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It is submitted that the industry is large scale red category unit and was granted consent to operate under the water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Varied/LDH2/2025/29208383 dated 19/12/2025 and the Air (Prevention & Control of Pollution) Act, 1981 vide no CTOA/Varied/LDH2/2025/29162333 dated 19/12/2025 both valid upto 18/12/2026 for manufacturing of Fasteners & Sheet Metal Parts @ 25 MTD with special conditions as under:
1. The industry shall adhere to the raw material, production, activities, processes, effluent quantities, source of air & water pollution and other consent parameters as allowed earlier in the consents granted by the Board under the Water Act, 1974 & Air Act, 1981 on 16.11.2022 & 17.10.2022, respectively.
2. The industry shall submit a clear-cut certificate from the District Town Planner, mentioning that the expansion / process modification / addition of new industrial activity in red category unit located in existing spot zone or new heat treatment units established in the newly added mixed land use area can be allowed specifically in view of the amendments made by Directorate of Town and Country Planning, Punjab vide letter no. 5780-5816 CTP(PB)/SP-135 dated 24.09.2021.
3. Further action with respect to the industry’s request for de-sealing of phosphating plant and heat treatment section established in new land shall be taken after the receipt of the clear-cut report from DTP.
4. The industry shall apply for varied consents of the Board if there is any change in process/ machinery/ raw material /products.
5. The industry shall ensure that there is no public nuisance due to its operation.
6. The industry shall obtain the necessary permissions from other Govt. departments, if any.
7. The industry shall not throw burn or burry any solid wastes in open outside premises or in drain / water bodies.
8. The industry shall promote use of alternatives of single use plastics (SUP) and awareness to discourage use of plastic, through their Corporate Environment Responsibility (CER) activities.
9. The industry shall ensure that there are no usages of single use plastic- thermocol disposable items such as water bottles / water pouches/water cups, plates, forks, spoons, straw etc. and single use decorating material made of plastic-thermocal or any other non-biodegradable material in the premises.
10. The industry shall properly handle and manage the solid wastage as per the provisions of the Municipal Solid Waste Rules 2016 and ensure that the solid waste is segregated & disposed of in an environmentally sound manner.
Now, the industry has applied for obtaining varied 'Consent to Operate' under Water Act, 1974 and Air Act, 1981 with requisite documents through OCMMS. The industry has deposited consent fee against the un-depreciated fixed assets of Rs. 4226.78 Lacs as on 12.07.2025 as per CA certificate dated 16.07.2025, which was already adequate upto 31/03/2030 under the both acts as per Board's Office Order dated 29/10/2018.
The industry was visited by the undersigned alongwith Environmental Engineer on 03.03.2026 and it was observed as under:
1. The industry was in operation during the visit.
2. The industry was engaged in the process of manufacturing Fasteners and sheet metal components.
3. The industry has installed 06 no. barrels for zinc plating plant and same was in operation. It was observed that some patches of the floor area was not impervious. The industry has installed one automatic zinc plating plant and same was in operation. The industry has also installed APCD i.e. wet scrubber for the treatment from the emissions generated from its operation. During visit, it was observed that there was no water scrubbing media in the APCD for scrubbing of emissions and motor installed with the APCD was also found in non-operational condition.
4. The industry has installed one automatic phosphating section which was in operation. As per record of this office, the industry has requested to de-seal the phosphating machinery to the Board, during visit it was observed that the phosphating section was in operation without prior permission of the Board and the industry has replaced its old sealed plant with the new automatic plant.
5. The industry has also added a new machinery i.e. geomat coating area without prior ‘Consent to establish'/ (NOC)/'Consent to Operate' under Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 from the Board.
6. The industry has installed a water meter on the fresh water supply from where it was used in the manual zinc plating section and automatic phosphating section and reading of the same was 528.04 KL.
7. The industry has installed 01 water meter on the fresh water supply from where it was used in automatic zinc plating section and 01 water meter on the line coming from condensate reuse water and the readings were 19989.0 KL and 19290.0 KL respectively.
