From UN/SBC Technical Guidelines on Co-processing of Hazardous Waste in Cement Kilns To a Co-processing Legal Frame in India

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1 Cement Manufacturers Association CMA-IIP INTERNATIONAL CONFERENCE ON ENHANCED USAGE OF ALTERNATE FUELS & RAW MATERIALS (AFR) - CO-PROCESSING IN CEMENT PLANTS From UN/SBC Technical Guidelines on Co-processing of Hazardous Waste in Cement Kilns To a Co-processing Legal Frame in India Jean-Pierre Degré Cementis August 2013

2 Jean-Pierre Degré Chemist & Geologist Engineer, 41 years experience with Holcim. > September 2011: Partner Cementis ( : Holcim Belgium : Senior Vice-President Head of the Alternatives Resources Division Holcim Group Support In charge of the worldwide Wastes to Resources strategy Implementation in more than 40 countries At the base of the worldwide development and recognition of the co-processing concept: using wastes as Alternatives Resources in Resource s Intensives Industries Expert in the development of low/neutral CO2 cementitious binders production : Development Manager Holcim France and BNL : BD Manager Holcim FrBNL and development of the co-processing concept : Expert in Clinker & Cement production processes, thermal efficiencies and environmental strategies Some other assignments: Expert delegate to the UN/SBC Expert in waste management to the European Commission Consultant as world expert for energy efficiency in clinker process

3 Summary 1 The UN/SBC Guidelines on Co-processing History International acceptance 2 Co-processing: Definitions and Position within the WMH 3 Co-Processing legal frame & permitting processes Home work and wastes / AFR acceptances criteria s Environmental, end-product monitoring & external audits 4 Co-processing in India: The way to go 5 Discussions

4 Unep / Basel Convention The Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and their Disposal is the most comprehensive global environmental treaty on hazardous and other wastes. Basel Convention was negotiated in the late 1980s, and entered into force in Basel Convention acts is based on : International and validated agreements, facilitating sound waste management. Technical Guidelines submission, to promoting regulation and control of sound technologies for waste treatment / disposal.

5 International Recognition of the Co-processing Concept Process started in 2008 achieved in 2012 COP 9 : Bali DECISION IX/17: Review of other selected technical guidelines pursuant to decision VIII/17, e.g., on incineration on land (D10), specially engineered landfill (D5) and wastes collected from households (Y46) Specific co-processing guidelines are considered. A voluntary country is needed to draft and propose guidelines to the rest of Basel Convention community (more than 190 countries). COP 10: Cartagena 2011 The draft proposal from Chile, Volunteer Country, has been fully endorsed by all the members countries Guidelines for Co-processing of Hazardous Wastes in Cement Kilns

6 UN/SBC TG s Co-processing Technical Guidelines are now the OFFICIAL RECOMMENDATION of United Nations: Co-processing is officially validated as a sound and recommended technology for hazardous and non-hazardous waste management, pop s related wastes included Co-processing is consolidated as recovery operation in the waste management hierarchy, International and technical criteria / references are now available for local legal frames, Minimum standards are now defined, limiting informal and non-low standard players.

7 International validity Technical Guidelines on Co-processing are based on Best Available Technologies (BAT) and Best Environmental Practices (BEP). Main references: US EPA GIZ Holcim European Union Stockholm Convention Between others.

8 Co-processing Now fully recognized!!!

9 Example 1 - South Africa - National policy Key definitions

10 Example 2 - Chile National policy now integrating co-processing

11 Co-processing is a THE alternative to save our environment and improve industry ecological footprint Co-Processing is the use of waste materials in RII s (Resources Intensives Industrial processes) such as cement, lime, steel, glasses, power generation etc...instead of fossil fuels & natural resources Applied locally Co-processing benefits to: Upgrades waste management within the waste hierarchy Reduces wastes health & environmental impacts Maintains and improves the industrial sector's competitiveness Decreases (largely) the costs of waste management Improves all human and technical-economical factors

12 Co-processing must be specifically positioned in the Waste Management Hierarchy as a combined option to recover mineral and organic parts of the wastes Avoidance & Reduction Reuse Recovery Main drivers: - Life Cycle Assessment - Decision tree process 100 % material recovery Co-processing Recovery 100 % Energy recovery Disposal Incineration / co-incineration with energy recovery Landfilling

13 UN/TG s on Co-processing: A complete value chain approach. Acceptance criteria. Waste pre-qualification Quality Control minimum requirements Waste acceptance and reception Storage requirements Pre-processing Operational and environmental controls OH&S Design Safety Co-processing Operational Environmental controls OH&S Design Safety End product quality

14 How to proceed in India..? Some Recommendations. Co-processing represent a huge opportunity in India The lack of high quality limestone and fossils fuels will request the Indian Cement Industry to diversify its resources needs towards LGR Low Grade Resources - as Wastes!!! At federal and local levels, India must adapt the UN TG s to local conditions So far, the co-processing permitting process is a nightmare, long and complex. It must be simplified without compromise on OH&S, Environment, Product and process quality The Cement industry must anticipate the future legal frame Start wastes to AFR QC systems investing in specific environmental lab s Start emission monitoring with systematic reporting to public and authorities. Promoting communication and sensitization activities with key stakeholders (Communities, NGOs, Academics, etc.). Implementing external auditing system by independent experts: for example to edit and publish, for each site, a yearly report on pre and co-processing activities

