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It is submitted that the industry was granted 'Consent to Operate' under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDH2/2023/22555801 dated 21/07/2023 valid upto 30/06/2028 for wire drawing @ 25 MTD with trade effluent @ 4000 Ltr/Month lifted by re-processor of spent acid i.e. M/s JBR Technologies Ltd (Unit-II), Vill Mangarh, Kohara, Ludhiana, generated from acid pickling process.
Thereafter, the industry was visited by officer of the Board on 10.10.2024 and during visit violations were observed and detailed report sent to Zonal Office. Accordingly, the industry was issued notice u/s 33-A of the Water Act, 1974 alongwith show cause notice for revocation of consent to operate granted under the Water Act, 1974 with hearing before the CEE, Ludhiana on 11.12.2024, wherein it was decided as under:
1. The industry shall maintain record of water consumption in the process area/ trade effluent lifted on daily basis and keep it available in the premises.
2. The industry shall provide additional storage tank to avoid any overflow from the main pickling process tank, in case effluent is not lifted in time by re-processor/CETP operator.
3. The industry shall use fresh water from single metered supply only and shall not provide unmetered pipeline for fresh water consumption in process area in future.
4. The industry shall submit Bank Guarantee of Rs. 1.00 lac as an assurance to comply with provisions of the Water (Prevention & Control of Pollution) Act, 1974, within 15 days.
5. Environmental Engineer, Regional Office-2, Ludhiana shall visit the industry within 15 days to carry out complete water auditing of acid pickling process and send further recommendations in the matter.
6. It was made clear to the industry that in case of non-compliance as above, the Board shall feel constrained to confirm directions for closure, without any further notice/ opportunity.
In compliance of the hearing decisions, the site of the industry was again visited by officer of the Board on 02.07.2025 and it was observed as under: -
1. The trade effluent is lifted to CETP Operator on monthly basis and records of water consumption were inspected. The records of lifting of effluent have not been maintained on the register.
2. 3 No. storage tanks of 2000L, 1500L, and 500L were observed which were full upto 95%, 30%, 95% respectively. Therefore, total effluent stored was around 2800L. The last lifting of effluent was on 25/06/2025 of 3000L. Within 6 days the effluent stored was already 2800L. It shows that the industry is consuming more water than mentioned on records and agreement of lifting of effluent is only 4000L which is far less than the actual generation which could be around 15000L.
3. In the process area, the industry has installed a water meter and reading of 348.05kL was noted. The industry is using fresh water from single metered supply which got collected in storage tank of 500L. 2 No. pumps are provided with portable pipes to pump out water to be used in the process area.
4. Spillage and stagnation of acid around the process area was observed.
The industry is not complying with the decisions of personal hearing and not complying with the provisions of the Water (Prevention & Control of Pollution) Act, 1974.
Accordingly, notice to issue directions u/s 33-A of the Water Act, 1974 alongwith show cause notice for revocation of consent to operate granted under the Water Act, 1974 has been issued to industry with hearing before the CEE, Ludhiana on 11.09.2025 and after hearing it was decided as under :-
1. The industry shall not use hydrochloric acid (HCl) in its process without permission of the Board.
2. The industry shall make revised agreement with reprocessor as per the actual generation of spent sulphuric acid and submit the same to the Board, within 15 days.
3. The industry shall also increase the capacity of storage tank, accordingly.
4. The industry shall apply for varied consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 alongwith complete documents, within 15 days.
5. The industry shall get its trade effluent lifted to reprocessor regularly and maintain the record of water consumption and effluent lifted to reprocessor on daily basis.
6. The industry shall install CCTV cameras with 30 days of backup, facing towards the entry gate of the processing shed, fresh water meter installed in processing area & eluent storage tank, within 15 days. The industry shall devise a self-monitoring mechanism through CCTV cameras to ensure that no unmetered fresh water is taken for the process and no illegal disposal is made.
7. The industry shall ensure that there is only single metered supply of fresh water near the processing area and the industry shall not discharge any trade effluent into sewer or illegally through any other means.
8. The industry shall prepare a schedule for lifting of trade effluent atleast once in a fort night, so that timely disposal of the effluent could be ensured.
9. The industry shall improve the overall housekeeping in the premises of the industry within 07 days.
10. The Environmental Engineer, Regional Office-2, Ludhiana shall visit the industry to verify submissions made by the industry during the hearing, carry out audit of the waste water generation and process consent application on merits.
Now, the industry has applied for obtaining varied consent to operate under the Water Act, 1974 with requisite documents. The industry has deposited Rs. 36000/- vide e-R No. 414491608 dated 20/11/2025 under Water Act, 1974 as consent fee against the un-depreciated fixed assets of Rs. 91.76 Lacs as per CA certificate dated 13/09/2025, which is adequate upto 30/06/2030, as per Board's Office Order dated 29/10/2018.
The industry was visited by the officer of the Board on 24.12.2025 During the visit, it was observed as under:
1. The industry was in operation and engaged in the wire drawing process by involving the process of acid pickling.
2. The industry has made revised agreement with M/s JBR Technologies, Kohara, Machhiwara Road, Ludhiana @ 12000 Ltr./Month for lifting of its trade effluents.
3. The industry has installed water meter at pipeline from where fresh water is consumed in process area and reading of same was 387.58 KL.
4. The industry has provided wet process area with H2SO4 being used for pickling of wires and it has installed 7 no. of wire drawing machines out of which 2 were under maintenance.
5. The industry has maintained record of water consumption viz-a-viz trade effluent lifted to CETP till date. The details of fresh water consumption and effluent lifted to CETP, for last 4 months is attached herewith.
6. Considering evaporation losses, the record of fresh water consumption and effluent lifted were well maintained and found to be in order. During visit no unmetered supply and no bye-pass arrangements was found in the wet process area. The industry has last lifting its effluent of quantity 4000 Ltr to JBR technologies Unit-2 on 19.12.2025.
7. The industry has provided 2 no. underground storage tank of dimension 12’x3’x5’ and 4.5’x8.5’x5’ (which was full upto height 3.5’) to store the effluent and during the visit approx. 4000 Ltrs effluent was stored in storage tank.
8. The industry has installed CCTV cameras facing towards the entry gate of the processing shed, fresh water meter installed in processing area & effluent storage tank.
9. Domestic effluent generated by the industry is discharged into sewer.
10. The site of the industry falls in Industrial Area –C as per khasra no’s mentioned in the gazette notification.
11. The industry has submitted building plan prepared by Sh. Rajnish Kumar Singla approved Architect from Director of Factories, Punjab.
In the subject cited case, the industry has mentioned ground water extraction @ 1.0 KLD. Considering 25 working days per month, ground water extraction will be 25 KL/month, which is less than 300 KL/month.
It is therefore recommended that Consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 may be granted upto 30/06/2030 with suitable conditions as per policy of the Board.
(Competency – Senior Environmental Engineer)
Cost of plant & machinery = 91.76 Lacs
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