STATUS OF CO-PROCESSING OF WASTE IN CEMENT PLANTS AS PER HAZARDOUS AND OTHER WASTES MANAGEMENT RULES, Dr B Sengupta,

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1 STATUS OF CO-PROCESSING OF WASTE IN CEMENT PLANTS AS PER HAZARDOUS AND OTHER WASTES MANAGEMENT RULES, 2016 Dr B Sengupta, Former Member Secretary, Central Pollution Control board bsg161@gmail.com Presented at 3rd International Conference on Alternate Fuels & Raw Materials in Cement Industry Towards Realising Swachh Bharat Dream on 23rd & 24th March 2017 at New Delhi, India

2 CO-PROCESSING Co-processing The use of suitable waste materials in manufacturing processes for the purpose of energy and/or resource recovery and resultant reduction in the use of conventional fuels and/or raw materials through substitution.

3 » Environmental damage is getting out of control.» Climate change is impacting us all.» Communities are objecting to implementation of landfills and incineration facilities for waste management.» Landfill is building liabilities for the business & society.» Industries are shifting to Green procurement processes.» Importing countries are demanding compliance to sustainable waste management practices.

4 » Promotes Circular Economy» Reduces required number of landfills pollution caused by dumping greenhouse-gas emissions environmental impact of extraction through mining dependence on primary resource markets cost of production of Cement» Mitigates Climate Change Impacts» Conserves Energy and Material resources» Involves highly organised industrial sector

5 CEMENT DEMAND IN 2024 AND INPUTS REQUIREMENT Particulars (estimate) Cement production Coal for kilns and CPP 360 MT/Annum 750 MT/Annum 60 MT / Annum 156 MT/Annum Limestone 380 MT/Annum 998 MT/Annum Gypsum 12 MT/Annum 33 MT/Annum Power 5100 MW MW Source: CMA 2015

6 CO-PROCESSING OF WASTE IN CEMENT KILN AGREEMENT IN INTERNATIONAL CONVENTION Cement kiln co-processing technology is accepted by Basel convention for disposal of hazardous wastes The cement kiln co-processing technology is accepted by Montreal protocol for disposal of POPs. Cement kiln co-processing of POPs, hazardous and non hazardous wastes is practiced widely and successfully in many countries around the world

7 INITIATING POLICY REFORMS FOR SUSTAINABLE WASTE MANAGEMENT THROUGH CO-PROCESSING Important Recommendations of Basel Convention Guidelines : 1. The waste management hierarchy needs to be respected. 2. Additional emissions and negative impacts on human health must be avoided 3. The quality of the cement must remain unchanged 4. Companies that co process must be qualified with appropriate infrastructure. Assure compliance with all laws and regulations Have good environmental and safety compliance records Have personnel, processes, and systems in place committed to protecting the environment, health, and safety Safe and sound receiving, storage, processing and feeding of hazardous wastes Systems for the provision and analysis of waste representative samples should be in place Contd

8 INITIATING POLICY REFORMS FOR SUSTAINABLE WASTE MANAGEMENT THROUGH CO-PROCESSING Important Recommendations of Basel Convention Guidelines : 5. For optimal performance, AFRs should be fed to the cement kiln through appropriate feed points, in adequate proportions and with proper waste quality and emission control systems. 6. Due to the heterogeneity of waste, pre-processing is required to produce a relatively uniform waste stream for coprocessing in cement kilns. To be carried out in a purposemade facility, which may be located outside or inside the cement plant

9 Alternative Fuels which can be used to increase thermal substitution rate (TSR) in cement industry (use of CV of waste as fuel in cement kiln) S. NO. Fuel Calorific Value (kcal / kg) 1. RDF from Municipal Solid Waste Used Tires Hazardous Waste Industrial Plastic Waste Biomass Slaughter House Waste Poultry Litter Dried Sewage Sludge Source : Holtech & CPCB

10 Alternative Raw Materials which can be used as blending material S.No. Alternative Raw Material Available Quantity in million tonnes per annum 1. Fly Ash (cement blending material) Blast Furnace Slag from Steel Industry Lime Sludge (Paper, Carbide, Sugar Industry Sludge) Red Mud from Aluminum Industry Foundry Sludge / Sand - 6. Chrome Sludge as mineraliser - 7. Lead Zinc Slag Phosphate Chalk - Source : Holtech

