Inventorisation and Characterisation of Hazardous Waste Categories in Andhra Pradesh: Preliminary Study Report Submitted to The Project Director, CBIPMP Andhra Pradesh Pollution Control Board Head Office, Hyderabad by Centre for Environment and Development, Thiruvananthapuram GreenOrigin Ventures Pvt. Ltd., Hyderabad and Lahmeyer GKW Consult GmbH, Kolkata June, 2013
Hazardous waste resulting in irreversible damage to the environment does not leave any scope for negotiation on the premise of techno-economic feasibility For any clarifications, please feel free to contact Dr. Babu Ambat, Project Coordinator, director@cedindia.org Er. N. Sateesh Babu, Project Director, sateesh@greenorigin.in; aphwi@greenorigin.in
Inventorisation and Characterisation of Hazardous Waste Categories in Andhra Pradesh: Preliminary Study Report Submitted to The Project Director, CBIPMP Andhra Pradesh Pollution Control Board Head Office, Hyderabad Propriety Note: Data contained in this report reflects best professional judgment in the light of information available at the time of preparation and has been submitted in confidence, contains privileged or confidential technical information. Any use which a third party makes of this report, or any reliance on or decisions made based on it, are the responsibilities of such third parties. Consultant accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this report. by Centre for Environment and Development, Thiruvananthapuram, GreenOrigin Ventures Pvt. Ltd., Hyderabad and Lahmeyer GKW Consult GmbH, Kolkata June, 2013
TABLE OF CONTENTS S. no. Topic Page no. 1.0 INTRODUCTION 1 1.1 Background 1 1.2 Organisation of the Report 2 2.0 PROJECT: AT A GLANCE 4 2.1 Objectives 4 2.2 Contract Signing 4 2.3 Project Implementation Framework 5 2.4 Deliverables 5 2.5 Project Quality Plan 7 2.6 Project Office 7 3.0 HAZARDOUS WASTE GENERATION IN ANDHRA PRADESH: A QUICK REVIEW OF EXISTING FINDINGS 8 3.1 Hazardous Waste Categories 8 3.2 Board Resolution Restricting the Disposal of HW from Other States 9 3.3 Recycling of Hazardous Waste 10 3.4 Treatment, Storage and Disposal Facilities 10 3.5 Co-processing of Incinerable Waste in Cement Kilns 11 4.0 APPROACH AND WORK PLAN FOR HAZARDOUS WASTE INVENTORISATION 13 4.1 Approach 13 4.1.1 Dry data collection through questionnaire survey 13 4.1.2 Data review and analysis 13 4.1.3 In-depth studies to cross check provided data and to establish waste 15 generation factors 4.1.4 Spatial data base generation 16 4.1.5 Inferences and way-forward 16 4.2 Work Plan 17 4.3 Sampling and Analysis Programme 21 4.4 Communication Strategy 22 4.5 Schedule of Project Activities 26 5.0 SOURCES OF INFORMATION, INDUSTRY-SPECIFIC HAZARDOUS WASTE STREAMS AND PROPOSED INDUSTRIES FOR IN DEPTH STUDIES 28 5.1 Sources of Secondary Information 28 5.1.1 Andhra Pradesh Pollution Control Board 30 5.1.2 Commissionerate of Industries 31 5.1.3 Andhra Pradesh Industrial Infrastructure Corporation (APIIC) 32 5.1.4 Factories Department 34 5.1.5 Other departments 35 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH ii
5.1.6 Summary observations 37 5.2 Industry Sector-Specific Potential Hazardous Waste Streams 38 5.3 List of Proposed Industries for In-depth Studies 45 5.3.1 Bulk-drug industries 46 5.3.2 Power plants 47 5.3.3 Cement plants 48 5.3.4 Sponge iron plants 48 5.3.5 Metal finishing units (galvanising and electroplating) 49 5.3.6 Petroleum refineries 49 5.3.7 CETPs 50 5.3.8 TSDFs 50 5.3.9 Dry visits to selected industries 50 6.0 PROJECT RISKS AND ASSUMPTIONS 52 6.1 Project Risks 52 6.2 Project Assumptions 53 7.0 DESCLAIMER 55 List of Figures Figure 2-1 Project Implementation Framework 5 Figure 4-1 Approach for Inventorisation of Hazardous Waste in Andhra Pradesh 14 to draw Effective Interventions Figure 5-1 Typical Sequence of Activities by a New Entrepreneur 29 List of List of Tables Table 3-1 Profile of Hazardous Waste Generation in Andhra Pradesh, 2010 8 Table 3-2 Co processed Hazardous Waste in Cement Kilns 11 Table 4-1 Work Plan for Accomplishment of Project 17 Table 4-2 Designed Hazardous Waste Monitoring Programme 21 Table 4-3 Communication Plan 23 Table 4-4 Scheduling of Project Activities 26 Table 5-1 Department-Specific Functions and Relevance to Hazardous Waste 35 Generation Table 5-2 Industry Sector-Specific Relevant Hazardous waste streams 39 Table 5-3 Industry Category-Specific Number of Industries to be Visited for Indepth 43 Studies Table 5-4 Industry Sector-Specific Number of Industries to be Visited for Indepth 45 Studies Table 5-5 Prioritization of Bulk-drug Industries for In-depth Studies 46 Appendices Appendix I Dry Data Requirement from APPCB Head Office and its Zonal Offices 56 Appendix II Model Generic Questionnaire 57 Appendix III Schedule I & Schedule II of Hazardous Waste Rules 63 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH iii
Appendix IV Treatment and Disposal Options for Schedule- I Wastes 71 Appendix - V District-wise Compilation of Hazardous waste generating industries in 75 2006 By APPCB Soft Copy in CD Appendix VI District-wise Compilation of Hazardous waste generating industries in 76 2010 By APPCB Soft Copy in CD Appendix VII Broad Category-wise Reprocessed Compilation of Hazardous Waste 77 Generating Industries in AP w.r.t. 2010 Data of APPCB Appendix - VIII List of Red, Orange and Green Category Industries 78 Appendix - IX List of Registered Industries with Commissionerate of Industries, AP 82 Soft Copy in CD Appendix - X List of Industries Likely to have Relevance to Hazardous Waste 83 Generation from the List of Commissionerate of Industries, AP - Soft Copy in CD Appendix - XI List of Industries as per Directorate of Factories, AP Soft Copy in CD 84 Appendix - XII Consultant s Generic Terms and Conditions 85 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH iv
ACRONYMS 1 WB The World Bank 2 MoEF The Ministry of Environment & Forests, Govt. of India 3 CPCB The Central Pollution Control Board 4 APPCB The Andhra Pradesh Pollution Control Board 5 CBIPMP Capacity Building for Industrial Pollution Management Project 6 Client CBIPM Project Management Unit, Andhra Pradesh Pollution Control Board, Sanath Nagar, Hyderabad 7 CED Centre for Environment and Development, Thiruvananthapuram 8 GreenOrigin GreenOrigin Ventures Private Limited, Hyderabad 9 Lahmeyer Lahmeyer GKW Consult GmbH, Kolkata 10 Consultant CED, GreenOrigin and Lahmeyer 11 APIIC The Andhra Pradesh Industrial Infrastructure Corporation 12 JETL Jeedimetla Effluent Treatment Limited 13 PETL Patancheru Enviro-Tech Treatment Limited 14 HWM Cell Hazardous Waste Management Cell at APPCB 15 Stakeholders CBIPMP, APPCB, MoEF, World Bank, Industries, Common Facility Operators, Industry Associations, Experts, and Public 16 Project Inventorisation and Characterisation of Hazardous Waste Categories in Andhra Pradesh 17 HW Hazardous Waste 18 HW Rules The Hazardous Waste (Management, Handling and Transboundary Movement) Rules, 2008 and subsequent amendments thereof 19 TSDF Common Treatment, Storage and Disposal Facility 20 CETP Common Effluent Treatment Plant 21 WGFs Waste Generation Factors 22 HWMP Hyderabad Waste Management Project TSDF at Dundigal, Rangareddy District 23 CWMP Coastal Waste Management Project TSDF at Pharma City, Parawada, Visakhapatnam 24 tpa Tonnes per Annum 25 tpm Tonnes per Month 26 Kcal/hr Kilo Calories per Hour 27 MLD Million Liters per Day 28 GIS Geographical Information System 29 4-R Concept Concept Exploring Reuse, Recycling, Renovation and Recovery Opportunities 30 CV Calorific Value 31 TCLP Toxic Characteristic Leachate Procedure 32 AOx Adsorbable Organic Halides Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH v
1.0 INTRODUCTION 1.1 Background The Andhra Pradesh Pollution Control Board (APPCB), Government of Andhra Pradesh, in its continued efforts to ensure pollution control from various industrial sectors, proposed to procure consultancy services for inventorisation and characterization of hazardous waste from industries in the State and to draw appropriate interventions to ensure proper collection, storage, transportation and safe disposal. APPCB, hereafter referred as the Client engaged the joint venture of Centre for Environment and Development, Thiruvananthapuram, M/s. GreenOrigin Ventures Pvt. Ltd., Hyderabad and M/s. Lahmeyer GKW Consult GmbH (Lahmeyer) hereafter referred as the Consultant, for accomplishment of the project by availing grants from the World Bank funded project tilted Capacity Building for Industrial Pollution Management (CBIPM) administered through the Ministry of Environment and Forests (MoEF), Government of India. Hazardous waste is any waste, which by reason of any of its physical, chemical, reactive, toxic, flammable, explosive or corrosive characteristics causes danger or is likely to cause danger to health or environment, whether alone or when in contact with other wastes or substances The Ministry of Environment and Forests, Government of India, notified the Hazardous Waste (Management and Handling) Rules on July 28, 1989 under the provisions of the Environment (Protection) Act, 1986, which were further amended in the year 2000 and 2003. Subsequently, Hazardous Waste (Management, Handling and Transboundary Movement) Rules, 2008 are enacted for effective management of hazardous waste (HW), mainly solids, semi-solids and other industrial wastes, which do not come under the purview of the Water (Prevention and Control of Pollution) Act and the Air (Prevention and Control of Pollution) Act, and also to enable the Authorities to control storage, transportation, treatment and disposal of waste in an environmentally sound manner. Hazardous waste has been defined as any waste, which by reason of any of its physical, chemical, reactive, toxic, flammable, explosive or corrosive characteristics causes danger or is likely to cause danger to health or environment, whether alone or when in contact with other wastes or substances, and shall include: Wastes listed in Column 3 of Schedule-1; Wastes having constituents listed in Schedule-2, if their concentration is equal to or more than the limit indicated in the said schedule; and Wastes listed in List A, and B of Schedule-3 (Part-A) applicable only in case(s) of import and export of hazardous wastes in accordance with to Rules 12, 13 and 14 if they possess any of the hazardous characteristics listed in Part-B of Schedule-3. The inventorisation exercise will bring out more detailed information in terms of total quantum of waste generated vis-a-vis its characteristics in terms of recyclable/reusable, land-disposable and incinerable components Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 1
Common facilities need to be planned based on reliable estimates 1.2 Organisation of the Report to form the basis for planning/augmenting treatment, storage and disposal facilities (TSDFs) or to verify the adequacy of existing TSDFs. Such common facilities need to be planned based on reliable estimates of the current waste generation and projections for the future. Reasonably reliable estimates based on process and product-wise generation of waste will facilitate planning the type of on-site and off-site storage/treatment to be provided before disposal of waste in an environment friendly manner depending on the characteristics and quantity of waste generation. With this backdrop, the Andhra Pradesh Pollution Control Board took-up the task to inventorise the hazardous waste in the State of Andhra Pradesh, under the World Bank funded CBIPM programme. This Preliminary Study Report reaffirms sequence of steps and approach of the Consultant for accomplishment of project scope of work, for ready reference of the Client. The Report is organized in to 7 chapters and coverage in each chapter is precisely discussed below: Chapter-I : An introduction to the project has been given by highlighting premise for Inventorisation of the hazardous waste generation and implementation framework of the CBIPM programme. Chapter-II : Chapter III : Chapter IV : This chapter covers objectives, signing of the agreement by the client and consultant, consultant s project implementation framework, deliverables and considerations in maintaining the quality of the work and reporting This chapter reviews readily available information with APPCB on geographical distribution of hazardous waste generating units and categorization of generated waste for recycling/incineration and land-filling. Thus, this chapter gives indicative figures of the hazardous waste categories generation in AP. This chapter covers approach and work plan for hazardous waste Inventorisation. Approach covers questionnaire survey, data review and analysis, in-depth studies to cross check provided data by the units to establish waste generation factors, spatial data base generation, and drawing inferences and way-forward. This chapter elaborated work plan by giving activity-specific methodology and expected out-put. Besides, sampling and analysis plan finalised for this project, communication strategy and scheduling of the project activities are given in detail. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 2
Chapter V : This chapter explores potential sources of secondary information on industries, which could facilitate to know the list of industries which are likely to be relevant to hazardous waste generation, in order to issue specifically designed questionnaire. Besides, list of industry category-specific hazardous waste streams have been identified, covering relevant streams from Schedule I and Schedule II of HW Rules, upon thorough review of relevance and reporting patterns. This Chapter also identified industry-category specific proposed list of industries for in-depth studies. Chapter VI : Chapter VII : This chapter covers project risks, assumptions and measures that are expected to eliminate/reduce the risks, for ready reference of all the stake-holders of the project execution. This chapter specifies boundaries of use of this report as exclusively for use of the client only and no liability on consultant in case of unauthorized use of the data without prior consent of the consultant, as the data input is from various sources, including interviews and discussions. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 3
