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It is intimated that the unit was earlier issued 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.
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 Buddha 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/Buddha 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 Buddha 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.
The Milk plant was visited by the undersigned alongwith AEE RO-2, LDH 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. 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. The unit has requested to allow our unit to discharge the treated industrial wastewater to the tune of 900KLD into MC sewer considering the above facts. However, the directions were issued by the Government of Punjab u/s 5 of the EPA, Act 1986 dated 10.10.2019 to segregate the industrial effluent from the Municipal sewer. However, the industry has not given any request/ representation to the Govt. for giving the exemption to discharge its treated effluent into MC sewer.
Keeping in view of above, show cause notice for refusal of consent to operate under water Act, 1974 be issued to the industry with an opportunity of personal hearing before the Competent Authority of the Board.
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