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Subject: Proceeding of the personal hearing given before the Senior Environmental Engineer, Zonal Office-I, Ludhiana on 23.12.2025 w.r.t. show cause notice for refusal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 - M/s Sumit Knit Fab, B-3, Industrial Area-A, Extension, Ludhiana.
The Following were present:
On behalf of Punjab Pollution Control Board
Er. Sukhwant Singh, Environmental Engineer, Zonal Office-1, Ludhiana.
On behalf of the industry
Sh. Rishi Jethi, Proprietor
The Environmental Engineer, Zonal Office-1, Ludhiana brought out that the industry is a small scale red category unit engaged in the process of dyeing and washing of the garments.
The industry was issued notice u/s 33-A of the Water Act, 1974 as well as show cause notice for revocation of consent to operate under the Water Act, 1974 and revocation of authorization under the Hazardous and other Waste Rules, 2016 alongwith notice for imposition of EC with hearing before Chairman of the Board on 25.04.2024.
In compliance to decisions of personal hearing, the consent to operate granted to the industry under the Water Act, 1974 was revoked and directions u/s 33-A of the Water Act, 1974 were issued. In compliance to above directions, the PSPCL authorities disconnected the electric supply of the industry vide TDCO letter no. 104/11 dated 29.04.2024 and the D.G set were sealed by the officer of the Board in the presence of the industry.
In compliance to decision of personal hearing, the letter was issued to the Assistant Excise and Taxation Commissioner, Excise and Taxation Department, Ludhiana and MC Ludhiana. The Excise and Taxation Department, Ludhiana has submitted its report vide their letter no. 124 dated 13.05.2024 and as per the report the unit has made purchases from the firms dealing in dyes and chemicals in the year 2005 and is carrying out the dyeing process. The unit is in the business of dyeing of fabric since, 2005.
The industry had applied for consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 through OCMMS alongwith request for restoration of electric connection. Accordingly, after verification, the industry was granted consent under the Water Act, 1974 dated 14.04.2025 valid upto 13.07.2025 alongwith restoration of electric connection temporarily for 3 months with special condition that committee of officers of the Board will be constituted to verify the compliances made by the unit w.r.t violations observed during earlier visit. The committee shall submit report within one month.
The industry was granted Consent to Operate under Water Act, 1974 and Air Act, 1974 up to 09/09/2025 and electric connection was also restored upto 09/09/2025 with special condition that this consent will be subject to reports received from Committees formed to verify the compliance made by the unit and for examining imposition of EC and the industry is bound to comply with any direction issued by Hon'ble NGT/CPCB/PPCB in future. The industry was visited by the team of officers of the Board constituted by the Board vide letter no. 3049-52 dated 09.05.2025 and monitoring of ETP was carried out by the visiting team and as per the report, it has been found that the analysis results examined by the team w.r.t. reduction in conc. of parameters i.e. TDS, BOD & COD in the treated effluent after treatment are practically not feasible, as the decrease in BOD and TSS is more than 92%, COD is more than 99% and TDS is more than 62% through physio chemical treatment in ETP, which is not possible.
Further, as per the report the total water consumption is around 46.4 KL in the process as per the visit, but as per the record maintained by the industry, the average daily water consumption is 5.56 KL, 7.71 KL and 7.64 KL for the month of May, June & July 2025, which is huge difference and creating doubt regarding dilution/ untreated discharge / unmetered supply. The detailed report is as under :-
The analysis results examined by the team w.r.t. reduction in conc. of parameters i.e. TDS, BOD & COD in the treated effluent after treatment is practically not feasible. Thus, team apprehended that the industry is carrying out dilution in the ETP / in the treated trade effluent collection tank.
The industry has not provided any bye-pass arrangement. However, the industry has provided haudi near its main gate and close to RO reject collection tank. Also, the industry has provided washroom near to effluent collection tank. The outlet of the washroom as well as haudi were found connected with the MC sewer. The team apprehended that the industry might misuse above mentioned haudi and washroom to discharge RO reject and effluent into MC sewer through these arrangements during odd hours.
The generation of effluent as well as its treatment has been found within the quantum of consent granted to the industry as per the data analysed. However, there is a lot of difference between the fresh water consumption as per the record maintained by the industry and actual readings taken by the visiting team for 24 hours.
The industry is required to obtain authorization under HWM Rules, 2016 for category 37.3 i.e. concentration and evaporation residue from the Board. Also, the industry is required to maintain the records w.r.t. generation and lifting of hazardous waste of category 5.1 & 33.1 and shall submit the same to the Board on monthly basis.
The industry is required to maintain its production records/record regarding no. of batches of dyeing & washing being carried out on daily basis so that fresh water requirement and subsequently generation of trade effluent based on machinery installed can be adjudged.
The industry is required to install/repair water meter to adjudge the quantity of backwash for Ultra filtration so that complete water balance can be made.
The industry is required to get the study carried out w.r.t. availability of steam from the boiler and its consumption in different processes of the industry as well as in evaporator so that adequacy of the systems installed by the industry can be adjudged including evaporation rate of evaporator.
