1

The concept note

For

Challenges against implementation of ZLD in textile processing

Industries and clusters in India

Prepared by

Industrial Pollution Prevention Group

Centre for Environment Education, Ahmedabad

April-2016
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Acknowledgement

I am thankful to SGTPA-Surat for entrusting CEE-Ahmedabad to examine the

facts about implementation of ZLD system in the textile industries and its clusters
in response to the draft notification issued by the Ministry of Environment, Forest
and Climate Change (MoEF &CC), the government of India.

I am also thankful to my subordinates Shri Nandankumar Project Officer and Shri

Parth Patel Project Officer in CEE –Ahmedabad for assisting me during
preparation of this note.

The concept note is prepared as per the discussion with the members of the
SGTPA on 14th March, 2016 and their requirements. The note includes the
important issues like SWOT analysis, the global scenario of ZLD, challenges
against ZLD, its alternatives and some suggestions as to where and why ZLD
shall be implemented. The note further includes the data/feedback pertaining
to field visits, photographs related to the visits, environmental issues of the textile
sector and the need and viability of ZLD.

J.K. Vyas

Head
Industrial Pollution Prevention,
Centre for Environment Education
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Contents

Sr No Chapters Page No

1 Background: Global and Indian scenario of 4

Textile processing industries

2 SWOT analysis 8

3 Environmental issues of textile industries 9

4 Effluent Treatment System 10

5 Implementation of ZLD in textile processing 14

in global and Indian Context

6 Policies regarding ZLD in textile processing 14

in India

7 Need and viability of ZLD in textile 14

processing in different textile Clusters in
India

8 Challenges against ZLD 15

9 Comparison of the cost between ZLD 19

and non ZLD

10 Alternatives to ZLD 19

11 Practical feedback- through site visits 20

12 Comments/suggestions 20

13 Photographs of the site visits 24

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1. Background
The Ministry of Environment Forest &Climate Change (MOEF&CC) has prepared
a draft for circulation to the textile industries to achieve Zero Liquid Discharge
(ZLD) if their waste water discharge is more than 25KLD and also to the clusters of
the textile sector regardless of their effluent discharge quantity. The ministry has
invited comments/suggestions in this regard from concerned stake holders. The
comments/suggestions are to be sent to the MS and DD CPCB New Delhi.

CEE -Ahmedabad is entrusted with the task of preparation of the concept note
in this regard by SGTPA-Surat and accordingly this note is prepared.

The history of textiles

The history of textile is almost as old as that of human civilization and as the time
moved on, the history of textile has further enriched itself. In the 6th and 7th
century BC, the oldest recorded indication of using fiber comes with the
invention of flax and wool fabric at the excavation of Swiss lake inhabitants. In
India the culture of silk was introduced in 400AD, while spinning of cotton traces
back to 3000 BC.

In China, the discovery and consequent development of sericulture and spin silk
methods got initiated at 2640 BC while in Egypt the art of spinning linen and
weaving developed in 3400 BC. The discovery of machines and their
widespread application in processing natural fibers was a direct outcome of the
industrial revolution of the 18th and 19th centuries. The discoveries of various
synthetic fibers like nylon created a wider market for textile products and
gradually led to the invention of new and improved sources of natural fiber. The
development of transportation and communication facilities facilitated the path
of transaction of localized skills and textile art among various countries.

The textile industry is one of the oldest and largest industrial sectors in India and
our country is the second largest producer of textile and garment next to China.
The textile units are scattered all over India. (Figure-1) The textile industry in India
constitutes one of the country’s major export sectors. India makes a major
contribution to world trade in cotton yarn, accounting for some 25% of the total.
Indian Textiles Industry has an overwhelming presence in the economic life of
the country. Apart from providing one of the basic necessities of life, the textile
industry also plays a pivotal role through its contribution to industrial output,
employment generation and export earnings of the country.
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This sector contributes about 14% to India’s industrial production, 4% to country’s

Gross Domestic Product (GDP), 27% to the country’s foreign exchange inflows
and 13% to the country’s export earnings. The textile sector, the second largest
provider of employment after agriculture; provides direct employment to over 45
million people.