8. The industry has installed the ETP based on ZLD system consisting of Oil & Grease Trap - Equalization Tank - Reaction Chamber - Neutralization Tank - Primary Settling Chamber - Filters - Treated Water Collection Tank leading to MEE. The industry has also installed RO system with the existing ETP and same was not in operation and not in line with the existing ETP.
9. The industry has installed 01 no. PNG based boiler of capacity 0.4 TPH with the MEE and same was in operation. The industry has made arrangement for the storage of condensate recovery water by providing two storage tanks of capacities 5000 ltr and 2000 ltr respectively. The condensate water was being used in the process area.
10. The reading of ETP outlet was 230.0 KL, MEE feed was 3201.735 m3 and condensate was 133.473 m3.
11. The industry was maintaining the record of fresh water consumption in process areas/condensate water of ETP reuse in the process. However, the same was not in sync with the actual readings on water meters.
12. The industry has also installed STP for the treatment of domestic effluent and the same is being discharged onto land for plantation after treatment through STP. The industry has installed water meter at the outlet of STP and is maintaining the record of the same.
13. It is pertinent to mention here that the industry was visited by officer of the Board of surprise basis on 29.12.2025 and during visit effluent sampling was carried out from final outlet of STP and as per analysis report the concentration of various parameters were found pH = 8.1, TSS = 173 (mg/l), TDS = 630 (mg/l), COD = 350 (mg/l), BOD = 112 (mg/l), O&G = 5.1 (mg/l). All the parameters are found within the prescribed limits of the Board except BOD.
14. The industry has provided hazardous waste storage room of size 8’ X 12” X 12’ with lock and key facility.
15. The industry has got its 10600 Kgs sludge to TSDF Nimbua vide no. 60478 dated 02.03.2026 and 4815 Kgs vide no. 60062 dated 06.02.2026.
16. The industry has provided a stock yard for the storage of e-waste, oil filter and air filters however during visit all the stock yard filled with plastic waste in haphazard manner.
17. It has provided proper hoods with nut forming machines and rotary furnaces with adequate stack heights.
18. The industry has installed D.G. sets of capacities 600 KVA and 1250 KVA with canopies and adequate stack heights.
19. During visit, it was observed that the industry has installed additional machinery in the extended land area of 3,433 sq. m., including a heat treatment continuous mesh belt machine (electrically operated), rotary furnace for gas carburizing, pit-type tempering furnace (electrically operated), and CNC/VMC machines, which were in operation.
Site suitability
1. Land area of 11,700 sqm (Existing)
As per the Notification no. 4560-71 dated 16.10.2017 issued by the Department of Town and Country Planning, Punjab, regarding the amendment in Master Plan, Ludhiana (2007–2031), it has allowed adjustment of three industrial units — namely M/s Yerik International, M/s Mitter Fastners, and M/s Freeman — from residential to industrial zone. These units were already existing in the said location (right-hand side of Khanna–Ludhiana Road, near Village Doraha) prior to the notification of the earlier Master Plan and are now recognized as part of the designated industrial zone, in view of their longstanding operation and survey verification by the District Town Planner. This amendment has been approved in the 33rd meeting of the Board held on 11.09.2017.
