| File Note: |
BRIEF BACKGROUND:
M/s Mohali Green Environment Pvt. Ltd. (SPV) along with M/s Saidpura Envirotech (developer/operator) is establishing a CETP at Village Saidpura for treatment of effluent from the pharmaceutical units of Derabassi, SAS Nagar.
The unit was earlier granted CTE vide No. CTE/Ext/SAS/2022/18761494 dated 01.07.2022 for following:
Raw Material CETP Influent @2000 Kilo Liters/Day and Domestic Wastewater @500 Kilo Liters/Day
Product CETP Treated Water @2000Kilo Liters/Day and Domestic Treated Water @500Kilo Liters/Day
By-product Primary Sludge @1335Kgs/day, Biological Sludge @2850Kgs/day and Inorganic Solids from Evaporation @49500Kgs/day
The validity of the said CTE (NOC) was further extended upto 30/6/2024 subject to certain conditions and following additional conditions:
1) The project proponent shall complete the construction and commissioning work of CETP at the site by 30/6/2024.
2) The project proponent shall submit revised Environmental Clearance from MoEC&CC as per the special condition of the previous granted consent to establish by the Board, within 02 months.
3) The project proponent shall submit proper transportation mechanism to be followed by operation of CETP, within one month.
4) The project proponent shall get the inlet wastewater quality parameters of all the member industries analyzed from reputed lab, within one month.
The site was inspected on 13.03.2024, 08.04.2024, 18.05.2024, 30.05.2024 and 11.06.2024. During each visit, it was observed that the CETP had not been commissioned within the stipulated timeline of 30.06.2024, thereby violating the conditions of the CTE. the project proponent (SEPL and MGEPL) was served show cause notice for revocation/ cancellation of consent to establish (NOC) from pollution angle granted under the provisions of the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981 vide Board's letter no. 1626-28 dated 25/6/2024 alongwith an opportunity of personal hearing before the Chairman of the Board on 12/7/2024.
After hearing the officers of the Board and the representatives of the CETP operator/ SPV, the Chairman of the Board decided as under:
1) Extension in the validity of NOC under the provisions of the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981 may be granted upto adequacy of fee subject to suitable conditions.
2) The SEPL shall complete the construction and commissioning work of CETP at the site by 31/10/2024 and MGEPL shall monitor the progress, so that CETP must completed and commissioned on or before 31/10/2024.
3) The MGEPL shall expedite the process for obtaining revised Environmental Clearance.
4) The MGEPL shall submit fool proof mechanism to lift effluent from the member units and distribution of treated trade effluent amongst the member units within one month to the O/o Environmental Engineer, Punjab Pollution Control Board, Regional Office, SAS Nagar.
5) The SEPL shall get the inlet effluent quality parameters of all the member units analysed from reputed lab, within one month and thereafter submit the same to the O/o Environmental Engineer, Punjab Pollution Control Board, Regional Office, SAS Nagar.
6) The SEPL shall execute MoU with all the member units w.r.t achieve desired inlet quality parameter of the effluent before sending it to CETP, within one month. If member units fails to meet specific inlet parameters, the said industrial unit is bound to install its own pre-treatment plant within its premises.
7) The SEPL shall submit bank guarantee from localized bank amounting to Rs. 50.0 Lakhs as an assurance to comply with the above mentioned decisions through SPV in the O/o Environmental Engineer, Punjab Pollution Control Board, Regional Office, SAS Nagar within 7-days. It was made clear to SEPL that if the company fails to complete and commission CETP by 31/10/2024, the bank guarantee amounting to Rs. 50.0 Lakhs will be encashed without giving any further notice/ opportunity.
8) Environmental Engineer, Punjab Pollution Control Board, Regional Office, SAS Nagar shall visit the site of the CETP fortnightly to monitor the progress of the CETP and thereafter send the report with recommendations to the Competent Authority.
