f the treated water looks dark brown, or stinks, the STP owner knows that the STP has

some trouble. But even if the treated water looks clear and odour-free, it may still not
meet specifications; and the owner may not be even aware that his STP has a
problem. And the truth is, there are many such defective STPs running in Bengaluru,
about which the owners may not be aware.

This article explains why we have so many faulty STPs, and what needs to be done to
change this.

But why should apartments have STPs at all?

Many of us may think that running STPs is a specialized job; so why should we attempt
to run an STP in our apartment complex in the first place? Why can’t the Bengaluru
Water Supply and Sewerage Board (BWSSB) operate STPs as a public service?

Well, there is a sound reason for that: using a local STP allows us to recycle nearly half
of our total daily water usage. This brings down our freshwater demand by 50%. Then
BWSSB will be able to distribute the same quantity of Kaveri water to double the
population!

STPs should be regulated

Since 2005, the number of privately-owned STPs has been growing fast in the city. But
in an unregulated market, a lot of substandard STPs were sold. These STPs have
design and fabrication flaws, and cannot treat sewage even if they are run by the best
operators. Even if the STPs are good, most of the operators in the market are
unqualified, which again means they cannot treat the sewage properly.

Hence the solution is to regulate the design, fabrication, operation and maintenance of
STPs. Section 17 of the Water (Prevention & Control of Pollution) Act, 1974 lays down
several measures to regulate these aspects. These responsibilities are assigned to
KSPCB. These responsibilities include inspection and approval of new STPs, training of
operators, spreading awareness among the public, etc.

Unfortunately, the Water Act remains mostly unimplemented even today. As a result,
these areas have remained weak, and need reforms.

First, we will see what reforms are needed in the STP-approval process, and then,
reforms needed in other areas.

1. Reforms needed in the STP-approval process

The STP-approval process has two stages – CFE and CFO:

 1. In the first stage, KSPCB checks the design of the STP, and if the design is
acceptable, issues CFE (Consent For Establishment) to the developer. This
permits the developer to construct the STP as per the submitted plan.
2. The developer constructs the STP and then applies for the second approval,
called CFO (Consent For Operation). Here, KSPCB checks if the STP is built
correctly (as per the approved CFE) and is defect-free. If the STP passes the
checks, KSPCB issues a CFO.

The developer can operationalise the STP only if they have the CFO.

Subsequently, throughout the life of the STP, KSPCB conducts annual inspections to
check for ageing-related problems and tampering. When the STP passes each
inspection, KSPCB extends the CFO by another year.

This process may seem perfect, but isn’t. At present, the CFE-CFO procedure is not
formally documented. KSPCB does not use data collection forms to ensure that the
process is executed consistently for all STPs. Most importantly, the developer simply
abandons the STP, and quietly slips it over to the RWA without its explicit acceptance.
Due to such factors, multiple defects remain in the STP, and apartment owners end up
spending their hard-earned money to rectify these.

The following diagram shows the current practices for STP construction and approval
on a timeline. (Click to see full-size image):

And the diagram below shows the timeline for the desired/ideal workflow.
Note:

 The timeline is not accurate; the gaps are only indicative.

 The part above the timeline shows the actions taken by the developer or the
RWA (Residents Welfare Association).
 The part below the timeline shows the actions taken by the authorities
(KSPCB/BBMP).

In all, the revised workflow has eight additional steps; and one step (CFO) is split into
two separate steps (PCFO+FCFO).

The following table explains each event shown on the timeline. The table highlights the
additional steps to be taken as per the desired/ideal workflow in pale green; and the
step to be removed is highlighted in pink. The additional steps are also mentioned
in bold letters.

EVENT BY REMARKS
 Declare the number of
apartments and
quantity of sewage
 Select an STP type
(Several STP types are
available, but some
types are not
approved)
 Finish the engineering
calculations and
Design STP Developer drawings

Apply to KSPCB, and submit

Apply for CFE Developer the details mentioned above
Verify the STP design1 KSPCB  Verify STP type
(whether approved)
  Verify calculations
 Verify engineering
drawings where
required;
 Check feasibility
 Check ergonomics
and safety of the
design

 Rectify all problems

pointed out by KSPCB,
and re-offer.
 Repeat the cycle until
all problems are sorted
Rectify problems Developer out.

All the calculations, plans

and engineering drawings
are treated as frozen at this
point, and the developer is
expected to construct the
STP strictly in compliance
Issue CFE KSPCB with those documents.
The constructed STP must
comply with the calculations
and drawings approved as
Construct the STP Developer per the CFE.
Apply for CFO Developer
At this stage, the STP is
completely dry, as there are
no occupants in the building.
Without sewage, the KSPCB
inspector cannot check
how various stages of the
STP function. Therefore the
Inspect STP inspection is limited to
(but not the effluent) KSPCB physical checks.
Attend to all problems
detected by KSPCB. Repeat
the cycle till all problems are
Rectify problems Developer resolved.
Issue CFO KSPCB KSPCB issues full clearance
 to operate the STP although
the inspector was not able to
check its functioning.

This is because, unless the

CFO is given, the building
cannot get OC (Occupancy
Certificate). And without OC,
the buyers cannot move in.
Without residents, the
complex cannot generate
sewage. Without an
adequate quantity of
sewage, the STP cannot
operate.

Hence KSPCB has to issue

a CFO prematurely to break
this logjam.
KSPCB issues a Provisional
CFO. PCFO is issued with
Issue PCFO Terms Of Reference
(Provisional CFO) KSPCB (preconditions to be met)2.
Finish the construction of
other plants and machinery;
clubhouse, common
Finish the construction Developer facilities, etc.
Submit Completion
Certificate to BBMP, and
apply for OC.

