effluent was discharged in Cess Pool. This effluent is calculated to be contributing to
7500 kg of BOD (1500 mg/L BOD considered in calculations), which is estimated to be
equivalent to 19500 kg of oxygen.
With reference to the above estimation by the joint committee, the following points may
please be relooked into to finally arrive at damage to environment:

791
 In the lab analysis carried out by HSPCB, the BOD has been reported as 170 mg/l in ETP-
III effluent discharged to Thirana Drain. As 30 mg/l is permissible limit for ETP-III effluent
discharge, the difference in BOD (i.e. 140 mg/l) needs to be considered for estimating
environmental damage in monetary terms.
 In the lab analysis carried out by HSPCB, the BOD has been reported as 900 mg/l in
effluent discharged to Cess Pool. However, 1500 mg/l BOD has been considered by the
committee in calculating environmental damage.
 Analogy to calculate oxygen requirement is based on consideration that 192 gram of
oxygen used to oxidize 72 gram of carbon. The oxygen required for each carbon atom is
considered in calculations, whereas the oxygen available with the molecule (C6H12O6)
was not considered. So to consider that effluent will exchange all the oxygen from
atmosphere is not correct. The cost of treatment of such effluent should have been
considered @ 1.066 g O2/g of BOD (= 192 g O2/ 180 g C 6H12O6) instead of @ 2.67 g O2/g
of carbon as considered by the committee.
 As Px PTA effluent passes through forced aeration where atmospheric oxygen is forced
transferred into effluent. There is always dissolved oxygen available upto 2 mg/l in the
aerated water. This quantity of oxygen from the air will be in equilibrium as per partial
pressure with the atmosphere. This aspect shall be taken into consideration.
 The damage calculation is based on analysis of single sample as stated under SN 2. This
aspect is also required to be looked into.
It is reported that the interim report was submitted by the CGWB member on 8/8/2019 and
modified report was submitted on 5/9/2019. Two reports have been received from ADC,
Panipat office (attached as Appendix IV). It is considered that these are the same reports as
submitted by the CGWB member (as there is no date on the subject reports). CGWB
collected 31 ground water samples covering an area of about 500 Sq. km around PRPC to
assess the ground water contamination. Additionally, the data collected by the HSPCB during
the preliminary study was also used for the study. Parameters such as Electrical
Conductivity, Chemical Oxygen demand (COD), Total Organic Carbon (TOC), Iron, Fluoride
and heavy metals in ground water samples were used as indicators to demarcate the
contaminated ground water area.
 CGWB expert estimated that ground water in about 75 Sq. km area around the refinery
is contaminated by one or more than one parameters as discussed above. Considering
contaminated aquifer thickness of 30 m and specific yield of 12%, total 270 Million Cubic
Meters of water is estimated to be contaminated which is not fit for drinking water
purposes.

792
 Dewatering and refilling of contaminated aquifers is proposed in the report. Surface

water from the Western Yamuna Canal is proposed to be recharged in the aquifer. The
contaminated ground water withdrawn is proposed to be used for irrigational
requirements in the surrounding areas and partly for industrial requirements in Panipat
Refinery.
 The water conservation fee @ Rs. 20/- per cubic meter has been considered in the
report. Accordingly, environmental compensation for dewatering 270 MCM of water is
estimated to be Rs. 540 Crores.
With reference to the above estimation, the following points may please be relooked into:
 CGWB has relied on single sampling of effluent carried out by HSPCB during initial
assessment. No fresh sampling of effluent was carried out by CGWB for independent
assessment of effluent quality. Also, CGWB did not carry out a fresh analysis of COD in
the ground water samples collected by them. CGWB has relied on COD analysis of
ground water samples as carried out by HSPCB.
 Environmental damage estimated by CGWB is based on the presumption that since off-
specifications effluent is being discharged and ground water is found to be
contaminated, the entire ground water pollution has been caused by this effluent only.
No quantitative assessment has been made to confirm the pollutant source(s) and
extent of pollution caused by these sources(s).
 Majority of effluent discharged to Thirana Drain is expected to join the surface water
body and not the ground water aquifer. An assessment needs to be made to quantify
the effluent which would have joined surface water streams and ground water resources
respectively to estimate environmental damage to respective source in quantitative
terms.
 Feasibility and quantum of ground water contamination by other industrial and
agriculture activities predominant in Panipat District is required to be carried out to
exactly find out the cause of pollution.
 Present levels of contaminants in ground water have not been compared with prevailing
ground water quality before PRPC starts its commercial operations to establish the
baseline ground water quality and to assess the incremental increase in ground water
pollutants. A study carried out by TERI for IOCL (based on fresh ground water sampling
and comparing results with NEERI EIA report carried out in 1993) in this regard has
indicated no deterioration in ground water quality from the year 1993 to present
condition.
 There may be seasonal variation in ground water quality, due to which EC (TDS), COD
and Iron component may change. The variation in TDS happens over a period of time
due to extraction of ground water for irrigation.

