Guest Article by Manoj Misra
Note: This article is dedicated to the memory of Prof. Brij Gopal who introduced me to the concept of stream standards as different from effluent standards and often lamented former’s absence from our current water pollution control mechanisms. Prof. Gopal passed away suddenly in Delhi on 4 January 2021.
Public Health demands use of ‘Stream’ standards alongside ‘Effluent’ standards – Law provides for it but the authorities have failed to implement.
Is the city of Delhi condemned to suffer high ammonia content each winter in its drinking water supplies from River Yamuna?

The answer is perhaps yes! Though the only reason is not what is commonly believed namely the release of pollutants into Yamuna by Haryana or pollution entering river from within the Delhi limits. A fundamental reason is our understanding of the current pollution monitoring and control paradigm with over reliance on ‘effluent’ standards and a neglect of ‘stream’ standards. This lacuna exists despite the national Water Act mandating the latter. Let me explain.
But first the Ammonia conundrum in drinking waters…
Ammonia in drinking water According to Bureau of Indian Standards, maximum permissible ammonia level in drinking water is 0.5 ppm (parts per million). Ingestion of water at higher ammonia levels can cause serious health issues in humans including organ failure and brain damage.
Against this on several recent occasions the ammonia level in Yamuna waters received by Delhi at the Wazirabad water intake point has been found to be as high as 6 – 7 ppm or more and resulted in cessation or reduction in treatment activities at the Wazirabad, Chandrawal and Okhla water treatment plants in the city.
Key sources of Ammonia in water are leachates from landfills, fertilizer run off from agricultural fields, organic wastes from industries like sugar, paper, tanneries, dyes and distilleries etc, economic enterprises like dairying and abattoirs and above all sewage from urban settlements.

Ammonia in Delhi waters There are internal (within National Capital Territory of Delhi-NCTD) and external (outside of NCTD in Haryana and in UP) causes for high ammonia levels reported in Delhi each winter.
Amongst external causes are discharge – into the river or the drains (Drain No 2 and 8) carrying raw water for Delhi[i] – of high level of partially or untreated sewage emanating from the upstream cities of Yamunanagar/ Jagadari, Karnal, Panipat and Sonepat in Haryana and perhaps few smaller cities like Kairana and Baghpat across the river in Uttar Pradesh. This sewage is a toxic mix of not just household liquid waste but also effluents from large number of industries (fertilizer, textiles, dyes, pulp and paper, thermal power plant, oil refineries, sugar, distilleries, tanneries etc) operating in and around these cities.
Within NCTD amongst the internal reasons for winter period high ammonia content in water is lifting of water from a stagnant pool (Reservoir of Wazirabad barrage), low microbial activity (low rate of nitrification) due to low ambient temperatures and high solubility of ammonia in water at low temperatures, presence in river of fertilizer drenched runoff from high inputs farming activity in active floodplains, wash water from activities like dairying within active floodplains and possible emptying upstream of the barrage at Wazirabad, of septage directly into the river from residential colonies like Jagatpur Khadar and Milan Vihar in west bank and Sonia Vihar and Rajeev Nagar in east bank.
It is common knowledge that whenever ammonia issue in Delhi heats up it is an emergency augmentation by Haryana of ‘dilution’ flows in the river that resolves the crisis. This practice underscores the importance of ‘stream’ standards.

Basis of Stream Standards A stream or a river in its pristine state has a certain inbuilt capacity to assimilate pollution received from external sources. But this capacity is limited by various in-stream factors. One is the natural flow which is also variable over the seasons. Other is the presence of plants and animals that aid in the assimilation of pollutants. Third is the stream’s geomorphology which influences the rate of oxygenation of the stream’s water.
Thus streams with characteristic virgin flows, biota and geomorphology shall be differently endowed in terms of their capacity to assimilate pollution and to self rejuvenate. This fact requires to be factored into our pollution control regime. Unfortunately, it isn’t?
Moreover, from human angle different streams or different sections in case of large rivers have a certain existing ‘designated’ use. These range from drinking, ritual bathing, spiritual, fishing, irrigation, recreation etc. Clearly there is a need to recognize these formally and then make all out effort as part of pollution control measures to either maintain stream quality and quantity where such needs are already being met or improve the stream conditions from what it exists today to meet those needs. There is presently little targeted effort towards the same by the pollution boards or related agencies?
Yes, we do sometimes announce the current state of a large river say Ganga or Yamuna’s water quality as meeting ‘drinking’ or ‘bathing’ quality in its different sections but it is seemingly practiced mechanically without any credible independent assessment, trend over time or reference to any pre defined designated use category, targets etc?

Problems with current pollution control paradigm The current paradigm of pollution control in the country totally misses the quantitative question since it is geared to monitor and control quality of the ‘effluent’ at the source of the pollution without really bothering about assimilative capacity of the stream, ‘how much’ (quantity) or what happens when this and all other such effluents enter a stream or a pond or low lying land.
This leads to three kinds of problems.
One is that whenever the effluent standards at source are exceeded the regulatory body warns and acts as per law against the defaulting polluter. But it misses entirely the larger picture of the cumulative end result of this pollution along with all the others entering the stream?
Secondly since it is the source effluent that is monitored there is no way to regulate the number or density of polluting units in an area vis a vis the assimilative capacity of the receiving water body or a river.
Thirdly while the state of health of a stream receiving the polluted effluents is of little bother to a regulator, the impacts of these are felt and attention of the public is focused there only.
For example while the public and media in Delhi laments about a heavily polluted river Yamuna and worry little about the number of polluting units or the volume of pollution emanating there from, the regulatory agency like DPCC remains more focused on quality of effluent that various point sources in the city produce. Even when directed by courts to report on stream health the regulator resorts to qualitative measures like BOD or Coliform levels at various points in the stream bothering little about the status of flow or presence / absence of biota or changes if any in the geomorphology or total effluents entering the river and how it has been increasing and its impact on the river.

