Complete Overview of Post Compliance Audit under GPCB

The Gujarat High Court introduced Environmental Audit Scheme in 1996 to address the farmers' issues in the Kheda district. They filed a petition to save the Khari-cut canal and river Khari from pollution by bringing it to the public notice. Today, the Environment Audit Scheme has become crucial for industrial establishment in Gujarat. This scheme is supervised by the Gujarat Pollution Control Board (GPCB) and implemented in the state. The GPCB prepares the audit report format to be submitted by the auditors and updates it from time to time. In 2015, the board classified the industries required to submit periodic environmental audition reports and follow post-compliance auditsunderGPCB-mandated guidelines.

Additionally, the scheme also envisages actions for failure to submit a report for industries and furnishing incorrect information on the part of auditors. Based on the evaluation of the environmental audit formats prepared under the Environmental Audit Scheme, the post-compliance audit under GPCB have to be met by specific industries, as elaborated below. On 14^th September 2022, a set of new guidelines were introduced.GPCB has delineated these guidelines for environmental auditing to be followed by all recognised schedule I and II environment auditors.

Classification of industries

The GPCB has classified industries in the below-mentioned categories -

• Dyes- Intermediaries (an intermediary industry that deals with naphthalene and its derivatives, aniline)
• Pigments (metal–phthalocyanine based)
• Benzene-based industries
• Nitrochloro benzene-based industries
• Aniline-based industries
• Common Effluent Treatment Plants (CETP), Treatment, Storage, and Disposal Facilities (TSDFs) and all biomedical waste incineration facilities
• Textile processing industries with carbonising units
• Textile processing industries having a daily effluent discharge of one lakh litre per day or more
• Stainless steel rolling and rerolling mills
• Lead recovery units from scrap
• Industrial plants manufacturing products such as sugar, fertiliser, oil refinery, caustic soda, petrochemicals, dyes and dye intermediaries, pigments, tanneries
• Industrial plants such as cement plants, thermal power plants, integrated iron and steel plants, zinc smelters, copper smelters, aluminium smelters

Industrial Waste Parameters introduced in the 2022 Guidelines

The Gujarat Pollution Control Board has described the methodology and procedure as a need was felt to devise updated policy in the form of guidelines. This was done to bring about uniformity in sampling and analysis during the environmental audit of the industry. Furthermore, these guidelines intend to set standard limits of specific test parameters and design a structure of post-compliance audit under GPCB by specifying the frequency of air, water and hazardous waste sample collection.
Also, specifying intervals during the environmental audit of industries based on the area of the industry, the quantity of effluents released, and the capacity of the installed pollution control devices is essential.

Criteria for Collection of Water and Wastewater Samples

Discharge Quantity (kilolitre per day)	Frequency (if the final treated discharge is done in a CETP)	Frequency (if the final treated discharge is not done in CETP)
Less than 25 KLD	1 sample per monitoring	2 samples per monitoring
25-50 KLD	2 samples per monitoring	3 samples per monitoring
More than 50KLD	3 samples per monitoring	3 samples per monitoring

 

Criteria for analysis of parameters in waste Water Samples

• pH
• Temperature
• Total suspended solids
• Total dissolved solids
• Biological Oxygen Demand (BOD) (3 days at 27 degrees Celcius)
• Chemical Oxygen Demand (COD)
• Ammonical Nitrogen

Sampling Criteria for Ambient Air Quality Monitoring

Certain criteria for air quality monitoring must be met for post-compliance audits under GPCB. These criteria are as follows -

WithinGujarat Industrial Development Corporation (GIDC) Estate: No ambient air quality monitoring for industry located in GIDC estate. In such cases, the audit report should mention NAMP (National Ambient Quality Monitoring Program).

