Central Pollution Control Board draft guidelines for preprocessing and co-processing of hazardous wastes in cement kilns. Response to invitation for Suggestions

Published on 10/02/2017

Central Pollution Control Board draft guidelines for preprocessing and co-processing of hazardous wastes in cement kilns. Response to invitation for Suggestions.

Dr. Yashpal Singh

Co-processing  involves  the usage or disposal of waste material as raw material and/or a source of energy in energy intensive industries like cement  and replaces natural mineral resources (material recycling) and fossil fuels such as coal, petroleum and gas (energy recovery) by ‘processed waste’. The co-processing of hazardous substances in cement industry is an extremely viable option, whereby  wastes are not only destroyed at a higher temperature of around 14000⁰ C and longer residence time but its inorganic content gets fixed with the clinker apart from using the energy content of the wastes. No residues are left, as against after  incineration where residues need to be land filled as incinerator ash. The acidic gases, if any generated during co-processing get neutralized, since the raw material is alkaline in nature.

A very well drafted and comprehensive draft guidelines on the preprocessing and co-processing of Hazardous Wastes in the Cement Industry has been evolved, in January 2017, by the Central Pollution Control Board, India and put up to stakeholders for suggestions before finalisation. (Attached-Guidelines for coprocessing_final_report 010217 ) It is felt that the draft guidelines may need a review in order to make them specifically separate for Hazardous wastes and for wastes not covered under the HOWM Rules 2016. It is also felt that the provision of trial runs should be retained and be waste and utilisation specific, as given at para 9 of the MoWM Rules 2016. There also does not appear to be a case for the recommended exemption from the E.C. mechanism for co-processing.

The following issues may need consideration and have already been forwarded to the CPCB for necessary action.

1. Guidelines could include a listing of only those wastes which can be used in co-processing, both as alternative fuels as well as alternative raw materials (AFR). Waste resources serving only as alternative fuels(AF) or only as raw material(AR) sources may not be included for the purpose of the co-processing guidelines.
2. The guidelines appear to have been drafted in compliance to requirements as specified in Rule 9 of the HOWM Rules 2016. The applicability of the guidelines could be restricted, therefore, to only those wastes which are covered under the Hazardous and Other Wastes (Management and Trans Boundary Movement) Rules 2016.
3. Where other wastes are found suitable and recommended to be used for Co-processing in Cement Plants, a separate set of guidelines as done in 2010 for co-processing of distillery spent wash concentrate could be evolved. Reference to these wastes wherever made in the draft guidelines of 2017, under reference, could be removed and brought up separately. This appears feasible because such wastes are regulated by different legislative procedures and require specific redressal. Authorization under the HOWM 2016, may not apply to all waste categories.
4. The provisions of Rule 9 of the HOWM Rules 2016 indicate that guidelines have to be provided for specific wastes and specific utilization and where such guidelines are not available, the approval has to be sought from the CPCB. The CPCB is expected to grant such approvals on the basis of trial runs and thereafter draw up the SOP or guidelines. Once the guidelines are drawn up, the SPCB would be able to grant authorization. The need of law is therefore to provide for waste and utilization specific guidelines and till such time as they are not formulated, the CPCB would give an approval based on trial runs.
5. Para 3.0 page 5 of the draft guidelines of 2017 exempts trial runs only because the emission standards have been notified and prescribes that co-processing shall be carried out only as per guidelines.( But as per the provisions of the HOWM Rules 2016, guidelines can only be prescribed after waste and utilization specific trial runs.)

A mention has been made in an earlier guideline issued by the CPCB (guidelines on Co-processing in Cement/Power/Steel Industry, CPCB, Feb 2010) that the CPCB has granted permission to only 4 types of Hazardous Wastes (Paint Sludge from automobile sector, Petroleum refining sludge, TDI tar waste, ETP sludge from M/s BASF India Ltd.) and two types of other wastes (Plastic Wastes, Tyre Chips) and that this list will be updated time to time based on trial runs.

