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It is intimated that industry is a large scale red category milk processing plant and was granted consent to operate under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDH3/2024/25071536 dated 30/05/2024 for the processing of milk & milk products 900 KLD and for the disposal of trade effluent @ 1200 KLD out of which 900 KLD into sewer and remaining 300 KLD onto land for plantation after treatment in ETP and domestic effluent @ 60 KLD Partially onto land for plantation and partially into sewer after treatment in ETP which was expired on 30/06/2024 with additional condition that the industry shall take adequate steps to stop the discharge of its industrial effluent into MC sewer by 30.06.2024 and Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Varied/LDH3/2022/19058460 dated 23/08/2022 valid upto 31/03/2027
Now, the milk plant has applied for renewal of consent to operate under Water Act, 1974 for the processing of milk & milk products @ 900 Kilo Liters/day with the disposal of trade effluent @ 1200.0 KLD out of which 900 KLD to municipal sewer after treatment in ETP, 300 KLD onto land irrigation for irrigation in 9.84 acre for plantation & parks and domestic effluent @ 60 KLD disposal to sewer after treatment through ETP.
The industry had already deposited Rs. 3,50,000/- vide UTR no. SBIN418186955415 dated 05.07.2018 & Rs. 18,00,000/- vide UTR no. UTIBR52022060100485536 dated 01.06.2022 & Rs. 2,76,000/- 400111218 dated 01.11.2022 under Water Act, 1974, after deducting the NOC normalization fee is adequate upto 17.01.2028
Earlier, notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as amended in 1988 was issued to the milk plant with an opportunity of personal hearing before Chairman of the Board on 18.03.2025 postponed to 28.03.2025 in which it is decided that:
1. The milk plant shall submit a concrete report alongwith Pert Chart showing the timelines for disposal of treated wastewater in compliance of the directions issued by the Government of Punjab u/s 5 of the E(P)A, 1986, dated 10.10.2019, within 15 days in the office of Environmental Engineer, Regional Office-3 of Ludhiana.
2. The Environmental Engineer, Regional Office-3, Ludhiana shall examine the report and shall submit detailed report with clear-cut recommendations, within 01 month.
3. Further action in the matter shall be taken only after report and comments of the Environmental Engineer, Regional Office-3, Ludhiana on the report to be submitted by the Milk Plant authorities.
4. The matter shall be reviewed after 01 month.
In compliance to the decisions of personal hearing the Verka milk plant vide its letter no. 12015 dated 18/08/2025 has submitted the reply in compliance to the decisions of the above personal hearing conducted as under:-
The milk plant has 25 acres of total land area, wherein, only 6.2 acres of land is available for plantation, which is already being utilized for disposal of 300 KLD of treated wastewater. The plant is surrounded by the National Highways and adjoining GADVAS University and no further provision is left for development of more plantation area to dispose of 900 KLD of treated wastewater. He requested to discharge the excess treated wastewater @ 900 KLD into Municipal sewer. The unit has further stated as under:- (i) Comparison of characteristics of sewage of Ludhiana city and Treated Wastewater of Unit: a) The MoEF&CC vide Notification No. GSR 1265(E) dated 13.10.2017 has laid down treated sewage standards. The Board is imposing these standards for monitoring the adequacy and efficacy of the STP installed at Ludhiana, the treated sewage of which is allowed to be discharged into sewer leading to Budha Nallah. b) The nature and characteristics of untreated wastewater generated by our unit are comparable with domestic effluent. Since the Board as well as MoEF&CC has allowed to discharge the treated sewage having BOD level of 30 mg/l into inland surface water/Budha Nallah, but our unit is discharging the treated wastewater having BOD level in the range of 4 to 10 mg/l. Thus, the treated wastewater discharged by our unit into sewer, is of better quality than the treated sewage of the STPs of Ludhiana City. As such, discharge of treated wastewater by our unit into sewer, is definitely acting to improve the water quality as well as morphology of Budha Nallah despite the fact that the quantity of treated wastewater of our unit is meagre in quantum as compared to the quantity of sewage generated in Ludhiana City. (ii) Bottlenecks for restraining the discharge of Treated Industrial Wastewater into MC Sewer: As per special conditions imposed, we have been restrained to discharge the treated wastewater into sewer, as such, we are left with two options either to upgrade the existing ETP to ZLD treatment system or to make arrangement to utilize the treated wastewater onto land for irrigation purposes. The submissions with regard to these two options are given as under: Providing