Need for taking up auditiced.cag.gov.in/wp-content/uploads/C-10/F-3/Envt.PII_Exit...Need for taking up audit High inherent risk of pollution and generation of huge waste in the normal

Need for taking up audit

High inherent risk of pollution and generation of huge wastein the normal course of operation and maintenance atWorkshops, Sheds and Production Units;

To ensure efficiency in conservation of energy by adoptingefficient conservation measures.

Absence of a comprehensive environment management policyin IR poses a risk of non-compliance with statutory provisionsand orders on environment issued by the different authorities

of the Government of India and State Governments.

Audit ObjectivesTo obtain reasonable assurance that :

laws, rules and regulations relating to prevention and control of air,

water and noise pollution are being complied;

resources are managed and conserved effectively by optimizing use

of renewable sources of energy and in accordance with Vision 2020;

waste is managed in compliance with laws, rules and regulations

and according to best practices; and

health and safety of workers is managed according to the

requirements of Indian Factories Act and Railway manuals.

Sample SelectionUnits Sample Size

Workshops-Mechanical 31

S &T Workshop 10

Engineering Workshops 9

Sheds 44

EMU/MEMU/ DEMU Car Sheds 11

Coaching Depots / Wagon Depots 33

Production Units

4

Audit Findings Consent to Establish (CTE)under Air and Water Act was not obtained in

122 workshops and sheds (88 per cent) across all zonal railways;

Consent for Operation (CFO) under Air and Water Act was not obtainedin 94 workshops and sheds (68 per cent) across all Zonal Railways;

CTE was not obtained in three zones (CR, ER and NER) on the plea thatthe workshops were established prior to enactment of the Act;

The conditions of SPCB specified at the time of renewal were complied inonly20 out of 44 workshops and sheds across nine Zonal Railways.

Production Units like CLW,DLW and RWF had not complied with theconditions put forth by the SPCBs.

Air Pollution

Out of 44 workshops and sheds which obtained consent for operation

under Air and Water Act, only 13 workshops and sheds in seven Zonal

Railways were able to conduct the ambient air quality check as per the

prescribed periodicity of the SPCB;

DLW had not complied with the conditions put forth by the SPCB

regarding acoustic barrier, monitoring of emission standards and

chimneys; Two out of five fume extractors were not in working

condition

In eight workshops ambient air quality check was not conducted;

Air pollution control equipment were not provided in 95 workshops andsheds (69 per cent);

In CLW, Fume Extractor which was procured at a cost of Rs.0.46

crore and installed in the year 2004 at melting shop with Electric Arc

Furnace was not in working condition since November 2010;

Noise Pollution

Frequency of noise level checks as prescribed by the SPCBs were not

followed;

Noise level exceeded the tolerance range in 387 out of 1105 locations.

However, in five workshops and the noise level was within the prescribed

limit;

In 22 workshops and sheds over eight Zonal Railways, the stack height of DG

sets was less than the prescribed height;

Acoustic enclosures for noise reduction in DG sets were provided only in 60

workshops and sheds;

Eight workshops and sheds obtained “No Objection Certificate (NOC)” from

Regional Inspectorial Organisation for operation of DG sets. None of the four

Production units obtained “NOC”.

Water Pollution

ETP was not available in 83 workshops and sheds (60 per cent) across all

Zonal Railways. The sources of effluents were not connected to the ETP in

eight workshops and sheds;

In 53 workshops and sheds where ETP was provided, water quality check, as

prescribed by the concerned SPCB, was conducted only in 17 workshops and

sheds (32 per cent) over ten Zonal Railways;

The effluent generated at sheds was being discharged into the pond located

nearby without treatment. The sludge drying bed was not being used and

sludge was disposed of along with the garbage;

Only in 15 workshops and sheds across the nine Zonal Railways, analysis of

liquid waste was done before and after treatment. This is mandatory as per

Water (Prevention and Control of Pollution) Act, 1974;

ISO Certification

Surveillance audit was conducted in 24 workshops and sheds(17 per cent). Of the 12 units, eight workshops and sheds havefully complied with the suggestion of the surveillance auditteam;

Surveillance audit was not conducted in seven workshopsand sheds after certification;

Validity of accredition of ISO 14001 has been renewed up toMarch 2012 for 22 workshops and sheds;

In DLW, the validity of the certification expired in December2011;

ISO 18001 accredition was obtained by 16 workshops andsheds (11 per cent) across nine Zonal Railways;

Surveillance audit was either not conducted in someworkshops or the validity of the accredition of ISO 18001 hadnot been renewed.

Conservation of Water

Water Recycling Plant (WRP) was provided only in one coaching

depot at Jabalpur (WCR). In respect of Production Units, WRP was

provided only at ICF;

In SR, Coaching Depot at Basin Bridge WRP supplied in December

2009 is yet to be operational for want of over head tank for storage of

recycled water. Despite incurring expenditure of Rs.2.82 crore, fresh

water was being used for washing the coach;

Rain Water Harvesting system was not available in any of the units test

checked over 12 Zonal Railways;

Rebate on water cess was not availed due to reasons like non

compliance of Environment Protection Act, non-installation of Sewage

Treatment Plant, Water Recycling Plant, non-provision of water meter,

non-achieving of target for saving water.