2.0 THE PROJECT: AT A GLANCE 2.1 Objectives 2.2 Contract Signing & Progress The major objectives envisaged by the client under the consultancy assignment Inventorisation and characterisation of the hazardous waste generation in Andhra Pradesh, are: To inventorise hazardous waste generation in Andhra Pradesh, in pursuit of the provisions of the Hazardous Waste Rules, 2008 and subsequent amendments thereof, while referring to CPCB set guidelines To create a detailed geo-referenced database of the industrial facilities relevant to hazardous waste on the territory of Andhra Pradesh To suggest plan of actions in the light of findings of hazardous waste inventory in respect of waste minimization, proper collection, storage, treatment and disposal. Project Contract no.1a1.1 has been signed on February 11, 2013 between APPCB and Consultant The Consultant comprising Centre for Environment and Development (CED), GreenOrigin Ventures Pvt. Ltd. (GreenOrigin) and Lahmeyer GKW Consult GmbH (Lahmeyer) submitted proposal for execution of APPCB desired consultancy services for inventorisation and characterisation of hazardous waste categories in Andhra Pradesh (Loan No: 7924-IN/ Credit No: 4755-IN; Lump-Sum Contract No. 1A1.1) CBIPM project management Unit invited Consultant to have contractual negotiations on January 10, 2013 and on the next day detailed negotiations have been held with CBIPMP Team. Accordingly, the Consultant submitted concurrence to the out-come of negotiations vide their letter dated January 11, 2013. The project Contract has been signed on February 11, 2013 by Mr. Sanjay Kumar, the Project Director and Member Secretary of APPCB on behalf of the Client, and from the consultants side Dr. Babu Ambat, Executive Director on behalf of the CED and Lahmeyer and Mr. JSRK Sastry, Director on behalf of GreenOrigin signed the agreement. Mr. Sateesh Babu, Project Director & Technical Lead from GreenOrigin and Mr. SSS Murali, EE APPCB joined discussions with the Member Secretary, APPCB. The Consultant had preliminary discussions with the client on same day as a mark of commencement of the services, (starting date), of the services to be rendered by the Consultant. The Consultant submitted the Inception Report on Mar 25, 2013. The report has been deliberated at length on May 03, 2013 by the Core Team of APPCB and observations were made regarding the sources of Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 4
information on HW generating industries and analyzing the overlaps of these sources to arrive at a list which could be likely to have relevance to HW generation. The Consultant suggested a specific questionnaire for HW inventorisation in line with the Project Objectives. Whereas the Annexure I of the scope of work seeks an exhaustive list of information from the industry, does not limit to HW inventorisation, but includes many other inputs from water and air domains. Therefore, to enable industry to specifically focus on providing information related to HW generation, it has been felt appropriate to proceed with the focused questionnaire designed by the Consultant for inventorisation purpose. However, it has been opined that a structured template covering the entire data requirement as given in Annexure I of ToR may be published on APPCB website for on-line entry and submission by the Industry either to submit along with the Statutory submission requirement of Environmental Statement by Sept 30, 2013 or to essentially submit at the time of renewal of CFO. The GIS based data management system being developed as part of this project will also have a provision to select the industry, geographically, and attach specific inputs as per the designed templates. This arrangement would eventually facilitate efficient data mining, subsequent up-dation and reporting. 2.3 Project Implementation Framework Organisation of Consultant s Team is very important for smooth execution of various project activities. The planned organizational set-up is depicted in Figure 2-1. Figure 2-1: Implementation Frame Work APPCB CBIPMP Management Team Project Director & Lead HW management Expert-I HW Expert Expert-2 Env. Scientist/ Chemist Associates having expertise in chemical engineering, sludge stabilisation, process chemistry and planning with GIS/IT Project staff covering environmental engineering, chemical engineering/chemistry and GIS MoEF recognised laboratory and/or laboratory of CED/premier academic institutions P r ofessionals and their roles are carefully chosen to match their unequalled talents with the important requirements necessary for successful job Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 5
MoEF recognized laboratories would be deployed for sampling and/or analysis 2.4 Deliverables execution. Of particular note, in the proposed Project Organization is our selected use of key professionals of repute, to help direct the progress of the project. Team has been organised such a way that the Team leader is assisted by key experts, associated experts and staff, directly, while the project staff extend full time support to them. External laboratory services will be engaged to avail assistance in sampling and/or analysis of hazardous waste proposed to be collected during the field studies. The assignment is scheduled for accomplishment in 12 months duration and involves necessary approvals, as required from APPCB. The project deliverables envisaged are as follows: i. Preliminary study report covering secondary data collection, commencement of questionnaire survey and short-listing of industries for field investigations. This report after having discussions on submitted Inception Report scheduled to be submitted in June, 2013. ii. iii. iv. Second interim report after completing field visits to identified units. This report is scheduled to be submitted in 8 months of mobilization. Draft final report incorporating entire scope of work. This report is scheduled to be submitted in 10 months of mobilization. Final report after incorporation of changes suggested by APPCB. This report is scheduled to be submitted in 12 months of mobilization, with an understanding that APPCB will provide its views in fortnight. The deliverables are the results of various recognized project tasks i.e. Task-I : Data collection and questionnaire survey (Dry Inventory - secondary information) Task-II : Data review and analysis Task-III : In-depth studies and determination of waste generation factors (Field Visits in-depth studies comprising physical observations including collection of few samples for analysis) Task IV : Spatial data base generation, processing and analysis; and Task-V : Inferences and way forward All deliverables will be provided by the consultant in colour hard copies (3 copies of draft version and 10 copies of final version) and also in electronic form. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 6
2.5 Project Quality Plan The Consultant s highly qualified and competent key professional experts, additional expert pool, and committed staff will take-up the responsibility to ensure the accomplishment of quality requirements. The Consultant s Team emphasizes the data verification at various levels to ensure the reliability, besides monitoring, control and improvement of the quality services. Overall the Consultant will apply quality checks during all stages of the project execution. Roles and responsibilities of the involved project Team members are clearly defined to have parallel accomplishment of the project activities. The Project Leader monitor s the progress of the project and seeks the resource mobilization from the respective financial heads for timely achieving the project objectives. The Team Leader and other key experts will ensure coordination and cooperation with the client. A detailed work plan has been developed and presented in this report with clearly defined activity-specific out-put. Key project experts include scientists from the institutes including CPCB, who would draw protocol for chain of custody and analysis procedures Quality criteria for sampling and analysis is an essential imperative to ensure that hazardous waste samples from identified industries are collected, preserved, transported and analysed as per the approved sampling and analysis protocol. The industry sector-specific number of samples proposed to be collected is detailed in sampling and analysis programme presented in this report. However, the specific name of the units, sampling and characterisation protocols will be clearly brought out in the next report. The key project experts include scientists from the institutes including the Central Pollution Control Board, who would draw protocol for chain of custody and analysis procedures. The Consultant will undertake sampling and analysis on its own to the extent possible and simultaneously engage MoEF recognized laboratory (ies) for cost-effectiveness, and to ensure complete coverage of concerned parameters. The project Team proposed to be involved in industrial visits will undergo required safety and health training programme, and all of them will be insured against liability as per the respective Consultant s Firm Rules. The contractors engaged by the Consultant for sampling and analysis, will also be asked to ensure safety and health protection measures. A draft version of all the deliverable reports, as detailed in previous Section, will be made ready in advance and same will be reviewed for omissions and needed changes, before formal submission to the client. Besides, the client s technical in-puts will be incorporated timely, to ensure the desired quality out-puts in scheduled time lines. 2.6 Project Office The Consultant is represented through GreenOrigin Ventures Pvt. Ltd. having their project Office at 4th floor, 6-3-354/1/2, Hindi Nagar, Building behind Himalaya Book World, Punjagutta, Hyderabad. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 7
3.0 HAZARDOUS WASTE GENERATION IN ANDHRA PRADESH: A QUICK REVIEW OF EXISTING FINDINGS 3.1 Hazardous Waste Categories APPCB has taken-up an internal compilation of the hazardous waste generation in Andhra Pradesh, based on the issued authorisation letters in the year 2010. Salient findings of the assessment are discussed in this Chapter. Hazardous waste generation profile in Andhra Pradesh is as follows: Total Hazardous waste generation : 1086740 MTPA Land fillable waste : 414747 MTPA (38.16%) Recyclable waste : 629167 MTPA (57.89%) Incinerable waste : 42826 MTPA (3.95%) (MTPA Million tonnes per annum) Zone and regional office-wise distribution of hazardous waste generation is given in Table 3-1. APPCB Zone Table 3-1: Profile of Hazardous Waste Generation in Andhra Pradesh, 2010 Regional Office no. of hazardous waste generating units Total hazardous waste generation Recyclable waste Incinerable waste landfillable waste (1) (2) (3) (4) (5) (6) (7)=(4)-((5)+(6)) Hyderabad Hyderabad 64 1328.791 816.105 1.35 511.336 Ramachandra Puram Karimnagar 193 1671.447 1648.297 1.88 21.27 Rangareddy 697 176388.1422 95305.9352 2431.11 78651.097 Mehboobnagar 171 34799.156 29038.146 720.09 5040.92 Warangal 53 14691.08 12823.98 1.8 1865.3 Zonal sub-total 1178 228878.61 139632.46 3156.23 86089.92 Nalgonda 151 80503.657 37757.652 6840.12 35905.885 Medak 475 125948.893 60118.893 14169.357 51660.643 Adilabad 29 8629 2829 0 5800 Nizamabad 12 25.8 25.8 0 0 Zonal sub-total 667 215107.36 100731.35 21009.48 93366.53 Kurnool Karnool 44 14732.986 8074.756 0 6658.23 Ananthapuram 58 2129 1366 134 629 Chittoor 90 12570.49 4791.6 1.2 7777.69 Kadapa 23 401.57 296.57 0 105 Zonal sub-total 215 29834.05 14528.93 135.2 15169.92 Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 8
Vijayawada Prakasam 46 5535.49 15.51 725.98 4794 Nellore 142 1574.16 232.7 39.9 1301.56 Krishna 163 12812.57 5570.33 2653.1 4589.14 Khammam 43 1931.142 1930.042 0 1.1 Guntur 92 4152.86 2643.02 170 1339.84 Zonal sub-total 486 15006.22 10391.6 3588.98 1025.64 Visakhapatnam Visakhapatnam 207 440914.311 257042.078 11022.616 172849.617 Srikakulam 60 102048.24 88150.94 2458.65 11438.65 Vizianagaram 70 4503.42 1556.19 1084.73 1862.5 East Godavari 217 25999.685 7662.455 354.99 17982.24 West Godavari 122 13448.89 9471.31 15.41 3962.17 Zonal sub-total 676 586914.549 363882.973 14936.396 208095.18 Grand Total 3222 1086740 629167 42826 414747 Following inferences can be drawn from the discussions held with the Hazardous waste management cell and above Table include: i. About 35 % of total industries in Andhra Pradesh are falling in the purview of Hazardous Waste Rules. Significant hazardous waste quantities are being generated from Visakhapatnam and Hyderabad regions ii. Incinerable waste generation is only 3.95% of the total hazardous waste generation. iii. Reported recyclable waste accounts for 57.89% and significant quantities are used oil/ waste oil. It has been noted that a share of the used/waste oils are processed out-side the State. iv. Significant recyclable hazardous waste is reported from Visakhapatnam, Rangareddy and srikakulam districts. v. Significant incinerable waste is reported from Medak, Visakhapatnam and Nalgonda followed by Rangareddy, Krishna and Srikakulam districts. vi. Significant land-fillable waste quantities are reported in Visakhapatnam, followed by Rangareddy, Medak and Nalgonda districts. vii. Sector-wise analysis was not undertaken earlier, and same is considered in current World Bank funded project. viii. As sector-specific analysis is proposed to be undertaken in current study, the waste generation factors could be arrived and variations in WGFs could be reviewed in respect of cleaner technologies, cleaner production, application of 4R-concept and other better management practices 3.2 Board Resolution Restricting the Disposal from Other States APPCB in its 116 th Board Meeting held on July 20, 2007 has taken a Policy Decision vide resolution no. 1698, to restrict and not to permit any interstate movement of hazardous waste for disposal in Andhra Pradesh. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 9