Indian textile industry can be divided in to several segments some of which are
as under:

 Cotton: second largest cotton and cellulosic fibers producing country in

the world.

 Silk: INDIA is the second largest producer of silk and contributes world’s
18% raw silk production.

 Wool: INDIA has 3rd largest ship population in the world, having 6.15 crores
sheep, producing 45 million kg of raw wool, and accounting for 3.1% of
the total world wool production, INDIA’S rank 6th amongst clean wool
producer countries and 9th amongst greasy wool producers.

 Man-made fibers: the fourth largest in synthetic fibers/yarn globally.

 Jute: INDIA is the largest producer and second largest exporter of the jute
goods.
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Figure 1: The map showing locations of textile industries in India

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Table 1: India’s Competitiveness with Other Country

Key countries / regions Key positives Key negatives

China Efficient, low cost, Growth at the cost of

vertically integrated profits

India, Pakistan Vertically integrated, low Lacks economies of scale

cost and infrastructure
support

Mexico (NAFTA), Turkey Proximity to market, duty Lack China and India’s
and quota free degree of
competitiveness

ASEAN (Vietnam, Cheap labor No other cost or

Cambodia, Indonesia) locational advantage

AGOA (African) Quota and tariff free, Lacks integration and

countries, Bangladesh cheap labor China and India’s
degree of
competitiveness

Hong Kong, Korea, Trading hubs proximity to No cost advantage,

Taiwan China protected currently by
quotas

USA and EU Non-quota barriers likely to US$ 400 bn trade loss

prove irritant to imports likely

Source - Industry, I-SEC Research

The contents in the table show that there is no doubt about India’s competitiveness. The country
will become even more competitive once its infrastructure issues are sorted out. China has
probably already reached its peak and further improvements may not be as dramatic.

Figure 2: The world market share

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2. SWOT Analysis of textile sector

HELPFUL HARMFUL
(for your objective) (for your objective)
Strengths Weakness
 Tradition in Textiles and long operating  The textile industry of India is one of
experience the highly disintegrated industries.
 Large and growing domestic market  Few segments of this industry are
 Strong raw material base not highly productive.
 Production across entire textile value  There is a huge dependency of the
chain industry on cotton.
 Stable, low-risk economy, safe for  The mill segment is gradually
(Within Organization)

business growth declining.

 Easy availability of abundant raw
Internal

 Labor laws are not very favorable.

materials like cotton, wool, silk, jute
 The power and interest rates, and
 Widely prevalent social customs
indirect taxes are high.
 Variety of distinct local culture
 Constructive geographic and climatic  Inadequacy of technological
development which in turn is
conditions
responsible for affecting the
productivity.
 The act of generating economies of
scale lacks.
Opportunities Threats
 The textile industry records an annual  Competing with other progressing
growth of around 6-8%. countries like China.
 A shift towards the market of branded  Striking a balance between the
ready-made garment is being observed. quality and price of products.
 More number of emerging malls and retail  Satisfying the demands of people
industries are providing opportunities to all across the globe and at the
(Outside Organization)

industry’s segments like handicrafts and same time, steadily improving the
apparels. quality of the products.
External

 There is a provision of more FDI and  Striking a balance between

investment opportunities. demand and supply.
 Withdrawal of quota restriction is  Environmental and international
contributing immensely in market labor laws.
development.  Removal of quota system will
 The global needs are being catered with fluctuate the export demand.
product development.
 An upsurge in the purchasing power and
disposable income of Indian customers
has opened room for new market
development.
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3. Environmental issues of textile industries