2. Land area of 3,433 sqm (Expansion).
There is addition of land area of 3,433 sq. m. comprised in Khewat No. 175/164, Khatoni No. 211, Khasra No. 628/1, 629/1 and the industry has submitted Municipal Council Doraha, Ludhiana’s letter no. 329 dated 03.05.2023 regarding the said land, which is reproduced as under:
“ਉਪਰੋਕਤ ਵਿਸ਼ੇ ਦੇ ਸਬੰਧ ਵਿਚ ਆਪ ਵੱਲੋਂ ਦਿੱਤੀ ਗਈ ਦਰਖਾਸਤ ਮਿਤੀ 24/04/2023 ਅਤੇ ਮਾਸਟਰ ਪਲੈਨ ਤੇ ਮਾਰਕ ਕੀਤੀ ਸਾਈਟ ਮੁਤਾਬਿਕ ਲਿਖਿਆ ਜਾਂਦਾ ਹੈ ਕਿ ਖਸਰਾ ਨੇ 628/1 *2-10, 629/1 (1- 10) ਨਗਰ ਕੌਂਸਲ ਦੀ ਹਦੂਦ ਅੰਦਰ ਮੌਜੂਦ ਮਾਸਟਰ ਪਲੈਨ ਅਨੁਸਾਰ Mixed Land use ਵਿਚ ਪੈਂਦਾ ਹੈ। ਇਹ ਆਪ ਜੀ ਨੂੰ ਸੂਚਨਾਂ ਹਿੱਤ ਹੈ।”
The industry has installed additional machinery in the extended area, including a heat treatment continuous mesh belt machine (electrically operated), rotary furnace for gas carburising, pit-type tempering furnace (electrically operated) and CNC/VMC machines. The machinery installed in the additional area falls under Green Category as per item no. 101.3 (heat treatment using furnace without cyaniding) and 101.4 (heat treatment using new technologies such as induction hardening and gas carburising).
The project proponent has already obtained approval for CLU and site plan for the additional area from Nagar Council Doraha vide letter no. 288 dated 19.03.2025, which is reproduced as under:
ਉਪਰੋਕਤ ਵਿਸ਼ੇ ਦੇ ਸਬੰਧ ਵਿਚ ਹਵਾਲੇ ਅਧੀਨ ਲਿਖਿਆ ਜਾਂਦਾ ਹੈ ਕਿ M/S Mitter Fastners (on Delhi Ludhiana Road) at Village Doraha (H.B No 244) ਦਾ ਜੋ ਨਕਸ਼ਾ ਪਹਿਲਾ ਮਿਤੀ 08-05-2000, 03-03-2004, 24-05-2006 ਪਾਸ ਕੀਤਾ ਸੀ, ਉਸ ਦਾ ਅਡਿਸ਼ਨ ਸੀ.ਐਲ.ਯੂ ਅਤੇ ਨਕਸ਼ਾ ਇਨਵੈਸਟ ਪੰਜਾਬ ਪੋਰਟਲ ਰਾਹੀਂ ਇੰਡਸਟਰੀਅਲ ਅਪਲਾਈ ਕੀਤਾ ਗਿਆ ਸੀ। ਜਿਸਨੂੰ ਨਗਰ ਕੌਸਲ ਵੱਲੋਂ ਐਸ.ਟੀ.ਪੀ ਦੀ ਪ੍ਰਵਾਨਗੀ ਉਪਰੰਤ ਪਾਸ ਕੀਤਾ ਗਿਆ ਹੈ ।
As the machinery installed in the additional area falls under Green Category as per item no. 101.3 (heat treatment using furnace without cyaniding) and 101.4 (heat treatment using new technologies such as induction hardening and gas carburising).
The industry was issued a letter by DTP, Ludhiana vide its memo no. 184 dated 20.01.2025 stating that the industry falls under the jurisdiction of MC, Doraha. As per site plan of the industry, the unit was operating at site before the notified Master Plan of Ludhiana (2007-31) and the site of the industry falls in Industrial Zone (Spot zoning) and expansion area of the industry falls under mixed land use along road front zone. As such, in this area, only green category industry is allowed. However, in this letter, the DTP, Ludhiana has not mentioned any khasra nos of the site, so that comments on the suitability of site cannot be given.
The industry has made expansion at site by adding new machinery in the additional land, which falls under mixed land use and falls within the MC limits of MC, Doraha. The overall category of the industry falls in red category. Hence, the expansion made by the industry in the newly added area (expansion land) cannot be considered at this stage.
It is therefore, recommended that varied 'Consent to Operate' under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 may be refused, please.
Competency – Worthy CEE, PBIP
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