15 Co-processing legal frame & permitting Proposed bases for implementation (1 / 4) Plant Homework Prior Permit demand Permit key topics Wastes to AFR organization on place Wastes markets overview Clinker process know-how and assessment done Pollutants balances on traditional fuels and RM known and published Emission monitoring on place Wastes / AFR acceptance criteria s Environmental Monitoring End-product control External Audit and Reporting Generic AFR acceptance criteria s fixed based on market possibilities and process capabilities (Pollutants balances & process audit / optimization) Wastes to AFR pre-processing activities foreseen and regulated if needed DRE trial burn if pop s related wastes are concerned Continuous emission monitoring for dust, Nox, SO2, VOC Emission detailed control at least once a year by an agreed lab: all pollutants, HM, D/F etc Leaching test on place for end-product to prove their acceptance for drinking water application Yearly site specific audit and report on wastes (pre & co-processing) activities done by an expert accepted by all stakeholders (population, authorities, etc ) Audit publication to all stakeholders

16 Co-processing legal frame & permitting Proposed bases for implementation (2 / 4) 1 Prerequisites Homework A strong Wastes to AFR organization on place Environmental performances on track, known and published Pollutants baselines balances known and published Baseline: Pollutants concentration and comportment using fossils fuels and natural RM. Permitting process for generic AFR families (solid, liquid, sludge's..) When a trial burn will be requested: only for pre-processed AFR not for each type of waste. A trial burn will be site / process specific. Yearly independent external audit for all wastes management activities A communication strategy on place and started

17 Example for Mineral Pollutants Limits Order of magnitude for E-H-Q-P factors Element To be noted: Figures to be considered as examples (5 stage preheater precalciner kiln) Those limits must be fixed In-situ, case by case during the permitting process based on pollutants baselines analysis So, case-by-case, it will be possible to estimate criteria s for AR acceptance for a specific kiln. Antimony (Sb) Arsenic (As) Beryllium (Be) Cadmium (Cd) Chromium (Cr) Fluorine (F) Cobalt (Co) Mercury (Hg) Lead (Pb) Nickel (Ni) Selenium (Se) Tellurium (Te) Thallium (Tl) Vanadium (V) Zinc (ZnO) Strontium (SrO) Baryum (BaO) Phosphorus (P 2 O 5 ) Titanium (TiO 2 ) Copper (Cu) Sulphur (SO 3 ) Chlorine (Cl) Na 2 O-cq Examples for Stricter Limit values (kg/ton.cl) x E = environmental equilibrium H = occupational health P = industrial process Q = quality of clinker E E E E H E H E E E E E E E Q Q Q Q Q Q P P P Radioactivity (Ra-226+Th-232) 260 Bq/kg E

18 Co-processing legal frame & permitting Proposed bases for implementation (3 / 4) 2 - Wastes to AFR: Acceptance criteria s Full traceability: from Cradle to Grave No compromise on OH&S, Environment, Product and Process quality Same acceptance processes for non hazardous and hazardous wastes All types of wastes potentially acceptable Banned wastes list fixed in the TG s Pre-processing is a prerequisite Specific legal frame and boundaries to be fixed for pre-processing activities Avoiding for example to play on dilution effect to reduce the environmental performance of the waste treatment Acceptance criteria s fixed case-by-case via In-Situ pollutants balances For pop s related wastes: a DRE will be required prior permitting A specific process to certify Cement operation for pop s related wastes treatment should be envisaged

19 Pre-Processing: Key challenges is to transform inhomogeneous waste into homogenous AFR for co-processing Waste AR

20 From Waste to AFR: The Pre-processing operations are generally mandatory and must be regulated

21 Co-processing legal frame & permitting Proposed bases for implementation ( 4 / 4 ) 3 - Emissions limits, monitoring & reporting Emissions Monitoring systems Continuous for dust, Nox, SO2 and VOC At least once a year for all other parameters (HM, D/F...) Compliance analysis & Reporting For pop s related products a DRE trial burn is requested with results > % destruction efficiency Emissions limits similar to wastes incinerators Exception for clinker process specific parameters as Nox fixed by the clinkering process conditions (BAT around 500 mgr./nm3) CO, Sox, VOC: as those emissions are specifically coming from raw materials, the local authorities must fixed limits values based on in-situ baselines realized with traditional fuels and raw materials. 4 - End-Product Control Cement End-product must fulfill criteria's applicable for drinking water applications

22 Emissions limits EU example for co-incineration co-processing

23 Co-processing: a win-win-win solution for Indian Cement sector 1. To decrease its environmental footprint using Alternatives and Low Grade Resources 2. Increasing its competivity. 3. Provide Locally Wastes Management Solutions including for hazardous wastes and pop s AFR Waste-based Alternative Fuels and Raw Materials Advanced waste processing - BAT - thermal (gas/py) - Upgraded pre-proc... AMICO BFS, fly ash, nat. Pozzolana, limestone Synthetic MIC from LGR & waste New binders AR & waste-based with low CO2 AAgg. (CDW for CP) Alternative aggregates - Urban quarrying - CDW - IBA... AR Clinker Manufacturing Cement Binder Manufacturing Concrete and Building Products Production

24 Thanks you Do you have some question? Cementis and partners as Alterros have more than 25 years of experiences in Industrial Ecology, wastes and low grade resources management, preparation and use of wastes as Alternatives Fuels, Alternatives Raw materials and Alternatives binders For Cement operator, we can propose, develop and support their strategy and business development on AR For countries, regions or collectivities levels, we are able to offer a safe, secure and environmentally sound way of solving wastes concerns, from MSW to highly hazardous wastes as pop s To propose, promote and implement specific legal frame, lobbying and communication