3.3 Recycling of Hazardous Wastes APPCB is continuously pursuing and encouraging the industries for exploring opportunities for recycling of hazardous waste. Few specific points concerned to recycling of hazardous waste are given below: i. 22 used oil recycling facilities registered by CPCB are operating in the State. ii. 13 registered lead waste recycling units are recycling used batteries / scrap iii. Iron sludge generated in reduction reaction, employed by the bulk drug industries, is being diverted to cement kilns. This quantity is to the tune of 100 TPM; and iv. M/S. Floris Chemitech in West Godavari District is involved in recovery of micro-nutrients i.e. Potassium Sulphate and other salts from the rejects of bulk drug industries. The industry has a capacity to process 300 TPM of crude salts. 3.4 Treatment, Storage and Disposal Facilities There are two authorized common treatment, storage and disposal facilities in Andhra Pradesh i.e. at Dundigal in Rangareddy District and Pharma city, Parawada, Visakhapatnam. Specific details of TSDFs are precisely given below: 1. TSDF at Dundigal, Rangareddy District (M/s. Hyderabad Waste Management Project - HWMP) i) TSDF is established as a part of bilateral aided project between Government of India and Government of Australia, under BOO basis in 2001 Planned capacity is 4.5 million tonnes, with life span of 30 years Commenced operations since September, 2001. Approved capacity is 1.5 lakh tonnes per annum. First cell with 3 compartments (5 acres) was commissioned in 2001 and capped in 2005 Second cell with 4 compartments (6 acres) was under capping in 2010; and Third cell is in operation. ii) Common hazardous waste incinerator is established with a capacity of 1.5 TPH having provision to handle bulk solids, tarry wastes, semi solids and pumpable wastes Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 10
Thermal capacity of the incinerator is 5.5 Million K cals/hr; and Incinerator commenced its operations since November, 2006. 2. TSDF at Pharma City, Parawada, Visakhapatnam (M/s. Coastal Waste Management Project - CWMP) Pharma City was established by APIIC and M/s. Ramkey Pharma city (I) Ltd., as a joint venture at Parawada, Visakhapatnam As per CFE issued to M/s. Ramkey Pharma City (I) Ltd., following common infrastructure is permitted for establishment in Pharma City: - Power plant 100 MW capacity with multi fuel use i.e. Gas/coal/oil with distribution substations and transformers. - TSDF facility with a capacity of 2,00,000 TPA - Water treatment plant, storage system, water distribution system - Effluent/Sewerage network, CETP of 50 MLD Capacity, - Storm water drainage - Common boiler 230 TPH - Common DG Set 15MW; and - Incinerator 1.5 TPH Land-fill and incineration facilities are under operation. 3.5 Co-processing of Incinerable Waste in Cement Kilns APPCB has promoted co-processing of high calorific value bearing hazardous waste in cement kilns, as a substituted fuel. This win-win combination of the waste generators and the cement industries, led to commencement of hazardous waste co-processing in rotary kilns in cement industries with specific modifications in feeding and their tail gas treatment system. It has been reported that about 35,036 tonnes of hazardous waste was coprocessed in cement manufacturing industries till the year 2010-11. The year-wise details are given in Table 3-2. Table 3-2: Co processed Hazardous Waste in Cement Kilns S. no. Name of the Cement Industry Quantity of incinerable waste coprocessed, Tonnes Total, Tonnes 2008-09 2009-10 2010-11 1 Ultratech Cement Ltd. 1554 6428.1 7107.35 15089.45 2 M/s. India Cements, Nalgonda - - 9077.55 9077.55 3 M/s. Anjana Port land - 1710 1990 3700 cements, Nalgonda 4 M/s. NCL industries Ltd. 5766.995-1337 7103.995 Total 7320.995 8138.1 19577 35036.095 Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 11
It can be seen from the Table that co-processing of hazardous waste in cement industries is gradually increasing each year, substantially relieving the recurring expenditure due to operation of dedicated industry-specific and/or common hazardous waste incinerator. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 12
4.0 APPROACH AND WORK PLAN FOR HAZARDOUS WASTE INVENTORISATION 4.1 Approach Approach discussed and planned to be adopted for Inventorisation of hazardous waste generation is discussed in this Section. Flow and interrelationship of activities are schematically represented in Figure 4.1. Specific steps in the approach are precisely discussed below. 4.1.1 Dry Data Collection Through Questionnaire Survey 4.1.2 Data Review and Analysis A comprehensive questionnaire (generic + sector-specific considerations) will be sent to all the identified hazardous waste generating industries based on preliminary information as available from APPCB. In accordance to the Hazardous Waste (Management and Handling) Rules, hazardous waste generators can be identified based on the following: If concentration of particular constituent exceeds the limit given in Schedule-II, the waste will be categorized as Hazardous waste, besides waste streams falling in Schedule I. a. Based on processes listed in Schedule I: Consultant examines processwise generation of waste streams for each industry to decide whether the process/waste stream falls under the list of Schedule I of Hazardous Waste (Management and Handling) Rules. If yes, the waste will be identified as hazardous waste. b. Based on analysis reports: In case, the processes/waste stream of particular industry are not found in the list of Schedule I of the Rules, consultant will review possible hazardous constituents, as listed in Schedule-II of the Rules, that are likely to be present in the wastes based on raw material used, process adopted, reaction(s) and the unit operation(s) involved. To determine, whether a waste stream is hazardous or not, the characteristics of waste generated from processes will be reviewed for relevant parameters as per list of Schedule-II of the Rules. If concentration of particular constituent exceeds the limit given in Schedule-II, the waste will be categorized as hazardous. In specific cases, to cross check the given data of the industries, consultant undertakes sampling and analysis of such waste, as per CPCB s manual on sampling, analysis and characterization of hazardous waste (LATS/16/2002-2003). Where necessary, analysis may include water leachability and TCLP test for the purpose of suitable treatment and disposal method. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 13
Iinventorisation and Characterisation of Hazardous Waste Categories in Andhra Pradesh I Contract no:1a1.1 of CBIPMP, APPCB June 19, 2013 Data collection & Designing questionnaire Questionnaire survey & Compilation Data review and analysis Collection of list of industries from APPCB/APIIC etc. and identifying ones, which attract HW (M&H) Rules Quantitative and qualitative compilation of hazardous waste data in prescribed formats Dispatching letters through APPCB to non-responsive industries Industry-specific letters to seek additional information to clear major incompatibilities Industry Sectors Designing generic questionnaire applicable for all industrial sectors: Part-A Designing sector-specific relevant hazardous waste questionnaire: Part-B Dispatching questionnaire (Part-A + Part-B) to all the industries as per APPCB List of industries Non-responsive industries Industry sector details Compilation of dry-inventory of hazardous waste generation in Andhra Pradesh based on questionnaire survey Sector/group specific waste generation factors Analysis of variation Incompatible Data compatibility/ Scientific evaluation/ Verification Incompatible Processing of inventory data for sectoral analysis Identification of sector-specific HW streams and candidate industries for in-depth studies Study visits to selected Industries for cross verification Establishing WGFs Procurement of latest imageries, secondary sources of maps Development of basic land-use features admin. boundaries, river basins, roads, drainage pattern etc. Industry-specific and spatial data collection from various sources including APIIC - industrial estates, CETPs etc. Collection of lat-long details of hazardous waste generating units Creating nodes Data attachment to each node in prescribed formats Spatial data entry, processing, analysis OK Inferences & Way forward Compilation of Inventory of Hazardous waste generation in Andhra Pradesh District-wise summaries, sectoral inferences, spatial data base Draft action plan for effective management of hazardous waste in Andhra Pradesh For discussions with APPCB and finalisation Figure 4.1: Approach for Inventorisation of Hazardous Waste in Andhra Pradesh to Draw Effective Implementation Plan Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 14
4.1.3 In-depth Studies to Cross Check Provided Data and to Establish Waste Generation Factors In order to verify the data provided by the industries through questionnaire, the consultant propose to visit selected industries in identified sectors in association with APPPCB representatives to conduct in-depth study. The indepth studies are aimed to cross check the data made available and also to establish waste generation factors. The coverage of aspects in estimation of waste generation factors is as follows: i) Defining waste generation factor (WGF) The waste generation factor depends on size of operation, waste management practices and process technology adopted. The Consultant identify industries in consultation with APPCB for indepth studies, however, choice of industries are selected covering size of production and process technology in order to arrive at waste generation per tonne of product manufactured. This value referred as waste generation factor (WGF) is defined as Quantity of waste generated (tpa) WGF = --------------------------------------------- Quantity of product produced (tpa) Effluent treatment plants, incineration facilities are normally considered as common facilities within the industry. Therefore, in case of multiple products, waste generation factor for ETP sludge / incineration ash will not be used for other industries. ii) Sludge Estimation The Consultant will also explore quantification of hazardous waste by availing appropriate technique, such as: Measurements of waste collection pit and time required to fillup of pit by waste; In case of small and medium scale industries, where ETP is not properly maintained and values are not reported, Consultant will collect liquid effluent containing toxic constituents and test the sample for estimating sludge generation by; - Settleability test, - Measurement of sludge volume index, - Jar test for typical coagulant doses needed for treatment (coagulation or precipitation). Based on the observations, sludge generation per tonne of product will be estimated. iii) Actual Weighing: For wastes like tarry wastes, heavy metal filtration residues and waste arising from organic chemicals manufacturing units and rolling mills or where the wastes could be collected in a drum or bag and subsequently weighed in a spring balance. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 15
Information collected during questionnaire and in-depth studies will be compiled and presented as per the specific formats iv) 4.1.4 Spatial Data Base Generation 4.1.5 Inferences and Way-forward Discussion with plant personnel: For off-specification products arising from the pesticides formulation, pharmaceutical units and other complex processes involving multiple products operation, the WGFs will be arrived in consultation with operators/middle level/top management personnel. This estimated waste generation factor from the above methods will be availed to cross check the information provided by industries in particular sector. This will also be used for estimation of waste generation, where information is not available for the particular size of production in the selected sector. The information collected during questionnaire survey and in-depth studies will be compiled and presented as per the specific formats (concurrence of APPCB will be taken to the formats designed by the consultant). For uplinking the data set on to GIS platform, specific templates will be designed covering overall details of the industry, as indicated in RFP document and take prior concurrence of APPCB. Latest imageries will be procured for entire state and GIS maps will be developed for specific features. Lat longs of the hazardous waste generating units would be marked and if the area of any unit is higher than 50 acres, multiple locations will be demarked. The data sets of each hazardous waste generating industry will be up-linked to developed GIS maps for spatial analysis. To be more precise, two regions i.e. Visakhapatnam and Hyderabad will be zoomed-in to higher resolution, as maximum share of hazardous waste generation is from these two regions. Inferences in respect of status of hazardous waste generation, spatial distribution of sources, sector-specific and region-specific analysis of information for drawing way-forward, in concurrence with state priorities and national hazardous waste management policy. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 16
