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It is submitted that the industry is small scale red category unit. Earlier the industry was granted consent to operate under the Water Act, 1974 vide letter no. CTOW/Fresh/LDH4/2020/13315726 dated 21/12/2020 valid upto 30/06/2025 and Air Act, 1981, vide letter no. CTOA/Renewal/LDH4/2020/13315044 dated 21/12/2020 valid upto 30/06/2025, for manufacturing of Nuts/Bolts Finishing @2metric Tonnes/Day. Earlier, the industry was visited by the officer of the Board on 29.08.2025 and observed that the industry is a small-scale red category unit. The industry was in operation and is engaged in process of auto blacking after pickling using HCL. The industry has installed oil fired furnace of capacity 02 MTD along with water scrubber as APCD. During visit the APCD was not in operation. The industry has installed 01 no. D.G. set of capacity 40 KVA with canopy and adequate stack height. The industry has installed water meter on fresh water source in the process area and reading noted as 280.14 KL. The industry has made an agreement with CETP operator for lifting of trade effluent @ 13000 Ltr./month. The industry has provided 01 storage tank of capacity 20000 Ltrs. which is almost full of its capacity. The industry has failed to produce the record of fresh water consumption viz-a-viz effluent lifted during the visit. The industry has stored Hazardous waste (empty canes) in open area in the industry premises. The industry is operating its unit without valid Consents of the Board. As such the industry is not complying with the provisions of the Water Act, 1974, Air Act, 1981 and HWM Rules, 2016. As such, the industry is violating with the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981. The matter has been considered by the Competent Authority of the Board and it has been decided to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as amended in 1988 and u/s 31-A of the Air (Prevention & Control of Pollution) Act, 1981 as amended in 1987 with an opportunity of personal hearing before Chief Environmental Engineer, Ludhiana. Accordingly Notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as amended in 1988 and u/s 31-A of the Air (Prevention & Control of Pollution) Act, 1981 as amended in 1987 was issued to the industry with an opportunity of personal hearing before Chief Environmental Engineer, Ludhiana on 10.10.2025, wherein it was decided as under: 1. The industry shall not use HCL as the cleaning / de-rusting agent. 2. The industry shall lift the sludge collected in the effluent collection tank to TSDF Nimbua, within 07 days, so that effluent collection tank of 20,000 Ltr. can be fully utilized for storage of effluent generated from the process. 3. The industry shall reassess the effluent quantities and make revised agreement with CETP operator, if required, as per the actual generation of effluent and submit the same to the Board, within 15 days. 4. The industry shall prepare a revised lifting schedule with the CETP operator and to ensure that the lifting shall be made atleast 4-5 times in a month and take a written assurance from the operator. 5. The industry shall install CCTV cameras with 30 days backup within 15 days, facing towards a) entry gate of processing shed b) flow meter provided on freshwater supply provided for processing activities c) effluent storage tanks d) any other suitable point deemed fit to ensure that whole of the water consumed is metered and whole of the trade effluent is lifted to CETP operator The industry shall maintain in-house monitoring mechanism through mobile phone/ office screen for visualizing the above CCTV cameras so as to ensure that no intentional or unintentional lapse happens and no untreated effluent is bye-passed. 6. The industry shall ensure that there is no unauthorized mode of wastewater disposal. The industry shall ensure that there is only a single fresh water supply for the industry and meters shall be provided for the water being used for process. 7. The industry shall maintain proper record of fresh water consumption and trade effluent generated & effluent got lifted by the CETP operator on daily basis. 8. The record shall be available in the industry at all times, kept in a designated box in the process area to ensure easy and ready accessibility to record keeper as well as regulatory authority. In case, the record is not maintained by the industry, it will be presumed that the industry is disposing of its wastewater illegally and action as deemed fit shall be taken in accordance with law. 9. The industry shall provide stand-by motor/ arrangement and ensure that APCD installed with furnace always remain in operative condition and shall be operated regularly and efficiently to achieve the emission standards prescribed by the Board. 10. The industry shall install a separate energy meter (electric sub-meter) with the Air Pollution Control Device and shall maintain record of operation of the same. 11. The industry shall provide proper arrangements for storage of hazardous waste of various categories, shall re-assess the categories of hazardous waste generated from its premises and shall apply for authorization under the Hazardous & Other Wastes (Management and Trans-boundary *Movement) Rules, 2016. 12. The industry shall apply for consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981, within 07 days. 13. The Environmental Engineer, Regional Office-4, Ludhiana shall visit the industry to verify contentions of the industry, carry out audit of the waste water generation, submit compliances with respect to the decisions alongwith fresh recommendations and process consent applications on merit.
