What Should an Industry Do If Groundwater Withdrawal Is Restricted?

When an industry learns that groundwater withdrawal at its site is restricted, difficult to increase or subject to stringent conditions, the first reaction is often:

How can we obtain permission for more groundwater?

That is not always the best first question.

The better engineering question is:

How much fresh water does the facility actually need after every practical opportunity for reduction, reuse and recovery has been evaluated?

A factory consuming 500 m³/day of water does not necessarily require 500 m³/day of fresh groundwater.

Part of that requirement may potentially be met through:

• treated ETP water;

• treated STP water;

• condensate recovery;

• cooling-water optimisation;

• RO recovery;

• process-water recycling;

• rainwater utilisation;

• municipal or industrial water supply; or

• treated sewage from an external source.

Groundwater restriction should therefore trigger a water-system redesign exercise, not merely another attempt to increase borewell capacity.

CGWA's regulatory framework itself is built around sustainable groundwater management and recognises significant differences between locations, hydrogeological conditions and groundwater-resource stress.

Why Can Groundwater Withdrawal Become Restricted?

There is no single reason.

An industrial project may face groundwater constraints because of:

• the groundwater classification of its assessment unit;

• existing groundwater stress;

• project location;

• applicable Central or State regulations;

• whether the project is new or existing;

• proposed quantity of abstraction;

• water availability from alternative sources;

• changes in groundwater conditions;

• expansion of production;

• conditions attached to an existing NOC; or

• project-specific regulatory scrutiny.

CGWB classifies groundwater assessment units as Safe, Semi-Critical, Critical and Over-Exploited according to the relationship between groundwater extraction and extractable groundwater resource.

CGWA also continues to regulate groundwater development by issuing NOCs to industries, infrastructure and mining projects in areas under its jurisdiction, while other States may regulate abstraction through their own groundwater authorities or designated agencies.

Therefore, before redesigning a project around a regulatory assumption, an industry should establish:

What exactly is restricted?

Is it:

• all new abstraction?

• additional abstraction?

• a particular borewell?

• total permitted quantity?

• a renewal issue?

• a stressed-area condition?

• a project-specific requirement?

• or an issue arising under the applicable State authority?

That distinction matters.

Restricted Groundwater Does Not Automatically Mean the Project Is Impossible

For many industrial projects, water consumption is not the same as freshwater consumption.

This distinction can completely change project feasibility.

Consider an industrial plant requiring:

300 KLD total water circulation

Suppose engineering review identifies:

• 45 KLD treated STP reuse;

• 40 KLD treated ETP reuse;

• 25 KLD condensate recovery;

• 20 KLD cooling-system saving;

• 15 KLD process-water recycle.

Total fresh-water replacement potential:

145 KLD

The resulting fresh-water requirement could theoretically fall from 300 KLD to about 155 KLD, subject to actual process quality requirements and technical feasibility.

The plant still uses approximately 300 KLD internally.

But it no longer needs 300 KLD of fresh groundwater.

That is why the first response to a groundwater constraint should usually be:

Prepare a credible industrial water balance.

Step 1 — Determine the Actual Freshwater Requirement

Before trying to obtain more groundwater, separate:

total water circulation

from

fresh-water make-up requirement.

A detailed plant water balance should identify all incoming sources.

Fresh Sources

• groundwater;

• municipal water;

• industrial water supply;

• surface water;

• purchased tanker water;

• treated external sewage;

• other authorised supplies.

Water Users

• process;

• product;

• washing;

• cooling tower;

• boiler;

• domestic consumption;

• utilities;

• horticulture;

• laboratory;

• housekeeping.

Wastewater and Recoverable Streams

• process effluent;

• sewage;

• cooling blowdown;

• boiler blowdown;

• condensate;

• RO reject;

• wash water;

• filter backwash;

• recovered process water.

The objective is to establish:

What is the minimum technically practical external fresh-water demand?

This is the core purpose of an Industrial Water Audit in a groundwater-constrained facility.

Step 2 — Measure Water Instead of Relying on Estimates

Many factories do not actually know where their water goes.