Outside GIDC Estate: if the industry lies outside the Gujarat Industrial Development Corporation, the parameters will be as follows -

Total Premise Area (sq. mt)	Frequency of Sample Collection
Less than 5000	2 samples in one season (preferably winter)
5000 to 10,000	3 samples in one season (preferably winter)
More than 10,000	At least 3 samples in one season (preferably winter)

 

Parameters for Ambient Air quality monitoring

• Particulate Matter(PM10)
• Particulate Matter (PM 2.5)
• Sulphur Dioxide (SO2)
• Nitrogen Dioxide (NO2)

Sampling Criteria for Process GasEmission

Besides the criteria mentioned above, there are other parameters that must be met for post-compliance audits under GPCB. Sampling and analysis of Process Gas Emission monitoring are one of them. This is to be carried out as per the latest Consolidated Consent and Authorisation (CCA) issued by GPCB to industrial establishments as Consent to Operate.

Sampling Criteria for Flue Gas Emission

Flue gas sampling is not required if the industry uses a boiler or thermic fluid heater with fuels other than NG, LPG, LNG, or PNG. For all other approved fuels, the sampling frequency will depend on the capacity of the boiler used, which is given in the table below

Boiler capacity (In case of approved fuels are used)	Frequency
Less than 5 TPH	One season frequency
5 to 10 TPH	Two seasons sampling
More than 10 TPH	All three season sampling

 

Sampling Criteria for DG sets

Capacity	Sampling frequency for Stand By DG Sets	Sampling frequency for Continuous Operational DG Sets
Less than 500 KVA	Exempted	1 season monitoring
500 to 1000KVA	1 season monitoring	2 season monitoring
More than 1000 KVA	2 season Monitoring	3 season monitoring

 

Sampling Criteria for Noise Monitoring

For small-scale industry: the industry will require one sample set in one season.

For the medium and large-scale industry: the industry will need at least two sets of samples during only one season.

Sampling Criteria for Hazardous Waste

The Sampling Criteria for Hazardous Wasteforms an essential part of post-compliance audit under GPCB. For instance, sampling and analysis of the sludge from wastewater treatment will not be required in the case of chemical sludge. However, in case of sampling and analysis of process waste/ hazardous waste must be performed once during one season only (if process waste generation is more than 10 MT per month).

Process filing of Audit Report

Before Environment compliance auditing, the mandatory licences and permits must be obtained by the industrial setup from the Gujarat Pollution Control Board. The following points must be considered when the applicant prepares an audit report and post compliance audit under GPCB.

• Any industry hereafter applying for consent or seeking permission for trial production for manufacturing/processing items mentioned in Schedule-I or Schedule-II shall have to get its Environment Management System inspected by respective auditors regarding adequacy and efficacy.
• If an industrial unit falls both in Schedule-I and Schedule-II, it is treated as a unit falling inSchedule-I.
• This scheme is in addition to and not derogating the powers of the GPCB and the State Government under existing provisions of the various enactments and rules relating to preventing and controlling pollution and protecting the environment.
• The Environment Audit Scheme is without prejudice to any action that mightbe taken against any individual industrial unit, a cluster of units or a class of industries.

Importance of Post compliance audit under GPCB

The coming of the Environmental Audit Scheme enabled the establishment of Common Effluent Treatment Plants (CETP) for the industrial clusters, with facilities for safe disposal of treated effluent, including setting up of TSDFs forsolid hazardous waste. The Gujarat High Court had directed the board to hire professionals who can become a link between the individual industries on the one hand and the GPCB and other public authorities as well as the association of industries on the other hand, with the added vital elements of accountability and transparency.

How will Enterclimate Assist You? 

Comprehensive assistance in Environmental Auditing Enterclimate will provide you with end-to-end assistance in the entire journey of Environmental and Post compliance audit under GPCB and offer expert services in legal auditing.

Expert Guidance Through our market understanding and expertise in environmental laws, we provide personalised services for all your business needs keeping the client's best interests and business objectives in mind. We realise the importance of sustainable business practices and strive to provide all-inclusive assistance.

Swift Redressal of all your doubts Our solutions also include advisory to globally established businesses on their environmental licensing and compliance in India. We ensure that issues during the application stage are met with swift quality solutions. We also seek to maintain a prompt, positive, seamless experience with our clients.