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It is submitted that the subject cited industry is a small scale Red category unit. Earlier, the site of subject cited industry was visited by the AEE (OS) of this office on 16.08.2024 and during visit it was observed that:
1. During the visit the industry was in operation and engaged in Auto black process.
2. The industry could not produce agreement made with CETP operator for lifting of its trade effluent.
3. The industry has not installed any water meter on its source of fresh water in process area.
4. The industry is disposing its untreated effluent directly into sewer from the wet process area.
5. The industry has not submitted any documentary proof regarding the date of commissioning.
6. The industry has commissioned its unit without NOC/consents of the Board and is operating without the consent to operate under Water Act, 1974 & Air Act, 1981 of the Board.
Accordingly, industry was issued directions u/s 33-A of Water (Prevention & Control of Pollution) Act, 1974 & u/s 31-A of Air (Prevention & Control of Pollution) Act, 1981 vide letter no. 5059-60 dated 05/09/2024 to PSPCL for disconnection of electricity. In compliance, PSPCL authorities has disconnected the electric supply of the unit vide TDCO no. 103/12 dated 24/09/2024.
After making compliance, the industry was granted 'Consent to Operate' under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Fresh/LDH2/2025/28252664 dated 09/04/2025 and under the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Fresh/LDH2/2025/28252676 dated 09/04/2025 for short period of six months i.e. upto 08/10/2025.
Now, the industry has applied for obtaining fresh consent to operate under the Water Act, 1974 with requisite documents. The industry has already deposited consent fee against the un-depreciated fixed assets of Rs. 4.10 Lacs as on 31/03/2025 as per CA certificate dated 19/02/2026, which is already adequate upto 30/06/2029 under Water Act, 1974, as per Board's Office Order dated 29/10/2018.
Accordingly, the industry was visited by the undersigned on 19/03/2026. During the visit, it was observed as under:
1. The industry was in operation during visit.
2. It is engaged in process of adding Auto Black finish of Hardware Goods @ 2.0 TPD by using raw material as Caustic @ 2 Kgs/day, Acid @ 4 Kgs/day and Sodium @ 4 Kgs/day.
3. The manufacturing process of the industry is as Raw material (hardware goods) - Cleaning with acid - Washing with fresh water – Drying - Auto Black – Cooling – Ready – Packing – Dispatch.
4. The industry has installed 01 no. oil based auto black furnace, 01 pickling section and 01 water rinse.
5. The industry has not provided APCD with the furnace.
6. The industry has made agreement with M/s JBR Technology Pvt. Ltd., Ludhiana (CETP) for disposal of its trade effluent @ 4000 ltr/month on 11.02.2025.
7. The industry has installed water meter on pipeline leading to process area whose reading during visit was 1.93 KL.
8. Lastly, the industry was lifted its trade effluent to CETP @ 2000 ltr on dated 23.02.2026.
9. The industry has only maintained the record till 24.02.2026 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 and seems to be fabricated.
10. No bye pass of effluent was observed during visit.
11. The industry has not installed any CCTV cameras.
12. The industry has provided 01 no. storage tank of capacity 2000 ltr.
13. Domestic effluent generated by the industry is discharged into sewer.
14. The industry has submitted building plan prepared by Sh. Sukhjeet Singh approved Architect from Director of Factories, Punjab.
The site of the industry falls under industrial zone as per Master Plan, Ludhiana. The industry has submitted MC Ludhiana letter no. 582 dated 07/03/2025, which is reproduced as under:
ਉਪਰੋਕਤ ਵਿਸ਼ੇ ਸਬੰਧੀ ਆਪ ਵੱਲੋਂ ਮਿਤੀ 21-02-2025 ਨੂੰ ਦਿੱਤੇ ਬੇਨਤੀ ਪੱਤਰ ਦੇ ਸਬੰਧ ਵਿੱਚ ਦੱਸਿਆ ਜਾਂਦਾ ਹੈ ਕਿ ਆਪ ਦੀ ਸਾਈਟ ਬੀ-29, ਖਸਰਾ ਨੰ 1041-1042-1044-1203/1045-1204/1045-1205/1045, ਖਾਤਾ ਨੰ. 109/114, ਵਸੀਕਾ ਨੰ. 9209 ਮਿਤੀ 12-03-2014 ਵਾਕਿਆ ਪਿੰਡ ਲੁਹਾਰਾ ਹਦਬਸਤ ਨੰ: 260 ਤਹਿਸੀਲ ਵਾ ਜਿਲ੍ਹਾ ਲੁਧਿਆਣਾ ਰਕਬਾ 100 ਵ ਗਜ ਦਾ ਜੋ ਏਰੀਆ ਹੈ, ਇਹ ਸਾਈਟ ਪ੍ਰਵਾਨਤ ਮਾਸਟਰ ਪਲੈਨ ਅਨੁਸਾਰ ਇੰਡਸਟਰੀਅਲ ਜੋਨ ਅਧੀਨ ਪੈਂਦੀ ਹੈ।
In the subject cited case, the industry has mentioned ground water extraction @ 0.66 KLD. Considering 25 working days per month, ground water extraction will be 16.5 KL/month, which is less than 300 KL/month.
It is pertinent to mention here that in case of M/s Kalsi Sons Fabricators, #13581, Street No. 7, Parbhat Nagar, Dholewal, Ludhiana, Competent Authority of the Board has decided not to restore electric connection in such cases till such small scale illegal industry deposit Rs 1.0 lac as environment compensation.
The industry has earlier deposited EC amounting to Rs. 1 lac vide R no. 60/5568 dated 04.04.2025 in this office.
It is therefore recommended that:
1. The industry may be imposed an environmental compensation amounting to Rs. 1.0 Lakh being a small scale unit as approved by the Competent Authority in the case M/s Kalsi Sons Fabricators.
2. Consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 may be refused with suitable conditions as per policy of the Board. (Competency: Senior Environmental Engineer)
3. PSPCL authorities may be directed to disconnect the electric connection available with the industry. (Competency: Chief Environmental Engineer)
4. Environmental Engineer, RO-2, Ludhiana may be directed to seal the machinery.
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