The common water balance is often:

Borewell → overhead tank → plant

with little measurement afterwards.

That is not enough for groundwater optimisation.

The plant should ideally meter major users such as:

• process sections;

• cooling towers;

• boilers;

• RO systems;

• washing areas;

• ETP;

• STP;

• domestic blocks;

• horticulture;

• recycled-water lines.

Without measurement, the company may spend significant CAPEX trying to produce additional water while continuing to lose water through uncontrolled consumption.

A good water audit can expose:

• overflowing tanks;

• failed level controls;

• excessive flushing;

• leaking pipelines;

• unnecessarily high washing flows;

• cooling-tower over-blowdown;

• RO reject losses;

• poor condensate return;

• untreated reuse opportunities;

• inaccurate abstraction records.

Step 3 — Reduce Process Water Consumption

The cheapest cubic metre of water is often the one the factory does not need to consume.

Process-level reduction may include:

• counter-current washing;

• spray-nozzle optimisation;

• automatic shut-off valves;

• batch sequencing;

• reuse of final rinse as initial rinse;

• dry cleaning before wet washing;

• improved housekeeping;

• closed-loop systems;

• reduction of product-change wash volumes;

• segregation of clean and contaminated streams.

This is where generic groundwater consultants and process engineers often diverge.

A groundwater problem can sometimes be solved inside the manufacturing process, not at the borewell.

Step 4 — Optimise Cooling-Water Consumption

Cooling towers can be among the largest freshwater users in an industrial plant.

The basic water balance includes:

evaporation + blowdown + drift + losses

replaced by make-up water.

Evaporation is inherent to the cooling process.

Excessive blowdown often is not.

Cooling-water optimisation may involve reviewing:

• cycles of concentration;

• conductivity control;

• make-up water quality;

• scaling tendency;

• corrosion;

• silica;

• hardness;

• TDS;

• chemical treatment;

• automatic blowdown;

• side-stream filtration;

• drift eliminators;

• leaks and overflow.

Increasing sustainable cycles of concentration can reduce both:

• fresh-water make-up; and

• wastewater blowdown.

For groundwater-constrained industries, cooling-water optimisation can therefore produce a double benefit.

Step 5 — Maximise Condensate Recovery

Steam-intensive industries should examine their condensate system carefully.

Condensate is not merely water.

It is usually:

• already treated;

• hot;

• low in dissolved solids compared with raw water; and

• carrying recoverable thermal energy.

Poor condensate return creates two avoidable demands:

more fresh water

and

more fuel.

The plant should review:

• condensate collection;

• contamination risks;

• flash steam;

• return piping;

• traps;

• condensate pumps;

• recovery percentage;

• temperature;

• boiler feedwater integration.

In paper, textile, chemical, food, pharmaceutical and other steam-intensive facilities, improved condensate recovery can materially change the overall freshwater balance.

Step 6 — Reuse Treated STP Water

Domestic sewage should not automatically become a disposal stream.

Where treatment quality and end-use requirements permit, treated STP water may potentially be used for:

• toilet flushing;

• horticulture;

• cooling-tower make-up;

• floor washing;

• road washing;

• utility applications.

For a factory employing several hundred or several thousand people, sewage generation can represent a meaningful internal water resource.

The key is fit-for-purpose treatment.

The question should be:

What quality does the reuse application require?

and then:

What treatment is needed to reliably achieve it?

Not every reuse application requires the same water quality.

Step 7 — Reuse Treated ETP Water

Industrial effluent can be more complex than sewage, but it can also provide a substantial reuse opportunity.

Potential reuse depends on:

• process chemistry;

• TDS;

• COD;

• hardness;

• oil and grease;

• heavy metals;

• colour;

• specific contaminants;

• biological quality;

• final reuse requirement.

Possible applications can include:

• cooling;

• washing;

• utility use;

• scrubbing;

• gardening where suitable and permissible;

• selected process reuse;

• RO feed after appropriate pretreatment.

