| File Note: |
The report/ recommendations of the RO in the matter were perused in detail and the following discrepancies needs to be clarified by RO before proceeding further with application processing:
1. The project proponent has attached CA certificate mentioning its cost of fixed assets as Rs. 22.14 Crore as on 31.07.2025 wherein the cost of Land is given as Rs. 10.98 Crore, Building is given as Rs. 7.22 Crore and Plant & Machinery is given as Rs. 3.93 Crore. However, as per CA certificate attached with online application filed in 2021 (issued on 15/02/2021); the total cost of fixed assets is given as Rs. 12.17 Crore wherein the cost of Building is given as Rs. 6.50 Crore and Plant & Machinery is given as Rs. 3.30 Crore. Therefore, there has been considerable increase in fixed assets w.r.t. Land & Building and Plant & Machinery heads w.e.f. 2021. The RO is required to clarify if there has been any addition in land or annexation of any additional land by the project proponent and how it has ascertained that no addition in building and P&M has been done by the project proponent in the meanwhile.
2. Additionally, the project proponent has not submitted any latest approved building or layout plan for the site, approved by the competent authority. The RO has also not made any comments regarding this matter if there is any change/ addition in building or increase in machinery like increase in no. of service bays etc. since it has applied for varied CTOs with increase in 25% capacity. Since, the project proponent has applied for varied CTOs, approved layout plan is required/ mandated as per SSTE notification dated 02.03.2022.
3. The project proponent has proposed that due to increase in the no. of Servicing of Cars @ 75 Nos. /Day from 60 nos./day, the water consumption remains same because it has installed automatic car wash station, due to which water consumption has significantly reduced. The above proposal of the project proponent is not justified, as the total water consumption has been shown to remain the same for both the pre-cleaning and post-soap washing stages, without any technical justification, supporting calculations, or operational logics being submitted in this regard. No documentary evidence, performance data, or water balance details of the automatic car wash system have been furnished to substantiate the claimed reduction in per-vehicle water usage. Moreover, the Regional Office has endorsed the said submission without carrying out any site verification or independent assessment. The same, therefore, cannot be considered and appears to be an attempt to avoid the necessary upgradation of the existing Effluent Treatment Plant (ETP) and allied wastewater management arrangements in view of the increased servicing capacity.
4. Since the servicing capacity of the unit has been increased, an increase in the generation of hazardous waste is imminent. However, the unit has submitted only the old agreement with the authorized TSDF operator, which does not reflect the enhanced quantity of hazardous waste generation. The unit has not yet updated its TSDF agreement in accordance with the revised servicing capacity and the consequent increase in hazardous waste and is required to submit the same.
5. The last CTO under Air Act, 1981 was granted subject to condition that “The industry shall get the monitoring of APCD conducted from Board’s lab / approved lab, once in a year and shall submit analysis results to the Board.” However, as per visit of RO, the emission sample has not been carried out by the visiting officer. It is required to clarify regarding reasons for the same.
6. The Regional Office has reported that the trade effluent generated by the unit is treated through an ETP of 30 KLD capacity and disposed of on land for plantation. However, detailed clarification is required regarding the plantation developed for effluent disposal, including the total area, exact location, type of plants grown, and whether the same has been developed as per the guidelines of Karnal Technology. The present health, survival rate, and overall condition of the plantation also need to be specified.
7. Further, it is required to clarify whether the unit has installed flow meters at the source of water supply and at the washing section for monitoring water consumption. The RO shall also confirm whether records of total water consumption, process water usage, wastewater generation, and disposal through plantation are being maintained and verified during inspections. Details regarding the installation of flow meters at all relevant points and the maintenance of daily records thereof may also be furnished.
8. The Regional Office has stated at one place that the domestic effluent (05 KLD) after treatment in the septic tank is being reused/discharged into the sewer, and that the trade effluent (20 KLD) after treatment in the ETP is also being reused/discharged into the sewer. In this regard, it is required to clarify the exact mode of reuse of the domestic effluent after the septic tank, including the specific purpose for which it is being reused, if any. Further, if the treated trade effluent is being discharged into the sewer, the RO shall clarify whether the unit has obtained the requisite permission/NOC from the concerned sewerage authority for such discharge. Documentary proof in support of the same may be furnished.
9. In the last CTO granted to the unit under the Water Act, 1974 a condition was imposed to the effect that it shall obtain necessary clearance for abstraction of ground water from the Punjab Water Regulation & Development Authority (PWRDA). It is required to clarify if the unit has obtained the same (if applicable).
If approved, the RO may be directed to furnish clarification on the above observations, so that further action in the matter can be taken. |