This signifies that:

 The construction is
completed (including
common areas)3
 The construction
complies with the
Apply for OC Developer sanctioned plans

Issued only after verification

Issue OC BBMP of facts and full compliance.
Transfer the property Developer  Execute Sale Deed
 for all apartments with
clients
 Hand over the
common areas to the
Managing Committee
(MC)

The apartment owners start

arriving one-by-one. They
generate sewage. Initially,
the quantity is so small that
the STP cannot treat it.
Therefore the developer
Sewage starts keeps the STP off4.
As more owners arrive, the
sewage quantity increases
gradually. But the STP
cannot be started until a
certain minimum quantity (as
Sewage builds up per design) is available.
The STP can be started only
when it gets sufficient
sewage on a daily basis.
Thus the STP start date
would be delayed by several
weeks.

An STP needs several days

to stabilise. The designer
must keep a close watch to
ensure that the STP
functions consistently,
without intermittent failures.
If there are any issues
related to operations,
ergonomics or safety, rectify
Start STP operation Developer those.
Inspect STP KSPCB KSPCB is invited to inspect
Test the effluent the STP when it’s operating
with almost rated load (the
final quantity for which the
STP is designed). KSPCB
inspector is also required to
test the treated sewage.
 In the ideal workflow, the
KSPCB inspector is required
to actively look for
operational flaws in the
working STP and to report
these.
Attend to the issues pointed
out by the KSPCB inspector.

Note that the STP is rectified

at the developer’s cost. (This
cost must not be passed on
Rectify problems Developer to the buyers.).
Repeat the “inspect STP and
Inspect the STP, test treated sewage” cycle,
test the effluent KSPCB till there are no issues at all.
The KSPCB inspector
actively looks for operational
flaws. The FCFO is issued
only after the STP is able to
pass two consecutive
inspections without any
problems. (If the system is
Issue FCFO5 unstable, it cannot be given
(Final CFO) KSPCB FCFO.)
The developer must continue
to operate the STP for a
minimum of two years. There
will be annual CFOs during
this period also (not shown in
timeline).

This system makes sure that

Operate STP for a minimum statutory
period
Conduct third-party audit
any residual problems in the
STP are detected during the
inspections, and they are
rectified at the developer’s
Developer cost.
Developer The third-party auditor is
typically selected by the
RWA, which means the
developer cannot manipulate
 the results. This gives
confidence to the RWA that
all the issues related to
design, engineering,
construction, operation,
ergonomics and safety would
be detected.
Attend to all comments given
Rectify problems Developer by the auditor.
The MC accepts that
henceforth it will take over
complete responsibility of the
STP. This includes attending
to any issues that come up in
Get MC’s concurrence Developer future.
KSPCB makes a change in
its database to show that the
Transfer STP to RWA KSPCB MC has taken over the STP.
Annually, KSPCB inspects
the STP to ensure that:
 There are no ageing-
related problems (e.g.
corrosion, wear out)
 The STP is not
tampered with
 The STP does not
exceed the approved
quality and quantity of
Annual CFOs KSPCB sewage

Attend to all the problems

pointed out by KSPCB and
MC get the CFO extended by a
Rectify the problems (RWA) year.

2. Reforms needed in other areas:

If the CFE-CFO process is revamped, the RWA will get defect-free STPs. But is that
enough?

For a moment, compare an STP with your car. How do you keep your car in the best
condition? You begin by buying the best-possible car, and then take care of three
human factors:
 1. Even the best car can be ruined by a reckless driver. So you must have a careful
driver for your car.
2. As the owner, you must be fairly conversant with its well-being. At the first sight
of trouble, you must take it to service.
3. You must use a qualified service. Cutting corners means ruining the car.

Exactly the same factors work for STPs. We need STPs that are designed and
fabricated well. In addition, we need good operators, knowledgeable owners and good
maintenance service. But in the case of STPs, none of these factors are guaranteed
currently!

1. Good STP designers:

KSPCB has failed to develop a support system for the rapidly-growing number of
private STPs. There is no system to ensure that only well-qualified STP designers
are allowed to design and construct STPs. Worse, if your STP designer has
neglected safety and ergonomics, you may be held liable for any accident inside
the plant.
2. Good STP operators:
KSPCB has not set up an education/training system to produce well-trained STP
operators. So, even if you have a well-designed STP, if it is operated by an
untrained person, your STP may not produce good results consistently.
3. Knowledgeable owners:
Yes, you have an important role to play. But how knowledgeable are you as an
STP owner? Worry not, we have published an STP Guide, which is downloadable
from the KSPCB website. This comprehensive book covers the design,
construction, operation, maintenance and troubleshooting of STPs. KSPCB should
also arrange regular public training programmes on STPs for RWA members.
4. Good service:
STPs need regular maintenance service and occasional breakdown service. This
calls for qualified service providers. In addition, we need the services of tank
cleaners who can handle raw sewage and sludge. An unqualified contractor can
only ruin an STP. However, KSPCB does not maintain a list of approved vendors.

2. Typical conditions are:

(a) Do not take external sewage for treatment in the STP;
(b) If either the quantity or quality of sewage changes, the proponent must seek a fresh
CFO.

3. The STP is part of common areas. Other examples of common areas are clubhouse,
swimming pool, water treatment plant, fire hydrant system etc.

4. Ideally, the raw sewage has to be transported to the designated BWSSB STP, but
that is too expensive. So the developer simply dumps the raw sewage in a UGD line or
even SWD, thus polluting it.
5. The current workflow does not have this step at all – once the STP gets CFO, it’s in
the clear, and no one actively searches for operational faults.