4.2 Work Plan Table 4-1: Work Plan for Accomplishment of Project No. Activity Methodology Milestones Task 0 Project Initiation Meeting the Project Director, CBI- PMP JV Partners and Team Leader to interact with the Project Director, CBI- PMP to exchange commitment for accomplishment of the project objectives. Contract signed Briefing of approach to the key Client s Team for their concurrence Interacting with the project management Team at APPCB Interacting with senior Officers of the HW Management Cell Finalisation of the approach Task 1 Data collection and commencement of questionnaire survey (Dry Inventory - secondary information) 1.1 Collection of information available with APPCB Senior Team members to interact with APPCB Officers regarding available information. Collection of authorization letter from APPCB for issuing questionnaires to the industries Listing of available information and collection 1.2 Review of other sources of Deputing project staff for collection of information from information Department of industries and APIIC. Communication to APPCB (Pl. refer Appendix-I for data requirement from APPCB Head Office and Zonal Offices) Collection of publicly available information of major industries 1.3 Compilation of information Compilation of readily available information in specific formats with prior concurrence of APPCB 1.4 Identification of representative industries in selected sectors, for verification of data through field visits (which have maximum quantity as well as varying characteristics) Listing of industries for maximum variations Identification of industries for field studies with rationale (waste quantity, complexity, geographical distribution etc.) in respect of Bulk drug manufacturing units Power plants (thermal, bio-mass based) Cement plants Methodology with technical program and clear milestonesrefined and finalized Earlier formal studies / compilation of inventory data are available to the project Team Industrial coverage is cross checked with other sources of industrial data from APIIC and department of industries. A draft compilation of available information is made ready for reference of subsequent stages. Tentative list of industries for field studies are identified by the project Team, so that APPCB may be requested for confirmation. Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 17
1.5 Administering questionnaire survey Sponge iron plants Metal finishing units (galvanizing, electroplating) Petroleum refineries Review of proposed generic and sector-specific questionnaire by Key project Team members (Pl. refer Appendix II for model generic questionnaire and sector-specific hazardous waste streams) Securing concurrence of the Board and to distribute the questionnaire to all member industries Questionnaires are sent to all the relevant industries Task 2 Data review and analysis - To review existing data and general information on hazardous waste generation sources, characteristics and mode of disposal 2.1 Verification and processing of received questionnaire responses (all HW streams are reported, Deputing Key professional Team members having pollution control implementation experience to design algorithm to review each industry and its sources, whether they fall in the First draft compilation on HW generation in Andhra Pradesh: 2012-13 would be ready with Schedule I and/or II relevance (Pl. purview of the study. specific remarks on the refer Appendix III), compatibility Key project Team members will design sequence of steps to industries which did not of reported data with prevailing identify the incompatibility of reported data by the project staff respond to the survey, WGFs, reasons for deviations, if Specific review of the incompatibilities identified provided in adequate any, Compatibility of HW Seeking additional information/ clarifications to address the information, highly deviating reported/lifted with the records of TSDFs, genuine reporting of treatment and disposal (Pl. refer Appendix IV) etc.) identified deviations waste generation factors w.r.t. prevailing etc. Task 3 In-depth studies and determination of waste generation factors (field visits in-depth studies comprising physical observations including collection of few samples for analysis) To visit few identified industries in Finalisation of industries for in-depth studies and obtaining An updated list of hazardous the state for detailed information concurrence of APPCB (up-dation of earlier list due to latest waste generating, recycling collection and to have discussions information received) and handling units, in a besides witnessing the hazardous Seeking association of APPCB representatives in each visit, to consistent and comparable waste management practices facilitate access to the source and also to facilitate in getting format, clearly identifying the Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 18
followed in the premises. Inventory and characterization of the HW, where necessary Visits to common TSDFs and CETPs required information and also to contribute in identifying the gaps nature and type of wastes giving an estimate of the HW generation, the handling, storage, treatment and disposal practices, information on any visible contamination of land or surface water, the performance of CHWTSDF, the disposal of industrial HW etc. Developing waste generation factors based on reported information, field investigations for homogeneous industries Compilation of waste generation factors based on reported information for homogeneous and heterogeneous industries. Based on field studies, generating actual waste generation factors for identified processes/production Arriving at appropriate WGFs and cross checking the compiled information with these arrived WGFs to identify the abnormal reporting cases Major sectors-specific and/or product-specific waste generation factors and inferences. Waste generation factors for set of industries are identified with reasonable acceptance level Task 4 Spatial data base generation, processing and analysis - To prepare GIS maps with hazardous waste inventory data for spatial analysis Collection of latitude and Procurement of imageries GIS based maps with longitude of each industry on a Project staff to compile each hazardous waste generating unit hazardous waste inventory GIS map, as a node Attaching data to each node on specifically designed template, for data in specified format and attaching to each node Deploying project professionals to verify the compilation and to generate meaningful list of maps for spatial analysis data for spatial analysis of hazardous waste movement, siting of disposal facilities and layer-specific processing of Filed cross check of the data provided at selected regions for alternatives etc. information authentication of secondary information Development of entire state map with zoomed in resolution in Finalization of the maps and data with enough cross checks and ground referencing with standard references etc. Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 19
Visakhapatnam and Hyderabad regions. Task V Inferences and way forward - To draw inferences and recommendations for effective management of hazardous waste Establishing current status Gaps and needs analysis Opportunities for improvement Key professional Team will evaluate the entire information, national/regional policies, current status of generation/ collection, 4-R Concept, and disposal practices, would draw draft action plan. Final draft report will be submitted to APPCB. Report will be finalized with due consideration of views received from APPCB. Effective interventions for management of hazardous waste in Andhra Pradesh. Note: Detailed work plan has been arrived after having discussions with the Client. Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 20
S. No Inventorisation and Characterisation of Hazardous Waste Categories in Andhra Pradesh I Contract no:1a1.1 of CBIPMP, APPCB June 19, 2013 4.3 Sampling and Analysis Programme Category Detailed discussions have been held with APPCB Officers and accordingly HW sampling and analysis programme has been arrived for the identified sectors. The Consultant will undertake field studies in selected industries with the provision to sample HW as per the break-up given in Table 4-2. Tentative no. of representative industries Table 4-2: Designed Hazardous Waste Monitoring Programme Number CV of Corrosivity Reactivity Flash point of Organic /Ignitability samples waste TCLP (for relevant parameters) 1 Bulk Drug manufacturing units 2 Power plants (thermal, Bio-mass based) 2 5 5 5 5 5 3 Cement Plants 2 5 5 5 5 5 4 Sponge iron plants 2 5 5 5 5 5 5 Metal finishing 6 5 5 5 5 5 units (galvanizing, Electroplating) 6 Petroleum AOx Relevant inorganics including anticipated metals 10 55 25 55 55 55 30 15 5 20 4 15 10 15 15 15 5 5 5 refineries 7 CETPs 3 15 10 15 15 15 10 5 5 5 8 TSDFs 2 15 15 15 15 15 15 5 5 5 31 120 Total number of samples Relevant trace organics 60 120 120 120 80 30 20 30 Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 21
Inventory and Characterisation of Hazardous Waste Categories in Andhra Pradesh I Contract no:1a1.1 of CBIPMP, APPCB June 19, 2013 4.4 Communication Strategy.. besides project management and review requirements, it has been felt appropriate to develop a communication plan for concurrence of APPCB Project communication strategy is aimed to ensure commitment and support by all key stake-holders for all aspects of the project. As there are multiple stake-holders to the project, factoring the views of them at various stages internalises the concerns for smooth execution and to timely achieving set out-puts. Projects of this nature, often attach high importance for reaching out to the hazardous waste generators, common facility operators and regulatory officers. Therefore, communication plays key role. Keeping this requirement in the background, besides project management and review requirements, it has been felt appropriate to develop a communication strategy for concurrence of APPCB. Specific Objectives: To effectively reach out to the hazardous waste generators and common disposal facilities for reporting the information To effectively appraise the project developments and to seek inputs for benefit of the project including timely completion Target Audience(s): CBIPMP, APPCB, MoEF, World Bank, Industries, common facility operators, industry associations, experts, and public Key messages: The Project effectiveness depends upon responses to the questionnaire survey; timely permissions from the industries for detailed investigations; access to the information of the generator regarding the process, material balance etc., compiled data from common TSDF facilities; and timely clearances from reviewers i.e. CBIPM project management unit. Communication tools e-mails, project fact sheets, various stage-specific reports, presentations, web-site matter etc. Communication plan Proposed communication plan for the Hazardous waste Inventorisation and characterisation project is given in Table 4-3 for its entire duration. Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 22
Table 4-3: Communication Plan Stage/ task/ deliverable Target firms Aim Communication tools Agency(ies) to act Commencement of the project Issuing authorisation letter Zonal and regional Offices To inform the Zonal Offices of Internal circular to APPCB Zonal CBIPMP Team and internal of APPCB APPCB regarding studies Offices communications within APPCB Consultant To issue authorization letter in Authorization letter to the order to facilitate consultant in Consultant collection of information from industries, field studies, sampling etc. Inception Report CBIPMP, APPCB, MoEF, World Bank To establish same understanding about the project among executing and review Team members. Submission of a draft report e-mailing final report in acrobat form. Submission of 3 hard copies of final report to CBIPM project management unit Consultant to submit the report CBIPMP is to finalise Questionnaire survey Designing questionnaire for collection of information on Hazardous waste First round: Sending questionnaires to all the hazardous waste generating, processing units and TSDFs CBIPMP / APPCB and Consultant Industries likely to generate hazardous waste, and common treatment and/or disposal facilities To seek each industry-specific complete relevant data on hazardous waste generation. To collect specific information of the industries and CETPs Recycling/reprocessing facilities regarding sources of hazardous waste generation, characteristics, storage arrangements, recycling/re-use Discussions/ meeting Consultant to propose draft format Couriering hard copy of relevant questionnaire to all industries Keeping a soft copy of the questionnaire on web-site for down loading CBIPMP to provide finalised format Consultant to dispatch the questionnaires with CC to CBIPMP APPCB-HO and APPCB ZO Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 23
