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It is submitted that the industry is a small scale red category unit and was granted consent to operate under the Water Act, 1974 vide no. CTOW/Fresh/LDH2/2017/5579291 dated 03/07/2017 and under the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Fresh/LDH2/2017/5579287 dated 03/07/2017 both valid upto 30/06/2022 for the manufacturing of Chain Wheel / Bicycle Parts @ 2000 No.s/day.
Earlier, the industry was visited by the officer of this office on 08.09.2025 in compliance to letter of the office of EE, Ludhiana-4, PPCB issued vide no. 1191-93 dated 22.08.2025 for non lifting of trade effluent in the month January 2025 to July, 2025. During visit, it was observed that:
1. The industry was in operation and engaged in manufacturing of bicycle parts and is operating its unit without obtaining valid Consent to operate under Water Act, 1974 and Air Act, 1981.
2. The industry has provided one electroplating section by installing 3 no dhols out of which 01 was empty and dry and 02 no. of Electroplating tanks, which was in operation during visit.
3. The industry has provided one no. rotary furnace with adequate stack which was not in operation during the visit.
4. As per record of this office the industry has made agreement with M/s JBR Technologies, Focal Point, Phase-8 Ludhiana @ 10000 Ltr/Month for lifting of its trade effluent. However, during visit no record of the same has been produced.
5. The industry has not installed water meter at fresh water supply line. The industry has failed to produce/maintained the record of fresh water consumption viz-a-viz trade effluent lifted to CETP which shows that the industry may be discharging its trade effluent through unauthorized mode.
6. The industry has provided tank of capacity 8000 Ltrs to store the trade effluent and the same was 50% full. The industry was one of unit that is in the list of non lifting of trade effluent to CETP operator.
7. The industry is discharging domestic effluent into sewer.
8. The industry has provided one submersible pump for extraction of ground water.
Accordingly, the industry was issued directions u/s 33-A of Water (Prevention & Control of Pollution) Act, 1974 vide no. 4667-68 dated 24.09.2025 for disconnection of electric connection available to the industry and seal the wet process/trade effluent generating process alongwith D.G set installed by the industry.
Further, in compliance to the directions, the industry was visited by JEE of this office on 29.09.2025 and it was observed that the industry was in operation and engaged in manufacturing of cycle parts. The wet process area of the industry and DG set of the industry was sealed during the visit.
In compliance, PSPCL authorities has disconnected the electric supply of the unit vide TDCO no. 95/103 dated 23/12/2025.
Now, the industry has increased its raw material from MS Sheet @ 2.0 TPD to 2.2 TPD & Chemicals @ 2.0 Kgs/day to 2.2 Kgs/day as well as production from Chain Wheel / Bicycle Parts @ 2000 No.s/day to 2200 No.s/day. The industry has also decreased its agreement with M/s JBR Technology Pvt. Ltd., Ludhiana (CETP) for disposal of its trade effluent from 10000 ltr/month to 4000 ltr/month.
Accordingly, the industry has applied for obtaining varied consent to operate under the Water Act, 1974 and Air Act, 1981 with requisite documents. The industry has deposited consent fee against the un-depreciated fixed assets of Rs. 19.90 Lacs as on 30/11/2025 as per CA Certificate dated 12/12/2025, which is adequate upto 30/06/2028 under both Acts, as per Board's Office Order dated 29/10/2018 after deducting penalty charges 400% and NOC Regularization fee for increase in the fixed assets.
The industry was visited by the undersigned on 24.12.2025 and it was observed as under:
1. The industry was not in operation due to disconnection of electric connection.
2. The industry is engaged in manufacturing of Chain Wheel / Bicycle Parts @ 2200 No.s/day by using raw material as MS Sheet @ 2.2 TPD & Chemicals @ 2.2 Kgs/day.
3. The process chart of the industry is as Sheet blanking - Punching - Pipe cutting - Bending - Welding - Shot blasting - Acid Dip – Zinc galvanizing – Finishing.
4. The industry has also decreased its agreement with M/s JBR Technology Pvt. Ltd., Ludhiana (CETP) for disposal of its trade effluent from 10000 ltr/month to 4000 ltr/month.
5. The industry stated that it has reduced its agreement owing to the fact that the demand of chrome bright finish has reduced and powder coating is now being preferred.
6. The industry has installed two no. wet process areas, both were found sealed during the visit. One wet process did not have water meter on its fresh water line.
7. The industry was guided to maintain record w.r.t. fresh water consumption for the wet process & effluent lifted to M/s JBR Technology Ltd. and to install water meter on fresh water supply to its unmetered wet process area.
8. The industry has provided storage tank capacity from 8000 ltr.
9. Domestic effluent is being discharged onto land for plantation after passing through septic tank.
10. The industry has installed CCTV cameras, facing towards the entry gate of the processing shed and effluent storage tank and fresh water meter installed in processing area.
11. The industry has installed colour coating bhathi and diesel oil fired rotary furnace.
12. The industry has installed 02 no. D.G sets of capacity 125 KVA each, with adequate stack height placed in an acoustic room.
13. The industry has submitted copy of revised building plan from the approved architect Sh. Vishal Behal, Competent Person of Director of Factories, Punjab.
The industry has submitted the CLU issued by STP, Ludhiana vide letter no. 4514 dated 13.06.2012 stating that the site falls in Industrial Zone as per Master Plan, Ludhiana.
In the subject cited case, the industry has mentioned ground water extraction @ 1.154 KLD. Considering 25 working days per month, ground water extraction will be 28.85 KL/month, which is not more than exempted quantity.
It is further submitted that vide office memorandum no. 428 dated 23.09.2025 among other decisions the Board has decided as under:
“The Bank Guarantee be returned and /or permanent restoration be allowed on compliance of specified violation or submission of necessary document based on single site visit subject to decision of the Competent Authority.”
Further, while processing the consent application (No. 27057285) of M/s Kalsi Sons Fabricators Worthy Chairman of the Board has approved to impose environmental compensation amounting to Rs. 1.0 Lakh to such small scale industries vide note dated 11.10.2024. As the industry has made compliance of earlier violations.
In view of above, it is recommended that:
1. The industry may be imposed environmental compensation amounting to Rs 1.0 Lakh being a small scale unit as approved by the Competent Authority in the case M/s Kalsi Sons Fabricators.
2. 'Consent to Operate' under Water (Prevention & Control of Pollution) Act, 1974 may be granted upto 30/06/2028 (upto the validity of consent fee). (Competency – Senior Environmental Engineer).
3. Environmental Engineer, RO-2, Ludhiana may be directed to de-seal the machinery.
4. PSPCL authorities may be directed to restore the electric connection available with the industry, permanently after deposition of EC by the industry. (Competency: Chief Environmental Engineer)
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