In compliance to hearing decisions no. 1, the project proponent was granted ‘‘consent to establish’ (NOC) under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 vide no. CTE/Ext/SAS/2024/25949995 dated 25/07/2024 having validity upto 31/12/2024, subject to special conditions as mentioned above.
In compliance to hearing decision no. 2, the site was visited by officer of this office on 01.10.2024 & 11.02.2025 and was found not complying with the decisions of personal hearing given to it. Meanwhile, CETP has submitted a request letter in this office dated 29.01.2025 regarding issuance of Certified Compliance Report (CCR) to obtain revised Environmental Clearance and a request to lift additional 250 KL of LTDS effluent from member units. A report was sent to the competent authority of the Board through E-noting for non-compliance of decisions of the personal hearing.
A show cause notice was thereafter issued to the CETP vide Board's letter no. 6579-80 dated 07/03/2025 alongwith an opportunity of personal hearing before the Chairman of the Board.
The representatives of the SEPL attended the hearing and submitted a written reply which has been taken on record. They submitted that the website development of the CETP and adequate stack height of the D.G. set shall be provided within one week. Due to non-availability of two documents viz. letter of authorization of DC/ADC to SDM allowing the latter as chairman of the committee for public hearing and Certified Compliance Report (CCR) to be given by the Regional Office of the Board, CETP is not able to obtain revised environmental clearance. They further informed that GPS along with RC details are mentioned in the reply. SEPL has placed order for STP which shall be completed by 15.05.2025. The agreement to be signed with member units has been framed along with terms and conditions which is attached in the reply. They further requested to waive off the bank guarantee of Rs. 50.0 lacs imposed upon the CETP as the CETP has already invested Rs. 66.43 Cr till date on this project and the project has not yet been commissioned. The representatives of the MGEPL attended the hearing and showed a transportation plan which was found to be unsatisfactory.
It was observed by the Chairman of the Board that SEPL has invested Rs. 64.60 Cr for the establishment of the CETP upto 23.01.2025 i.e. upto last date of hearing and thereafter invested further Rs. 1.83 Cr for the development of CETP after 23.01.2025 till date i.e. 19.03.2025. After hearing the representatives of the SEPL & MGEPL and officers of the Board and considering the material aspects of the case, the Chairman of the Board decided as under: -
1) The CETP shall deposit the earlier imposed bank guarantee of Rs. 50.0 lacs by 30.04.2025.
2) The CETP shall develop the website for accessing the information to the public, by 31.03.2025.
3) The CETP shall provide adequate stack height with DG set of 1010 KVA by 31.03.2025.
4) Environmental Engineer, Regional Office, SAS Nagar shall provide Certified Compliance Report (CCR) of the compliance of the EC done by the CETP as well as assist the CETP in procurement of letter of authorization of DC/ADC to SDM allowing the latter as chairman of the committee for public hearing, by 31.03.2025.
5) The CETP shall apply for obtaining revised EC by 07.04.2025 after obtaining documents as mentioned at serial no. 4) above.
6) The CETP shall submit the copy of the final MoUs to be signed with the member units w.r.t desired inlet quality parameters of the effluent in the Regional Office, SAS Nagar of the Board by 15.04.2025.
7) MGEPL shall provide revised proper transportation plan covering all details by 15.04.2025.
8) It was made clear to the representatives of SEPL and MGEPL that if they fail to comply with all the above said decisions of personal hearings by 15.04.2025, no further relaxation regarding submission of bank guarantee of Rs. 50.0 lacs shall be given to the facility.
9) A team of the Senior Environmental Engineer, Zonal Office-1, Patiala and Environmental Engineer, Regional Office, SAS Nagar shall visit the CETP by 07.04.2025 and review the progress of above compliances to be made by SEPL and MGEPL and submit report/ recommendations immediately thereafter.
10) The CETP shall be visited by the above said team on a monthly basis and submit compliance status by CETP from time to time.
The proceedings of the hearing were conveyed to the CETP vide Board’s letter no. 7068-69 dated 31.03.2025 for compliance.