The textile industry is water and labor intensive and produces pollutants of
different forms. The manufacturing operation also generates vapors during
dyeing, printing and curing of dye or color pigments. Dust emission is associated
with fiber processing/boiler operation. Other than these process operations,
textile mills have wood, coal or oil fired boilers and thermic fluid heaters which
are point emission sources.
Major environmental issues in textile industry result from wet processing. Wet
processes may be carried out on yarn or fabric. The transformation of raw
cotton to final usable form involves different stages. The various important wet
processes involved in the textile industry are as follows:
 Sizing / Slashing: This process involves sizing of yarn with starch or polyvinyl
alcohol (PVA) or carboxyl methyl cellulose (CMC) to give necessary tensile
strength and smoothness required for weaving. The water required for sizing
varies from 0.5 to 8.2 litre / kg of yarn with an average of 4.35litre / kg.
 Desizing: The sizing components which are rendered water soluble during
sizing are removed from the cloth to make it suitable for dyeing and further
processing. This can be done either through acid (sulphuric acid) or with
enzymes. The required water at this stage varies from 2.5 to 21 L /Kg. with an
average of 11.75 L/Kg.
 Scouring / Kiering: This process involves removal of natural impurities such
as greases, waxes, fats and other impurities. The desized cloth is subjected to
scouring. This can be done either through conventional method (kier boiling) or
through modern techniques (continuous scour). Kiering liquor is an alkaline
solution containing caustic soda, soda ash, sodium silicate and sodium peroxide
with small amount of detergent. The water required for this process varies from
20 – 45 L/ Kg. with an average of 32.5 L/Kg.
 Bleaching: Bleaching removes the natural coloring materials and renders
the cloths white. More often the bleaching agent used is alkaline hydrochloride
or chlorine. For bleaching the good quality fibre, normally peroxide is used. The
chemicals used in peroxide bleaching are sodium peroxide, caustic soda,
sulphuric acid and certain soluble oils. The water and chemical requirement and
the effluent generation normally vary based on the type of operation and the
material (yarn / cloth) to be processed. Bleaching the yarn both through
hypo‐chloride and hydrogen peroxide methods require same quantity of water
and it varies between 24 to 32 L/kg. But in the cloth bleaching, the water
requirement is much higher and it fluctuates between 40 ‐ 48 L/kg.
 Mercerizing: The process of Mercerization provides lustre, strength, dye
affinity and abrasion resistance to fabrics. It is generally carried out for cotton
fabrics only for easy dyeing. Mercerization can be carried out through cold
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caustic soda solution followed by washing with water several times. The water
required for this process varies from 17 to 32 L / kg, with an average of 24.5

 Dyeing: Dyeing is the most complex step in wet processing which provides
attractive color for the product. Dyeing is carried out either at the fiber stage, or
as yarn or as fabrics. For dyeing process, hundreds of dyes and auxiliary
chemicals are used. In brief, the water requirement for dyeing purpose (include
all types and shades) varies from 36 – 176 L/kg with an average of 106. The
effluent generation during dyeing process fluctuates from 35 to 175 L/kg with an
average of 105 L/kg.

Table 2: The characteristics of the textile wastes after the various processes

Processes pH Total BOD mg/L

Suspended
solids mg/L
Sizing / Slashing 7.0 – 9.5 8500 –22500 620 – 2500
Desizing 6–8 16000 –32000 1700 – 5200
Scouring / Kiering10 –13 2200 –17400 100 – 2900
Bleaching 6 6500‐22000 ‐
Mercerizing 12 ‐13 430 –2700 150 – 280
Dyeing 10.5 10200 400 - 700

4. Effluent Treatment System of textile units/CETPs

As in the case of other countries, textile industries in India are also highly water
polluting, besides causing air pollution. Major air pollution sources are the boilers
and thermic fluid heaters. The liquid effluent characteristic and effluent quantity
vary according to the processes involved, chemicals used and the scale of
operation. Therefore, very often the quality of effluent from one industry varies
from the other similar industry.
As the textile manufacturing units use different type of raw materials, chemicals
and processes, the wastewater treatment may require the use of unit operations
specific to manufacturing processes in use. Techniques for treating industrial
process waste water in this sector are - source segregation and pre-treatment of
waste water streams.
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The major treatment processes can be summarized as follows:

