Astamudi Wetland Pollution Report NGT Aug 17 2022
Astamudi Wetland Pollution Report NGT Aug 17 2022
Astamudi Wetland Pollution Report NGT Aug 17 2022
Versus
Versus
VOLUME 1
Index
Versus
I, Mini Mary Sam, aged 55 years, W/o Ranjan Jacob, Senior Environmental Engineer do here
by submit that I am authorised to represent the Kerala State Pollution Control Board, and that I
am conversant with the facts of the above case and I may state as follows.
Grievance in this application is about the failure to take action for protecting Astamudi
wetland and Vembanad-kol wetland, a Ramsar site in Kollam district of Kerala. As per the order
dated 28.02.2022,the state PCB needs to enforce consents /EC conditions applicable to
pharmaceutical units and house boats as well as other authorities dumping wastes and to take
appropriate action by way of prosecution and stopping polluting activity.
ASHTAMUDI LAKE
Ashtamudi Lake, situated in Kollam District of Kerala, is the most visited backwater and lake in
the state. Fishing, coconut husk retting for coir production and inland navigation services are the
prominent activities connected with the lake. It has a catchment area of 1700 sq.km. and an area
of 61.4 sq.km. Kallada River is the major river discharging into the Ashtamudi Lake. Ashtamudi
Wetland was included in the list of wetlands of international importance, as defined by
the Ramsar Convention for the conservation and sustainable utilization of wetlands. Studies
show that, the lake is under pollution stress due to dumping of solid waste and discharge of
sewage. Several major and minor drainage channels loaded with waste products from households
and establishments join the lake at the southern end. Coconut husk retting for coir fibre
manufacture is predominant at certain locations in the eastern arm of the estuary.
For identifying and controlling the pollution of the lake, the Board had conducted a
Sanitation Survey of Ashtamudi lake as per the direction dated 03.10.2018 of the Local Fund
Accounts Committee of Kerala Legislative Assembly. Socio Economic Unit Foundation
(SEUF), an NGO, was entrusted by the Board with the responsibility of conducting the survey
as per the agreement dated 10.01.2020. It was decided to conduct the survey of the area around
100m from lake which included houses, flats, industries, establishments, drains joining the lake
etc. The data collection was done with a mobile application named ASAN developed by Kerala
State Remote Sensing and Environment Centre specially customized for the purpose of
sanitation survey of Ashtamudi Lake.
The survey was carried out in Kollam Corporation and the Grama Panchayaths of Perinad,
West Kallada, East Kallada, Munroethuruth, Panayam, Kundara, Perinad, Thrikkaruva,
Thevalakkara, Thekkumbhagam, Chavara and Neendakara. As per the survey 65% of the
residents dispose their sewage through septic tank and soak pit, 15% uses toilet pits and 18%
residents dispose directly into the lake.
According to the survey 40% of the residents are segregating waste as biodegradable (wet
waste) and non-biodegradable (dry waste). Method of disposal of wastes varies with the area.
The local bodies are collecting dry waste, mainly plastics through Haritha Karma Sena (HKS).
However, the fraction of the population availing the service of the HKS is less. The wet waste
from households and establishments are managed at the point of generation itself. The dry
waste from the remaining households were found disposed through burning, burying, dumping
into the lake or drains.
Thus the main reason for the pollution of the lake water is the indiscriminate discharge of
sewage and dumping of solid waste from households and establishments.
Regarding dumping of solid wastes, the local bodies have to take action since as per the
provisions contained in the Solid Waste Management & Handling) Rules 2016, the Local
Bodies are vested with powers and duties to manage the solid waste generated within its limits.
The Board had issued direction to the local bodies to improve the door to door collection and to
dispose the solid wastes as specified in the SWM Rules. There is found to be a gap of 20% on
an average between the solid waste generation and solid waste management in the local bodies.
The Board is also monitoring the progress of implementation of SWM Rules from the periodic
reports and action plans submitted by the local bodies. The matter of mismanagement of solid
waste noticed in the surveillance by Board Officers is followed up in the periodic meeting of the
District Level Monitoring Committee (DLMC) constituted as per direction of this Hon’ble
Tribunal in O.A. 606/18. Two rendering plants have been set up in private sector and 3 more are
under construction. This will provide a permanent solution for the chicken waste which
contributes to a large proportion of the solid waste generated. Kollam Corporation has recently
completed 80% bio mining of legacy waste from Kureepuzha dumpsite situated on the banks of
the lake. A 200 TPD bio-methanation based Waste to Energy Plant is also planned at
Kureepuzha. This will go a long way in solving the solid waste management problems in the
corporation area as well as nearby local bodies.
