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It is submitted that earlier the industry had obtained consent to operate in small and red category under the Water (Prevention & Control of Pollution) Act, 1974 vide CTOW/Renewal/SAS/2023/23763216 dated 16.10.2023 valid till 31.03.2024 and the Air (Prevention & Control of Pollution) Act, 1981 vide CTOA/Renewal/SAS/2023/23763206 dated 16.10.2023 valid till 30.09.2027 for manufacturing of Tractors Parts @ 1000 Numbers/Day using raw material Sheets (MS, Flats & Angle etc.) @ 3.0 T/day Paint & Thinner @ 150.0 Liter/day Chemical of Phosphating @ 5.0 Liter/day, subject to certain terms and conditions mentioned therein.
Thereafter, the industry obtained auto-renewal of consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 vide CTO/Renewal/SAS/2024/25281377dated 28.03.2024 valid till 28.03.2029, subject to certain terms and conditions mentioned therein.
Thereafter, the industry had applied fresh authorization under Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 for category 5.1 & 21.1. The site was visited on 08.09.2025 and the same was sent through OCMMS portal.
While processing the application of the industry, the following discrepancies were noted in the application:
1. The industry has indicated its source of Hazardous Waste under Category 5.1 as “from D.G. Set”; however, it has not furnished details of Hazardous Waste under Category 5.2, i.e., waste oil filters generated during repair/servicing of the D.G. Set, in its online application. The industry is required to execute an agreement with TSDF for disposal of Hazardous Waste under Category 5.2.
2. As per the process flow chart submitted, it is evident that the unit is engaged in the phosphating process. Accordingly, sludge generated from the process falls under Hazardous Waste Category 12.5 (phosphate sludge). The industry is required to execute an agreement with TSDF for disposal of Hazardous Waste under Category 12.5.
3. The industry is engaged in painting operations (using paints and thinners) and has applied for Hazardous Waste under Category 21.1 and executed an agreement with TSDF for the same. However, it has not provided details of Hazardous Waste under Category 33.1 (empty paint containers/drums), nor has it attached an agreement with authorized recyclers for lifting of HW Cat. 33.1 with the online application. This is despite the fact that a specific condition in the earlier CTO under the Air Act, 1981 (dated 21.10.2022) required the unit to execute such an agreement.
4. It is required to clarify as to where the Hazardous Wastes under Categories 5.2 (waste oil filters), 12.5 (phosphate sludge), and 33.1 (empty paint containers/drums) have been/ are being disposed of by the industry; since the industry has neither provided such details in its application from or the annual return in Form-IV nor furnished valid agreements with TSDF/authorized recyclers for disposal of these wastes.
As such, show cause notice for refusal of application for authorization under the Hazardous & Other Wastes (Management and Transboundary Movement) Rules, 2016 issued alongwith opportunity of personal hearing before the Senior Environmental Engineer (P) on 24.10.2025. The representatives of the industry attended the hearing and submitted written reply which has been taken on record. He submitted that the unit has executed agreement with authorized recycler for lifting of HW Cat. 33.1 and updated agreement with TSDF for lifting of HW Cat. 5.2 & 12.5. He assured to apply for fresh authorization incorporating the details of the said Hazardous Wastes and requested to return the application. After hearing it was decided that:-
1. The application of the industry for grant of authorization under the Hazardous & Other Wastes (Management and Transboundary Movement) Rules, 2016 be returned online.
2. The industry shall immediately apply online for fresh authorization under the Hazardous & Other Wastes (Management and Transboundary Movement) Rules, 2016 for Hazardous Waste Categories 5.1, 5.2, 12.5, 21.1 and 33.1.
3. Environmental Engineer, Regional Office, SAS Nagar shall personally visit the industry, process the said authorization application on merits and submit comments regarding as to where the Hazardous Wastes under Categories 5.2 (waste oil filters), 12.5 (phosphate sludge), and 33.1 (empty paint containers/drums) had been/ are being disposed of by the industry.
4. Further action shall be taken after receipt of report from the Regional Office, SAS Nagar.
Now, the industry has applied for fresh authorization under Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 for generation, collection, storage and disposal of hazardous waste of category 5.1 @ 0.05 KL/annum, Category 5.2 @ 0.050 T/Annum, Category 12.5 @ 0.300 T/Annum, Category 21.1 @ 2.4 T/annum and 33.1- @ 300 No./annum along with requisite documents.
The industry has submitted Membership & Waste Off take agreement (Membership No 3027) dated 16.10.2025 with Nimbua Greenfield (Punjab) Limited, Village Nimbua, Tehsil Derabassi, SAS Nagar for lifting of 21.1 Paint Sludge @ 2.4 TPA, 5.2 Wastes or residues containing oil (oil filter) @ 0.050 TPA and 12.5 Phosphate Sludge @ 0.300 TPA. The industry has submitted copy of agreement signed with M/s Rajwant Industries, Plot No. 18 P, 227, Industrial Area, Phase 9, Mohali, SAS Nagar and M/s BRS Lubricants, Plot no. D-57 Focal Point, Mandi Gobindgarh, Distt. Fatehgarh Sahib for the disposal of Hazardous waste category 5.1 (Used Oil) valid till 30.11.2028. The industry has submitted copy of agreement signed with M/s Surya Chemicals and M/s Rajwant Industries for category 33.1 valid till 04.10.2026
The industry was visited by the officer of the Board on 21.11.2025 and during the visit, it was observed that:
1. The industry was in operation and is engaged in manufacturing of tractor parts.
2. The industry has provided hazardous waste room (7’*4’*8’) for storage of hazardous waste.
3. The industry has provided danger sign outside the hazardous waste room.
4. The industry is maintaining the record. As per the records shown during visit, the last lifting of 800 kg of paint sludge was done on 19.03.2025. During visit empty paint containers @ 12 no. were stored in the hazardous waste room.
5. The industry has provided environmental data board outside its premises.
6. The industry is located in industrial area approved for setting up of such type of industries.
In view of above, if may approved, the industry may be granted authorization under Hazardous & Other Wastes (Management & Trans boundary Movement) Rules, 2016 upto 30.09.2027 with usual conditions as per the policy of the Board and the following additional conditions:
1. The industry will apply for fresh authorization under Hazardous & Other Wastes (Management & Trans boundary Movement) Rules, 2016 in case of any increase in quantity of Hazardous Waste generation.
2. The industry shall maintain proper record of generation and disposal of hazardous waste generated within the premises.
3. The industry shall not dispose any of the hazardous waste through any un authorized mode, at any point of time.
4. The industry shall not generate any other category of hazardous waste in its premise, except the hazardous wastes mentioned in this authorization.
5. The industry shall comply with the provisions of Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, at all times.
6. The industry shall ensure regular lifting of hazardous waste and also ensure that the quantity of hazardous waste generated per year shall not be stored beyond 90 days (extendable upto 180 days) in its premises at any time.
Competency: Senior Environmental Engineer (Small, Red)
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