 Precipitation, coagulation and flocculation (Primary treatment)
 Biological oxidation (Secondary Treatment)
 Membrane filtration
 Reverse osmosis
 Adsorption by activated carbon
 Advanced chemical oxidation

The above treatment processes are briefly discussed below:

Primary and Secondary Treatment

The conventional treatment systems like Physico-chemical treatment or Physico-
chemical treatment followed by biological treatment system are installed in
majority of textile industries. The first step in the wastewater treatment is to mix
and equalize the waste water streams that are discharged at different time, and
different intervals from different stages in the processes. Some industries also
prefer screening, oil trap prior to equalization for removal of solids and oil and
grease. Equalization ensures that the effluent have uniform characteristics in
terms of pollution load, pH and temperature. The effluent is then subject to flash
mixing for the addition of coagulants such as lime, alum, ferrous sulphate, ferric
chloride, poly-electrolyte and processed through clari-flocculator or flocculator
and settling tank. Selection of appropriate coagulants and doses of chemicals is
determined on the basis of treatability study of effluent samples. The chemical
treatment helps in reduction of color and suspended solids. A significant
reduction in BOD and COD values is also observed. This Physico-chemical
treatment is followed by biological treatment process which further reduces
BOD and COD values. The textile process houses which undertake chemical
processing do not have much organic load in their effluents. In such cases, the
recent trend is to set up an activated adsorption system or an Ozonation unit
instead of biological treatment.

Tertiary Treatment
Textile effluents may require tertiary or advance treatment methods to remove
particular contaminants, dissolved salts or to prepare the treated effluent for
reuse. Some common tertiary operations are removal of residual organic color
compounds by adsorption and removal of dissolved solids by membrane
filtration. Sometimes the wastewater is also treated with ozone or other oxidizing
agent to destroy many contaminants. Evaporation and crystallization are other
methods to minimize effluent disposal problems.
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Advance methods for tertiary treatment

Adsorption
The adsorption process is used to remove color and other soluble organic
pollutants from effluent. The process also removes toxic chemicals such as
pesticides, phenols, cyanides and organic dyes that cannot be treated by
conventional treatment methods. Dissolved organics are adsorbed on surface
as waste water containing these is made to pass through adsorbent. Most
commonly used adsorbent for treatment is activated carbon.
The activated carbon once it is saturated needs replacement or regeneration.
The chemical regeneration can be done within the column either with acid or
other oxidizing chemicals.

Ion Exchange
Ion exchange process is normally used for the removal of inorganic salts and
some specific organic anionic components such as phenol. In the ion exchange
process the impurities from the effluent streams is transformed into another one
of relatively more concentrated with increased quantity of impurities because of
the addition of regeneration chemicals.

Reverse Osmosis
After primary, secondary and/or tertiary treatment, further purification by
removal of organics and dissolved salts is possible by use of reverse osmosis. The
process of reverse osmosis is based on the ability of certain specific polymeric
membranes, usually cellulose acetate or nylon to pass pure water at fairly high
rates and to reject salts. To achieve this, Water or waste water stream is passed
at high pressures through the membrane. The applied pressure has to be high
enough to overcome the osmotic pressure of the stream, and to provide a
pressure driving force for water to flow from the reject compartment through the
membrane into the clear water compartment.
RO membranes are susceptible to fouling due to organics, colloids and
microorganism. In a typical reverse osmosis system, the feed water is pumped
through a pre-treatment section which removes suspended solids and if
necessary, ions such as iron and magnesium which may foul the system. The
feed water is then passed through the reverse osmosis modules at high pressure.
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Table 3: Performance of Treatment System for Wash Water Parameter