Another major contributor to the pollution of the lake is the sewage from households and
establishments. A common sewage treatment plant of capacity 12 MLD is being constructed in
Kureepuzha by Kollam Corporation and is expected to be completed within one year. The
Board had granted Consent to Establish the STP. This STP will help in reducing sewage
pollution to the lake.
The Board is carrying out periodic surveillance, seizing of banned single use plastics etc.
in the district. The progress of implementation of the Environmental Laws is monitored through
the periodic reports collected from the Local Bodies. The industries, hospitals, high rise
buildings etc. are granted Consent of the Board only after ensuring that there is adequate
effluent/sewage and solid waste treatment facility. No industry/establishment is currently
granted consent to make discharge into Ashtamudi lake. The Board is granting Consent to house
boats and resorts after verifying the adequacy of the solid waste & sewage management
facilities. The Board is also conducting periodic inspection and sampling from the
effluent/sewage treatment plants of the industries/establishments to ensure that the outlet
parameters are meeting the discharge standards. Necessary directions are given to defaulter
units to take adequate corrective measures if the parameters are found to be exceeding the
permissible limits.
The Board is collecting water samples from 5 numbers of stations in Ashtamudi lake under
the State Water Quality Monitoring Programme (SWMP). The analysis reports show presence
of fecal coliform in the range 110 cfu/100ml to 680cfu/100ml. Also the parameter electrical
conductivity is high due to tidal effect and is of the range 16730µmhos/cm to 21630µmhos/cm.
The high electrical conductivity is because the lake is estuarine. Due to this high electrical
conductivity the lake is classified in the category”below E” of surface water bodies. Analysis
report for the period 2019-2021is tabulated in Table 1.
pH EC DO BOD TC FC
River Stations CLASS*
µmhos/cm mg/l mg/l MPN/100ml MPN/100ml
Max 8.1 19350 5.6 4.0 920 680
Neendakara
2019 NWMP Min 7.5 18120 3.4 1.4 480 260 Below E
1441
Mean 7.8 18382 4.2 3.1 672 458
Max 8.1 19220 5.6 4.5 540 220
Neendakara
2020 NWMP Min 6.6 18200 3.6 2.9 310 100 Below E
1441
Mean 7.5 18649 4.4 3.4 365 136
Max 7.4 18410 6.1 3.5 610 150
Neendakara
2021 NWMP Min 6.3 15000 5.1 2.5 350 100 C
1441
Mean 6.9 16609 5.8 3.0 462 123
Table 1: Ashtamudi Kayal analysis report for the period 2019-2021
Apart from the above major causes of pollution, coconut husk retting and related
operations, though of small scale, are noticed to be carried out in the lake which contributes to
pollution. The fishing boats fitted with outboard engines releases hydrocarbons and heavy
metals into the system. The agricultural practices which involve the use of chemical/organic
fertilizers and insecticides/pesticides, and the residues on entering the system may cause
pollution and eutrophication. Boat breaking activities were resulting in deposition and burning
of the solid wastes on the banks damaging the mangroves. Aquaculture and fish processing units
were also noticed as causing pollution. The Board on receipt of public complaints or on noticing
any violation during surveillance or compliance monitoring is issuing necessary directions to
individual industries and local boides to control the pollution.
VEMBANADU LAKE
Vembanad Lake is a designated Ramsar site, a wetland of global importance for its
biodiversity values. The lake is bordered by Alappuzha, Kottayam and Ernakulum districts.
Five main rivers flow into the lake, are the Achenkovil, Manimala, Meenachil, Muvattupuzha,
Pamba and Periyar.
The Board is monitoring the quality of the lake from five points under State Water
Quality Monitoring Programme and from eleven points under the Project of Backwater
Resources in the portion of the lake coming under the Alappuha district. The analysis report of
the samples taken for the period 2019-2021 are shown below in Table 2 & Table 3.