In compliance of hearing decision, the industry has been given CCR and copy of noting page in which the Deputy Commissioner, SAS Nagar has appointed SDM, Derabassi to attend the Public Hearing.
In compliance of the hearing decisions, the CETP was visited by the team comprising of SEE, ZO-1, Patiala, EE, RO, SAS Nagar, EE (UP), RO, SAS Nagar in the presence of CETP operator and MGEPL members on 03.04.2025 and during visit it was observed as under:
1) The civil construction, electrical and mechanical works of CETP components has almost been completed at the site.
2) The installation of laboratory, RO and UF has almost completed
3) The construction of internal roads, are being carried out at the site.
4) The installation of expansion work of boiler and MEE work was under process.
5) The CETP has provided separate mechanical flow meters at inlet line of LTDS, HTDS and outlet line of treated effluent.
6) The CETP has started stabilization process by taking fresh water and total LTDS effluent @ 194 KL from the units namely M/s Synthemed Labs Pvt. Ltd., Derabassi and M/s Saurav Chemical Ltd, Derabassi.
7) The CETP has provided DG set of capacity 1010 KVA with canopy and without stack.
8) During visit, the team has interacted with the members of MGEPL and SEPL. The following instructions & suggestions were given by the officials of the Board to the members of MGEPL and SEPL is as under:
a) The SEPL shall submit the transportation plan for the lifting of raw effluent from the member units as well as details of vehicles procured as per the guidelines such as GPS tracking details, RC, driver license as well as MoU with the vendor and the CETP operator for lifting of effluent.
b) The SEPL shall develop website for accessing the information to the public.
c) The MGEPL& SEPL shall appoint dedicated team to obtain & submit the revised Environmental Clearance to the Board.
d) The SEPL shall provide fool proof mechanism to lift effluent from the member units and distribution of treated trade effluent amongst the member units/ farmers.
e) The SEPL shall submit its inlet effluent quality parameters of all the member units analysed from reputed lab and also submitted MoU with the member units w.r.t achieve desired inlet quality parameter of the effluent.
f) The SEPL shall submit the bank guarantee amounting to Rs. 50 lakhs, in spite of the regular persuasions by the Board.
g) The MGEPL and SEPL shall immediately execute an agreement for collection, transportation, treatment and disposal of effluent from the member units.
The project proponent was thereafter granted consent to operate under the Water (Prevention & control of Pollution) Act, 1974 vide no. CTOW/Fresh/SAS/2025/28278041 dated 10.06.2025 and under the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Fresh/SAS/2025/27259376 dated 10.06.2025, both valid upto 31.10.2025 for treatment of Low TDS effluent @ 700 KLD in CETP of capacity @ 2000 KLD and Domestic effluent @ 3KLD shall be treated in septic tank alongwith special conditions.
1) This consent is temporarily granted for operation of CETP for LTDS effluent only.
2) The project proponent shall submit revised Environmental Clearance from MoEF&CC immediately.
3) The project proponent shall ensure that MGEPL industries shall comply with the raw effluent permissible parameters as per the agreement between SEPL and MGEPL, so that the treatment in the CETP does not get impacted and final treated effluent parameters are achieved as per PPCB norms.
4) The project proponent shall enhance the plantation in and around the site.
5) The project proponent shall maintain record w.r.t lifting of the effluent, log book of quantity and quality of discharge from the units, quantity of inflow into CETP, details of the treatment at each stage of CETP, quantity of treated water recycled, reused within the units and in the plant.
The project proponent has applied renewal of consent to operate under the Water (Prevention & control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981. However, on scrutiny of the application and replies submitted, the following key deficiencies persist:
(i) No compliance to the most crucial direction of depositing the ₹50 lakh bank guarantee;
(ii) Revised Environmental Clearance still not submitted;
(iii) Annexure-3 relating to inlet norms under DBO agreement not furnished;
(iv) Several CTO conditions complied only partly;
(v) Website not updated with operational details;
(vi) MoUs with member units incomplete (quantity/quality caps missing);
(vii) STP not installed;
(viii) In-house laboratory incapable of testing the full range of parameters prescribed by MoEF&CC notification dated 09.09.2024;
(ix) No proper record of stage-wise flow, chemicals, energy, recycle/reuse etc.
