STATUS OF CO-PROCESSING OF

WASTE IN CEMENT PLANTS AS PER

HAZARDOUS AND OTHER WASTES

MANAGEMENT RULES, 2016

Presented at 3rd International Conference on Alternate Fuels & Raw

Materials in Cement Industry – Towards Realising Swachh Bharat Dream

on 23rd & 24th March 2017 at New Delhi, India

Dr B Sengupta,Former Member Secretary,

Central Pollution Control boardbsg161@gmail.com

“Co-processing” The use of suitable wastematerials in manufacturing processes for thepurpose of energy and/or resource recovery andresultant reduction in the use of conventionalfuels and/or raw materials through substitution.

CO-PROCESSING

» Environmental damage is getting out of control.

» Climate change is impacting us all.

» Communities are objecting to implementation oflandfills and incineration facilities for wastemanagement.

» Landfill is building liabilities for the business &society.

» Industries are shifting to Green procurementprocesses.

» Importing countries are demanding compliance tosustainable waste management practices.

» Promotes Circular Economy

» Reduces

˃ required number of landfills

˃ pollution caused by dumping

˃ greenhouse-gas emissions

˃ environmental impact of extraction through mining

˃ dependence on primary resource markets

˃ cost of production of Cement

» Mitigates Climate Change Impacts

» Conserves Energy and Material resources

» Involves highly organised industrial sector

CEMENT DEMAND IN 2024 AND

INPUTS REQUIREMENT

Particulars 2013-14 2023-24 (estimate)

Cement

production

360 MT/Annum 750 MT/Annum

Coal for kilns and

CPP

60 MT / Annum 156 MT/Annum

Limestone 380 MT/Annum 998 MT/Annum

Gypsum 12 MT/Annum 33 MT/Annum

Power 5100 MW 13300 MW

Source: CMA 2015

CO-PROCESSING OF WASTE IN CEMENT KILN

AGREEMENT IN INTERNATIONAL CONVENTION

Cement kiln co-processing technology is

accepted by Basel convention for disposal of

hazardous wastes

The cement kiln co-processing technology is

accepted by Montreal protocol for disposal of

POPs. Cement kiln co-processing of POPs,

hazardous and non hazardous wastes is

practiced widely and successfully in manycountries around the world

INITIATING POLICY REFORMS FOR

SUSTAINABLE WASTE MANAGEMENT

THROUGH CO-PROCESSING

Important Recommendations of Basel ConventionGuidelines :

1. The waste management hierarchy needs to be respected.

2. Additional emissions and negative impacts on human health

must be avoided

3. The quality of the cement must remain unchanged

4. Companies that co process must be qualified with appropriate

infrastructure.• Assure compliance with all laws and regulations

• Have good environmental and safety compliance records

• Have personnel, processes, and systems in place committed to

protecting the environment, health, and safety

• Safe and sound receiving, storage, processing and feeding of

hazardous wastes

• Systems for the provision and analysis of waste representativesamples should be in place Contd…

INITIATING POLICY REFORMS FOR

SUSTAINABLE WASTE MANAGEMENT

THROUGH CO-PROCESSING

Important Recommendations of Basel ConventionGuidelines :

5. For optimal performance , AFRs should be fed to the cement

kiln through appropriate feed points, in adequate proportions

and with proper waste quality and emission control systems.

6. Due to the heterogeneity of waste, pre-processing is required

to produce a relatively uniform waste stream for co-

processing in cement kilns. To be carried out in a purpose-

made facility, which may be located outside or inside the

cement plant

Alternative Fuels which can be used to increase

thermal substitution rate (TSR) in cement

industry

(use of CV of waste as fuel in cement kiln)

S. NO.

Fuel Calorific Value(kcal / kg)

1. RDF from Municipal Solid Waste 2800-3800

2. Used Tires 6700-7700

3. Hazardous Waste 4000-9500

4. Industrial Plastic Waste 4070-6620

5. Biomass 2500-3800

6. Slaughter House Waste 700-1400

7. Poultry Litter 2700-3800

8. Dried Sewage Sludge 1700-1900

Source : Holtech & CPCB

Alternative Raw Materials which can be

used as blending material

S.No. Alternative Raw Material Available Quantity in million tonnesper annum

1. Fly Ash (cement blending material) 200.0

2. Blast Furnace Slag from Steel Industry 10.0

3. Lime Sludge (Paper, Carbide, Sugar Industry Sludge)

4.5

4. Red Mud from Aluminum Industry 3.75

5. Foundry Sludge / Sand -

6. Chrome Sludge as mineraliser -

7. Lead Zinc Slag 0.5

8. Phosphate Chalk -

Source : Holtech

POTENTIAL AVAILABILITY OF WASTE FOR

CO-PROCESSING IN INDIA

A.Fuel

B. Alternate Raw Material

Hazardous Waste 0.65 MTA

Biomass 150 MTA

Used Tyre 0.83 MTA

Industrial Plastic Waste 0.20 MTA

RDF from MSW 6.88 MTA

Flyash 200 MTA

Blast Furnace Slag 10 MTA

Source : CPCB & Holtec

AVAILABILITY OF OTHER COMBUSTIBLE WASTE

Source: NCBM 2015

S.