RO Stage
Primary RO Stage I
Influe Ozonati II
Parameters Treatme
nt on Perm Rejec Permeat
nt Reject
eate t e
pH 9.88 9.61 6.92 6.03 6.72 5.76 7.04
Total suspended
167 56 19 6 70 6 124
solids, mg/L
Total dissolved
3104 1946 3256 922 9830 196 17828
solids, mg/L
Chemical
oxygen 586 166 130 26 327 17 754
demand, mg/L
Biochemical
oxygen 190 41 41 1 16 02 208
demand, mg/L
Total Hardness,
96 ‐ ‐ ‐ 60 Nil 1080
mg/L
Chlorides, mg/L 334 636 692 314 108 34 4416
Colourle Colo Colourle
Color, % purity <10 <10 <10 10‐20
ss urless ss
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5. Implementation of ZLD in textile processing in global and Indian Context

So far as textile sector is concerned, Pakistan, Bangladesh, Vietnam and China

are the biggest competitors of India. It is gathered that globally these countries
are yet to implement ZLD so far. Though Bangladesh has expressed its willingness
to implement the system for the textile industries in their country primarily for the
purpose of water conversation and to reduce water pollution in rivers, streams
etc.

6. Polices regarding ZLD in textile processing in India:

In view of the indiscriminate use of the water, its insufficiency, its conservation
and the issues related to the waste water disposal and the pollution of the
natural streams/rivers; the government is intending to issue a notification under
the E.P.A. -86 for implementation of ZLD in textile units having its effluent
discharge more than 25 m3 /day and also for all textile units in clusters
irrespective of their waste water discharge. The draft notification is issued in this
context by MoEF&CC. In Chennai the judiciary has directed the CETPs of the
textiles to go for ZLD in 2009 and then to the textile units in 2011.

7. Need and viability of ZLD in textile processing in different textile Clusters in

India

The industries i.e. textiles in different parts of the our country have adopted the
concept of ZLD strictly according to their requirements e.g. the units in Tirupur in
Chennai have installed ZLD system in order to comply with the directions of the
Hon’ble court.
In Rajasthan the industries opted for ZLD because of the directions from the
court, scarcity of water, its requirement for conservation.
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8. Challenges against ZLD

 In his response to the draft notification by the Ministry of Environment,

Forest and Climate Change, Textiles Secretary, S. K. Panda, has said the
proposed standards — mandating ‘Zero Liquid Discharge’ (ZLD) for textile
processing units where waste water discharge is over 25 kilo liters a day —
will be “too stringent” for the domestic textile processing industry that is
largely unorganized and comprising of SMEs, according to reliable
sources.
 Power usage due to the implementation of ZLD has shot up as a result of
the treatment plants — 50 per cent of power used by industry goes into
these plants alone. As a result, the industry as a whole, has become less
competitive due to a forced additional 4 per cent hike in the final
garment price, which is a huge loss to the consumers.
 ZLD results in generation of the huge amount of hazardous solid wastes
(particularly waste mixed salt) causing disposal challenges, which is being
stored in storage yards within the CETPs. ZLD is generating thousands of
tons of sludge as solid waste. This sludge has to be disposed of in a
Secured Land Fill (SLF). The un-recovered Common Salt or Glauber’s salt
and the contaminants are sent to solar evaporation ponds for natural
evaporation or sent to final Forced Circulation Multiple Evaporators for
converting into Solid Waste. If we assume that all the dyeing factories
totally use about 600 tons of salt daily, then the rejected salt will be about
100-150 tons every day. Imagine this for a whole year and for several
years. We do not know what we are going to do with this future. It is a
sleeping monster. In future this solid waste management will be another
tough task. May be we will have to use incineration to burn them with
modern machinery fitted air pollution control equipment. Still we may end
up with salt.
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 The major challenges faced were related to corrosion of metal, scaling