SARK's industrial wastewater treatment consulting approach should therefore be connected directly with freshwater-reduction planning.

Step 8 — Segregate Wastewater Before Trying to Recycle It

This is one of the most important practical principles.

A plant may generate:

• relatively clean cooling blowdown;

• mildly contaminated wash water;

• high-COD process effluent;

• oily water;

• domestic sewage;

• RO reject.

If every stream is mixed together in one underground collection tank, the entire combined flow may require treatment to the standard demanded by the most difficult contaminant.

That can make reuse unnecessarily expensive.

Segregation can allow:

cleaner stream → simpler treatment → easier reuse

while reserving intensive treatment for concentrated streams.

This can reduce both CAPEX and OPEX.

Step 9 — Improve RO Recovery, but Do Not Chase Recovery Blindly

Reverse osmosis is frequently proposed as the default answer to water scarcity.

It can be useful, but high recovery is not free.

As recovery increases:

• reject becomes more concentrated;

• scaling tendency can increase;

• pretreatment requirements become stricter;

• membrane fouling risk can rise;

• chemical consumption may increase.

The target should therefore be:

economically and technically sustainable recovery

rather than simply the highest percentage possible.

RO should be evaluated as one element of the plant water architecture.

Step 10 — Evaluate Zero Liquid Discharge Only Where It Makes Sense

ZLD can significantly reduce external wastewater discharge and recover water.

But ZLD should not be presented as a magic solution to every groundwater restriction.

A typical high-recovery/ZLD system may involve:

• pretreatment;

• biological/chemical treatment;

• ultrafiltration;

• RO;

• multiple RO stages;

• evaporator;

• MEE;

• ATFD or crystallisation;

• salt/sludge management.

That means:

• energy;

• chemicals;

• maintenance;

• membranes;

• evaporator scaling;

• sludge;

• reject handling;

• manpower.

ZLD should be selected where required or technically/economically justified.

SARK's Zero Liquid Discharge services evaluate ZLD as part of an integrated plant water system rather than as a standalone equipment package.

Step 11 — Capture Rainwater as a Water Resource

Industrial campuses can have very large catchments.

A site may contain:

• tens of thousands of square metres of roof;

• roads;

• paved yards;

• warehouses;

• parking;

• open areas.

Rainwater should therefore be evaluated for both:

direct utilisation

and, where appropriate,

groundwater recharge.

A proper assessment should consider:

• catchment area;

• annual rainfall;

• rainfall intensity;

• runoff coefficient;

• first-flush diversion;

• roof contamination;

• surface contamination;

• storage volume;

• stormwater drains;

• recharge suitability;

• soil;

• hydrogeology;

• overflow;

• flooding.

CGWB continues to promote rainwater harvesting and artificial recharge as groundwater-management measures and identifies recharge pits, trenches, wells and other structures as applicable approaches depending on setting.

Step 12 — Do Not Assume Rainwater Recharge Equals Groundwater Abstraction

This is a common mistake.

If an industry abstracts:

50,000 m³/year

and theoretically collects:

50,000 m³/year rainfall runoff

it does not automatically follow that the two quantities cancel each other.

Actual groundwater recharge depends on:

• rainfall pattern;

• capture efficiency;

• runoff;

• losses;

• soil infiltration;

• aquifer connectivity;

• structure performance;

• clogging;

• groundwater depth.

Recharge should therefore be treated as a hydrogeological process, not a simple accounting adjustment.

Step 13 — Evaluate External Alternative Water Sources

When groundwater is constrained, projects should examine whether part or all of their requirement can come from authorised external sources.

Possible sources may include:

• municipal water;

• industrial development authority supply;

• canal/surface-water systems;

• treated municipal sewage;

• common industrial water networks;

• legally supplied tanker water.

The technical assessment should compare:

• availability;

• reliability;

• quality;

• distance;

• treatment requirement;

• storage;

• pipeline CAPEX;

• tariff;

• future security.

Sometimes a higher-cost external water source can still be economically superior to building a complex high-recovery treatment system.

