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It is submitted that the subject cited industry is a small scale Red category unit. Earlier, the industry was visited by the Er. Sahil Vinayak AEE (OS) of this office on 25.09.2025 in compliance to orders issued vide no. 1191-93 dated 22.08.2025. It is pertinent to mention here that, as per the list supplied by JBR, the industry has not got its effluent lifted during the period of January to May of 2025. As such, the industry is not getting its trade effluent lifted regularly. During visit on 25.09.2025, it was observed that:
1. During the visit, the industry was operational, including the wet process, and was engaged in the manufacturing of thread rods including zinc plating of the same.
2. The industry was operational without obtaining consent to operate under Water Act, 1974.
3. During the visit, the industry fails to produce daily basis water consumption record, JBR agreement and effluent li6ing manifests (before the month of July).
4. The industry has provided separate water meter on its water supply line to zinc plating plant and reading was 73.42 KL.
5. An effluent storage tank with a capacity of 5000 liters was provided by the unit; however, it was not accessible to check the quantity of effluent stored in it due to power cut off and a zinc plating tub was placed on it.
6. During the visit, the representative of the industry was present at the site and could not give any justification regarding non-lifting of effluent during the period of January-May.
Accordingly, the industry was given personal hearing before the Senior Environmental Engineer, Zonal Office-1, Ludhiana on 30.10.2025 w.r.t. Show cause notice for violation of provisions of Water (Prevention & Control of Pollution) Act, 1974, wherein, it was decided as under:
1. The industry shall regularly lift its trade effluent to the CETP operator in accordance with the agreement and ensure that no trade effluent is discharged into sewer or through any unauthorized means under any circumstances.
2. The industry shall maintain proper daily record of fresh water consumption and effluent lifted to the CETP and shall keep it available at site always.
3. The industry shall revise its agreement with CETP operator as per the actual generation of the effluent.
4. The industry shall provide additional storage tank to avoid any overflow from the main process tank, in case effluent is not lifted in time by re-processor/CETP operator.
5. The industry shall take up the matter with CETP operator for increasing the frequency for lifting of trade effluent, so that timely disposal of the effluent could be ensured
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 & effluent 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 Environmental Engineer, Regional Office-2, Ludhiana shall visit the industry within 03 days, verify the record maintained by the industry and process the consent application on merits.
Now, the industry has applied for obtaining fresh consent to operate under the Water Act, 1974 with requisite documents. The industry has deposited consent fee against the un-depreciated fixed assets of Rs. 28.3 Lacs as on 29/09/2025 as per CA certificate dated 29/09/2025, which is adequate upto 30/06/2030 under Water Act, 1974, as per Board's Office Order dated 29/10/2018 after deducting penalty charges 200 % and NOC regularization fee.
To verify the compliance, the industry was visited by the undersigned on 23/01/2026. During the visit, it was observed as under:
1. The industry was in operation during visit.
2. It is engaged in manufacturing of self-finished threaded bars (T-Bolts, Nuts, Threaded Bar, Scaffolding Parts) by using raw material as MS Steel (Wire Rod, Round Bar, Flat), Zinc Metal Silly, Nitric Acid, M, R and B Salt.
3. The manufacturing process of the industry is as Raw material – Drawing – Cutting – Treading – Zinc Electroplating – Packing – Dispatch.
4. The industry has now increased its agreement with M/s JBR Technology Pvt. Ltd., Ludhiana (CETP) for disposal of its trade effluent @ 2000 ltr/month to 7000 ltr/month.
5. The industry has installed water meter on pipeline leading to process area whose reading during visit was 12.50 KL.
6. Lastly, the industry has lifted its trade effluent @ 3000 Ltr to CETP on dated 16.01.2026.
7. The industry is maintaining record w.r.t. fresh water consumption for the wet process & effluent lifted to M/s JBR Technology Ltd. The audit report is enclosed herewith.
As per the record the quantity of water consumed for wet process is not in consonance as the quantity of fresh water consumption is much more than the amount of effluent lifted to JBR Tech. Pvt. Ltd.
8. Domestic effluent generated by the industry is discharged into sewer.
9. The industry has installed 03 no. CCTV cameras, facing towards the entry gate of the processing shed and effluent storage tank and fresh water meter installed in processing area.
10. The industry has now increased its storage tank capacity from 5000 ltr to 10000 Ltr. and 1500 ltr effluent was found during visit.
11. The industry has not installed any DG set in the premises.
12. The industry has submitted building plan prepared by Sh. Sukhjinder Singh approved Architect from Director of Factories, Punjab.
Site Suitability
The site of the industry falls in Industrial Area as per khasra no’s mentioned in the gazette notification.
In the subject cited case, the industry has mentioned ground water extraction @ 0.6 KLD. Considering 25 working days per month, ground water extraction will be 15 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)
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