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Sub: Proceedings of the personal hearing given by Chairperson of the Board on 25.02.2026 w.r.t show cause notice for refusal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 - M/s The Ludhiana District Cooperative Milk Producers Union Limited, Verka Ludhiana Dairy, Ferozepur Road, Ludhiana.
The following were present:
On behalf of PPCB
Er. R.K. Ratra, CEE, Ludhiana
Er. Kuldeep Singh, SEE, ZO-2, Ludhiana
On behalf of milk plant
Sh. Daljit Singh, GM
Sh. Harjinder Singh, DGM,
Sh. Shehzad, Manager
Senior Environmental Engineer, Ludhiana brought out that the milk plant was granted consent to operate under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Varied/LDH3/2022/19775729 dated 10.11.2022, which had expired on 31.03.2023. The consent was granted 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.
The milk plant had 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 sewer after treatment in ETP, 300 KLD onto land irrigation for plants, parks, 6.2 acrs and domestic effluent @ 60 KLD settling in septic tank then treated in ETP and disposal to sewer.
The milk plant was visited by the officer of the Board on 22.03.2023 and it was observed as under:
1. The plant was in operation and engaged in the production/ processing of milk as well as milk products.
2. The plant had installed ETP of capacity 1200 KLD consisting of the components as:- Inlet O&G traps Equalization tank Hydrolyzing unit CSTR (anaerobic reactor) Coagulation/Flocculation system 03 Parallel Aeration tanks Clarifier Treated water storage tank Filter Outlet.
3. During visit, the ETP was in operation and effluent samples from the inlet and outlet of the ETP was collected. As per analysis report, the concentration of various parameters outlet are pH= 7.7, TSS =20 mg/l, COD = 42 mg/l, BOD =10 mg/l and O&G = BDL mg/l, as per the report all the parameters were found within the limits prescribed by the Board.
4. The unit was maintaining the record regarding the operation of ETP as well as quantity of effluent treated. The plant had installed separate EMF at the final outlet leading to both mode of disposals (MC sewer + Plantation area) as well as plantation area only.
5. The unit had installed OCEMS at the final outlet and the same was in operation and was showing results of parameters as pH @ 8.32, TSS @ 5.5 mg/l, COD @ 54.2 mg/l and BOD @ 15 mg/l during the visit.
6. The plant had already provided planation area of 6.0 acres (2.0 Acres as per karnal technology and 04 acre of green/ lawn area in pockets) The plantation area provided by the industry was adequate to manage the discharge @ 300 KLD.
7. The milk plant had also made arrangement for the treatment of its domestic effluent through its existing ETP.
8. The plant had provided the dedicated outlets of treated effluent for the disposal off treated effluent at each pocket of plantation area.
A meeting taken by Member Secretary of the Board to review the compliance of directions u/s 5 of EPA, 1986 issued by the Department of Science, Technology & Environment, Govt. of Punjab vide order dated 10.10.2019 for segregation of industrial effluents discharged into municipal sewer of Ludhiana held on 13.07.2022, it was decided that:
(i) All the water polluting industries (except garment washing and service stations) discharging their effluent into municipal sewer, Ludhiana shall take adequate steps to stop discharging their industrial effluent into municipal sewer, Ludhiana by 31.03.2023 and period of consent be reduced suitably to ensure compliance of the directions given by the Govt.
(ii) The above additional condition shall be imposed on all the industries having valid consent to operate under the Water Act, 1974, if not already imposed.
(iii) Directions u/s 33-A of the Water Act, 1974 be issued to the industries not having valid consent to operate under Water Act, 1974 for imposing above condition as well as to obtain consent to operate of the Board, within 15 days.
(iv) Notice u/s 33-A of the Water Act, 1974 for closure of all the scattered dyeing units of Ludhiana be issued with opportunity of personal hearing before Competent Authority.
The milk plant was discharging its wastewater to the tune of 900 KLD into sewer which was not in line with the directions issued by the Government of Punjab on 10.10.2019.
The milk plant was afforded an opportunity of personal hearing before Chairman of the Board on 09.08.2023 w.r.t show cause notice for refusal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 was issued to the milk plant with, wherein it was decided as under:
1. The milk plant shall submit complete plan for re-utilization of treated wastewater onto land for plantation / irrigation by 31.08.2023. The plan shall be comprehensive and shall include complete details w.r.t details of re-use / disposal arrangements of treated trade effluent, PERT chart for timely completion of activities to be undertaken for the project, agreement with the universities for discharge of treated wastewater onto land for plantation.
2. The proposal to be submitted by the milk plant shall be reviewed in the mid of the Month of October, 2023.
3. The milk plant shall also explore the possibility of vermi-composting so as to ensure environmentally sound handling of bio-degradable waste.
4. The application for consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 shall be decided after receiving the plan to be submitted by the industry for utilization of treated trade effluent.