Step 14 — Consider Treated Municipal Sewage as an Industrial Resource

Large urban and industrial regions increasingly generate large quantities of treated sewage.

Where infrastructure and regulatory conditions permit, treated sewage can potentially become a source for:

• cooling;

• industrial utilities;

• secondary treatment/RO feed;

• selected non-product-contact uses.

This creates an important conceptual shift:

wastewater disposal problem

becomes

industrial water source.

For water-intensive industry near urban areas, this option should increasingly enter project feasibility studies.

Step 15 — Review the Production Process Itself

Sometimes water demand is embedded in the chosen manufacturing route.

Two plants producing the same product can have very different specific water consumption because of:

• technology;

• equipment;

• washing sequence;

• cooling method;

• product recovery;

• process integration;

• housekeeping.

If groundwater restriction is severe, it may even be economically preferable to alter:

• equipment selection;

• process configuration;

• cleaning system;

• cooling system;

• production scheduling.

Water scarcity can therefore become a process-design parameter.

Step 16 — Calculate Specific Water Consumption

Absolute consumption alone can be misleading.

A plant using 300 KLD at 100 tonnes/day production has:

3 m³ water/tonne product

If production increases to 150 tonnes/day while freshwater remains 300 KLD:

2 m³/tonne

Specific water consumption has improved.

Every groundwater-dependent industry should monitor a suitable production-linked KPI such as:

• m³/tonne product;

• litres/unit;

• m³/batch;

• m³/m² product;

• litres/vehicle;

• m³/room-night for hospitality.

This connects groundwater management with operations rather than treating it as an environmental-department issue.

Step 17 — Prepare More Than One Water Scenario

Groundwater-constrained projects should model alternatives.

Scenario A — Current System

Existing groundwater + current reuse.

Scenario B — Optimised Operation

Reduced losses + cooling optimisation + improved condensate.

Scenario C — High Reuse

ETP/STP reuse + process recycling + RO recovery.

Scenario D — Diversified Supply

Reduced groundwater + treated sewage/municipal supply + rainwater.

Scenario E — High Recovery / ZLD

Maximum feasible recovery where justified.

Compare each scenario on:

• fresh groundwater requirement;

• CAPEX;

• OPEX;

• energy;

• chemical consumption;

• reliability;

• regulatory risk;

• expansion potential.

This turns water scarcity into an engineering decision rather than a compliance panic.

What If the Existing Industry Already Has a Groundwater NOC?

An existing permission should be treated as a defined regulatory position, not an unlimited entitlement to additional water.

Before expansion, compare:

permitted abstraction

with

actual abstraction

with

future requirement.

Also review:

• NOC validity;

• conditions;

• borewells;

• flow meters;

• abstraction records;

• piezometer requirements;

• groundwater-level records;

• rainwater-harvesting infrastructure;

• water balance;

• reuse commitments.

CGWA states that NOCs carry conditions to be implemented by the project proponent, so the permit and operating reality should be reconciled before expansion is planned.

What If the Industry Is in a Semi-Critical, Critical or Over-Exploited Area?

These assessment units deserve greater caution.

CGWA currently requires an Impact Assessment Report and groundwater modelling for projects extracting or proposing more than 100 m³/day in Over-Exploited, Critical and Semi-Critical areas; higher thresholds apply to Safe areas depending on alluvial/non-alluvial hydrogeology.

That does not mean every project below 100 KLD is automatically uncomplicated.

It means larger abstractions in stressed groundwater areas trigger more extensive technical assessment.

Before increasing abstraction, industries should therefore consider whether their real objective can be achieved through freshwater-demand reduction instead.

Groundwater Restrictions Should Be Checked Before Industrial Expansion

Consider a plant that plans to double production.

The engineering team may assess:

• machinery;

• electrical load;

• steam;

• compressed air;

• building area;

• environmental consent.

Groundwater is often assumed to increase automatically with production.

That assumption should be challenged.

Expansion can be an opportunity to:

• retrofit recycling;

• install metering;

• upgrade STP/ETP;

• optimise cooling;

• increase condensate return;

• improve RO recovery;

• collect rainwater;

• diversify supply.