Demands of Water Act 1974 The Water Act of 1974 requires that:
Both CPCB and SPCB shall “lay down, modify or annul, in consultation with the State Government concerned, the standards for a stream or well: Provided that different standards may be laid down for the same stream or well or for different streams or wells, having regard to the quality of water, flow characteristics of the stream or well and the nature of the use of the water in such stream or well or streams or wells;”
Despite the Water Act being in place for more than 46 years now we are not aware of any river or any river stretch in the country enjoying an official recognition based on stream standards as provided above by the Water Act?
How and in what manner do we lose out when we fail to resort to Stream Standards?
Under the law, any project or industry must seek a prior ‘consent to establish’ as well as ‘consent to operate’ from the concerned state pollution control board.
Now when these consents are considered only from the point of view of effluent standards then the following get ignored:
- How many polluting units can be permitted to be established in an area (catchment) of a receiving stream? How much pollutants are already entering from already permitted / existing sources and what is the remaining assimilative capacity of the stream? What will be the impact of this additional pollutants on the various parameters of the stream?
- How much water can be permitted to get abstracted from that stream?
No wonder our streams continue to go from bad to worse and pollution control bodies struggle to stem the rot and are not able to maintain or improve the stream health compared to its designated or desired level. Lesson is that stream health cannot be ensured just by enforcing ‘effluent’ standards.
Returning to river Yamuna in Delhi….
Till the 1950s the drinking water for the city was lifted from the river at two points. At Wazirabad in the north to meet the water needs of north and central Delhi and at Okhla in the south to meet the needs of south Delhi. Obviously the river section in Delhi had ‘drinking water’ as its paramount use. Now if the city managers had then officially declared it so all efforts of planners would have been to ensure that this use (Stream standard of ‘drinking’ quality) was kept in mind and maintained as the city grew. It would have set a model for the management of other urban rivers in the country as well.
But the sad fact is that the first ever Master Plan of Delhi (MPD) from 1962 which laid the framework for Delhi’s growth as a city had little to say about the city’s relationship with its life-line river and accordingly a great opportunity was lost. Perusal of all the succeeding MPDs reveals that there is little in them about the need to restore the drinking water use category of river Yamuna in Delhi. Resultantly there are two distinct rivers in the city, one upstream and the other downstream of the barrage at Wazirabad. One which still supplies drinking water to the city and the other which is often lamented as sewage canal.

Way forward Delhi shall continue to suffer high ammoniacal nitrogen in its drinking water unless there is a paradigm shift in pollution abatement strategies from its current focus on point source effluent monitoring to desired focus on over all stream health. This does not mean that effluent quality should not be monitored. It only means that stream standards need be given due importance so that both effluent and stream standards together help us tackle effectively the challenges of polluting influences and degrading stream health.
Since Delhi is the first town on the river Yamuna downstream of the barrage at Hathnikund (HKB) with all others like Yamunanagar, Karnal, Panipat and Sonepat located couple of kms away from the river proper, the entire stretch of river from HKB to Delhi should be designated as ‘drinking’ quality standard and not ‘bathing’ quality standard as is presently presumed. Once thus designated a lot in terms of pollution monitoring and abatement shall change for the better. This would require assessing upfront the extant assimilative capacity of the river and then setting an upper limit in terms of kind, quantity and quality of polluting matter and activities that can be allowed to enter the river or permitted close to it as efforts are made alongside to restore the river’s self rejuvenation capacities.
In other words this shall mean ensuring E flows in the river; review of consent to establish and operate of all polluting industries in the basin targeting a Zero Liquid Discharge (ZLD) regime; aggressive promotion of natural or organic farming to eliminate the scourge of non point entry as runoff into the river of nitrogenous fertilizers, insecticides and weedicides; highly restricted removal of sand from scientifically identified locations and controlling unregulated removal of ground water from the active floodplains.

Once implemented this shall become a bellwether of sorts and enable the nation fulfill in its entirety the Preamble of the Water Act of 1974 which reads:
“An Act to provide for the prevention and control of water pollution and the maintaining or restoring of wholesomeness of water…….”
Shall we finally move beyond the Preamble’s first part namely ‘prevention’ and ‘control’ of water pollution to restoring wholesomeness of water in our streams? Amen.
Manoj Misra (yamunajiye@gmail.com)
END NOTES:
[i] https://sandrp.in/2019/05/28/common-problems-of-a-common-effluent-treatment-plant-in-yamuna-basin/, https://sandrp.in/2020/07/24/delhi-drinking-water-canal-gets-toxic-mix/, https://sandrp.in/2019/05/16/delhis-drinking-water-is-9-inch-wall-away-from-toxic-industrial-effluents-sewage/