and choking in tubes and necessity of skilled manpower to operate the
plant.
 For the chemical sludge, the best way to dispose it off is its gainful
utilization for cement coprocessing but it needs tie up with a
willing/recipient cement company
 The recovery of water and salt (Sodium sulphate and brine) offsets this
costs significantly, but it would apply only to water scarce areas where
the cost of water is high.
 High Carbon foot print of a ZLD facility is another major concern. The
typical power consumption ranges from 8 to 10 kW/m3. The thermal
evaporators alone consume about 20-40 Kw/m3 in addition to several
tons of firewood for the boilers.
 Implementation of ZLD requires a host of advanced wastewater
treatment technologies. Implementation of ZLD in Tamilnadu has
highlighted several Technology shortcomings such as in Thermal
evaporation & brine concentration, Salt separation and Crystallization,
Color removal etc.
 ZLD requires use of higher amount of chemicals in wastewater treatment
 ZLD Increases the energy usage tremendously.
 Impact on cost of processing (implementing ZLD pushes up costs of
production by 25-30%)
 ZLD is an ‘end-of-pipe’ concept to mitigate the impact of wastewater
pollution on the environment and human health
 ZLD has very High CAPAX.
 It will be necessary to stop production if there is a breakdown in the Zero
Discharge Plant which is a great loss.
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 The ultrafiltration is a requisite before RO to minimize the damage to RO

membrane which increases the cost of initial investment as well as the
cost of treatment drastically
 Maintenance and operation cost of RO (ZLD) is very high
 The problems of Corrosion/leakages are encountered while using ms
pipes which is required to be replaced by HDPE pipe which increases the
cost and more so in the case of ZLD.
 The use of PAC to reduce the color content of the effluent requires the
handling of powdered carbon leading to the issues of carbon dust
emission (air pollution) in the plant
 MEE operation consumes more power and (thus more carbon footprint).It
also generates salts which create problems of handling and disposal
 The entire ZLD system is highly sophisticated and needs skilled and
experienced man power for its efficient operation which again increases
the overall cost of treatment, operation as well as maintenance.
 The Zero Liquid Effluent Discharge is a very tough task. The plant must be
designed very lavishly. All the tanks, pipe-lines, pumps, equipment,
machinery, RO membranes, Multiple Evaporators should be designed for
at least 20 – 30 % more than the requirement. During back washing, sand
filters, carbon filters & Ultra Filtration generates contaminated wash water
of about 20% of effluent feed. This is sent back to effluent collection tank
and hence the plant needs higher design capacity by 20 – 30
%. Automation & Instrumentation is a must to safeguard the plant. A good
laboratory is a must. All the critical equipment must have stand by ones.
 Biological plant needs continuous monitoring. Any mistake may stop the
entire plant for several days. RO Plant needs maximum protection. Any
small mistake will easily damage all the Membranes and it will cost several
Lakhs of Rupees. Multiple Evaporators will easily get scaling & choking. For
this it will be necessary to select a combination with costly Forced
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Circulation Multiple Evaporators instead of simple Falling Film Multiple

Evaporators.
 Most of the textile units in India are small scale & medium scale with land
area below 10000 sq. yard. Putting up new ZLD compatible plant will
require as much more land which is very costly & not available with the
industries into their premises or in the adjoining area so the commercial
viability will not be there.
 A ZLD plant is combination of RO & evaporator, a typical process house
would be consuming 200 to 1500 m3 water daily, to treat such quantum of
water & evaporate the same will require huge amount of electricity
ranging from 3000 to 15000 kW per day. To produce such amount of
electricity lot of fossil fuel, natural gas or enriched uranium is required and
subsequently to control water pollution we will contributing equally for air
pollution.
 The cost of ZLD will escalate to such level that production will not be
globally competitive and it will add more troubles to the already depleted
export market of the Textile sector.
 The figure for consumption of the water in Textile sector in the country is
just @ 2% of the total water consumption.
 The cost of ZLD plant was estimated as follows
Capital cost - Rs.18 crores per MLD + Land cost (varies in different
Areas) + Cost of disposal of solid waste
Land - 1.5 acre per MLD + the cost of finance
Operating Cost - Rs.225 per m3 + Depreciation
 90-95 % water can be recovered from the effluent, but cost of fresh water
varies from area to area. For e.g. in UP it is free, Ichalkaranji it is Rs 17/m3
whereas in Tirupur it is Rs 75/m3.
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Table 4: Recovery & Loss in Zero Liquid Effluent Discharge