RIVER EC DO BOD TC FC
YEAR SWMP PH CLASS
STATIONS µmhos/c mg/l mg/l MPN/100 MPN/100
EC DO BOD TC FC
YEAR RIVER STATIONS SWMP PH CLASS
µmhos/c mg/l mg/l MPN/100 MPN/100
EC DO BOD TC
YEAR RIVER STATIONS SWMP PH FC MPN/100 CLASS
µmhos/c mg/l mg/l MPN/100
EC DO BOD TC FC
YEAR RIVER STATIONS SWMP PH CLASS
µmhos/c mg/l mg/l MPN/100 MPN/100
Major portions of the lake have not been classified according to the Best Designated Use
criteria developed by Central Pollution Control Board. Hence the water quality has been
compared with Primary Water Quality Criteria for Bathing Water. The analysis reports show
high values of fecal coliform than the permissible limit (desirable) of 500 MPN/100ml.
Dissolved oxygen content is seen to be below the limit(5mg/l) at certain points.
A main activity in the stretch of the lake in Alappuzha district is tourism. A large no. of
houseboats are plying in the lake. With an increase in number of houseboats catering to
backwater tourism, commensurate waste management facility is yet to be developed.
Intensification of agriculture and use of high yielding varieties of rice has also led to increased
use of fertilizers and pesticides which may ultimately reach the lake.
The actions taken by the Board to reduce the pollution threat are as follows:
Consent of the Board under the Water Act has been made mandatory for houseboats with
condition to provide sewage collection facility and to treat the collected sewage at
common treatment plant. The Board had charged an amount of Rs 90,45,400/- as penalty
from houseboat owners for not complying norms and conditions.
Action is taken through Port Officer, Alappuzha to find out unauthorized house boats.
Another major issue in the district is waste from peeling sheds. As a solution to this
problem, the demand for a CETP is high. For establishing CETP in Chandiroor region as
part of ACCEPT Society, several official and public meetings were held in multiple level
with very little positive result. Due to the strong protest of few neighbours the progress of
the project is limited.
A CETP at Mega Food Park, Pallipuram with a capacity to treat 20 lakh L/D effluent was
commissioned in March 2022, thus providing a protection to Kaithapuzha, a tributary of
Vembanad Lake, from further pollution due to peeling sheds in Puthenthodu.
Inspections for house boats and resorts near to the lake are being conducted for ensuring
compliance to consent conditions.
Directions were issued to all local bodies in the district to implement adequate solid
waste management facilities including composting facilities, Material Collection facility
(MCF)/Material Recovery Facility (MRF).
Haritha Kerala Mission (HKM) and KSPCB had jointly organized two training programs
with all stakeholding departments to create awareness in environmental law enforcement
responsibility of each department and ensuring synergic function of these departments for
environmental conservation. HKM and Suchithwa Mission had organized three training
programs in this line for LSGI officials to improve environmental rule implementation
for the better waste management and protection of water bodies.
Continual awareness programs are being given to create awareness about the
consequences of lake and stream pollutions, in association with residence associations,
peeling shed owners and sea food industries associations in regular interval.
Awareness classes or seminars are conducted for school students regarding the waste
management as a part of environmental day program focusing on mentoring youth for
environmental conservation.
Based on the inspections conducted, notices were issued to 10 establishments for non
compliance of consent conditions and letters issued to 39 units directing to apply for the
consent of the Board which are not still under the consent regime of the Board. The matter is
being followed up by the Board.
A total of 101 industries were identified and mapped using Enviclean application. The
following data are collected:
Water Consumption
Effluent Generation Quantity
Whether effluent treatment plant provided
Waste water treatment plant/ system provided
Whether applied for consent or not
Periodical inspections and monitoring are being conducted by the Board for ensuring
the compliance of consent conditions in major commercial and residential establishments
which are already under the consent regime of the Board. Efforts are being taken to bring more
units under the purview of the Board which do not have the consent of the Board.
Seven drains flowing through Kochi city and falls into Vembanadu Lake were identified. The
photos showing the location of the drains are enclosed as Annexure A and the table showing
flow measurements is attached as Annexure B. The analysis report of the sediments and the
water samples collected from these drains are attached as Annexure C & Annexure D
respectively.
In certain drains, the values of BOD are more than 3mg/l& Dissolved Oxygen less than 4
mg/l , which are prescribed as the limits by CPCB for determining whether the stretches for
water bodies are polluted or not which indicates that more treatment is necessary for wastewater
before letting it into drains.
