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It is submitted that the Senior Law Officer had observed that the Board is taking actions on the apprehensions of the Regional Office and has given opinion in the matter that the action being taken by the Board for revocation of consent to operate and confirmation of directions u/s 33-A of the Water Act, 1974 for closure of M/s Deeps Tools Pvt. Ltd. on the basis of apprehension of pollution is not sustainable, when many other industries are also situated and operating in the nearby area.
In this regard, it is submitted that RO reported that during visit to the area on 25.5.2024, it was observed that an open drain in Industrial Area-A, Ludhiana was having whitish brown semi solid sludge and was also carrying some industrial effluent. The drain was checked and it was observed that a sewer line opposite M/s Deeps Tools Pvt. Ltd. 320-21, Industrial Area A, Ludhiana, was carrying the same effluent during visit also. The matter was enquired and it was observed that the effluent was being discharged by M/s Deeps Tools Pvt. Ltd. The industry has provided a tank adjoining their premises and the tank carries the same sludge and effluent. The effluent was seen discharged into the sewer which ultimately leads to the drain.
Further, a bluish green layer of some chemical was seen on the sludge along the entire stretch and in the sewer which further indicates that the industry is discharging its trade effluent into the sewer also. During visit the samples from the different points in the drain, of the sludge from the drain, sludge from the tank adjoining the industry and the effluent being discharged from the sewer by the industry has been collected and sent for analysis in the lab. The results are tabulated as under:-
Sr. No. Parameters Unit Outlet of industry From manhole at 250m From manhole at 500m Prescribed standards
1. pH - 7.7 6.9 6.7 6.0 - 9.0
2. Total Suspended Solid (TSS) mg/l 380 2680 4800 100
3. Chemical Oxygen Demand (COD) mg/l 230 648 1920 250
4. Biochemical Oxygen Demand (BOD) mg/l 60 85 420 30
5. Phosphate mg/l 19.6 15.7 20.7 5
6. Total Chromium mg/l 0.93 2.38 13.56 2
7. Zinc mg/l 0.18 0.24 2.0 5
8. Nickel mg/l 2.8 5.3 30.7 3
9. Iron mg/l 55 170 2520 3
From the above table, it has been observed that the conc. of various parameters are beyond the prescribed limits and the industry is discharging the effluent in the drains through underground pipeline.
It is further submitted that RO has not given apprehension but has physically verified the facts at site as per above detail.
The opinion of Senior Law Officer is sent to Competent Authority and is under approval.
Now, the industry has applied for renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 & Air (Prevention & Control of Pollution) Act, 1981.
Now, vide its note dated 02.08.2024, RO reported that during visit on 25.05.2024 it was clearly found that the effluent from the vibrator section was discharged into sewer from the tanks meant for recirculation. The white sludge found in the storage tank of the unit, was also found in the drain. Therefore, the claim of the industry that no effluent has been discharged by the unit is not acceptable. Further the assertion of the unit that being industrial area other may also discharge effluent into sewer cannot be ruled out.
RO recommended that: 1. The Environmental compensation on the unit for degrading the environment may by imposed. 2. The industry shall ensure that all the sludge in the drain shall be stored and be got lifted to TSDF.
In view of the above, it is recommended as under:
1. Consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 may be refused due to above said reasons.
2. The Environmental compensation on the unit may be imposed for degrading the environment as proposed by RO.
3. The industry shall ensure that all the sludge in the drain shall be stored and be got lifted to TSDF.
(Category - Red, Medium) (Competency -CEE)
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