Stage/ task/ deliverable Target firms Aim Communication tools Agency(ies) to act practices, mode of transportation and disposal. Second round: Sending Non-responded industries Same as above. Couriering reminder letters CBIPMP to dispatch the communication to increase to the questionnaires questionnaires with CC to the number of responses dispatched in first round Keeping the list of nonresponded APPCB-HWM Cell and to get questionnaire industries on the APPCB ZO survey web-site of APPCB Third round: Sending Notices/communications to further enhance no. of responses/ filled-in questionnaire forms Seeking clarifications on the information provided by the industries Non-responded industries as per first and second round of questionnaires dispatched Industries which have not provided right information or needs additional clarity Same as above. Letters to the Zonal Officers/regional officers from Member Secretary To get complete and reliable information Notices to the non-responded industries for questionnaire survey from the Regional Offices of APPCB Keeping the list of industries to which the notices are proposed to be issued on the web-site of APPCB Letters / emails/ teleconversations Project Director and MS to issue letter to all ZOs and Regional Officers to follow-up the submission of questionnaires. Regional offices to issue notices to the industries which did not responded to the first two communications CBIPMP to dispatch the questionnaires with CC to APPCB-HWM Cell and APPCB ZO Consultant Field investigations Communication to identified industries regarding in-depth investigations Selected industries by the consultant and APPCB for physical verification/sampling and analysis To verify the information given in filled-in questionnaire and to arrive at waste generation factors Letters / e-mails / teleconversations CBIPMP to issue first letter to each identified industry Consultant to follow-up the same for arranging Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 24
Stage/ task/ deliverable Target firms Aim Communication tools Agency(ies) to act visits. Spatial data generation and processing Designing spatial data CBIPMP / APPCB and Discussions/ meeting Consultant to propose template Consultant draft format To process each industryspecific data in the same format, having provision to spatially process and retrieve data CBIPMP to provide final format Data compilation formats Data compilation and reporting formats CBIPMP / APPCB and Consultant To process collected information in desired formats of APPCB Discussions/ meeting Consultant to propose draft format CBIPMP to provide final format Review of reports and offering technical inputs Different reports as per the CBIPMP / APPCB, MoEF, listed deliverables World Bank and Consultant To fulfill deliverables requirement, as per signed contract Submission of a soft copy of reports in acrobat; and Three hard copies of draft and 10 copies of final report. Consultant to submit draft report CBIPM project management unit, APPCB to provide technical inputs within fortnight for finalisation of reports by the Consultant. Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 25
4.5 Scheduling of Project Activities Table 4-4: Scheduling of Project Activities Activity Kick-off Meeting with CBIPMP and APPCB Officers Secondary data collection Questionnaire survey -I phase Questionnaire survey - II phase questionnaire survey -III phase Compilation of data data review In-depth studies WGFs GIS Data generation - procurement of imageries Digitization of basic features + data uplinking Spatial analysis Drawing inferences and way forward Duration in months I II III IV V VI VII VIII IX X XI XII Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 26
Activity Duration in months I II III IV V VI VII VIII IX X XI XII Inception report submission Preliminary report submission Intermediate report submission Final draft report submission Final report submission after receipt of views Submission of reports Preliminary Study Report Submitted by Centre for Environment & Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 27
5.0 SOURCES OF INFORMATION, INDUSTRY-SPECIFIC HAZARDOUS WASTE STREAMS AND PROPOSED INDUSTRIES FOR IN-DEPTH STUDIES 5.1 Sources of Secondary Information To identify sources of information on industries and their relevance to hazardous waste generation, an attempt has been made to review functions of different organisations which are involved in administering regulation of industrial activities, such as Pollution Control Board, Commissionerate of Industries, APIIC, Directorate of Factories etc. AP government established a single window facility to the entrepreneurs, which facilitates in following clearances: For establishment: AP Government established a single window facility to the entrepreneur, which facilitate in clearances. 1. Permission from Gram Panchayat, Municipality, UDA, T & CP, Factories Department. 2. Acquisition and alienation and allotment of land. 3. Power feasibility & Power connection. 4. Supply of Water and Water connection. 5. APGST & CST Registrations. 6. Financial assistance from APIDC. 7. Pollution clearance. 8. Registration of firms. 9. Drug Licenses. 10. NOC from Fire Services Department. 11. License for establishment of distillery. For operation: 1. Factories license. 2. License for storage of Petroleum/ Diesel/ Naphtha. 3. Boiler license. 4. Pollution clearance for operation. 5. Food grain license. 6. License for RS & DS, Chlorate of Potash. Please refer Figure 5-1 for typical sequence of activities perceived by a new entrepreneur in establishing a manufacturing facility in Andhra Pradesh. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 28
Figure 5-1: Typical Sequence of Activities by a new Entrepreneur The sequence of steps suggests the availability of list of industries and their department-specific jurisdiction, in order to analyse the suitability for availing the same list for short-listing of potential additional hazardous waste generating industries, beyond the list of industries covered in HW inventorisation in the year 2010. Relevance of different departments/ institutions and the utility of their data are discussed in Sub-Sections. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 29
5.1.1 Andhra Pradesh Pollution Control Board The trend of bulk drug industries and others in the state is of any indication, often industries submit their application for all possible coverage of products and anticipated maximum production capacities to avoid frequent applications to the Board. it does not give any significant conclusion by considering the used oil alone generating industries into the purview of hazardous waste inventorisation through questionnaire survey, particularly when scale of operation is small to medium in category, and used/spent oil is not a process waste but an auxiliary source. APPCB is involved in issuing water consent, air consent and authorisation for hazardous waste storage, transportation and disposal. Therefore, list of industries maintained by APPCB is directly relevant, having significant level of pollution. Therefore, the list of industries for which authorisation has been issued is the list that is directly relevant to hazardous waste generation, as these are verified by regulatory officers before issuing Authorisation. The consultant collected inventory of hazardous waste generating industries in the state conducted by APPCB in 2008 and 2010, thus the data of preceding years are captured. Please refer Appendix V for district-wise inventory data in 2008, Appendix VI for district-wise inventory data in 2010, Appendix VII for Category-wise reprocessed compilation of 2010 data. It has been noted that data compiled in these inventories are on the basis of capacities applied for or permitted in the authorisation letters rather than actual hazardous waste generation in the previous years. The trend of bulk drug industries and others in the state is of any indication, often industries submit their application for all possible coverage of products and anticipated maximum production capacities to avoid frequent applications to the Board. Therefore, often the quantities mentioned in these applications for getting authorisation are on higher side, and do not match with the figures reported by the TSDFs, for the respective values. Among the clearances an entrepreneur obtains, very important sources are authorizations issued by APPCB and clearance issued by factories Directorate. Principle observation upon processing of industrial data, is that there are many a number of industries, which generate only used oil/spent oil and including them in complete list of industries as relevant to hazardous waste generating industries may unwarrantedly make alarming recommendations with little utility in respect of enforcement and drawing policies, plans and intervening programmes. As it is clear that the used/spent oil has market value, thus there is no reason why an industry disposes it haphazardly. While there is a little share of waste oil which by definition refers to the spills & leaks that need to be recovered for proper disposal, as such may not worth economically for recovery of oil. In view of the above discussion, it does not give any significant conclusion by considering the used oil alone generating industries into the purview of hazardous waste inventorisation through questionnaire survey, particularly when scale of operation is small to medium in category, and used/spent oil is not a process waste but an auxiliary source. During discussions with APPCB officers, it is felt that there could be some hazardous waste generating industries, which are not covered by the Board; therefore some rational analysis of the issue may facilitate their regional Officers to track additional possible industries which could be brought under the purview of issuing authorisation for handling hazardous waste. Therefore, the consultant made an attempt to review the modus operandi followed by new entrepreneurs in the State while establishing their Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 30
industries, in order to track appropriate source of list of industries for facilitating the Regional Officers. 5.1.2 Commissionerate of Industries The Commissionerate of Industries, Andhra Pradesh has following principle mandates: To assist and guide for promotion and setting up of Industrial units Industrial approvals and Clearances from various departments / agencies at a single point. To register Micro Enterprise/ Small Enterprise/Medium Enterprises Sanction of incentives to eligible industrial undertakings. Create a transparent and automatic system of allotment of Scarce Raw Materials to industrial units Enable educated youth who are unemployed to set up their own ventures by arranging for financial assistance under Prime Minister s Rozgar Yojana (PMRY) Scheme, and so on. Registration of industry and referring that number for subsequent clearances is considered as an imperative requirement. Therefore, list available with Commissionerate of Industries is the possible exhaustive list. The Consultant interacted with the senior officers in the Department and realized following specific points: 1. New entrepreneurs first register with the district Industry centre (DIC), which acts as a single window facilitator for guiding the entrepreneur to establish the industry. 2. All large industries are registered with DIPP, Ministry of Commerce, therefore may or may not be registered with DIC and all remaining industries gets registered with DIC. 3. All industries registered with DIC are classified into red, orange and green categories, as per APPCB list, and accordingly advised for taking clearances from respective Offices. 4. Those industries, which do not cover under the list of Red, Orange and Green, are exempted from applying for consents, and are deemed to be non-relevant to pollution or pollution control board for the purpose of taking clearances. Please refer Appendix VIII for list of red, orange and green category industries. 5. Registration of industry and referring that number for subsequent clearances is considered as an imperative requirement; therefore, list available with Commissionerate of industries is the possible exhaustive list. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 31
6. A point to be noted hear is that all registered industries with DIC are not necessarily commenced their operations. The list also provides status of their commencement. 7. The data is made available to the Consultant by the Commissionerate of Industries and same is given in Appendix IX, as a softcopy in CD. 8. An attempt has been made by the consultant in identifying the line of activity based possible relevance of industry sector to hazardous waste. Besides, it is also considered that industries, which have given date of commencement of the project, are only considered with the understanding that only those units commenced their operation, hence relevant for generation of possible HW. 9. The list of industries, as arrived in point no. 8 is intended to be compared with the list of industries inventorised by APPCB in 2010, District-wise, for identifying the industries which still can be covered, in principle. However, actual operation of the industry, coverage of products and relevance to the hazardous waste may be established by the respective Regional Office of APPCB, to extend the applicability of HW Rules, in the next phase of renewal of water/air consents. 10. Please find the list of industries, as identified for further exploration by the respective regional Offices is given in Appendix X, as a soft copy in CD. This Appendix has a total list of 4214 industries of which 1682 are large and medium scale industries and remaining 2532 are SSI and SMEs. 5.1.3 Andhra Pradesh Industrial Infrastructure Corporation (APIIC) APIIC is a body entrusted with the objective of providing industrial infrastructure through development of industrial areas. The Corporation has so far developed more than 300 industrial parks spreading over an extent of about 1,21,655 acres (including allotted area). Besides, the Corporation is also developing sector focused parks like apparel park/food processing parks/leather parks, Special Economic Zones in the state. Major functions of APIIC include: 1. To formulate, promote, finance, aid, assist, establish, manage and control schemes, projects or programmers, to provide and develop infrastructure facilities, including factory sites, factory sheds, godowns, marketing facilities, warehouses facilities of communications, power, water drainage, housing, hospitals and other medical and health and educational institutions and other services of any description in order to promote and assist the rapid and orderly establishment, growth and development of industries and commerce in the State of Andhra Pradesh. 2. To aid, assist, promote and finance industries set up in the factory sheds constructed or factory sites developed by the Company, whether owned or run by Government, statutory body, co-operatives, company, firm or Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 32