793
 COD content in shallow ground water may also be attributed to usages of pesticide and
fertilizers and even organic manure and the same case will be for TOC. High Iron content
in water may be due to soil quality, and soil samples are needed to be checked for iron
content. Also iron content may appear in local area if hand pumps and tube wells are old
and not frequently operated. There is a need to establish the reasons for high iron
content, TOC, COD and EC in some samples. For comparing, available old data for the
same/nearby sampling locations shall be used where present sampling is being done.
The committee may go for fresh consolidated time average samples again at those
points which are showing higher values and their analysis at three different labs of
national repute to dispel any ambiguity.
 As per CGWB Report, the contaminated ground water is proposed to be dewatered and
proposed to be partly used for irrigational requirements in the surrounding areas and
partly for industrial requirement of PRPC. Joint Committee may please ensure suitability
of this water for irrigation as the water is reported to be contaminated. Also, the surface
water from Western Yamuna Canal is proposed to be recharged in the ground water
aquifers. Joint Committee may please ensure that the quality of Western Yamuna Canal
is better than the existing ground water quality and it is fit for ground water recharge.
 Engineering feasibility of simultaneous withdrawal and refilling of aquifers needs to be
assessed for its implementation as same water will percolate back to reservoir, if used
for irrigation again.
 Large variation in ground water quality were observed in CGWB report, although some
of the sampling locations appears to be very close. For example, Iron in Sample No. 11
(Mahinder singh S/O Shri Sadhuram, CISF colony, Baholi) and Sample No. 12 (Mahinder
singh S/O Shri Sadhuram, CISF colony, Baholi) are reported to be 1.877 mg/L and 0.043
mg/L respectively. Similarly, Iron in Sample No. 15 (Pawan s/o Pale ram, near railway
line,Baholi) and Sample No. 16 (Munsiram, sohanlal dera,Inside Raily line,Baholi) are
reported to be 4.985 mg/L and 0.031 mg/L respectively. Reasons for such large
variations in ground water quality for nearby sampling locations have not been covered
in the report.
 TOC have not been measured at all 31 sampling locations selected by CGWB (TOC have
been measured only at 15 locations out of total 31 locations). In general, it is observed
that TOC has not been measured at locations which are far away from refinery. It is
proposed to carry out analysis of TOC in all ground water sampling locations to study the
prevailing levels of TOC in the entire study area (including uncontaminated ground
water).
 Large variations were observed in the ratio of TOC (measured by CGWB) to COD
(measured by HSPCB) at different sampling locations. This ratio (TOC/COD) varies from
as high as 5.23 for Sample No. 14 (Ravi kumar ranga,KBPL gate,Phool singh dera) to as
low as 0.08 for sample No. 15 (Pawan s/o Pale ram, near railway line,Baholi). This ratio is
3.68 for Sample No. 17 (Vill-Singhpura, Satpal sarpanch dera, Babadargha), although this

794
sampling location is very close to Sample No. 15. Reasons for such large variations in
TOC/COD ratio in ground water quality have not been covered in the report, although
both TOC & COD represents similar type of contamination. Normally in refinery waste
water the ratio of COD: TOC does not vary much. It is proposed that same agency
(CGWB) shall carry out sampling and analysis of both the parameters (TOC & COD) in all
31 sampling locations.
 Joint Committee’s view that ground water is fit for Industrial use and irrigation purpose
as cited in their report and solution provided to replenish ground water with Western
Yamuna Canal water seems to be unsustainable as it may further deteriorate the ground
water quality (especially w.r.to micro-bacterial contamination) and soil quality. It might
also result in emission, noise and increase in carbon foot print due to continuous
operation of pumps. Moreover, water quality/quantity might not be matching with
industrial/irrigation water requirements.
For a sustainable solution, extensive rain water harvesting (annual rain fall more than
600mm) in contaminated ground water zone should be explored to bring back the
quality to the normal as deem fit for drinking water with timely monitoring. Meanwhile,
IOCL may be asked to provide safe drinking water to affected population.
An effort has been made by EIL for more scientific assessment of ground water pollution by
assuming that entire effluent discharged to Cess Pool has percolated down and polluted the
ground water, whereas only 20% of the effluent discharged to Thirana Drain has percolated
down and polluted the ground water. Accordingly, mathematical impact of water/effluent
ingresses to the ground water has been carried out, which is attached in ANNEXURE-I. The
following is the summary of the assessment:
COD TDS Iron