11 POTENTIAL AVAILABILITY OF WASTE FOR CO-PROCESSING IN INDIA A.Fuel Hazardous Waste Biomass Used Tyre Industrial Plastic Waste RDF from MSW 0.65 MTA 150 MTA 0.83 MTA 0.20 MTA 6.88 MTA B. Alternate Raw Material Flyash Blast Furnace Slag 200 MTA 10 MTA Source : CPCB & Holtec

12 AVAILABILITY OF OTHER COMBUSTIBLE WASTE S. No. Name of fuel Availability Present disposal method 1. Paint sludge tonnes/ annum Incineration / secured landfill 2. ETP sludge 6.2 million tones / annum Dried ETP sludge are disposed in landfill 3. Ink sludge 240 MT / annum Dried ETP sludge are disposed in landfill 4. Refuse Derived Fuel 5. Groundnut shell 6. Tire Derived Fuel 7. Pharmaceutic al waste 8. Spent wash from distillery Incineration / composting tonnes / annum Incineration 0.33 MT / annum Co-processing Source: NCBM 2015

13 GENERAL PRINCIPLE FOR CO-PROCESSING The important general principles in co-processing are : 1. Additional emissions and negative impacts on human health must be avoided 2. The quality of the clinker/cement must remain unchanged. 3. Companies that co process must be qualified Assure compliance with all laws and regulations Have good environmental and safety compliance records Have personnel, processes, and systems in place committed to protecting the environment, health, and safety Be capable of controlling inputs to the production process Contd

14 Requirements for undertaking co-processing are 1. Best available technology for air pollution prevention and control with continuous emission monitoring 2. Exit gas conditioning/cooling and temperature less than 200 O C in control devices to prevent dioxin formation. 3. Adequate emergency and safety equipment and procedures, and regular training 4. Safe and sound receiving, storage, processing and feeding of hazardous wastes 5. The operator of the co-processing plant should develop a waste evaluation procedure to assess health and safety of workers and public, plant emissions, operations and product quality, variables that should be considered when selecting waste include: (a) (b) (c) Kiln operation Emissions Clinker, cement and final product quality

15 AVAILABLE HAZARDOUS WASTE WHICH CAN BE USED AS PARTIAL FUEL IN CEMENT KILN Organic residue from Pharmaceuticals and Pesticide industry Spent solvent Sludge from petrochemical / oil refinery Slaughter House Waste Waste Oil Paint sludge Effluent Treatment Plant Sludge Spent Pot Lining from Aluminum Industry Spent Carbon

16 List of White-papers prepared by Regulatory Forum consisting of Member Secretaries of 5 SPCBs under the Chairmanship of MS, GSPCB 1. Amendment of the Hazardous Waste Management Rules, 1989, under the Environment Protection Act, 1986, to include co-processing in cement plants as a disposal option. 2. Preparation of technical guidelines for setting up environmentally sound pre-processing facilities to prepare homogenous waste mixes suitable for co-processing in cement kilns. 3. Developing emission standards for co-processing alternate fuel and raw (AFR) material in cement kilns including hazardous wastes. 4. Increasing the use of fly ash generated by coal based power plants and refuse-derived fuels (RDF) in cement plants. 5. Developing guidelines for the transport and storage of hazardous waste

17 HAZARDOUS AND OTHER WASTES (MANAGEMENT AND TRANSBOUNDARY MOVEMENT) RULES, 2016

18 » For the management of hazardous and other waste, and occupier shall follow the following steps, namely:- a) Prevention; b) Minimization; c) Reuse; d) Recycling; e) Recovery, utilisation including co-processing; f) Safe disposal.