individual or others and to provide them with capita, credit, means and resources for the prosecution of their work and business and to enable them to develop and improve their management, production and marketing techniques. 3. To implement schemes of incentives (financial and otherwise), subsidies and the like formulated by the Government of Andhra Pradesh, Government of India or other authorities or institutions and to administer such schemes in incentives as may be devised by the company from time to time in the interest of the establishment and development of industries and commerce in the State of Andhra Pradesh. 4. To carry on the business of hire purchase in, or to enter into hire purchase agreements with respect to the purchase and sole of, any goods, plant and machinery, tools and implements as aforesaid with any person, association, society or other body corporate on such terms and conditions as may be lawful. 5. To promote, establish, improve, develop, administer, own and run Tools Rooms, Pattern Shops Service Shops, Repair Shops or Work Shops to maintain, repair, refine, manipulate, alter or improve any plant, machinery, implements, accessories, appliances, apparatus, tools, goods or things of any description capable of being used by any customer of or person having dealings with the Company, or commonly dealt in by persons engages in any such business which may seem capable of being profitably dealt with by the Company and to manufacture, import, export, buy sell or otherwise deal in workshop machinery of all kinds. APIIC can only give an authentic industrial estate land layout maps/plot details but not the operations being performed in various plots. 6. To undertake such other activities, industrial, commercial or financial, this will create conditions conducive to the growth of industries in the State of Andhra Pradesh. The consultant approached APIIC with a request to provide the lay-outs of 300+ industrial estates established and promoted by APIIC with the list of allottees. The detailed discussions with concerned Environment Team reveals following: 1. The initial list of allottees available with the APIIC do not match with the current list of operators, as the land would have been transferred for other applications after initial block-in period. 2. APIIC made an attempt earlier to have compilation of the industries in their industrial estates and those compilations did not match with the list available with APIIC and as such the repeated such inventories reveals different findings without any set pattern. 3. APIIC is yet to make the industrial estates maps and list of industries made available to the Consultant. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 33
4. Therefore, it can be realized that APIIC can only give an authentic industrial estate land layout maps/plot details but not the operations being performed in various plots. Therefore the partial utility of the data from APIIC drives us to conclude that the layout plans of APIIC and inventory data through questionnaire will facilitate the location of the industry as per given lat-longs data by the industries for cross verification on the APIIC maps. 5. APIIC establishes industrial area local authorities (IALAs) for effective governance in the local industrial areas. These authorities maintain all the records concerned to the industries and common services. Therefore, relatively better information may be available at these IALAs; as such the Central Environment Team at Head Office of APIIC is having the authority to collect the information periodically for taking respective interventions. The consultant is pursuing with APIIC to get possible information and solicits intervention from APPCB for getting the same. 5.1.4 Factories Department Factories Department is primarily involved in following: Advice and guidance for management of factories Approval of plans of new factories Welfare measures for the industrial workers The definition of factory is of concern here, as it refers to atleast 10 workers and for identified industrial sectors only, as given under the Factories Act. Factories by definition need to have atleast 10 workers, therefore those industries having less than 10 workers gets exempted. Besides, the entire list may not be relevant to hazardous waste generation.. The consultant approached the Department and held detailed discussions with Senior Officers regarding coverage of the Act and relevance of list available with them to hazardous waste generation. The discussions revealed following: The Factories Department feels that the list available with the APPCB can only be relied, as the list with them is with the different objectives and by knowing the name, the line of activities and their relevance cannot be arrived. However, it is given to understand that department has about 40000+ industries list. From discussions, the consultant understands that list as given by the department is an authentic list of factories. Factories by definition need to have atleast 10 workers, therefore those industries having less than 10 workers gets exempted. Besides, the entire list may not be relevant to hazardous waste generation, due to various lines of activities. As such, it is given to understand that industries which are involved in storage of chemicals in godowns are getting exempted from the license requirement, and thus need to be captured, in general, than others, as all others are Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 34
5.1.5 Other Departments getting captured by the multiple departments including Directorate of Factories, and can t escape under the normal circumstances. List of Industries in AP under the surveillance of Directorate of Factories is given in Appendix XI. Other departments in respect of their functions and relevance to the hazardous waste generation information are discussed in Table 5-1. Table 5-1: Department-Specific Functions and Relevance to Hazardous Waste Generation S. Department Major function Relevance to Hazardous waste No. 1 Central Excise Collection of Central Excise duty and Service Tax Industries which are producing taxable products a source of Department Besides, other taxes like National information for assessing Calamity Contingent Duty, relevance of industrial activity to different kinds of CESS, Additional hazardous waste generation. duty of Excise, are also collected for the exchequer It may be noted that certain Facilitates Export by sealing industries are exempted from containers and packages under physical supervision. paying tax up to certain sales value, but may have relevance to possible HW; hence, the list as it is cannot be completely relied on. 2 State Commercial Tax Department 3 Industry associations Administration of Value Added Tax (VAT), Entertainment Tax and Profession Tax. Assessments of goods movement and posts Promote large, medium and smallscale industries involved in almost all major manufacturing fields. Can facilitate in tracking the movement of goods for limited no. of items, of which many might be from the entertainment and other domains. Industry association will keep list of all their members and there is a possibility of maintaining summary statistics including the hazardous waste generation etc. The list available with them may only be their members and not necessarily the entire industries in the state. However, it is felt appropriate to send a questionnaire to the major industry associations for their cooperation in getting filled-in questionnaires from their members. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 35
4 Civil supplies engaged in promotion, improvement, development of counsel and finance production, purchase, storage, processing movement transport distribution and sale of food grains, foodstuffs and any other essential commodities and to establish laboratories for the purpose of ensuring quality control 5 APIDC Project promotion- generation & implementation of project ideas. Equity participation Venture capital for IT, biotechnology & sunrise industries. Long, medium and short term loans Bill discounting Rehabilitation of sick industrial units 6 AP DISCOMs Engage in transmission and supply of electric energy Involved in transportation & distribution of commodities like - Kerosene, LPG & Petrol etc. It can provide list of depots, for seeking information regarding Hazardous waste generation. Involved in promotion of industries having several overlapping functions with APIIC. However, exhaustive list of reliable industries is not expected from the Department, as all the industries need not be approaching it for financial and other support. The HT lines commercial information could be retrieved from the Department; however, this information does not give the line of activity details for the purpose of arriving at the relevance to hazardous waste generation. As such there are HT lines for nonindustrial purposes and difficult to segregate. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 36
7 Mines and Geology 8 Public complaints Receipt and processing of Applications for the grant of leases under Mineral Concession Rules To monitor scientific exploitation of mineral wealth of the state. To control illicit mining, quarrying and transportation of minerals. Scanning and identification of Mineral Resources Guidance and Dissemination of Mineral Information Promotion of Mineral Based Industries. To monitor production and dispatches of various minerals. To monitor collection of royalty and seigniorage fee based on grades/quantity. Imposition of penalties on illicit mining, transportation and storage. Public complaints Legal cases Specific industries in non-attainment areas etc. List of Mineral based industries could be retrieved from the Department for sending questionnaires. All those industries, which have some public complaints/ legal/ court cases will attract the regulatory Boards and are often specifically tracked for the periodic updates. Therefore, specific industries other than the list already inventorised earlier are not anticipated. However, the advice from APPCB in this regard will be incorporated in the questionnaire survey. 5.1.6 Summary Observations Summary observations on source of information regarding hazardous waste generating industries are discussed below: 1. The list available with the APPCB is much more relevant as it is the list verified and authenticated by the regional offices after thorough review of the industrial process and upon inspection. 2. Directorate of Factories issues permission for those industries which have 10 or more workers and falls in the list of operations identified under the Factories Act, only. Therefore, the list may provide industries, but all of them may or may not be relevant to hazardous waste, and as such the list does not represent entire possible hazardous waste generating industries. Therefore the list would be a sub-set of industries listed with Commissionerate of Industries. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 37
3. Entire list of industries available with Commissionerate of Industries reveals that 1,00,195 (4520 large and medium scale industries; 95675 are small scale industries, and Small and micro enterprises together; Large, medium and small scale units are defined as more than rupees 10 crores, 5-10 crores and less than 5 crores investment on plant and machinery, respectively) industries are registered in Andhra Pradesh, so far. Registration with Commissionerate of industries does not mean that these industries are in operation since then, but are just registered to pursue the projects for their establishment and operation. It means this is an indicative list of industries only and not necessarily the list of industries which are in operation. As such the list also classified in respect of Large and medium scale industries, and small scale and small & micro enterprises. It may be worth to mention that industrial operations are classified into red, orange and green category. The red (64), orange (25) and green (55) categories cover 144 identified industry sectors and all others beyond this list are considered to be non-polluting and do not require to take CFE/CFO from the pollution control Board. Therefore, the relevance of the industries to pollution is limited to red, orange and green categories only emphasizing large and medium scale. 4. Therefore, in view of above specific observations, it has been felt appropriate to consider following in sequence: a. List of industries to which HW authorisation has been issued in 2010 will be considered as first list for issuing questionnaire (3222 in no.) b. List of new industries to which consent for operation issued during Jan-Dec, 2012 and not covered in point a will be considered as second list for issuing questionnaire c. List of relevant industries as identified from the Commissionerate of industries (4214 in no.) minus the above two lists will be considered as third list for issuing questionnaire d. Possible list of additional industries/ depots/ operations as per Section 5.1.5 and others including Directorate of Factories, would be considered as the fourth and final list for issuing questionnaire. e. It is also felt appropriate to keep the list of industries collected from the Commissionerate of Industries and the Factories Department on the web-site of APPCB for filing their response to the questionnaire, if relevant to HW Rules. 5.2 Industry Sector-Specific Hazardous Waste Streams Andhra Pradesh Pollution Control Board is reviewing, every month, applications for water/air consent and/or authorisation for hazardous waste. The APPCB s Technical Committee either considering or rejecting such applications on case by case, based on merits and limitations. The list of industries to which authorisation for storage and safe disposal of Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 38