The Board conducts monthly sampling of the Vembanadu lake at Oil Tanker Jetty, near
Marine Drive, Ernakulam and the analysis reports of 3 years are attached below in Table 4. The
values of Fecal Coliforms are well above the permissible limit of 2500MPN /100ml which is
the maximum permissible value. . The inference is that the wastewater needs treatment before it
is discharged into the lake.
pH EC DO BOD TC FC
River Stations CLASS*
µmhos/cm mg/l mg/l MPN/100ml MPN/100ml
Max 8.0 44000 8.1 3.6 310000 140000
2019 Min 6.8 1200 2.5 0.8 840 430 Below E
Mean 7.2 24300 5.3 2.0 48420 22040
Oil Max 7.7 46270 6.7 3.4 46000 24000
Tanker
NWMP 2020 Min 6.6 320 2.3 0.7 1100 480 Below E
Jetty
1575 Mean 7.2 25209 5.2 2.0 11618 7389
Max 7.9 42380 7.8 3.6 200000 32000
2021 Min 6.3 200 3.4 0.3 1500 630 E
Mean 7.1 20673 5.3 2.2 34375 8994
Table 4:Analysis Report of the samples from collected Oil Tanker Jetty , near Marine Drive, Ernakulam for the period 2019- 2021
Under NWMP, monthly sampling of the above mentioned four stations are being conducted.
In these stations, the values of Fecal Coliform are high above the permissible limit as per the
Primary Water Quality Criteria based on Designated Best Use for coastal waters marine outfalls,
specified for the stations. Analysis report of the samples collected from these stations for the
month of May 2022 is detailed below as Table 5. At present, for treating the waste water
generated in Kochi City, there is a Sewage Treatment Plant at Elamkulam, Kochi with 3.5MLD
capacity running and maintained by Kerala Water Authority. Construction of another STP of
5MLD capacity is nearing completion in the same premises. On commissioning of the new one,
the old STP will be demolished. Also M/s Kochi Metro Rail Ltd has obtained Consent to
Establish of the Board having validity up to 26.08 2025, for setting up 4 STPs of total capacity of
31MLD for treating the waste water generated in Kochi city, at different locations of the city.
The Identification and correction of industrial units functioning near Meenachil river,
Muvattupuzha river which discharge their treated waste water into Vembanad lake are in
progress, periodic inspections are scheduled to ensure that no contaminants are being discharged
into these rivers which eventually reach Vembanad Lake. The results of the SWMP samples
collected for the period 2019-2021 are given below as Table 6 & 7.
pH
River Stations CLASS*
EC DO BOD TC FC
µmhos/cm mg/l mg/l MPN/100ml MPN/100ml
Max 7.9 103 7.7 0.9 4900 2800
Kidangoor
NWMP Min 6.8 44 6.0 0.2 700 310 C
1339
Mean 7.5 70 7.0 0.5 2625 1418
Max 7.7 71 8.2 1.4 2900 1400
Theekoy
SWMP Min 6.5 36 5.0 0.1 1000 500 C
K29
Mean 7.1 48 7.0 0.5 1950 1046
Max 7.6 105 8.0 1.0 4300 2400
Bharanganam
SWMP Min 6.4 38 6.2 0.2 1600 800 C
K30
Mean 7.2 41 7.6 0.5 2667 1350
2019 Max 7.6 154 8.7 0.8 3000 1400
Kadappattoor K31 SWMP Min 6.9 42 6.7 0.2 1200 600 C
The analysis reports show that the parameters are within the limits except for the value of
fecal coliform prescribed for bathing under Primary Water Quality Criteria.
Periodic inspections are also conducted for ensuring the compliance of consent conditions
issued to house boats and resorts functioning near the lake so as to abate the pollution of the lake.
All these hotels and resorts are functioning with proper solid and liquid waste treatment plant
including Sewage Treatment Plants and also have implemented systems for recycling used
water. Board ensures the compliance of the units as per circulars /guidelines of the Board. The
list of industrial units having STP, functioning near Vembanad Lake and using treated effluent
for irrigation is enclosed as Annexure E and list of those industries which are discharging
treated effluent into the lake is enclosed as Annexure F.
In order to prevent the water pollution from house boats, DTPC has constructed a Common
Sewage Treatment Plant exclusively for house boats at Kavanattumkara Kumarakom. Consent to
Operate to the house boats shall only be granted if the houseboat treats the wastewater through
this facility. During the inspection and sampling conducted on 26.02.2022 the BOD and COD
level of treated water was found to be above the permissible limit. Hence a show cause notice
was issued to DTPC and enclosed as Annexure G.