19 » Title of the Rules has been amended as Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016» Major Amendments made in following areas Authorization / Renewal of authorization (introduced new forms, compliance verification report, Emergency Response Plans and undertaking for submitting bank guarantee) New Schedule-II for identification of HW Utilization of Hazardous waste includes Schedule IV wastes also. SoPs for recycling/utilization introduced Pass books applicable for all actual users Removal of Registration scheme Responsibilities of State Government Revised Import-Export provisions (Banned items 49 from 30; more clarity) Filing of Annual Reports by SPCBs & CPCB

20 » New Definitions added: - Captive Treatment, storage and disposal facility - Common Treatment, storage and disposal facility - Co-processing - Critical care medical equipment - Pre-processing - Utilisation - Waste & byproduct - Other waste - More clarity in earlier definitions

21 » Waste management hierarchy has been introduced as follows: - Prevention - Minimization - Reuse - Recycling - Recovery, utilisation including co-processing - Safe disposal

22 » Department of Industry in the State or any other government agency - to earmark or allocate industrial space or shed for recycling, pre-processing and other utilisation of hazardous or other waste in the existing and upcoming industrial park, estate and industrial clusters.» Submit annual report to the Ministry of Environment, Forest and Climate Change on integrated plan for ensuring environmentally Sound Management of Hazardous and other wastes.» Department of Labour in the State or any other government agency shall ensure the following in respect of workers involved in recycling, pre-processing and other utilisation of HW ; a) Recognition and Registration of workers b) Imparting industrial skill development activities c) Monitoring safety and health of workers.

23 » Occupier shall obtain an authorization / renewal of authorisation from the State Pollution Control Board in Modified Form 1. Applicant shall enclose copies of CTE, valid CTO. A Self certified compliance report shall be enclosed in case of renewal application.» State Pollution Control Board shall grant authorisation in Modified Form 2 after ensuring technical capabilities and equipment complying with the Standard Operating Procedures or other guidelines specified by CPCB through site inspection.» The authorisation granted shall be accompanied with copy of field inspection report signed by that Board.» Handing over of the hazardous and other wastes to the authorised actual user shall be only after making the entry into the passbook of the actual user» Includes Authorization for recycling of Other wastes listed in Schedule - III

24 Rule-9 : provisions of Recycling and Utilization of HW (1) SPCBs/PCCS may grant authorisation to actual users for utilization or recycling of Hazardous Wastes for which Standard Operating Procedures (SoPs) or guidelines have been provided by CPCB (2) Where SoPs or guidelines are not available, the applicants shall approach CPCB for grant of approval, which may be given by CPCB on the basis of trial runs. Upon completion of successful trial run, CPCB shall prepare SoPs for such Utilization and circulate the same to all SPCBs. (3) No trial runs are required for co-processing once the co-processing standards are notified. However, till the time the standards are notified, the procedure as specified at (2) above shall be followed.

25 » The sender of the waste shall obtain No Objection Certificate from the SPCB of both the States for transportation of waste in case of final disposal to a facility existing in a State other than the State where the hazardous waste is generated.» In case of transit of waste for recycling, recovery, reuse or utilisation through a State other than the State of origin or destination, the occupier shall intimate the concerned SPCB before he hands over the hazardous wastes to the transporter.» The authorisation for transportation shall either be obtain by the sender or the receiver on whose behalf the transport is being arranged.» Gray color Manifest shall only be sent to the SPCB of the sender in case sender is in another State

26 S. No. Type of Waste generated Quantity of Waste generation 1. Fly ash from thermal power plant 2. Blast furnace slag from iron and steel plant 3. Steel melting shop slag (SMS) from steel plant 200 Million Tonnes Per Year (600 MTA by 2030) Area of utilization / recycling / reuse Fly ash pozzolona cement, increase of ash dyke height, road construction, brick manufacturing 10 MTA Slag cement - Slag cement after removal of iron 4. Phospho gypsum 8 MTA Cement making 5. Distillery spent wash About 100 distillery in operation (capacity KLPD) Concentrated spent wash for power generation Contd

27 S. No. Type of Waste generated Quantity of Waste generation 6. Spent pot lining (aluminium industry waste) 7. Pharmaceutical / pesticide industry (distillation residue, process residue, mixed waste solvent, high COD waste) 8. Municipal solid waste 1,30,000 Tonnes /day 9. Plastic waste 15,500 Tonnes /day 10. Municipal waste water 35,000 Million litres /day Area of utilization / recycling / reuse - Carbon portion of SPL can be used as fuel in cement kiln 200,000 TPA Can be used as partial fuel in cement kiln RDF from MSW can be used as fuel in cement kiln / boiler Can be recycled / used as a fuel in cement kiln Treated water can be used in industrial process / irrigation etc. 11. Used tyres 83,000 TPA Shredded tyres can be used as fuel in cement kiln