The site of CETP was visited by the officer of the Board on 30.09.2025 and during visit it was observed as under:
1) The civil construction, electrical and mechanical works of CETP components has been completed at the site. The CETP was under stabilization. No effluent has been discharged from the outlet. The installation of laboratory, RO and UF has been completed.The construction work of internal roads has been completed.
2) The CETP is having only one multifuel (rice husk, briquette) fired boiler of capacity 15 TPH. CETP has provided trema cyclone followed by wet scrubber as APCD with it. CETP has provided stack alongwith sampling arrangements.
3) The CETP has provided DG set of capacity 1010 KVA with canopy and with adequate stack height.
4) CETP has provided plantation along the boundary. There is still vacant space in the CETP where plantation can be developed.
5) The CETP has provided separate mechanical flow meters at inlet line of LTDS, HTDS and outlet line of treated effluent. The project proponent has maintained record w.r.t lifting of the effluent from the effluent generating industries, in the said record name of industry, manifest number, quantity lifted on time and date & low TDS effluent has been mentioned. However, the result of testing of parameter likes (PH, BOD, COD, TDS, TSS, Amm. Nitrogen etc has not been mentioned). The PP has the facility to test Ph, TSS, TDS, COD, O&G only. The PP has not produced record of chemical used for treatment, flowmeter and energy meter provided at various stage of CETP quantity of treated water recycled, reused within the units and in the plant. The PP does not have the facility for in house testing of parameter deciding the nature of effluent i.e. HTDS or LTDS also to test outlet parameter as prescribed in MOEF&CC notification dated 09.09.2024.
6) The project proponent has developed the website with web adress https://saidpura.resustainability.com/ . CETP has uploaded copy of Environmental Clearance, Environment Statement in Form V for year 2024-25 and Annual return under HWM rules in Form IV for year 2024-25. CETP has not uploaded the record of CETP operation
7) CETP has shared copy of draft service agreement for treatment and recycling of effluents from member units. However in the said agreement maximum quantity of effluent in a day and also quality of parameter needs to be mentioned.
8) CETP has not yet installed STP as proposed in phase 1.
9) The CETP has started stabilization process by taking fresh water and total LTDS effluent @ 454 KL from the units namely M/s Synthemed Labs Pvt. Ltd., Derabassi @ 240 KL, M/s Saurav Chemical Ltd, Derabassi @ 54 KL, Akum Lifesciences-1, Derabassi @ 40 KL and STP Derabassi @ 120 KL (activated sludge).
10) The CETP has submitted transportation plan alongwith GPS routes for transportation from 14 nos. member industries, showing the time to be taken from each individual member by the tanker ranging from 6 minutes (for M/s Saurav Chemicals Ltd.) to 38 minutes (for M/s Cadchem Laboratories Ltd.) i.e. the tankers of CETP can visit each of the 14 member industries in one day to collect the effluent. The GPS enabled vehicles have been proposed for lifting of effluent.
11) CETP has failed to deposit Bank Guarantee of Rs 50.0 lacs as decided in the hearing given before the Chairman of the Board.
12) CETP has failed to submit revised Environment Clearance to the Board and approved building plan from competent authority till date.
13) CETP has not submitted compliance to achieve stringent standards prescribed (for the parameters Ph, BOD, COD, TSS, TDS, Oil and grease, Bio-assay test, Nitrates, Arsenic, Hexavalent chromium, Total chromium, Lead, Cyanide, Zinc, Mercury, Copper, Nickel, Phenolic compounds, Sulphides, Mercury, Phosphates) in MOEF&CC notification dated 09.09.2024 for discharge of wastewater by CETP.