It is entirely possible for production to increase substantially without groundwater demand increasing proportionately.

Groundwater Restrictions Should Be Checked Before Buying Land

For water-intensive projects, groundwater due diligence should occur before land acquisition.

Evaluate:

• current groundwater category;

• competent authority;

• proposed water demand;

• groundwater feasibility;

• municipal/industrial supply;

• treated sewage;

• existing water infrastructure;

• reuse potential;

• rainfall;

• hydrogeology;

• future expansion.

The Groundwater Regulatory Intelligence for Industries hub is intended to bring these factors together before groundwater becomes a late-stage project problem.

What Should the Final Industrial Water Strategy Look Like?

A resilient plant should avoid dependence on a single source wherever practical.

An idealised water architecture may look like:

Groundwater+municipal/industrial supply+rainwater+treated STP water+treated ETP water+condensate+process recycle

feeding different applications according to required water quality.

High-quality freshwater should be reserved for applications that genuinely require it.

Lower-grade water should be matched to lower-grade uses wherever technically appropriate.

This is fit-for-purpose water management.

How SARK Engineers & Consultants Approaches a Groundwater-Restricted Project

SARK's approach begins with the factory, not the borewell.

1. Regulatory Screening

Review:

• assessment-unit category;

• groundwater authority;

• current permission;

• proposed abstraction;

• project status;

• likely constraints.

2. Plant Water Audit

Measure where water enters, where it is consumed and where it leaves.

3. Water Balance

Develop:

source → user → wastewater → treatment → reuse → loss

for the complete site.

4. Reduction Study

Identify process and utility reductions.

5. Reuse Assessment

Evaluate STP, ETP, cooling, condensate, RO and process recycle.

6. Alternative Source Assessment

Evaluate feasible external supplies.

7. RWH / Recharge Assessment

Assess catchment, rainfall, storage/recharge feasibility and stormwater integration.

8. Water Scenario Modelling

Compare multiple supply and recovery configurations.

9. Groundwater Impact Review

Where applicable, evaluate the groundwater implications of the remaining abstraction requirement.

10. Implementation Roadmap

Prioritise measures according to:

• water savings;

• CAPEX;

• OPEX;

• regulatory need;

• payback;

• implementation complexity.

The end product should answer:

What is the lowest sustainable groundwater dependence this industrial facility can practically achieve?

Frequently Asked Questions

Can an industry operate if groundwater extraction is restricted?

Potentially yes, depending on the project and availability of alternative water strategies. Restricted groundwater does not automatically mean the plant cannot operate; water demand, reuse, alternative supply and current regulatory requirements should be evaluated.

What is the first step if a factory cannot obtain enough groundwater?

Prepare a detailed industrial water balance and determine the minimum technically practical fresh-water requirement before looking for additional supply.

Can treated STP water be reused in an industry?

Potentially yes, if treatment quality is suitable for the intended use. Common possibilities include flushing, horticulture, cooling and selected utility applications.

Can ETP-treated water replace groundwater?

Depending on effluent characteristics, treatment performance and reuse quality requirements, treated industrial wastewater may replace freshwater for suitable applications.

Can rainwater harvesting solve a groundwater shortage?

It can contribute materially at suitable sites, but rainfall is seasonal and actual recoverable or rechargeable quantity depends on catchment, storage, runoff and hydrogeology.

Is Zero Liquid Discharge necessary if groundwater is restricted?

Not automatically. ZLD may be required or appropriate in certain projects, but groundwater restriction alone does not make ZLD the correct solution. Water reduction and reuse should be assessed first.

Should an industry reduce groundwater before applying for more abstraction?

From an engineering perspective, yes. Demonstrating a credible minimum freshwater requirement also produces a more defensible long-term project water strategy.

What does OCS mean in CGWA groundwater regulation?

OCS refers to Over-Exploited, Critical and Semi-Critical groundwater assessment units. Larger abstractions in these stressed categories are subject to additional assessment requirements under CGWA's framework.