Item % Recovery for Reuse % Loss

Water 75 – 80 % 20 – 25 %
Common Salt 35 – 50 % 50 – 65 %
Glauber’s Salt 75 – 80 % 20 – 25 %

9. Comparison of the cost between ZLD and non ZLD

 The operating cost ZLD is @ Rs 200-250 Rs/KL in Tirupur

 The cost of non ZLD is @ Rs 15-30 /KL for primary and secondary treatment.
 Providing appropriate pretreatment for increasing the membrane life.
 Maximize renovated water recovery (permeate)
 Recovery of salt for reuse
 Minimize the quantity of rejects and minimize the O&M of reject
 management

10. Alternatives to Zero Liquid Effluent Discharge

Sea Discharge

The state of Gujarat is blessed with the largest coastline in the country and so
the treated effluent from CETPs can be safely discharged in to the sea. Sea
discharge is a better alternative against ZLD. In sea discharge we have two
methods. One is to treat the mixed effluent with primary, secondary and tertiary
treatments and dispose into the sea. Here all the water and salt are lost in to the
sea.

Another method is to treat with the above methods and recover water for reuse
by RO Treatment. Then send the final reject to sea discharge. Here we recover
about 85% of the water for reuse and avoid only the Multiple Evaporator losing
the salt. But the reject from RO Plant will have more contaminants more than the
sea Discharge Norms. Hence the RO reject cannot be easily discharged into the
sea. Therefore only the fully treated water (Primary, Secondary &Tertiary) can be
discharged into the sea. But for this we have to carry-out a large scale
Environment Impact Assessment study through the renowned institutes like NIO
or NIOT. This may take some time.
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Inland Surface Water Discharge

We have already seen that since the mixed effluent has a TDS of about 4,000-
6,000 ppm, we cannot discharge into inland surface water. There is one
possibility of mixing 1 – 2 times normal raw water with the treated effluent till the
TDS reaches less than 2,100 ppm and then discharge. This is to be done with
special permission from the Government. Even this is possible only after doing
primary, secondary and tertiary effluent treatment. If you assume a total effluent
generation from Tirupur Dyeing factories to be around 10 crore litres per day,
then we need another 10 – 20 crore litres of normal water per day to be mixed
with it. This will be against the principle of worldwide philosophy of “Water
Conservation”.

11. Practical feedback through site visits:

In order to know the response of the industries/clusters actually implementing

the ZLD system in their units, the field visits were carried out in the state of Gujarat
at Rakanpur-Ahmedabad, Kutch and also at Tirupur-Chennai. Their
views/opinion are incorporated in the chapters of challenges against ZLD and
also comments/suggestions.

12. Comments/Suggestions:

 The concept of establishment of ZLD is good but it cannot be generalized

and implemented hastily and uniformly over the entire country as it is very
sophisticated, expensive, requires skilled manpower, consumes more
power and emits more carbon leading to global warming. Further it also
requires high operation and maintenance price for its execution and
running.

 Each state has its own uniqueness about its eco system and the
environment, therefore in all such states where sea disposal facility is
available, the system of disposal of treated effluent it may be allowed as
while disposing treated effluent in to the sea, huge dilution is available
and the impact on the marine eco system will be minimum.
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 There are safe locations in the country especially in the state of Gujarat and
such other coastal states; where scientific disposal of the effluent in to the
sea is feasible and is at present being practiced very successfully. This mode
of disposal is practical, safe, cost effective and also environmentally
acceptable as it consumes less power compared to ZLD and has less carbon
foot print. Accordingly the option must be given to such states (SPCBs/PCCs)
to direct concerned textile industries/clusters to treat their effluent as per
marine norms and discharge at a point in to the sea to be decided by the
expert marine agency.