The plant had submitted the point wise reply vide its letter dated 28.08.2023, which was as under:
1. Verka Ludhiana Dairy was communicating with the Authorities of PAU and GADVASU for the utilization of treated wastewater onto the land for plantation/irrigation. PAU vide its letter no. DRPAU2023/12530 dated 14/08/2023 initiated the process for the assessment of the treated water for horticulture and plantation purposes. Once clearance from Authorities of PAU was received for the Utilization of Treated water the process for the complete plan would be submitted to PPCB. The process of Approval from GADVASU was also underway. The complete process for the completion of the project would take approx. 6 months.
2. Verka Ludhiana Dairy also initiated the process for the setup of the Vermicomposting. The Discussion in this matter was under way with the Dr. Satbir of Guru Nanak Dev University for design, cost estimate, and installation in a Scientific manner.
3. We were preparing complete action plan and it would take more time for finalization. So please allow us more time for submission.
Earlier directions u/s 5 of EPA, 1986 were issued for segregation of industrial effluents discharged into municipal sewer of Ludhiana by the Department of Science, Technology & Environment, Govt. of Punjab vide order dated 10-10-2019 that:
"14 Segregation of Industrial Effluents:
i. Industrial effluents and dairy waste whether treated/ partially treated or untreated shall not be discharged into municipal sewer.
The milk plant was generating trade effluent @ 1200 KLD out of which 900 KLD was being discharged 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. Thus, the milk plant was violating the directions issued by the Government of Punjab on 10.10.2019.
Accordingly, the milk plant was afforded an opportunity of personal hearing before Chairman of the Board on 16.10.2023 w.r.t notice u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as amended in 1988, wherein it was decided that the consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 be granted to the milk plant upto 31.03.2024 with special condition that the milk plant shall not discharge its treated / untreated wastewater into sewer and shall make arrangements for completely utilizing its treated wastewater onto land for plantation.
Thereafter, the milk plant was granted consent to operate under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDH3/2023/21481899 dated 06.12.2023, which had expired on 31.03.2024. The said consent was granted 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 with special condition that the milk plant shall not discharge its treated/untreated waste water into sewer and shall make arrangements for completely utilizing its treated wastewater onto land for plantation.
The milk plant was granted Consent to Operate under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDH3/2024/25071536 dated 30/05/2024, which had expired on 30/06/2024. The said consent was granted 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 with suitable condition and additional condition that the industry shall take adequate steps to stop the discharge of its industrial effluent into MC sewer by 30.06.2024.
The milk plant had not made any arrangement to segregate the waste water of slaughter house from the Municipal sewer. The milk plant was running without obtaining consent to operate under the Water (Prevention & Control of Pollution) Act, 1974. The milk plant was not complying with decision of personal hearing afforded to it dated 09.08.2023 and 16.10.2023 and was not complying with the consent conditions granted to it. The milk plant was violating the provisions of the said Act, due to above said reasons.
Accordingly, 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, wherein it was 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.
Thereafter, 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.
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 Milk plant was visited by officer of the Board on 05.12.2025 and it was observed as under:-
1. The plant was in operation and was engaged in the production/ processing of milk as well as milk products.
2. The plant has installed ETP of treatment capacity 1200 KLD for treatment of wastewater generated from the process. The plant has made arrangement for the treatment of its domestic effluent through its existing ETP.
3. The unit has submitted a letter vide no. 18757 dated 16/12/2025 regarding the plantation and park area available with the milk plant. As per the reply, the milk plant has approx. 12352.48 Sq. m of plantation area and 12277.93 of park area for the disposal of effluent generated from the plant. Further, GADVASU University has given 3.75 land for irrigation to the verka milk plant.
4. The plant has provided dedicated outlets of treated effluent for disposal of treated effluent in each pocket of plantation area.
5. During visit, effluent sample was collected from the outlet of the ETP. As per the analysis report, the concentration of various parameters are pH = 8.1, TSS = 22 mg/l, TDS =1353 mg/l, COD = 60 mg/l, BOD = 16 mg/l and Oil & Grease = BDL. Stack emission sampling was also carried out and as the analysis report, the concentration of particulate matter is 79 mg/Nm3.
As per the directions dated 10.10.2019 issued by the Govt. of Punjab u/s 5 of E(P)A, 1986, the unit cannot discharge its treated wastewater into MC sewer.
The unit does not have any arrangement for discharge of 900 KLD of treated wastewater apart from MC sewer.
Accordingly, show cause notice for refusal of Consent to Operate under the Water (Prevention & Control of Pollution) Act, 1974 was issued to the milk plant with an opportunity of personal hearing before the Chairperson of the Board on 25.02.2026.