The other area sources of pollution to Vembanad Lake include the discharge of pollutants
in the solid and liquid waste generated from nearby panchayats and municipalities. The wastes
dumped in the water shed includes drainages from houses, small shops, commercial
establishments and other small scale industries. There are 10 Panchayats and 2 Municipalities
sharing boundary with Vembanadu lake and the other 62 Panchayats and 4 municipalities in the
water shed and none of them have taken Authorisation for Solid waste management or set up
scientific waste anagement facilities. The Municipalities and Panchayats are discharging their
waste into these rivers and tributaries discharging into Vembanad Lake. Efficient Solid Waste
Management rule implementation including door to door collection of waste is not conducted
effectively in these LSGIs. Intimation letter was sent to all municipalities for obtaining
authorisation. Copy of the letter is enclosed as Annexure H.
The Board had got conducted 2 studies on Vembanad lake viz., 'Study on the Impact of
Heavy Floods on Environmental Characteristics of Vembanad Backwater' and 'Hydrochemistry
of Vembanad Backwater with Special Reference to Pollution Problems and its Management
Issues'. The Board has taken actions for implementing the recommendations of these studies.
All that is stated above are true to the best of my knowledge information and belief.
Versus
Versus
VOLUME 2
Index
ANNEXURE -A
Fig 1: Drain Cp Thodu, Near State Bank Of India, Bazar Road, Fortkochi
2
ANNEXURE - B
1 Drain Near
Holiday Bay N09 12 M 1.5 M 1M 18 0.06 1.08
Castle, Marine ̊58'48.198'' Sec
Drive, Kochi E076
̊16'30.7308''
2 Drain Near N09
Thevara ̊56'39.948'' 20 M 2M 1M 5 0.2 8
Market E076 Sec
̊17'38.922''
3 Drain Near
Choice Marina, N09 10 M 1M 1M 32 0.03 0.3
Thoppumpady ̊ 5'50.8008''
5 Sec
E076 ̊16'2.82''
4 Drain Near
Hotel Top N09 10 M 1M 1M 26 0.04 0.4
Form, ̊56'21.714'' Sec
Karuvelippady, E076
Fort Kochi ̊15'33.2928''
5 Drain Cp
Thodu, Near N09 12 M 1.5 M 1M 18 0.06 1.08
State Bank Of ̊58'4.5948'' Sec
India, Bazar E076
Road, ̊15'8.1216''
Fortkochi
9
Drain near
7 Tata Tritvam N09 ̊59.766' 10.7 1M 1M 41 0.02 0.21
Flats, Marine E076 M SEC
Drive ̊16.334'
10
ANNEXURE- C
ANNEXURE- D
ANNEXURE - E
ANNEXURE - F
NOTICI.],
WHEREAS the unit coffres under the purview o1'thc llnvironment (Protection)
Act, 19g6 and is bound to comply with the standards prescribed in the llnvironment
(Protection) Rules;
WHERE,AS unit was inspected and an elfluent sample was drawn from the
unit on 2610212022,
WHEREAS itwas reported that the IIOD lcvels in the treated water was
T4mgllitre and the limit was only 30mg/litre.
WFIERI1AS it was reported that the COD lcvcls in the trcated water was
'l-his shows the improper
2S6mglytre and the limit was only 250rng/litrc.
functionihg of effluent treatmcnt plant. ,
15
NOW THEREFORE you are hereby directed to show cause if any, within 15
days of receipt of this notice as to why legal proceedings for violating the provisions
of the Water (Prevention and Control of Pollution) Act, 197 4 shall not be initiated
against you.
Tr0tu
ENVIRONMENTAL ENGINE,ER.
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KO[AYA|"{ 1
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Date:..,,..........'.... l>
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'['he Secretary
District Tourism Promoti o il (D |PC)
Kodimatha
Kottayam
Email : [email protected]
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6/24/22, 10:24 AM DocScanner Jun 24, 2022 10-23 AM.jpg 16
ANNEXURE- H
https://mail.google.com/mail/u/0/?tab=rm&ogbl#inbox/FMfcgzGpGdhFkNqQRnXjLkgpqtTPXXWP?projector=1&messagePartId=0.1 1/1