 Imposing ZLD in the states where marine disposal is available will put
unnecessary huge financial burden and mental stress on industries/clusters
and there are all chances of closing down of the units/clusters leading to
huge unemployment and all other related nuisances.

 ZLD is an innocuous and worthy solution at such places/states where fresh

water availability is limited and no other safe disposal facility like marine
disposal is available.

Capital cost - Rs 2.5 crores per MLD + Land cost

 Operating cost - Rs 15 per m3

 It is emphasized that the need for ZLD has to be considered on a case to

case basis, instead of implementing the same across the country due to
different geographical conditions and requirements.
 It is agreed that in areas where there is a shortage of surface water, the
underground water strata is depleting and no other economical water
sources are available, the ZLD may be insisted upon.

 There are states/places where there is abundant availability of huge

quantity of fresh surface water i.e. rain water collected in lakes/dams
which would otherwise flow into the sea, does not require any ground
water abstraction.

 The option of disposal of treated effluent in to the sea is a safe and cost
effective alternative to ZLD.
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 The Member Secretary of a SPCB opined that ZLD should be tried in highly
polluting industries rather than textiles. Textile effluent is easily treatable to
achieve consented norms. In places of water scarcity, Treated Domestic
Sewage can be supplied to Industries, as being done in the cities of Surat
and Ahmedabad.

 The ZLD plant consumes huge power and fuel leading to pollution of the
environment. Implementation of ZLD will require an investment of Rupees
One Lakh Eight Thousand Crores (6000MLD @ 18cr/MLD) in addition to
land for setting up the plants. In many existing industries and textile clusters
established by State Governments, availability of required land is a
constraint. Cost of acquiring land, wherever available is also variable. The
huge capital and operating expenses of the ZLD plants will render the
entire textile industry unviable, resulting in collapse of the whole chain. It is
important to note that the Textile Industry of India is the second largest
employment generating industry only after agriculture. Unskilled labour is
easily absorbed in this industry. The textile industry commands a high
position in the economy of the country and earns valuable foreign
exchange.

 The Government has come up with revised Textile Upgradation Fund (TUF)
scheme to give capital subsidy to the new units and also to the existing
ones which want to bring modern machinery and increase output. The
approval to 24 Textile Parks in last one year and others are also given
earlier. Total would be 74 Textile Parks under which Rs.30000 crore
investment is expected, ZLD would be a big obstacle to attract
investments and the entire system would be out of the gear and will
critically affect the overall economy of our country.

 Textile processing sector is facing many challenges like increase in raw

materials cost, hike in equipment price, labour cost, lower productivity,
easy availability of skilled/unskilled labor, scale of economy, cut throat
competition amongst producers within and outside the country and many
others. All these issues are ultimately converting in to higher production
cost and making it difficult for textile industries to have leverage over the
other competitors and survive. Forced implementation of ZLD will make
matter worse and prove deadly to SMEs in textile sector. Countries like
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China, Philippines, Malaysia, Thailand, Korea, Brazil, Indonesia,

Bangladesh, and Myanmar etc. are posing a big threat to Indian textile
sector with enhanced global competition on commercial ground.
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13. Photographs of site visits:

A. Meeting at SGTPA Surat:

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B. Site Visits and consultation:

Different units of ZLD

Sand filters
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Reverse Osmosis Units involving high cost

Pumps, Blower and pipeline network showing highly power extensive process of ZLD
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Mechanical Vapor Recompressor (MVR)

Multiple Effect Evaporator (MEE) high power consumption and

maintenance
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Aeration Tank