28 Most Promising Alternate Fuels RDF from municipal solid waste [ MSW ] Used tyres Hazardous waste Industrial plastic waste

29 Hazardous Waste

30 Barriers Technical Barriers Non uniform quality due to varying sources Presence of high moisture and Chlorine Lack of pre-processing facilities Limited technical knowledge and skilled manpower Financial Barriers Time consuming and expensive trial runs needed for each new stream High capital cost for setting pre-processing platforms Huge competition for HW, impacting gate fee

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33 PARAMETER MIN MAX Moisture (%) Ash (%) VM (%) FC (%) Carbon Hydrogen Nitrogen Sulphur Oxygen GCV (Kcal/Kg) NCV (Kcal/Kg) Mineral matter Chloride as Cl (mg/kg) Fluoride as F (mg/kg) PARAMETER MIN MAX VOC (mg/kg) SVOC (mg/kg) BDL 0.2 PCB (mg/kg) PARAMETER MIN MAX Cadmium (mg/kg) Chromium (mg/kg) ,229.7 Copper (mg/kg) ,848.6 Cobalt (mg/kg) Manganese (mg/kg) ,800.0 Nickel (mg/kg) ,300.0 Lead (mg/kg) Zinc (mg/kg) ,000.0 Arsenic (mg/kg) Mercury (mg/kg) Selenium (mg/kg) Antimony (mg/kg) Vanadium (mg/kg) ,400.0 Thallium (mg/kg) Tin (mg/kg) PARAMETER MIN MAX PCP (mg/kg) BDL 1.4 TOC (%) Source: Dr. Parlikar, Geocycle India

34 » There is large variation in the characteristics of wastes on day to day and batch by batch basis.» Waste streams are required to be mixed in different proportions to prepare uniform AFRs. Hence, individual characteristics of the wastes bear no relevance to that of the waste mix.» It took 10 years for Indian cement industry to conduct trials of about 100 waste streams. There are thousands of waste streams to deal with.» Although incineration or landfill options are lower in waste management hierarchy, no trial is required for any waste??.» Technically, there has to be a mechanism to ascertain safety in handling & storage of wastes and compliance to coprocessing emission standards. Source: Dr. Parlikar, Geocycle India

35 Appropriate Laboratory for waste qualification Adequate waste storage facility with proper facilities to control fires and spillages. Environmentally sound facilities for waste Handling, preprocessing and feeding into kilns. Skilled and trained manpower for waste management Adequate systems for EHS and Medical Surveillance Emergency Response Plan. Online emission monitoring to ascertain environmental compliance to prescribed emission standards. Avoiding waste feed when kiln is in light up, shutdown or upset mode. Kiln specific trials for materials attracting Stockholm convention. 35

36 All wastes, other than the banned ones, can be pre & coprocessed depending upon the availability of the suitable infrastructure to handle & manage them. Banned wastes" not to be pre-processed or co-processed Radioactive waste Asbestos-containing waste Explosives and ammunition / weapons Anatomical medical waste Banned wastes not to be co-processed Electronic fraction of electrical and electronic waste (e-waste) Whole batteries as a targeted material stream Waste of unknown or unpredictable composition, including unsorted municipal waste These wastes however can be co-processed after pre-processing to remove the banned portion of the waste 36

37 » Waste generator is required to manage his waste respecting the Waste Management Hierarchy and SPCBs are required to authorize the same. (Rule 4)» A facility is required to obtain authorization from SPCB for receiving, storing and pre-processing of wastes based on the availability of compliant infrastructure to handle them safely. (Rule 6)» Co-processing in cement plant is to be implemented based on the compliance to prescribed emission standards. (Rule 9)» Interstate movement of wastes for recycling or co-processing to be implemented by intimation to the respective SPCBs. (Rule 18)» Pre-processing centers to be developed rather than landfill sites and convert SCF to RDF and wastes to AFRs.» Guidelines on penalties for damaging environment while handling hazardous wastes need to be adhered to.