It is evident that the CETP has repeatedly failed to comply with the mandatory conditions of the CTEs/CTOs, as well as the specific directions issued during multiple personal hearings before the Hon’ble Chairman. Critical deficiencies including non-submission of the revised Environmental Clearance, non-deposit of the ₹50.00 lakh bank guarantee, non-installation of the STP, incomplete MoUs with member units, inadequate laboratory facilities to meet the parameters prescribed under MoEF&CC notification dated 09.09.2024, non-submission of approved building plan, gaps in transportation mechanism, and non-uploading of essential operational data continue to remain unaddressed despite repeated opportunities, inspections and instructions.
The competent authority has decided to take stringent action against the CETP by issuing directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 and u/s 31-A of the Air (Prevention & Control of Pollution) Act, 1981 as well as refuse the application of the CETP for renewal of CTOs under both the Water Act, 1974 and Air Act, 1981, after affording an opportunity of personal hearing to it.
Meanwhile, the project proponent withdraw the consent applications on 03.12.2025.
Accordingly, notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 & u/s 31-A of the Air (Prevention & Control of Pollution) Act, 1981 issued vide Board’s letter no. 6398 dated 05.12.2025 alongwith opportunity to appear in person before the Chairperson of the Board at Punjab Pollution Control Board, Vatavaran Bhawan, Nabha Road, Patiala on 18.12.2025, with the following proposed directions:
i) A suitable Environmental Compensation (EC) be imposed on the CETP operators (MGEPL/SEPL) for continued non-compliance of the Board's directions and violation of the Water Act, 1974 & the Air Act, 1981.
However, the hearing could not be conducted on 18.12.2025, due to administrative reasons and it has been decided to give another opportunity of personal hearing on 22.12.2025 to the authority.
The hearing was not attended by the CETP operator or any of his representatives and next date of hearing to be scheduled.
PRESENT STATUS:
Now, the project proponent has applied renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 along with requisite documents. The project proponent has also applied expansion of consent to establish under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981.
Raw Material CETP Influent LTDS 1400 KLD, CETP Influent HTDS @600 KLD and Domestic Wastewater @500 KLD
Product CETP Influent LTDS 1400 KLD, CETP Influent HTDS @600 KLD and Domestic Wastewater @500 KLD
By-product Primary Sludge @1335Kgs/day, Biological Sludge @2850Kgs/day and Inorganic Solids from Evaporation @49500Kgs/day
As per calculation of fees submitted by RO, the consent fee under the Water Act, 1974 and Air Act, 1981 are adequate till 24.11.2026. But, the CTE fees deposited is inadequate and was only valid till 31.12.2025.
The project proponent has obtained amended Environmental Clearance vide no. File No: 21-47/2023-IA.III dated 01.12.2025 by the Government of India Ministry of Environment, Forest and Climate Change IA Division for expansion of boiler from 10 TPH to 22 TPH. This is establishment of Common Effluent Treatment Plant (CETP) at Saidpura Village, Sahibzada Ajit Singh (SAS) Naga District, Panjab of 5 MLD capacity (2 MLD in first phase for present requirement and 3 MLD in second phase for future requirement) for effluent generated by Pharmaceutical industries in the Free Enterprising Zone of Dera Bassi along with the Sewage Treatment Plant (STP) of 7 MLD (3.5 MLD in first phase for present requirement and 3.5 MLD in second phase for future requirement) for sewage of nearby villages. The total plot area is 7.0 acres (Phase I is 3.2 acres and Phase II is 3.8 acres). Built-up area for Phase I is 2.37 acres.
The Bank Guarantee amounting to Rs. 50 lakh imposed on the CETP in the personal hearing dated 12.07.2024 in the security to complete the work till date 30.04.2025. However, the project proponent has not submitted Bank Guarantee till date and the complete the work of CETP after the date completion date mentioned in the hearing decision i.e. 30.04.2025.
The site of CETP was visited by the EE & AEE of RO on 10.12.2025 and during visit it was observed as under:
1) The civil construction, electrical and mechanical works of CETP components has been completed at the site. The CETP was under stabilization. No effluent has been discharged from the outlet. The installation of laboratory, RO and UF has been completed. The construction work of internal roads has been completed.