Conservation of Energy

IR implemented certain energy efficient measures, the target ofimplementation was, however, not achieved in some cases.

Target for implementation of energy efficient measures were not set inmany workshops and sheds ;

None of the workshop, sheds, depots and production units (except ICF),installed wind power plants. There was also no planning for installingwind power plants;

83 solar panels were installed in 13 workshops (nine per cent) over eightZonal Railways. Solar plants were installed only in two Production units(ICF and RWF);

The saving in energy of 88075 kwh was assessed only in respect of eightunits over five Zonal Railways.

Use of Renewable Energy

None of the workshop, sheds, depots and production units(except ICF), installed wind power plants. There was also noplanning for installing wind power plants;

83 solar panels were installed in 13 workshops (nine per cent)over eight Zonal Railways. Solar plants were installed only intwo Production units (ICF and RWF);

The saving in energy of 88075 kwh was assessed only inrespect of eight units over five Zonal Railways;

Energy Audit

Only 28 workshops and sheds (20 per cent) conducted energy auditduring the review period across 13 Zonal Railways;

In eight out of the 28 workshops/sheds where energy audit wasconducted, the recommendations of energy audit team were fullyimplemented and in other units the recommendations were partiallyimplemented;

In respect of PUs, energy audit was conducted only in CLW during thereview period and energy audit recommendations were only partiallyimplemented as the competent authority considered some of therecommendation being not feasible;

The slow progress of energy audit and non-implementation ofrecommendations of energy audit not only deprived the IR of theprojected savings.

Waste Management

Authorization for handling hazardous waste was obtained in 30 workshops and sheds (25 per cent). Authorization was not obtained by 107 workshops and sheds and of them 18 workshops and sheds did not obtain authorization as no hazardous waste was generated in these workshops and sheds.

Out of four production units, DLW had not obtained authorization for handling hazardous waste;

At ICF/ Perambur and Mechanical workshop/Izzatnagar(NER), 292MT of hazardous wastes were not disposed off;

Hazardous Waste Management

Documentation

Only seven workshops and sheds maintained complete records as prescribed

in Form 3 throughout the review period 2009-12. Remaining 23 workshops

and sheds, however, maintained the records only partially.;

12 workshops and sheds submitted annual return in Form 4. Except DLW,

other PUs (ICF, RWF, and CLW) maintained records in Form 3 and submitted

annual return in Form 4.

Improper Disposal

quantity of waste oil generated was not assessed and the same was released

directly to the open ground;

Hazardous waste like condemned rubber gasket, brake blocks, cotton waste

soaked with grease and oil, oil filters etc. were disposed of by burning;

The procedure for disposal of hazardous waste was followed only in 10

workshops and sheds (seven per cent) across five Zonal Railways.

Recycling and Reuse of Hazardous Waste

In 11 Zonal Railways, 17 workshops tested samples in laboratory

to explore the possibility of reuse of lubricating oil drained

during maintenance schedule. The oil thus tested was reused in

10 workshops across seven Zonal Railw ays;

In all the four PUs, the waste oil and lubricating oil drained

during maintenance schedule was tested to explore possibility of

reuse.

38 workshops and sheds over 11 Zonal Railways and the

Production Units sold/auctioned the used batteries only to the

registered recyclers. In other workshops and sheds, used

batteries were either kept in open areas or sent to scrap yard for

auction.

Health and Safety

The periodical inspection by doctors was carried out only in 18

workshops and sheds (13 per cent) over eight Zonal Railways

and in one production unit at Rail Wheel Factory,Yelahanka

Monitoring of implementation of the recommended safety

measures was done in 17 workshops and sheds (12 per cent) over

seven Zonal Railways and in two production units (DLW and

RWF).

out of 123 workshops and sheds where health units were

attached, medical records of workers were maintained in the

health units attached to 25 workshops and sheds (20 per cent)

over seven Zonal Railways;

10,380 accidents occurred in 16 Zonal Railways during 2007-12.

Of them, 5339 accidents (53 per cent) occurred in 30 workshops

and sheds over three Zonal Railways (CR, ER and NR).

Recommendations IR needs to formulate a comprehensive environmental policy and frame

guidelines to check air and water pollution in workshops and sheds. IR

needs to enforce compliance with the existing statutory guidelines for

conservation of environment.

IR needs to take effective steps towards conservation of water and tapping

alternative sources of energy by installing wind power plants and solar

power plants. Effective steps also to be initiated for setting target for

adopting energy efficiency measures and conducting energy audits and

implementation of their recommendations.

A comprehensive waste management policy needs to be framed. Monitoring

for compliance with the laws and regulations for management of wastes

particularly the hazardous wastes needs to be strengthened.

IR needs to ensure inspections of workshops, sheds and production units by

officials of medical department as per prescribed frequency. IR also needs to

ensure availability and use of personal safety equipments by the workers.

Thanks