(mg/L) (mg/L) (mg/L)
Concentration in 31 Ground Water Samples (as
7.2 - 76.8 370 - 1420 0.009 - 25.167
per analysis carried out by HSPCB)
Impact on Ground Water due to estimated
0.352 1.266 0.00027
discharge by PRPC
Above assessment suggests that impact on ground water quality due to ‘Discharge of
effluent in Thirana Drain’ and ‘Discharge of untreated effluent in Cess Pool’ is negligible in
nature and couldn’t have impacted ground water quality to the extent as believed by the
joint committee.
In view of above observations, it is strongly recommended that a ‘Source Apportionment

Study’ should be carried out to establish the following:

795
 Establishing benchmark baseline environmental data (air, surface water, ground water,
etc.) before PRPC starts its commercial operations (based on available historical data)
 Evaluation of changes in the baseline environmental data over a period of time (based
on available historical data)
 Assessment of total damage to the environment components with reference to
benchmark baseline environmental data
 Quantitative assessment of proportion of environmental damage caused by IOCL-PRPC
and other industrial and agriculture activities predominant in Panipat District
The report was submitted by the NEERI member on 2/8/2019. The report has assessed the
following damage costs:
 Environmental damage cost due to excess discharge in Thirana Drain (separate damage
cost has been estimated for individual parameters of BOD, COD & TSS)
 Environmental damage cost due to direct discharge of effluent into Cess Pool
 Health damage cost due to air pollutants
The report is based on a single analysis carried out by HPCB and Environment damage
calculation is based on theoretical analysis rather than on factual basis. The following points
may please be relooked into to carry out a more conclusive damage cost assessment:
 Similar to CGWB report, NEERI has also relied on single sampling of effluent carried out
by HSPCB during initial assessment. No fresh sampling of effluent was carried out by
NEERI for independent assessment of effluent quality.
 Actual quantitative assessment of damage to surface and ground water resources has
not been carried out in the report. It is presumed that the environmental damage to
surface & ground water resources has happened since the effluent was reported to be
non-complying to the prescribed discharge standards.
 CPCB discharge standards have been considered as applicable for refinery effluent and
not for petrochemical effluent.
 Damage due to discharge in Thirana Drain: We are not sure how the non-compliance
periods of 506 days have been arrived, whereas joint committee earlier had considered
non-compliance period of 120 days. The non-compliance period is also based on one day
reading of BOD, COD & TSS. Further, if damage cost due to COD has been considered,
the damage cost assessed due to BOD is repetitive. Moreover, the damage to surface
water has also been assessed by CPCB in its report.

796
 Damage due to discharge in Cess Pool: The cess pool effluent was required to be
treated back in IOCL’s waste water treatment plants as it was created due to accidental
damage to the pipe line. Dilution of this effluent is not a solution as fresh water should
never be used to be mixed up with effluent to meet the norms. Also, the discharge year
considered as 2017 needs to be corrected. Moreover, the damage to ground water has
also been assessed by CPCB in its report.
 Health damage: With regards to health damage cost due to air pollutions, the NEERI
expert himself expressed uncertainty with regard to source of pollutants. However, for
the purpose of damage cost assessment, all the reported air borne diseases have been
assumed to be due to pollutants emitted from PRPC stacks. The report did not take
cognizance of spot sampling carried out by the Joint Committee, wherein air emissions
from PRPC stacks were found to be within permissible limits. Also, no cognizance has
been taken of the data of continuous stack monitoring system of PRPC. Further, no air
dispersion modelling was carried out to establish the ground level concentrations of
pollutants.
Health assessment of PRPC employees is also to be taken into account as they remain in
the first line of exposure to the air pollution.
In view of above observations, EIL is of the view to carry out a detailed scientific study
including air dispersion modelling to find the root cause of the health related problems.
NEERI expert in its report has also suggested that ambient air quality monitoring over the
refinery area needs to be carried out to avoid the ambiguity.
4. VOC emissions from PRPC is polluting the ambient air quality in the surrounding villages
The joint team collected spot samples from 4 stacks in Refinery and 2 stacks from Naphtha
Cracker in PRPC between 4th to 7th December, 2018 and Ambient Air Quality of villages Sithana,
Baholi and near the unit. The team also visited the open ponds within PRPC meant for storing
treated & untreated effluents. Following observations were made by the joint team:
 Irritation to eyes and odour were observed at various locations inside PRPC premises and
outside adjacent to PRPC premises
 Results of spot sampling of refinery and petrochemical stack emissions were carried out and
found to be within permissible limits with respect to SOx, NOx and PM. PM values in AVU1
and AVU2 stacks were measured as 53.5 mg/m3 and 4.8 mg/m3 respectively against
prescribed limit of 96 mg/m3. Similarly, PM values for HGU-76, HGU-77, NCU Heater-500
and NCU Heater-300 stacks were measured as 3.7 mg/m3, 3.5 mg/m3, 1.3 mg/m3 and 3.8
mg/3 respectively against the prescribed limit of 10 mg/m3.
 Ambient Air Quality (for SO2 and NOx parameters) of nearby areas was found to be within
permissible limits of National Ambient Air Quality Standards (NAAQS).