2) The CETP is having only one multifuel (rice husk, briquette) fired boiler of capacity 15 TPH. CETP has provided trema cyclone followed by wet scrubber as APCD with it. CETP has provided stack alongwith sampling arrangements. However the CETP is required to submit adequacy certificate of air pollution control device installed.
3) The CETP has provided DG set of capacity 1010 KVA with canopy and with adequate stack height.
4) CETP has provided plantation along the boundary. There is still vacant space in the CETP where plantation can be developed.
5) The CETP has provided separate mechanical flow meters at inlet line of LTDS, HTDS and outlet line of treated effluent. The project proponent has maintained record w.r.t lifting of the effluent from the effluent generating industries, in the said record name of industry, manifest number, quantity lifted on time and date & low TDS effluent has been mentioned. However, the result of testing of parameter likes (PH, BOD, COD, TDS, TSS, Amm. Nitrogen etc has not been mentioned). The PP has the facility to test Ph, TSS, TDS, COD, O&G only. The PP has not produced record of chemical used for treatment, flowmeter and energy meter provided at various stage of CETP quantity of treated water recycled, reused within the units and in the plant. The PP does not have the facility for in house testing of parameter deciding the nature of effluent i.e. HTDS or LTDS also to test outlet parameter as prescribed in MOEF&CC notification dated 09.09.2024.
6) The project proponent has developed the website with web adress https://saidpura.resustainability.com/ . CETP has uploaded copy of Environmental Clearance, Environment Statement in Form V for year 2024-25 and Annual return under HWM rules in Form IV for year 2024-25. CETP has not uploaded the record of CETP operation.
7) CETP has shared copy of draft service agreement for treatment and recycling of effluents from member units. However in the said agreement maximum quantity of effluent in a day and also quality of parameter needs to be mentioned.
8) CETP has procured skid mounted STP of 500 KLD and same was lying outside its premises near Main gate. However the same is yet to be installed as proposed in phase 1. The domestic wastewater line of Village Saidpura is yet to be laid.
9) The CETP has started stabilization process by taking fresh water and total LTDS effluent @ 454 KL from the units namely M/s Synthemed Labs Pvt. Ltd., Derabassi @ 240 KL, M/s Saurav Chemical Ltd, Derabassi @ 54 KL, Akum Lifesciences-1, Derabassi @ 40 KL and STP Derabassi @ 120 KL (activated sludge).
10) The CETP has submitted transportation plan alongwith GPS routes for transportation from 14 nos. member industries, showing the time to be taken from each individual member by the tanker ranging from 6 minutes (for M/s Saurav Chemicals Ltd.) to 38 minutes (for M/s Cadchem Laboratories Ltd.) i.e. the tankers of CETP can visit each of the 14 member industries in one day to collect the effluent. The GPS enabled vehicles have been proposed for lifting of effluent.
11) CETP has failed to deposit Bank Guarantee of Rs 50.0 lacs as decided in the hearing given before the Chairman of the Board. The representative of the CETP informed that Bank Guarantee was imposed as an assurance to complete the work by 30.04.2025.
12) CETP has failed to submit approved building plan from competent authority till date.
13) CETP has not submitted compliance to achieve stringent standards prescribed (for the parameters Ph, BOD, COD, TSS, TDS, Oil and grease, Bio-assay test, Nitrates, Arsenic, Hexavalent chromium, Total chromium, Lead, Cyanide, Zinc, Mercury, Copper, Nickel, Phenolic compounds, Sulphides, Mercury, Phosphates) in MOEF&CC notification dated 09.09.2024 for discharge of wastewater by CETP.
The RO has recommended that above mentioned observations be kindly considered during the course of Personal hearing of the CETP please.
In consideration of the above report; if approved, the competent authority be recommended that the CETP operator be given another opportunity of hearing and in the said hearing, the responsible member of SPV be also called upon to attend the hearing.
Comp.: Hon’ble Chairperson |