ZLD Treatment System: ➤ The CPCB has framed Indicative Guidelines in the month of December, 2014 on "Techno-Economic Feasibility of Implementation of Zero Liquid Discharge (ZLD) for Water Polluting Industries". ➤ In Para-6 of these guidelines, the definition of ZLD treatment system is given, which is reiterated as under: "Zero Liquid discharge refers to installation of facilities and system which will enable industrial effluent for absolute recycling of or re-use and converting solute (dissolved organic and in-organic compounds / salts) into residue in solid form by adopting method of "concentration and evaporation." ➤ In Para-8 of these guidelines, under the head of application of ZLD in industries, it has been categorically mentioned as under: "ZLD is applicable to industries having high BOD and COD load, colored bearing effluents, having metals, pesticides and other toxic / hazardous constituents." In the Document of December, 2014, the CPCB had framed ZLD treatment system guidelines for the following units: • Distillery • Tannery • Textiles • Pharmaceuticals • Dye and Dye Intermediates ➤In the guidelines of CPCB, it has been mentioned that requirement to achieve ZLD is a highly energy intensive process and by adopting ZLD the carbon foot print will be increased which is against our National Climate Change Policy. Due to this reason, CPCB has not insisted upon ZLD to industries other than Distilleries, Tanneries, Textiles, Pharmaceuticals and Dye and Dye Intermediaries. ➤Our unit is generating the wastewater ➤ Therefore, our unit is not generating the wastewater containing colour/ dyes /metals/ pesticides /other toxic / hazardous constituents, as such, the characteristics of waste water generated by our unit is not qualifying the mandate of CPCB for providing ETP based ZLD treatment system. ➤ Moreover, the ETP based on ZLD will require steam of the boiler to operate the ME/drier, resulting into increase in air pollution load viz-a-viz carbon footprint, which will be against the National Climate Change Policy. ➤ At present, the O&M cost of the ETP is about Rs. 90-100 per KL of wastewater. However, in case we convert the treatment system to ZL.D treatment system, the treatment cost will be about Rs. 300-400 per KL. of wastewater. Since our like units are in operation at various locations of the State as well as in the country. which have been allowed to discharge the treated wastewater. Therefore, after converting the existing ETP to ZLD treatment system, the cost per unit of production will increase and we will not be able to compete with such units and it will lead to make the operation of our unit non-viable. In nutshell converting the existing ETP to ZLD treatment system, will not be techno-economical viable. (iii) Utilizing Entire Quantity of Treated Wastewater onto land for Plantation/Irrigation of Green/land scaping area: • Our unit was established in the year 1972 and at that time it was in the outskirts of the Ludhiana city. Front side is located on Ludhiana-Ferozepur Road, on one side Sidhwan Canal is flowing and the remaining two are surrounded by GADVASU. The total land area of the unit is about 25 acres, out of which 18.8 acres is occupied by the industrial operations, utility, offices and ETP. Thus, we have left with only 6.2 acres of land area, out of which 2 acres of land area has been developed as per Karnal Technology and remaining area is under land scaping/ green lawns, where we are utilising about 300 KLD of treated wastewater. Thus, we have no option, other than to discharge about 900 KLD of treated industrial wastewater into Municipal sewer. (iv) Request of the Unit: It is our humble request to allow our unit to discharge the treated industrial wastewater to the tune of 900KLD into MC sewer considering the facts that: a. The unit is discharging the treated industrial wastewater having BOD level in the range of 4 to 10 mg/l, which is of better quality than the treated sewage of the STPs of Ludhiana City and of course acting to improve upon the water quality as well as morphology of Budha Nallah. b. Our unit is discharging meagre quantity of treated industrial wastewater into MC sewer as compared to the quantity of sewage generated in Ludhiana City. c. There is no land area available to develop the same as per Karnal Technology to utilize the treated industrial wastewater onto land for plantation/ irrigation as the unit is surrounded by Ludhiana-Ferozepur Road, Sidhwan Canal and premises of GADVASU. d. As per Indicative Guidelines-2014 framed by CPCB on "Techno Economic Feasibility of Implementation of Zero Liquid Discharge (ZLD) for Water Polluting Industries, the quality of wastewater generated by milk processing units is not fit to treat in the ZLD treatment system being a highly energy intensive process and can lead to increase the carbon foot print which is against our National Climate Change Policy. Besides, such treatment system may lead to become the operation of our unit non-viable.