797
 Ambient Air Quality (for PM10 parameter) of nearby areas recorded in the range of 123.5 to
290 micro-g/m3 were found to be higher than the permissible limits of 100 micro-g/m3 as
per NAAQS.
Although, PM10 parameter in ambient air of nearby areas was found to be higher than the
permissible limits, the same cannot be attributed to PRPC operation as refinery/petrochemical
complexes are not a major source of particulate matter (PM) pollution. This is also substantiated
by the fact that particulate matters were found to be within permissible limits in
refinery/petrochemical stacks emission. Higher emissions of PM10 is predominant problem in
most of this region and is primarily dominated by local phenomenon of transportation,
automobiles emissions, agriculture and other localized activities in the region.
Irritation to eyes and odour were assessed by the team based on human observations. We
understand that no measurement was carried out by the team to assess the levels of VOCs in the
ambient air quality, which could probably cause eyes irritation and odour. The ambient air
quality monitored by TERI for IOCL have indicated that Benzo(a) Pyrene and Benzene in ambient
air in surrounding villages are within permissible standards as per NAAQS laid down by CPCB.
A more detailed scientific study might be required to ascertain the exact reasons for eyes
irritation and odour. However, the possibility of VOC’s emissions from open effluent storage
ponds in the PRPC cannot be ruled out. As such, IOCL may be advised to propose an action plan
for covering of open ponds and control of VOC emissions from these ponds.
5. Stagnant effluent (cess pool) due to accidental leakage of untreated effluent have polluted the
ground water
It has been reported that accidental leakage of untreated effluent line has resulted in stagnant
effluent (cess pool). Joint team in subsequent visit have reported that the unit has restored the
area where earlier stagnant effluent was found discharged in green belt. Although the area has
been restored by IOCL, but the damage to surrounding soil and green belt vegetation cannot be
ruled out. This localized damage to soil and green belt cover may be assessed and action plan to
be made to restore these components to original conditions. Any significant ground water
pollution due to this accidental leakage of untreated effluent is not expected for reasons as
explained earlier in this report.

798
ANNEXURE-I
Assessment of Ground Water Pollution caused by Effluent Discharged from IOCL-PRPC
Assessment of Impact on Ground Water COD

Total quantity of off-specifications treated effluent discharged to Thirana Drain as (A) 7,34,400 m3
estimated by the Joint Committee
Total quantity of Thirana Drain Effluent percolated down and polluting the ground (B) 1,46,880 m3
water, assumed @ 20% of (A)
COD of effluent discharged to Thirana Drain (as per HSPCB lab analysis) (C) 460.8 mg/L
Total COD (in kg) discharged to ground water through Thirana Drain (= B x C /1000) (D) 67,682 kg
Total quantity of effluent discharged to Cess Pool as estimated by the Joint Committee (E) 5,000 m3
COD of effluent discharged to Cess Pool (as per HSPCB lab analysis) (F) 5,472 mg/L
Total COD (in kg) discharged to ground water through Cess Pool (= E x F /1000) (G) 27,360 kg
Total ‘COD’ estimated to be Discharged to Ground Water (= D + G) (H) 95,042 Kg
Quantity of ground water estimated to be contaminated (as per CGWB member report) (I) 27,00,00,000 m3
Impact on Ground Water ‘COD’ due to estimated discharge by PRPC (= H X 1000 / I) 0.352 mg/L
Assessment of Impact on Ground Water TDS

TDS of effluent discharged to Thirana Drain (as per HSPCB lab analysis) (C) 2,224 mg/L
Total TDS (in kg) discharged to ground water through Thirana Drain (= B x C /1000) (D) 3,26,661 kg
TDS of effluent discharged to Cess Pool (as per HSPCB lab analysis) (F) 3,050 mg/L
Total TDS (in kg) discharged to ground water through Cess Pool (= E x F /1000) (G) 15,250 kg
Total ‘TDS estimated to be Discharged to Ground Water (= D + G) (H) 3,41,911 Kg
Impact on Ground Water ‘TDS’ due to estimated discharge by PRPC (= H X 1000 / I) 1.266 mg/L
Assessment of Impact on Ground Water IRON