Thereafter the industry has applied for varied consent to operate under the Water Act, 1974 through OCMMS.
Accordingly the show cause notice for refusal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and under the Air (Prevention & Control of Pollution) Act, 1981 with opportunity of filing reply within 07 days, due to noncompliance of hearing decisions.
In this regard the industry has submitted reply, which was not satisfactory.
Accordingly, the varied consent to operate under the Water Act, 1974 applied by the industry was refused vide no. CTOW/Varied/LDH4/2026/30510724 dated 13.01.2026.
Now, the industry has applied for varied consent to operate under the Water Act, 1974 through OCMMS for NUTS & BOLTS FINISHING @ 2.0 MTD and discharge of trade effluent @ 0.5 lifted by the CETP operator and domestic effluent @ 0.1 into sewer.
The industry has deposited CTO fee of amounting to Rs. 7000/- vide R.no. 25428759 dated 30.05.2025 under the Water Act, 1974 and Rs. 7000/- vide R.no. 909295626 dated 30.05.2025 under the Air Act, 1981, which is adequate upto 30.06.2030.
The industry was visited by the officer of this office on 27.11.2025 and it was observed as under:-
1. The industry was in operation and is engaged in process of auto blacking after pickling using HCL.
2. The industry has installed oil fired furnace of capacity 02 MTD along with water scrubber as APCD.
3. The industry has installed water meter on fresh water source in the process area and reading noted as 360.71 KL.
4. The industry has made an agreement with CETP operator for lifting of trade effluent @ 13000 Ltr./month.
5. The industry has provided 01 storage tank of capacity 20000 Ltrs. and approx. 12000 ltr. lying stored.
6. The industry has maintained the record of fresh water consumption viz-a-viz effluent lifted. As per the record, the reading on 01.10.2025 was 291.53 KL and during visit was 360.71 KL. As such the industry has consumed fresh water @ 69.18 KL and lifted out 67.5 KL during this period, which is found inconsonance after assuming the evaporation loss. No bypass or unauthorized mode of disposal has been observed during the visit.
7. The industry has installed CCTV cameras with 30 days backup, facing towards a) entry gate of processing shed b) flow meter provided on freshwater supply provided for processing activities c) effluent storage tanks and whole process area.
8. The industry is located in designated area as per Master Plan Ludhiana i.e., Phase-6, Focal Point, Ludhiana. The site is suitable for such type of industry.
9. The industry has not provided adequate arrangement for storing the trade effluent generated till the time agreement is made; this confirms that the industry will be lifting spent HCL to CETP Ludhiana only.
10. The industry has stored hazardous waste of category 33.1 (empty cans) in unscientific manner. The housekeeping of the industry is very poor. The industry has informed during the visit that they will lift hazardous waste within 2-3 days.
11. The industry has failed to apply under varied Authorization for lifting out hazardous waste empty cans (category 5.1).
12. As such the industry is not complying with the provisions of the Water Act, 1974 and HWM Rules, 2016 as well as hearing decisions.
In view of above it is recommended that the consent to operate under the Water Act, 1974 be refused alongwith show cause notice for violation of the provisions of the HWM Rules, 2016, please.
Competency: SEE
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