This exercise of the Consultant identified the notified HW streams concerned to an industry sector as per Schedule I of the Rules; other applicable streams from the Schedule I itself; and applicable streams from the Schedule II considerations. hazardous waste has been given by the Board to 3222 Industries in 2010 and in addition, few industries are getting added every year, besides renewal of existing authorizations. The specific observations on the reporting patterns by different industry sectors has been made keeping in view of the provisions under HW Rules, 2008. This exercise of the Consultant identified the notified HW streams concerned to an industry sector as per Schedule I of the Rules; other applicable streams from the Schedule I itself; and applicable streams from the Schedule II considerations. This analysis is intended to facilitate the industries to report all relevant streams from their plants instead of just sectoral streams excluding other relevant streams from Schedule I and Schedule II. Please refer Table 5-2 for detailed list of relevant sector-specific hazardous waste streams. Table 5-2: Industry Sector-Specific Relevant Hazardous Waste Streams S. Industry sector Schedule I streams* Earlier no. Directly relevant to industry sector Others reported Schedule II Streams** 1 Aluminium products 11.1, 11.2, 11.3, 5.1, 34.3, 34.4 11.4, 11.5 2 Anhydrous 5.1 Ammonia 3 Anodizing 5.1, 34.3 4 Asbestos products 15.1, 15.2, 15.3 5.1 5 Auto spare parts & 5.1, 33.3, 34.4 servicing units 6 Bio-diesel 4.1, 4.2,4.3, 4.4, 5.1 4.5, 4.6 7 Blades 34.3 8 Breweries 5.1, 33.3, 34.3, 34.4 9 Cables 21.1, 21.2, 8.2 5.1, 34.4 10 Carbon 5.1 11 Cargo 5.1 12 Cellulose 5.1, 33.3,34.3, 34.4 13 Cement 4.1, 5.1 14 Ceramics 5.1 15 CETP 30.2, 34.3, 34.4, 5.1 34.2 16 Chemicals 5.1, 34.3 17 Chlor-alkali 16.1, 16.2, 16.3 5.1 18 Chromium/Chrome products 5.1, 34.1, 34.3 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 39
S. no. Industry sector Schedule I streams* Earlier Directly relevant to industry sector Others reported Schedule II Streams** 19 Clay 5.1 20 Coffee 5.1 21 Compressors 5.1, 34.3 22 Computer 5.1 stationary 23 Copper products 8.2 5.1, 33.3, 34.4 24 Coke & Power 5.1 25 Coal (dry)/mineral 5.1 processing 26 Coal Washery 5.1 27 Construction 5.1 28 Container cleaning 33.3 5.1 29 Cosmetics 5.1 30 Cotton wool 5.1, 33.3 31 Crushers 5.1 32 Dairy 5.1, 34.3, 34.4 33 Diamond jewellery 5.1 34 Distilleries 36.4 5.1, 34.3, 34.4, 33.3 35 Dredging 5.1 36 Drill bits 5.1 37 Drugs & Pharmaceuticals 28.1, 28.2, 28.5 5.1, 20.2, 20.3, 21.1*, 33.3, 34.3, 34.4, 35.3, 36.4, 34.2 26.1, 26.2 5.1, 33.3, 34.3 38 Dye & Dye Intermediates 39 Evaporator panels 5.1 40 Electrical equipments 5.1,5.2, 33.3, 34.3, 34.4, 21.1, 20.2 41 Electronics 31.1, 31.2 5.1, 5.2, 21.1, 34.3, 36.1 42 Electroplating 12.1, 12.2, 12.8 5.1, 34.3, 34.4, 20.1, 20.2 43 Explosives 5.1, 33.3, 34.3 E4 44 Fertilizers 18.1, 18.2, 18.3, 5.1, 33.3, 36.4 18.4, 18.5 45 Fermentation 28.2, 28.5 5.1, 33.3, 34.4, 34.3, 36.2 46 Ferro industries 13.1, 13.3, 13.4 5.1 B3 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 40
S. Industry sector Schedule I streams* Earlier no. Directly relevant to industry sector Others reported Schedule II Streams** 47 food & 5.1 confectionery 48 Galvanizing 12.1, 12.2, 12.3, 12.4, 12.6, 12.8 5.1, 34.3, 34.4, 33.3 49 Glass and fiber glass 23.1 5.1, 34.3 production and processing 50 Glue and gelatin 5.1 51 Heavy water plants 5.1 52 Incineration plants 36.1, 36.2 5.1 53 Industrial and 5.1 inorganic gases 54 Ink & Ink printing 21.1, 21.2 5.1, 33.3, 34.3, 34.4 55 Integrated iron & 5.1, 34.1 steel 56 Isolated storages 4.1 5.1, 5.2, 33.3, 34.3 57 Jute mills 5.1 58 Lab 5.1, 34.4 59 Lime manufacturing 5.1 60 Liquor bottling 5.1 61 Lubricating oil, greases or petroleum based products 4.1,4.2,4.3, 4.4,4.5,4.6 5.1, 34.4 62 Metal products 5.1, 34.4, 34.3 63 Mining/minerals 5.1 64 Nickel, cadmium & 10.1 5.1, 34.3 arsenic compounds 65 Oil & gas 2.1, 2.2, 2.3 5.1 exploration 66 Oil refinery 4.1, 4.2, 4.3, 5.1, 34.3, 34.2 4.4, 4.5, 4.6 67 Paints 21.1, 21.2 5.1, 33.3, 34.3, 20.2, 20.3 68 Pesticides 29.1, 29.2, 29.3 5.1, 33.3, 34.3, 36.4 69 Petrochemicals 5.1, 33.3, 34.3, 34.4, 34.2 70 Phosphate 5.1, 33.3, 34.3 processing 71 Plastic products 21.1, 21.2 5.1, 33.3, 34.3 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 41
S. no. Industry sector Schedule I streams* Earlier Directly relevant to industry sector Others reported Schedule II Streams** 72 Plywood 5.1 73 Pulp & paper 32.1, 32.2, 32.3 5.1, 34.3, 34.2 Industry 74 Resins 23.1 5.1, 33.3, 34.3, 34.4 75 Solvent recovery & use 20.1, 20.2, 20.3 35.1, 35.2, 35.3 5.1, 34.3, 34.4, 36.4 76 Sugar 5.1, 34.3, 34.4 77 Surgical and medical 5.1 products 78 Synthetic detergent 5.1 and soap making 79 Synthetic rubber 23.1 5.1, 33.3, 33.4 80 Synthetic fibers 5.1 81 Tanneries 30.1, 30.2 5.1, 34.3 82 Textiles 24.1, 24.2 5.1, 33.3, 34.3 83 Thermal Power 5.1, 34.2, 34.3 Plants 84 Tobacco products 20.1, 20.2, 20.3, 5.1 and processing 29.2 85 TSDF 36.1, 36.2, 36.3, 5.1 36.4 86 Vegetable oils and 5.1 solvent extraction 87 Zinc 6.1, 6.2, 6.3, 6.4 5.1, 34.3 Note: * List to be considered while reporting but not limited to only mentioned items ** List reported earlier by the industries, however, the respective numbers would vary as per the processes and corresponding waste characteristics Above Table covers prevailing industries including red category for analyzing the profile of hazardous waste generation in Andhra Pradesh, not an exhaustive list covering all categories. There are many more categories of industries, which generate only used/spent oil but are not known to be generating significant hazardous waste for the consideration under study. This is pertinent to mention that red, orange and green categorization of the industries is based on their pollution potential, which could be air pollution potential and/or water pollution potential and/or hazardous waste generation. Therefore, a specific industry having listed in it does not necessarily Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 42
mean generating hazardous waste. Therefore, the list of red, orange and green categories are considered to the extent to realize the relevance of the industry for the purpose of inventory. Among the entire Table, if industries generating used/spent oil (ITEM 5.1 IN Schedule I of HW Rules), alone are removed, then 55 industry sectors are falling in the purview, which are listed in Table 5-3. Table 5-3: List of Industry Sectors Having Multiple Sources of Hazardous Waste Generation S. Industry sector Schedule I streams* Earlier no. Directly relevant to industry sector Others reported Schedule II Streams** 1 Aluminium products 11.1, 11.2, 11.3, 5.1, 34.3, 34.4 11.4, 11.5 2 Anodizing 5.1, 34.3 3 Asbestos products 15.1, 15.2, 15.3 5.1 4 Auto spare parts & 5.1, 33.3, 34.4 servicing units 5 Bio-diesel 4.1, 4.2,4.3, 4.4, 4.5, 4.6 6 Blades 34.3 7 Breweries 5.1, 33.3, 34.3, 34.4 8 Cables 21.1, 21.2, 8.2 5.1, 34.4 9 Cellulose 5.1, 33.3,34.3, 34.4 10 Cement 4.1, 5.1 11 CETP 30.2, 34.3, 34.4, 5.1 34.2 12 Chemicals 5.1, 34.3 13 Chlor-alkali 16.2 14 Chromium/Chrome 5.1, 34.1, 34.3 products 15 Compressors 5.1, 34.3 16 Copper products 8.2 5.1, 33.3, 34.4 17 Container cleaning 33.3 18 Cotton wool 5.1, 33.3 19 Dairy 5.1, 34.3, 34.4 20 Distilleries 36.4 5.1, 34.3, 34.4, 33.3 21 Drugs & Pharmaceuticals 28.1, 28.2, 28.5 5.1, 20.2, 20.3, 21.1*, 33.3, 34.3, 34.4, 35.3, 36.4, 34.2 22 Dye & Dye 26.1, 26.2 5.1, 33.3, 34.3 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 43
S. no. Industry sector Schedule I streams* Earlier Directly Others relevant to industry sector Intermediates 23 Electrical equipments 5.1,5.2, 33.3, 34.3, 34.4, 21.1, 20.2 24 Electronics 31.1, 31.2 5.1, 5.2, 21.1, 34.3, 36.1 25 Electroplating 12.1, 12.2, 12.8 5.1, 34.3, 34.4, 20.1, 20.2 26 Explosives 5.1, 33.3, 34.3 E4 27 Fertilizers 18.1, 18.2, 18.3, 5.1, 33.3, 36.4 18.4, 18.5 28 Fermentation 28.2, 28.5 5.1, 33.3, 34.4, 34.3, 36.2 29 Galvanizing 12.1, 12.2, 12.3, 12.4, 12.6, 12.8 5.1, 34.3, 34.4, 33.3 30 Glass and fiber glass 23.1 5.1, 34.3 production and processing 31 Ink & Ink printing 21.1, 21.2 5.1, 33.3, 34.3, 34.4 32 Integrated iron & 5.1, 34.1 steel 33 Isolated storages 4.1 5.1, 5.2, 33.3, 34.3 34 Lab 5.1, 34.4 35 Lubricating oil, 4.1,4.2,4.3, 5.1, 34.4 greases or petroleum based products 4.4,4.5,4.6 36 Metal products 5.1, 34.4, 34.3 37 Nickel, cadmium & 10.1 5.1, 34.3 arsenic compounds 38 Oil & gas 2.1, 2.2, 2.3 5.1 exploration 39 Oil refinery 4.1, 4.2, 4.3, 5.1, 34.3, 34.2 4.4, 4.5, 4.6 40 Paints 21.1, 21.2 5.1, 33.3, 34.3, 20.2, 20.3 41 Pesticides 29.1, 29.2, 29.3 5.1, 33.3, 34.3, 36.4 42 Petrochemicals 5.1, 33.3, 34.3, 34.4, 34.2 reported Schedule II Streams** B3 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 44
S. no. Industry sector Schedule I streams* Earlier Directly relevant to industry sector Others reported Schedule II Streams** 5.1, 33.3, 34.3 processing 43 Phosphate 44 Plastic products 21.1, 21.2 5.1, 33.3, 34.3 45 Pulp & paper 32.1, 32.2, 32.3 5.1, 34.3, 34.2 Industry 46 Resins 23.1 5.1, 33.3, 34.3, 34.4 47 Solvent recovery & use 20.1, 20.2, 20.3 35.1, 35.2, 35.3 5.1, 34.3, 34.4, 36.4 48 Sugar 5.1, 34.3, 34.4 49 Synthetic rubber 23.1 5.1, 33.3, 33.4 50 Tanneries 30.1, 30.2 5.1, 34.3 51 Textiles 24.1, 24.2 5.1, 33.3, 34.3 52 Thermal Power 5.1, 34.2, 34.3 Plants 53 Tobacco products 20.1, 20.2, 20.3, 5.1 and processing 29.2 54 TSDF 36.1, 36.2, 36.3, 5.1 36.4 55 Zinc 6.1, 6.2, 6.3, 6.4 5.1, 34.3 Note: * List to be considered while reporting, but not limited to only mentioned items but includes other relevant categories. ** List reported earlier by the industries, however, the respective numbers would vary as per the processes and corresponding waste characteristics 5.3 List of Proposed Industries for In-depth Studies In accordance to APPCB identified industry-sectors for in-depth studies, number of industries to be visited is identified and same is given in Table 5-4. Table 5-4: Industry Sector-Specific Number of Industries to be Visited for In-depth Studies S. No Sector Tentative no. of representative industries 1 Bulk drugs 10 2 Power plants (thermal, bio-mass based) 2 3 Cement plants 2 4 Sponge iron plants 2 Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 45
5 Metal finishing units (galvanizing, electroplating) 6 Petroleum refineries 4 7 CETPs 3 8 TSDFs 2 6 31 5.3.1 Bulk-drug industries Proposed list of industries for in-depth studies in each sector are identified in next Sub-Sections. Andhra Pradesh is nesting a huge number of bulk-drug and pharmaceutical industries, covering production of wide variety of generic and specialty drugs. The synthetic batch operations involved in production of bulk-drugs is often complex in respect of implementation of environmental regulations. The complexity can be attributed to following variations: 1. A specific bulk drug production may involve several process reactions and associated process operations. 2. Not all the process reactions are employed by all the industries i.e. some may procure intermediates and employ only remaining reactions. Therefore the comparison of waste generation factors for a product is difficult to establish until unless all the process reactions and operations of two industries are same. 3. Scale of operation influence reaction conversion efficiency As maximum number of industries is proposed in Bulk-drug industry sector, an exercise has been carried out to identify the list of industries through a rationale. Prioritization of industries for in-depth studies is summarized in Table 5-5. Table 5-5: Prioritization of Bulk-drug Industries for In-depth Studies Name of the industry Ranking as per their maximum Remarks Total Land-fillable Recoverable Incinerable No. of Products Priority hazardous waste generation waste generation waste generation waste generation Total Score for indepth studies Qty Rank Qty Rank Qty Rank Qty Rank Qty Rank M/s. Divis Laboratories Ltd., Visakhapatnam M/s. Vegesna Laboratories Pvt. Ltd., Visakhapatnam M/s. Aurobindo Pharmaceuticals Ltd., Pashamaylaram 129942 1 355 9 128671 1 915 4 50 1 16 II 9813 8 1033 4 7616 4 1164 3 //960// 0 19 III 47110 2 1235 2 44632 2 1244 2 28 2 10 I Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 46