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39 S.No. Industry Name Hazardous waste Raw material Nonhazardous waste Dolachar / carbon black 1. Anjani Cements (iron sludge) 2. My Home industries Kesoram Cements Zuari Cements (RDF T+ Biomass ) 5. Keerthi industries Sagar Cements India Cements, Nalgonda District 8. India cements, Tandur Orient Cement, 15, Mancharial. Total Source: Telangana SPCB BBD

40 Sl.No. Industry Name Hazardous waste Raw material Nonhazardous waste Dolachar 1. Ultratech Cements, Tadipatri, AP Zuari Cements, Erraguntla, AP Bharathi Cements, Erraguntla, AP Dalmia Cements, Erraguntla, AP M/s Chettinadu Cements, Kalburgi, Karnataka 6. M/s Rajashree Cements, Gulbarga, Karnataka. 7. M/s Sree Jayajothi Cements Pvt Ltd., AP. 8. JSW Cement, Kurnool, AP Total Source: Telangana SPCB

41 Sr.No Industry Name Hazardous waste(mt) Raw material (MT) Non- Hazardous waste(mt) Dolachar/carb on black(mt) 1 M/s. Ambuja Cement Ltd Gir Somnath M/s. Ultratech Cement Ltd Kovaya Works M/s. Ultratech Cement Ltd Jafrabad Works M/s. Ultratech Cement Ltd Sewagram Works Kutch 5 M/s. Gujarat Sidhee Cement Ltd Junagadh M/s. Sanghi Industries Ltd Kutch M/s. Shree Digvijay Cement Co. Ltd Jamnagar 8 M/s. Recycling Solution Pvt. Ltd Panoli M/s. Saurashtra Cement Ltd Porbandar TOTAL Source: Gujarat SPCB BBD _

42 Sr.No Industry Name Hazardous waste(mt) Raw material (MT) Non- Hazardous waste(mt) Dolachar/ca rbon black 1 GNFC Dahej Unit 1134 _ 2 GNFC Unit : 2 Bharuch 1180 _ 3 Alembic Pharmaceuticals 342 _ Limited, Panelav 4 Novel Spent Acid _ Management, Vatva, Ahmedabad 5 Gujarat Paper Mills _ 4531 Association, Vapi TOTAL Source: Gujarat SPCB

43 1. For hazardous waste management following hierarchy should be followed:- a) Prevention Waste generation can be prevented using clean technology b) Minimization waste generation can be Minimized by using good practices c) Reuse; d) Recycling; e) Recovery, utilisation including co-processing; f) Safe disposal. Contd

44 2. For chemical industry (pharma, pesticides, dye and dye intermediates etc.) the waste minimization scheme as prescribed by CPCB should be followed. 3. After following waste minimization scheme the high COD waste to be segregated and high CV waste should be co-processed in cement kiln. 4. The spent solvent / mix solvent generated by chemical industry should be co-processed in cement kiln. 5. Setting of pre-processing plant to be encouraged either at cement plant site or at TSDF site. Contd

45 6. Co-processing emission standards to be followed by Cement plant who are engaged in co-processing of waste as fuel in cement kiln. 7. Rule 9 of hazardous waste management rules including SOP given by CPCB to be followed. 8. Fly ash / bottom ash, RDF, Phospho-gymsum, lime sludge and other industrial waste should be co-processed in cement plant for its effective utilization. 9. SPCB / PCC should play a catalytic role to promote co-processing in their respective state. 10. Data on inventory of waste both hazardous and non-hazardous should be made available by SPCB / PCC in their website. Contd

46 11. For setting of co-processing plant, SPCB / CPCB / MoEF should play important role by providing necessary technical and financial assistance (as given for CETP and TSDF). 12. SPCB / PCC to build-up capacity for monitoring emission of toxic pollutants including dioxine / furan in cement kiln emission. 13. Risk assessment for storing of hazardous waste in co-processing plant to be done and all precautions to be followed as recommended by CPCB in its guidelines on storing of hazardous waste. 14. RDF from MSW to be used as partial fuel in cement kiln. This may be included as a part of CSR programme to manage the MSW disposal problem. Contd

47 15. Coke oven sludge / distillation residue / mixed waste solvent, spent carbon etc. should be used as partial fuel in cement kiln 16. Oily sludge from oil refinery / petrochemical industry should be used for co-processing in cement plant 17. Spent pot lining (carbon portion) from aluminum industry should be used as partial fuel in cement kiln.

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