Further, show cause notice for violation of provisions of the Water (Prevention & Control of Pollution) Act, 1974 and imposition of Environmental Compensation for non-operation of Online Continuous Effluent Monitoring System (OCEMS) was issued to the milk plant with an opportunity of personal hearing before the Chairperson of the Board on 04.11.2025 in which it is decided that:-
1. The milk plant shall ensure continuous operation of Online Continuous Effluent Monitoring System (OCEMS) and transmission of data with PPCB server, at all times.
2. The milk plant shall get itself registered and establish connectivity of OCEMS with Online Data Acquisition and Monitoring System (ODAMS) portal of CPCB (https://cems.cpcb.gov.in) before 15.11.2025, in order to ensure the compliance of the directions issued by CPCB u/s 18 (1) (b) of the Water Act, 1974 and Air Act, 1981 at and thereafter submit compliance to the Board, immediately.
3. The milk plant shall adhere to the revised OCEMS calibration protocol available at https://cpcb.nic.in/ocems2/.
4. The Board shall be constrained to take strict action against the milk plant under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 along with imposition of Environmental Compensation for intentional avoidance of data submission or data manipulation by tampering the Online Continuous Effluent Monitoring systems and non-compliance of the aforesaid decisions.
In compliance to that the milk plant has submitted a letter LMU/Engg/16980 dated 18/11/2025 stating that:
1. Verka Milk Plant Ludhiana has resolved the issue and ensures continuous transmission of Data of OCEMS with PPCB server in future.
2. Verka Milk Plant Ludhiana has registered itself on CPCB server i.e. htttps://cpeb.gov.in. Under the login ID is engg.Idh@verka.coop and further submission of online data is under process we will soon update the office of PPCB after completion as early as possible.
3. Verka Milk Plant Ludhiana has calibrated the installed the OCEMS.
The Milk plant was visited by EE of this office alongwith AEE on 05.12.2025 and following observations were observed:-
1. The plant was in operation and the same was engaged in the production/ processing of milk as well as milk products.
2. The plant has installed ETP of capacity 1200 KLD.
3. The unit is maintaining the record regarding the operation of ETP as well as quantity of effluent treated. The plant has installed separate EMF at the final outlet leading to both mode of disposals (MC sewer + Plantation area) as well as plantation area only.
4. The industry has submitted a letter vide no. 18757 dated 16/12/2025 regarding the plantation and park area available with the milk plant. It mentions that it has approx 12352.48 Sq. m of plantation area and 12277.93 of park area for the disposal of effluent generated from the plant. It also mentions that GADVASU university has given 3.75 land for irrigation to the verka milk plant.(Copy enclosed)
5. The industry has also made arrangement for the treatment of its domestic effluent through its existing ETP.
6. The Plant had provided the dedicated outlets of treated effluent for the disposal off treated effluent at each pocket of plantation area.
7. During the visit effluent sample was collected from the outlet of the ETP and as per the analysis report received from the lab, the results of various parameters are as under:- pH = 8.1, TSS = 22 mg/l, TDS =1353 mg/l, COD = 60 mg/l, BOD = 16 mg/l and Oil & Grease = BDL and a stack emission sample has also been collected the results of which are particulate matter = 79 mg/Nm3 . As per the analysis report all the parameters are found within the limits prescribed by the Board.
Keeping in view of above, considering that the unit generate only organic effluent, meets prescribed standards, lacks adequate land for further irrigation and that ZLD is not techno-economically viable and keeping in view exemptions granted to washing units for discharge into MC sewer. The undersigned is of the view that, similar exemptions may be given to the milk plant but the decision regarding this can be taken at the level of competent authority only. Therefore it is recommended that the application of industry may be decided before the Competent Authority of the Board, please.
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