M/s. Kekule Pharma Ltd. M/s. Virchow Laboratories Ltd., Gaddapotharam M/s. SMS Pharmaceuticals Ltd. 22706 5 1095 3 19401 3 24 9 10 5 25 V 32172 3 376 8 0 11 8 10 1 10 42 X 24109 4 913 5 10 9 4365 1 12 3 22 IV M/s. Matrix 15554 7 861 6 3 10 598 5 7 7 35 VIII Laboratories Ltd. M/s. Sudarshan drugs 7633 11 19 10 39 8 71 8 3 9 46 XI M/s. Piramal Health Care 20075 6 7 11 2142 7 0 11 11 4 39 IX M/s. Aurobindo Pharma, Gundlamachanoor M/s. Virchow laboratories ltd. 8028 10 782 7 7594 5 186 6 9 6 34 VII 9533 9 6816 1 2592 6 125 7 4 8 31 VI 5.3.2 Power Plants From the above Table, considering the diversity, it is proposed to visit following first 10 industries on priority: 1. M/s. Aurobindo Pharmaceuticals Ltd., Pashamaylaram 2. M/s. Divis Laboratories Ltd., Visakhapatnam 3. M/s. Vegesna Laboratories Pvt. Ltd., Visakhapatnam 4. M/s. SMS Pharmaceuticals Ltd. 5. M/s. Kekule Pharma Ltd. 6. M/s. Virchow Laboratories Ltd. 7. M/s. Aurobindo Pharma, Gundlamachanoor 8. M/s. Matrix Laboratories Ltd. 9. M/s. Piramal Health Care 10. M/s. Virchow Laboratories Ltd., Gaddapotharam 11. M/s. Sudarshan drugs Power plants in Andhra Pradesh can be classified into thermal power plants (Coal, oil, gas and bio-mass based) and hydro power projects. Thermal power plans could be isolated or captive i.e. power plant is a unit within large industrial complex to support power requirement of the complex. As per the Scope, two industries i.e. one from the coal and other from biomass based power plants need to be visited. Therefore the choice of industries for coal based power and bio-mass based power units are as follows: Power plant (Coal based) considering the maximum capacity: 1. NTPC, Ramagundam 2600 MW; or 2. NTR Power station, Ibrahimpatnam 1260 MW / LANCO Power, Kondapalli 1155 MW Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 47
5.3.3 Cement Plants Power Plant (bio-mass based): Typically these plants are reporting a size of 6 MW power generations. Therefore, proposing to study one among following based on regional distribution: 1. M/s. Satya Maharshi Power Corporation Ltd. Mutlayapalem, Amaravathi, Guntur District.; or 2. Ind Bharat Energies Pvt. Ltd., Dilwarpur road, Miryalguda; or 3. Perpetual energy systems Ltd., Vizianagaram As per the scope, two cement plants need to be studied in-depth. Therefore, it is logical to cover one purely cement industry and the other could be a cement industry handling hazardous waste for co-incineration. Accordingly, upon review of the cement industries, following choice of industries are suggested for in-depth studies: Cement industry: Nalgonda is a major hub for cement plants in the state. Therefore, we propose to visit one of the following industries for in-depth studies, having significantly large production: 1. My home industries Ltd., Mallacheruvu, Nalgonda; or 2. M/s. Deccan Cements Ltd. Janpahad, Neruducherla Cement industry which adopted co-incineration of HW: Few cement industries in the state are accepting hazardous waste for coincineration, among them the prominent names include four i.e.: M/s. India Cements, Nalgonda M/s. Ultratech Cement Ltd. M/s. Anjana Port land cements, Nalgonda M/s. NCL industries Ltd. 5.3.4 Sponge Iron Plants Therefore, we propose to visit M/s. India cements or M/s. Ultratech Cements Ltd., for in-depth studies on priority. Sponge iron plants are spread in few districts i.e. Vijayanagaram, ananthapur, Kurnool, Chittoor, Nalgonda, medcherla, Krishna, Khammam and Mehboobnagar. Couple of plants in Vijayanagaram seems to have significant processing capacity, while the maximum is produced in Chittoor plant. We propose to cover one of the two sponge iron plants in Vijayanagaram, for in-depth studies i.e. 1. GSAL (India) Ltd., Srirampuram L Kota Vijayanagaram; or Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 48
2. Maa Maha Maya industries Pvt. Ltd. Relligurammapeta L Kota Vijayanagaram. 5.3.5 Metal Finishing Units (galvanising and electroplating) 5.3.6 Petroleum Refineries As per defined scope, the Consultant is to visit 6 industries in this category to verify data being submitted and for in-depth analysis. The list of galvanising and electroplating industries in Andhra Pradesh has been reviewed and following industries for in-depth studies, on priority, are identified considering maximum production capacity and diversity in reported hazardous waste streams: Galvanising units: 1. ECI Infra Towers Company Pvt. Ltd., Kaveli; 2. ARM Limited, 45&46, Keesara Road, Nagaram, RR District; 3. Relliance Galvanising Industries Plot no. 15 Rd.No. 2, Bhagyanagar Co-op Industrial estate, Balanagar, RR District; 4. Deepak Galvanising and Engineering Industries Pvt. Ltd., Plot no. 45 48, IDA Nacharam, RR District; or 5. M/s.Gowthami Steel Ltd., Aganampudi, Visakhapatnam Electro-plating units: 1. M/s. GVK Novopan Industries Ltd., IDA, Phase-II, Patancheru, Medak; 2. M/s. ECIL, IDA, Cherlapally, RR District; or 3. Hindustan Aeronautics Ltd., Balanagar, RR District It has been felt appropriate to cover 4 industries in this segment for in-depth studies. The composition may include existing two oil refineries and couple of other waste oil recyclers/reprocessing facilities. Accordingly, proposed list of industries is given below: Oil refineries: 1. HPCL Malkanuram Visakha Refinery, Visakhapatnam 2. M/s. ONGC, Minirefinery, Thatipaka, EG District. Waste Oil recycler / reprocesser: 1. Sri Balaji Lubricants plot no. 15 & 17, AIE, Pedagantyada; 2. Sri Priyanka Agro Enterprises Pvt. Ltd. Sy. No.681, Chandra Sekhara Puram, Kodavalur, Nellore; or 3. M/s. Jajala Impex Pvt. Ltd., Plot no. D-113 Phase-I, IDA, Jeedimetla, Rangareddy District. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 49
5.3.7 CETPs AP is having three operating CETPs at Jeedimetla, Patancheru and Parawada. Therefore, all the three CETPs are proposed to be covered for in-depth studies, as these are the potential source of hazardous waste for secured land filling. The address of these CETPs is given below: 1. Jeedimetla Effluent Treatment Ltd., Plot no. 267 Phase-I, IDA, Jeedimetla, RR District. 2. Patancheru Enviro Tech Ltd., Plot no. 23, 24 & 25, Phase-IV, Ida, Patancheru, Medak District. 3. CETP Of M/s. Ramkey Pharmacity (I) Ltd., Pharmacity, Parawada 5.3.8 TSDFs 5.3.9 Dry visits to selected industries AP is having three operating TSDFs. As per the scope, it is proposed to visit following first two major facilities for in-depth studies, i.e: 1. M/s. Hyderabad Waste Management Project HWMP, Dundigal, RR District 2. M/s. Coastal Waste Management Project CWMP, Pharma City, Parawada, Visakhapatnam; or 3. M/s. Maridi Eco Industries (Andhra) Ltd., Kapuluppada, Visakhapatnam As share of Category 5.1 alone generating industries in entire State s HW generation is mere in percentages, as such used oil/spent oil has resale value and there are registered recyclers to collect & process the waste besides use as fuel. It has been observed that visits to 25 industries/facilities, which generate maximum hazardous waste in the State will cover more than 50% of the total hazardous waste generation in the State. Therefore, while selecting industries for in-depth studies these major industries are kept in the backdrop, to have reliable data. While some of these industries are getting covered in in-depth studies not all are likely to get covered due to the set numbers against the identified sectors by the Board. Therefore, it is felt appropriate by the Consultant to visit remaining industries in top 25, for collection of dry reliable information. Thus, best efforts will be made to ensure reliability of information from the major waste generating facilities, which drives the policies and plans, for effective management of Hazardous waste in the State. HW inventory 2010 findings would be availed for identifying the maximum waste generating industries. This is also to mention that the industries which generate only used oil/spent oil (5.1 category of Schedule I of HW Rules), will be classified into large, medium and small scale categories and three representative industries in each category will be visited to collect data based on inventory records, so that WGFs could be arrived for the purpose of gross estimates in each segment i.e. large, medium and small scale industries in AP. As the share of this category of waste in entire State s HW generation would be in decimal percentages, as such used oil/spent oil has resale value and there are registered recyclers to collect & process the waste besides use as fuel. Therefore, entry of this stream into the environment as hazardous waste, under normal circumstances are remote. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 50
It is pertinent to mention that the Consultant has drawn a detailed communication strategy and presented in previous Chapter to reach out to all relevant industries. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 51
6.0 PROJECT RISKS AND ASSUMPTIONS Project activities primarily involve questionnaire survey, in-depth studies in identified industries and rational processing of the data including spatial analysis. The coverage of project include all the industries in Andhra Pradesh, which are likely to generate hazardous waste and field studies are confined to identified industrial categories only with clearly defined number of such visits in each industrial category with number of samples and parameters for analysis. This offers clarity on the scope of work for implementation of various tasks of the Project. The project activities primarily involve questionnaire survey, in-depth studies in identified industries and rational processing of the data including spatial analysis. Performance of these activities gets influenced by the key stake-holders abilities, their willingness to cooperate, and reliability of data provided to the Key Team members. Therefore, the Consultant hereby presents the summary of project risks and assumptions for ready reference of executing and reviewing Team members. As such, the work plan and communication plans are derived in a manner to keep the associated risks to its minimum, in order to achieve desired quality of outputs in scheduled project time lines. In the light of scope of services, approach finalised for the project and perceptions of professionals during the inception phase, the consultant hereby captures following risk and assumptions for information of the project stake-holders in order to safeguard the project interest to its best, in the given context. The specific points in this regard are given in next Sections. 6.1 Project Risks Specific anticipated risks of the project are given below: i. Poor no. of responses to the questionnaire survey An effective three-tier communication strategy has been proposed including regulatory notices, as the final stage, to obtain maximum responses. ii. iii. Insufficient access to available data and information with APPCB APPCB has given a hard copy of the 2010 compilation of inventory results. Other information and soft copies are assured. CBIPMP officers are highly cooperative, and thus access to the information as given in Appendix-I is anticipated. Reluctance of the industries in providing complete information through filled-in questionnaire forms The completeness of information is often an issue of concern in many of the questionnaire responses. Therefore, utmost care is taken in designing the sector-specific questionnaires, which will further be technically improvised by the APPCB Team, before dispatching. Thus, the risk is likely to be dwarfed. Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 52
iv. Specific products may not be produced during project period for developing WGFs While the industries for in-depth studies will be chosen by following set criteria to cover as many products of relevance as possible, the risk of some products not being manufactured during the project period or visits cannot be ruledout. However, best efforts will be made to maximize the project benefit. v. Lack of record keeping at the reprocessing facilities of waste oil / used oil and others Tracking of exact quantities of used oil and waste oil reprocessing within the state and sending out of the state are aimed for cross checking under the project. Lack of records and limited data provided by the reprocessing units may constrain the out-put. vi. vii. viii. Resistance of the industries to allow information dissemination to the public due to confidentiality issues Certain catalysts, reaction conditions effecting the conversion efficiencies are felt confidential by the respective industries. Therefore, for the purpose of the intended studies, best efforts will be made to achieve reasonably acceptable estimations. Representativeness of the selected industry categories for entire hazardous waste generation Specific sectors have been identified in the scope for focused efforts. Same will be considered for indepth studies. Quality of data and minimum number of comparable manufacturing process in the state, for developing reliable WGFs For reasonably achieving the waste generation factors, multiple sources of industrial data for same unit operation is an imperative requirement. Therefore, there is a risk of generalising few monitored same unit operations to others, and it is particularly relevant in batch process operations in synthetic organic chemical industry. 6.2 Project Assumptions For successful accomplishment of the project, the consultant assumes certain points, besides risks, which are given below. i. Full access to existing soft data and documents (Appendix I) ii. In-depth studies in industries would be conducted and suspected hazardous waste samples will be collected for cross verification of the data provided by the respective unit and also to establish reliable WGFs iii. The Client will advise, support and facilitate the Consultant in all relevant issues with regard to the objectives of the project Preliminary Study Report Submitted by Centre for Environment and Development, GreenOrigin Ventures Pvt. Ltd. and Lahmeyer GKW Consult GmbH 53