The industry is required to carry out dosing of chemicals (lime powder, ferrous sulphate, polyelectrolyte) through mechanized system.
The industry is required to make proper approach to reach stack provided with its boiler.
Further, a committee of officers of the Board has been constituted to assess/ impose EC to the unit for submission of report in compliance of decisions of hearing dated 06.05.2025 and the final report is awaited.
The industry had applied for renewal of Consent to operate under the Water Act, 1974 and Air Act, 1981 alongwith restoration of electric connection for further period and the industry was issued show cause notice for refusal of Consent to operate under the Water Act, 1974 and Air Act, 1981 with an opportunity of personal hearing before the Senior Environmental Engineer of the Board on 18.09.2025, wherein it was decided as under :-
1. The industry shall get the study carried out from some institute of repute for its processes alongwith the complete water auditing of the industry to support its contentions that it has adequate ETP and ZLD system including availability of steam from the boiler and its consumption in different processes of the industry as well as in evaporator, within 01 month.
2. The industry shall regularly maintain the production record w.r.t. no. of batches of dyeing & washing being carried out on daily basis.
3. The industry shall make arrangements to carry out chemical dozing in ETP through mechanical system, within 07 days.
4. The industry shall maintain the records w.r.t. generation and lifting of hazardous waste of category 5.1 & 33.1 and shall submit the same to the Board on monthly basis.
5. The industry shall apply/obtain authorization under HWM Rules, 2016 for category 37.3 i.e. concentration and evaporation residue, within 07 days.
6. The Environmental Engineer, Regional Office-1, Ludhiana shall pursue the EC verification committee for timely submission of its report so as to take further necessary action w.r.t. imposition of Environmental Compensation to the unit and to submit conclusive recommendations to decide the case.
7. The Environmental Engineer, Regional Office-1, Ludhiana shall personally visit the industry to verify the contentions made by the industry during the hearing and submit report alongwith conclusive recommendations to decide the consent applications.
In compliance to the decisions of personal hearing, the industry was visited by officer of the Board on 07.10.2025 & 08.10.2025 and it was observed that the industry was not complying with decisions of above said personal hearing, observations of visiting team. Accordingly, the applications for consent to operate under the Water Act, 1974 and Air Act, 1981 were refused.
The industry has now again applied for Consent to operate under Water Act 1974 and Air Act, 1981 along-with a request to restore the electric connection for further period.
The industry was visited by the officer of the Board on 07.11.2025 and observed that: -
1. The industry and the ZLD plant was not in operation.
2. The electric connection of the industry was disconnected by the PSPCL authorities as directed by the Board vide TDCO No. 104/62 dated 09.09.2025.
3. The industry has closed its outlet from washroom as well as haudi as per observations to avoid their misuse to discharge RO reject.
4. The industry installed water meter at the backwash of UF. However, the industry has still not done agreement with TSDF for HW of category 37.3.
5. The industry has not carried out study from institute w.r.t availability of steam to adjudge the adequacy of boiler and evaporator.
6. No system installed by the industry for mechanized dozing.
7. No justification is given on the difference in the fresh water consumption as per record and as per actual reading noted by the team.
8. The industry has not carried out any improvements/upgrades in treatment and HWM arrangements except water meter installation and closing of Haudi and washroom outlet as pointed by the joint team.
9. The industry is presently not fully complying with the hearing decisions due to its non -operation
In view of the above, the industry was issued show cause notice for refusal of Consent to operate under the Water Act, 1974 and Air Act, 1981 with an opportunity of personal hearing before the Senior Environmental Engineer of the Board on 23.12.2025.
Sh. Rishi Jethi, Proprietor from the industry attended the hearing and submitted the written reply which was taken on the record. He submitted the point-wise reply of the observations in the notice issued which is as under:-
1. They have made agreement for lifting of hazardous waste category 37.3 with TSDF Nimbua.
2. The unit has submitted request letter to GNDEC Ludhiana for carrying out study for the adequacy of the present boiler.
3. For mechanized dosing, the industry has installed 3 no. mechanical feed pumps to add chemical dozing in ETP.
4. The record w.r.t. fresh water consumption and re-used after ETP into the process has been attached.
5. The industry has provided railing on the ladder of the stack.
He further requested to restore the electric connection of the industry and to grant consent to operate at the earliest.
After hearing the industry, officer of the Board and considering material facts on record, the Senior Environmental Engineer of the Board decided that:-
1. The industry shall submit the report of the study to be carried out by the consulting agency (GNDEC Ludhiana) w.r.t. adequacy of the boiler and complete water auditing of the industry to support its contentions that it has adequate ETP and ZLD system including availability of steam from the boiler and its consumption in different processes of the industry as well as in evaporator, within 15 days.
2. The Environmental Engineer, Regional Office-1, Ludhiana shall visit the industry to verify the contentions made by the representative of the industry during the hearing & shall send the report alongwith recommendations so as to decide the consent application, within 07 days.
Submitted for confirmation of decisions of the hearing and for conveying to the industry and Regional Office for compliance of above decisions, please.
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