Overview of Consent for Operation (CFO) from SPCB

Consent for Operation (CFO –Air and Water), also known as Consent to Operate (CTO), is granted to industrial units before they can start operation. Under section 25/26 of the Water Act of 1974 and section 21 of the Air Act, of 1981, industries that have the potential to pollute the air and water) must apply for this Pollution No Objection Certificate at their concerned State Pollution Control Board (SPCB) or the Pollution Control Committee (PCC). The industry needs pre-operation NOC before it can start the intended operations. The Consent for Operation (CFO)is needed by green, orange and red category industries. Some State Pollution Control Boards also maintain a list of exempted categories (white category) of Industries that do not need consent and can function in any area in the respective state subject to site clearance by the local authority.

Once the industrial unit is established, along with the required pollution control equipment, the applicant must obtain consent to operate (CTO/CFO) for the unit. As this consent is given for a particular period, which must be renewed periodically, industrial units must ensure timely NOC renewal and adhere to the terms and post-compliances issued by the Board to the specific unit.

Consent for Operation (CFO)Approval Procedure

Once the unit is established along with the required pollution control systems, the entrepreneur must obtain consent to operate from the State Board before initiating the operational activities. The following are the stages in the consent management process.

Stage 1: Submission of Online Application and consent Fee through OCMMS

To simplify the Consent management and monitoring mechanism and promote the ease of doing business, states have adopted the Online Consent Management and Monitoring System (OCCMS) for receiving applications for fresh Consent to Establish (CTE) and Consent for Operation (CFO)as well as their renewal. Apart from the Pollution NOC, the authorisations needed by specific units handling plastic waste, electronic waste (E-waste), hazardous waste, biomedical waste, etc., require authorisation that the concerned SPCB/PCC also issues. Many states have adopted a Consolidated Consent and Authorisation (CC&A), which provides for a single-point application and clearance of the consent.

Stage 2: Application Scrutiny

The section Officer scrutinises the application and sends it to supervising Officer (Senior Scientific Officer / Scientific Officer / Environmental Engineer), who examines and makes recommendations if needed.

Stage 3: Site Inspection

The Board assigns anInspecting Officer who will visit the site after making a suitable appointment and inspect the complete facility in the owner's presence or a representative authorised by the owner. The officer is an expert and will make a recommendation and prepare an inspection report based on the findings and sample analysis of the trade effluent.

Stage 4: Issuance/ Rejection of Consent for Operation (CFO)

 Based on the recommendations of the inspecting officer and addressing all the concerns raised at the time of inspection, the Consent for Operation will be granted/rejected by Chairman / Member Secretary as per the delegation of powers in the concerned Pollution Control Board.

Inspection during Consent for Operation (CFO)

After the site construction is complete and the entrepreneur has successfully installed all required waste management and pollution abetment equipment as per the applicable standards, he will apply for CFO. The process can usually take 30 days. Therefore, the unit must make the application after considering this time. Apart from this, the unit must also ensure strict adherence to the applicable discharge standards of the pollutants in the trade discharge generated. The following limits must be ensured.

Air Emissions: Air pollution control devices must test emissions from chimneys, exhausts, and vents after exhaust treatment. The PPM concentration of the following pollutants must be regulated.

• PM10
• 5
• NOx

Wastewater Discharge: Effluent and Wastewater discharge must be tested and regulated. Various parameters must be met at the time of site inspection

• pH
• TSS
• TDS
• Oil & Grease
• BOD
• COD

Noise levels: The ambient and operating noise level at the facility must be tested and regulated as per the directions issued by the Board in the following circumstances

Noise Levels: Daytime (6 AM to 10 PM)

Nighttime(10 PM to 6 AM)

Approving Authority for Consent for Operation (CFO)

The approving authority for all green category units is the Environment Engineer, and the application is scrutinised at the regional office. However, the following table gives the list of approving authorities for different categories.

Document Required for Consent for Operation (CFO) under Air Act

Although consent is granted for air and water, the following sections separately outlay the document requirement in both cases.

Document Required for CFO under Air Act

• Index/Site Plan
• Topo Map
• Detailed layout plan of different processes and point sources of Emissions and position of Stacks and Chimneys.
• Process Flow Sheet
• Latest analysis report
• Details of Air Pollution Control devices provided or proposed
• Ambient Air Quality Report (If available)
• CFE Copy along with implementation for Specified Conditions
• List of raw materials with the quantity per month (MT/M)
• MSDS in the case of chemical industries

Document Required for Consent for Operation (CFO)under Water Act

• Details of Water Pollution Control devices provided or proposed
• Flow diagram of manufacturing process showing input and output in terms of products, and waste generated, including for captive power generation and demineralised water
• Map of the location of the site
• Site clearance from the local authority
• Break-up of water uses and water balance. (process consumption, domestic usage, canteen usage, gardening usage, Boiler usage, other uses).
• Boiler, Steam generating certificate indicating steam generation and consumption of coal tons per day duly certified by the office of the boiler inspector
• List of raw materials with the quantity per month (MT/M).
• Third-party analysis report of wastewater analysis, source sampling and ambient air quality analysis by NABL, MoEF accredited laboratory ( in case of consent renewal).

Validity of Consent for Operation (CFO) from SPCB

Consent to operate for the green category is awarded for a longer period as compared to the orange and red category industries. However. Every unit industry needs to renew the consent for operation well before the NOC expires. The following table denotes the validity period of different industries.