Under the circumstances of the statutory provisions as laid down in para 9 of the HOWM Rules 2016 and the fact that only a limited number of wastes and utilisation specific trial runs may have been conducted, there is a need to review the provision in the guidelines regarding grant of exemption from trial run for wastes where waste specific and utilisation specific trial runs have not been conducted. There does not appear to be any justification from relaxing the provision of para 9(2) of the HOWM Rules 2016.  In this regards, the following may be considered for inclusion in the guidelines:

“Where standard operating procedures or guidelines are not available for specific waste and specific utilisation, the approval has to be sought from the Central Pollution Control Board which shall be granting approval on the basis of trial runs and thereafter, standard operating procedures or guidelines shall be prepared by the CPCB. In cases where waste and utilisation specific standard operating procedures and guidelines have been drawn up by the CPCB, the authorization shall be granted by the State Pollution Control Board/ Committees. Where a waste and utilisation specific trial run has been conducted by the CPCB to demonstrate compliance to environmental standard there may be no need for a trial run but Authorisation shall be granted by the CPCB until such time as the guidelines/SOP are not finalized.

All clauses contrary to this could be considered to be deleted.

6. The draft guidelines also mention that use of wastes for co-processing in cement Kiln’s does not warrant the requirement of EC as per the MoEF & CC notification No. S.O. 3518(E) dated 23-11-2016. This may be reconsidered and removed. Co-processing and change in fuel mix does not fall in the category of activities as laid down in para 7(ii) of the EIA Notification of 2006 as amended on 23-11-2016. The decision to adopt co-processing is neither a change in configuration as a result of detailed engineering, nor a change in product mix, change in quantities within products or numbers or number of products within same category,

Likewise, the amended schedule 3(b) to the notification also makes no provisions of any exemption been granted to Cement plants going in for co-processing. It only clarifies the fuels that can be used in Cement industry and includes co-processing of waste as a permissible fuel provided it meets the emission standards. E.C. has to be obtained as provided in the schedule.

The second part of the note to the amended schedule 3(b) exempts composite cement plants form Environmental Clearance provided they have an Environmental clearance for manufacturing OPC, PPC or PSC. Co-processing of wastes in Cement Industry is not included in the definition of a Composite Cement Plant. I.S. 16415 of 2015 defines Composite Cement as “An intimately inter ground mixture of Portland Cement Clinker, granulated slag and fly ash with addition of gypsum (natural or chemical) or an intimate and uniform blending of ordinary Portland Cement, finely granulated slag and fly ash with addition of ground gypsum if required.” Co-processed Cement is not a composite cement and hence not eligible for any exemption on this count also.

Reference to exemption from obtaining an E.C. wherever made in the draft guidelines may therefore, kindly be considered to be removed.

7. Para 4.0 regarding trial runs may need to be revised in line with what is submitted at para 4 and 5 above and detailed procedures for trial runs as in the guidelines of 2010 drawn up.
8. The standard operating procedures at para 5.0 could be specific to Hazardous Wastes only. References to waste not covered under the HOWM Rules 2016 may be removed.
9. The draft guidelines at para 7.1 indicate that some wastes may not be suitable in large volumes but can be co-processed in small volumes with controlled feed rates into the system. This list could be elaborated based on trial runs along with optimum feed rates.
10. Emission standards have been mentioned at para 8.0. One of the internationally accepted guiding principles towards use of Alternative fuel and resource (AFR) has been that Air emissions from Cement Kilns from coprocessing should not be higher than those of Cement Kilns burning traditional fuels and the product should not be used as a sink for heavy metals. Co-processing, evidently has a potential to contribute additional contaminants to the emissions. The co-processing emission factors also include additional parameters over and above those prescribed by the MOEF for Cement Kilns based on traditional fuels through amended notification of 09-05-2016. These include HCL, HF, TOC, Hg, Cd+Ti, Sb, As, Pb, Co, Cr, Cn, Mu, Ni, V, Dioxins and furans establishing therefore that co-processing has a potential to contribute additional pollutants. This therefore calls for more caution as there is an increase in pollution and also that there is a possibility of all these pollutants being incorporated into the Cement which acts as a sink. Therefore it would be prudent to retain the requirements of waste and utilisation specific trial runs so that compliance to standards is established before guidelines are finalized.
11. The guidelines may also like to refer to such Hazardous wastes which may not have appropriate material or energy value but still can be disposed off in a cement Kiln without impacting the product quality. The CPCB at para 5.3 of its earlier guidelines issued in 2010 had said that such practices could be allowed on a case to case basis both with regards to procedures and standards.
12. The proposed guidelines could also come up with a list of such Hazardous wastes which are –
    1. Allowed for co-processing but need an authorization from the CPCB after a trial run.
    2. Allowed for co-processing by the state Pollution Control Board without a Trial Run but subject to CPCB guidelines and SOP.
    3. Allowed to be disposed off in a Cement Kiln on a case to case basis after seeking an authorization from the CPCB.