IRON of effluent discharged to Thirana Drain (as per HSPCB lab analysis) (C) 0.406 mg/L
Total IRON (in kg) discharged to ground water through Thirana Drain (= B x C /1000) (D) 59.6 kg
IRON of effluent discharged to Cess Pool (as per HSPCB lab analysis) (F) 2.806 mg/L
Total IRON (in kg) discharged to ground water through Cess Pool (= E x F /1000) (G) 14.03 kg
Total ‘IRON estimated to be Discharged to Ground Water (= D + G) (H) 73.63 Kg
Impact on Ground Water ‘IRON’ due to estimated discharge by PRPC (= H X 1000 / I) 0.00027 mg/L
NOTE: Similar assessment may be drawn for stagnant water in plantation area

799
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702

Comments on the Draft report circulated by Nodal Officer, HSPCB, for

A. The damage and cost of restoration w.r.t Oxygen depletion

Responsibility of assessment of damage and cost of restoration was assigned by the

1. Assessment of damage and cost of restoration w.r.t Oxygen depletion and

2. Assessment of damage caused to public health & environment (CSIR-NEERI

3. Assessment of damage caused to ground water and cost of restoration (CGWB

1. Assessment of damage and cost of restoration w.r.t Oxygen depletion

Environmental Damage due to Illegal Discharge of BOD:

The environmental Damage on account of oxygen depletion due to illegal discharge

Estimated Cost of Oxygen (H): Rs. 25/ Kg.

Total Environmental Damage in Monetary terms due to depletion of Oxygen

Environmental Damage due to Illegal Discharge of COD:

Estimated Cost of Oxygen (H): Rs. 25/ Kg.

Total Environmental Damage in Monetary terms due to depletion of Oxygen

Environmental Damage due to Discharge of Untreated Effluent in Cass

Total Environmental Damage in Monetary terms due to depletion of Oxygen

Total Cost of Environmental Damage by IOCL, Panipat Refinery: C1 + C2

Cost of Restoration of the Environment damage on account of

Amount of Oxygen depleted by Discharging untreated effluent (BOD) in Thirana Drain:

Amount of Oxygen depleted by Discharging untreated effluent in Cess Pool: 19500 Kg

Average Time required for maturity of Forest Trees (F): 10 years

Cost of Damage due to Discharge of TDS in Thirana Drain and

Total Cost of Prevention: A x B x C i.e. 6120 x 150 x 120 = Rs. 110160000

Therefore, the proposed cost of Restoration should be: 11.02 x 2 = Rs.

So, Total cost of restoration on account of damage caused due to

B. The following may also be incorporated in the

The environmental compensation (EC) calculated by the Joint team is as under:

Total Environmental Compensation as calculated by the Joint team is :

Therefore, balance environmental compensation to be deposited is:

C. Pls also note that the following statements were submitted

Environmental damage cost assessment due to discharge pollutants

Table l: Damage cost value for each pollutant[ I i

Suspended Solids 0.005

Biological Oxygen Demand 0.033

Chemical Oxygen Demand 0.098

Economic assessrnent cost on the environment due to the discharge of

From To Total Number of Davs

Environmental damage cost assessment due to discharge pol

0l-0l-201 9 to 02-04- 460 335 21.54

13-11-2017 142 122 I .58

13-11-2011 142 t22 0.40

Tota 2.20 -- (c)

The idea used is to understand the amount of freshwater which will be

Durafion Raw effluent Average Raw

t3-tt-2017 BOD 770

t3-11-2017 TSS 256

Cvx Caoo * Dvx Deoo: (Cv + Dv) x Feoo Eq (l)

' j l:,'l ','i '1' I !,,ii)l

'. S,'.r,.'.:r iii : rii'i.t){;l ,:,1 ii,i j . r: ;l i .',i ir. :l li:

!:{:, B.?S1.560 s i.ill $.r9 t r:,:,,1 1iS ),D50,.11$

Health damage cost due to air pollutants

Table 7: Water & air borne diseases details

20t7 436 505

20t8 388 11s7

2019 205 2495

Colran,par : COlvon,oo t * Y33L Eq

COleanipar: Cost of illness per person in Panipat area

Table 8: Health damage cost due to respiratory diseases

l5llll20l8 in OA No.738/2018, in the matter ofSatpal Singh & Others Vs IOCL,