Sh. Daljit Singh, GM alongwith Sh. Harjinder Singh, DGM and Sh. Shehzad, Manager of the milk plant attended the hearing and submitted a written reply which was taken on record. He stated that the milk plant has installed ETP for treatment of 1200 KLD of wastewater out of which 900 KLD is treated effluent is discharged into municipal sewer and remaining is utilized onto land for plantation in the park developed by the milk plant within its premises. He informed that the ETP is efficiently operated and achieves all the parameters as prescribed by the Board. He stated that the milk plant has developed 3.04 acres as park. Since the plant is surrounded by National Highway and GADVASU, there is no provision for development of treated wastewater. Now, GADVASU has also allowed development of plantation over 0.75 acres and irrigation for fodder cultivation over an area of 3 acres. He further stated that the MD, Verka has requested to the GADVASU seeking allotment of additional land for plantation/green belt development purpose utilisation of treated wastewater. He also informed that in order to explore long term sustainable solution, the Punjab State Cooperative Milk Producer Federation Limited (Milkfed) has taken up the matter with National Dairy Development Board (NDDB) being the designated technical body for preparing and submission of a detailed Techno Economic Viability Study (TEV) regarding installation of a Zero Liquid Discharge (ZLD) system at Verka Ludhiana Dairy. He stated that the unit was established in the year 1972 and is continuously striving to ensure the quality of processing of milk and production of milk products in a clean, hygienic manner, so as to make it available to the consumers at reasonable prices. He also stated that unit is also engaged in supplying essential items to the defence forces and timely dispatch of material is critical in view of operational and national importance. During course of hearing, he also informed that the discussions at Government level are under way with GADVASU and PAU for provisioning of additional about 30 acres land for disposal of treated waste water onto land for plantation as per Karnal technology. He assured that the Ludhiana District Co-Operative Milk Producers Union Limited is taking war footing steps to assure the waste water is either discharged onto land for plantation or for ZLD at the earliest. In light of above he requested to take sympathetic and judication view in the matter and grant the varied consent to operate to the milk plant under the Water (Prevention & Control of Pollution) Act, 1974.
The chair observed that the Ludhiana District Co-Operative Milk Producers Union Limited is taking steps towards adopting alternate mode of disposal of treated waste water apart from MC sewer. It was also observed that the milk plant is providing essential services to the defence forces, so it was found appropriate to grant short term consent so as to ensure the necessary action as required for ensuring compliance of environmental laws by the unit as well as the essential service to the defence forces is not interrupted.
After hearing the representatives of the milk plant and officers of the Board and considering the material facts of the case, the Chairperson of the Board decided as under: -
1. The milk plant shall ensure that no treated / untreated / partially treated waste water is discharged into the sewer. It shall be discharged either onto land for plantation or the industry shall provide adequate Zero Liquid Discharge treatment system for handling the same.
2. The milk plant shall submit revised proposal within 30 days for discharge of treated waste water either onto land for plantation or for ZLD treatment by justifying scientifically the adequacy of each arrangement for handling the treated waste water, containing total land available with the milk plant for disposal of treated waste water onto land for plantation as well as revised timelines of installation and completion of ZLD system with technical specifications of the components of the ZLD system along with mode of disposal of treated effluent elaborating the quantity wise disposal of effluent in re-use, plantation, utilities and other proposes including the PERT Chart to demonstrate the progress mentioning civil works and component wise installation (upgradation of existing ETP, tertiary treatment, RO and MEE) and commissioning with timelines.
3. The milk plant shall initiate action for the development of proposed plantation area and start to utilize part effluent (treated) for plantation, within one month after treatment through existing ETP. As and when the extra land for disposal of waste water onto land for plantation is arranged the proportional quantum of treated waste water is diverted towards said area.
4. The unit shall also ensure that for the new plantation area to be developed for disposal of treated waste water as submitted by the representative of the milk plant during the hearing partially grown plants (atleast 5 ft. height) are utilized at the place of new saplings.
5. The industry shall install piezometers at upstream and downstream locations so that groundwater sampling is carried out as per the prescribed norms within one month.
6. Short term consent upto 30.06.2026 as per application be granted to the milk plant with above said conditions.
7. Environmental Engineer, Regional Office-3, Ludhiana shall visit the industry after 15 days and verify the compliance of above said decisions and process the consent application on merit after giving comments on the proposal of installation of ZLD to be provided by the milk plant.
8. Senior Environmental Engineer (Sh. Gursharan Dass Garg as directed to visit R-17 industries of ZO Amritsar surprisingly as per office order 55 dated 18.02.2026) shall visit the industry after 30-days, verify the compliance made by the industry and send the status report w.r.t. above said decisions.
Submitted for confirmation of decisions of the hearing and for conveying to the industry and Regional Office for compliance of above decisions, please
A copy of the above proceedings be forwarded to Er. Gursharan Dass Garg, SEE, ZO-1, Patiala for necessary action in the matter.
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