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It is submitted that the subject cited industry is a small scale green category unit.
Earlier, it is intimated that, during a routine inspection in the area, the site of the subject industry was visited by the undersigned on 25.03.2025 and the following observations were recorded:
1. The industry was in operation at the time of the visit.
2. It is engaged in manufacturing of waffles by using maida, sugar and ghee.
3. All effluent generated from the industry discharged into soakage pit including from washing of utensils.
4. No ETP was installed indicating no treatment before disposal.
5. The industry is discharging its untreated trade effluent and domestic effluent into soakage pit. As per the representative of the unit, the depth of the soakage pit is approx.. 40 ft deep indicating a serious risk of ground water contamination. It is very much clear that the industry is polluting ground water by making illegal disposal arrangement for its effluent since many years.
6. The industry has been commissioned without obtaining a Consent to Establish (NOC) from the Board and is operating without valid Consent to Operate under the Water (Prevention & Control of Pollution) Act, 1974and Air (Prevention & Control of Pollution) Act, 1981.
Accordingly, the industry was issued directions u/s 33-A of the Water Act, 1974 for disconnection of electric supply vide 3118-19 dated 15.05.2025. Further, the PSPCL authorities vide TDCO number 103/64 dated 03.07.2025 issued orders for disconnection of electric supply of the industry.
To ensure the compliance of the directions issued against the industry was visited by Er. Ajaideep Singh Kullar, JEE and Er. Harmanjeet Singh, JEE(OS) on 15.04.2026 and during visit sealing of the wet process was completed.
The industry has applied for obtaining varied consent to operate under the Water Act, 1974 & Air Act, 1981 with requisite documents under green category. The industry has deposited consent fee against the un-depreciated fixed assets of Rs. 173.46 Lacs as on 31.03.2025 as per CA certificate dated 22.05.2025, which is adequate upto 31/12/2025 under both acts, as per Board's Office Order dated 29/10/2018 after deducting penalty charges 800 % and NOC regularization fee.
Accordingly, the industry was visited by the undersigned on 13.05.2026. During the visit, it was observed as under:
1. The industry was in operation during visit even after the industry was sealed as per the directions issued against the industry.
2. The industry is involved in manufacturing of Wafers, Chocolate Products, Other Confectionery Products @ 900 kgs/day by using raw material as Maida @ 450 Kgs/day, Sugar, Vegetable, Fat @ 350 Kgs/day, Coco Powder @ 100 Kgs/day.
3. The industry has installed 01 Gas fired oven, 01 Enrobing machine, 01 Conch machine with adequate stack.
4. It has also installed LPG fired ovens, wafers making machine, mixtures, refrigerators, layer cutting machines, wrapping machines, dipping and chocolate processing machines.
5. The industry claimed that the domestic as well as washing effluent of the industry is sent into the septic tank, which is infront of the industry by the name of M/s Hanuman Traders. The claim of the industry could not be verified as it failed to open the cover of the septic tank. There is no septic tank in the premises of the industry nor any permission has been obtained by the industry to discharge its effluent out of its premises.
6. The industry informed that the effluent from the septic tank is sent to ETP located in the adjoining unit M/s Aggarwal International. However, no conveyance mechanism was shown by the industry at the time of the visit.
7. The ETP of the unit M/s Aggarwal International was defunct. All the components of ETP were dry.
8. For the disposal of treated effluent from ETP, the industry has made an agreement for the vacant plot near the industry however the main gate of the plot was locked and the adequacy of area could not be verified.
9. The industry has installed one DG set of capacity 160 KVA which is provided with canopy but inadequate stack height.
10. The industry has submitted building plan approved from competent person approved under Factories Act, 1948.
Site Suitability
There are no specific sitting guidelines for such type of industries. However, the subject cited industry is located in Industrial zone as per Master Plan (2010-2031) of Ludhiana. The industry has submitted land use classification certificate from STP, Ludhiana vide letter no. 353 dated 09.09.2025.
In the subject cited case, the industry has mentioned ground water extraction @ 1.0 KLD. Considering 25 working days per month, ground water extraction will be 25 KL/month, which is less than 300 KL/month.
The industry is intentionally the violating the directions issued by the Board and is operating even after the sealing of the machinery was carried out by the officers of the Board.
In view of the above, it is recommended that:
1. The 'Consent to Operate' applied by the industry under Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 may be refused, please.
2. Show cause notice for violations under the provisions of Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 with an opportunity of personal hearing before the Senior Environmental Engineer, Zonal Office-1, Ludhiana.
3. The PSPCL authorities may be directed to immediately disconnect the electricity supply to the industry and to explain why the supply continued despite the issuance of the TDCO by PSPCL.
Competency: Senior Environmental Engineer
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