No.

Name of fuel Availability Present disposal method

1. Paint sludge 48000 tonnes/ annum Incineration / secured landfill

2. ETP sludge 6.2 million tones / annum Dried ETP sludge are disposed

in landfill

3. Ink sludge 240 MT / annum Dried ETP sludge are disposed

in landfill

4. Refuse

Derived Fuel

---- ----

5. Groundnut

shell

---- Incineration / composting

6. Tire Derived

Fuel

90000 tonnes / annum Incineration

7. Pharmaceutic

al waste

0.33 MT / annum Co-processing

8. Spent wash

from distillery

---- ----

GENERAL PRINCIPLE FOR CO-PROCESSING

The important general principles in co-processing are :

1. Additional emissions and negative impacts on humanhealth must be avoided

2. The quality of the clinker/cement must remain unchanged.

3. Companies that co process must be qualified

• Assure compliance with all laws and regulations

• Have good environmental and safety compliancerecords

• Have personnel, processes, and systems in place

committed to protecting the environment, health, andsafety

• Be capable of controlling inputs to the productionprocess

Contd…

Requirements for undertaking co-processing are

1. Best available technology for air pollution prevention andcontrol with continuous emission monitoring

2. Exit gas conditioning/cooling and temperature less than200OC in control devices to prevent dioxin formation.

3. Adequate emergency and safety equipment andprocedures, and regular training

4. Safe and sound receiving, storage, processing andfeeding of hazardous wastes

5. The operator of the co-processing plant should develop a

waste evaluation procedure to assess health and safety of

workers and public, plant emissions, operations and

product quality, variables that should be considered when

selecting waste include:

(a) Kiln operation

(b) Emissions

(c) Clinker, cement and final product quality

AVAILABLE HAZARDOUS WASTE

WHICH CAN BE USED AS PARTIAL FUEL IN

CEMENT KILN

Organic residue from Pharmaceuticals and Pesticide industry

Spent solvent

Sludge from petrochemical / oil refinery

Slaughter House Waste

Waste Oil

Paint sludge

Effluent Treatment Plant Sludge

Spent Pot Lining from Aluminum Industry

Spent Carbon

1. Amendment of the Hazardous Waste Management Rules,1989, under the Environment Protection Act, 1986, toinclude co-processing in cement plants as a disposal option.

2. Preparation of technical guidelines for setting upenvironmentally sound pre-processing facilities to preparehomogenous waste mixes suitable for co-processing incement kilns.

3. Developing emission standards for co-processing alternatefuel and raw (AFR) material in cement kilns includinghazardous wastes.

4. Increasing the use of fly ash generated by coal based powerplants and refuse-derived fuels (RDF) in cement plants.

5. Developing guidelines for the transport and storage ofhazardous waste

List of White-papers prepared by Regulatory Forum

consisting of Member Secretaries of 5 SPCBs under

the Chairmanship of MS, GSPCB

HAZARDOUS AND OTHER WASTES

(MANAGEMENT AND

TRANSBOUNDARY MOVEMENT)

RULES, 2016

» For the management of hazardous and other waste,and occupier shall follow the following steps, namely:-

a) Prevention;

b) Minimization;

c) Reuse;

d) Recycling;

e) Recovery, utilisation including co-processing;

f) Safe disposal.

» Title of the Rules has been amended as Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016

» Major Amendments made in following areas

˃ Authorization / Renewal of authorization (introduced new forms, compliance verification report , Emergency Response Plans and undertaking for submitting bank guarantee)

˃ New Schedule-II for identification of HW

˃ Utilization of Hazardous waste includes Schedule IV wastes also.

˃ SoPs for recycling/utilization introduced

˃ Pass books applicable for all actual users

˃ Removal of Registration scheme

˃ Responsibilities of State Government

˃ Revised Import-Export provisions (Banned items 49 from 30; more clarity)

˃ Filing of Annual Reports by SPCBs & CPCB

» New Definitions added:

- Captive Treatment, storage and disposal facility

- Common Treatment, storage and disposal facility

- Co-processing

- Critical care medical equipment

- Pre-processing

- Utilisation

- Waste & byproduct

- Other waste

- More clarity in earlier definitions

» Waste management hierarchy has been introduced as follows:

- Prevention

- Minimization

- Reuse

- Recycling

- Recovery, utilisation including co-processing

- Safe disposal

» Department of Industry in the State or any other governmentagency - to earmark or allocate industrial space or shed forrecycling, pre-processing and other utilisation of hazardous orother waste in the existing and upcoming industrial park, estateand industrial clusters.

» Submit annual report to the Ministry of Environment, Forest andClimate Change on integrated plan for ensuring environmentallySound Management of Hazardous and other wastes.

» Department of Labour in the State or any other government agency shall ensure the following in respect of workers involved in recycling, pre-processing and other utilisation of HW ;

a) Recognition and Registration of workers

b) Imparting industrial skill development activities

c) Monitoring safety and health of workers.

» Occupier shall obtain an authorization / renewal of authorisation from the

State Pollution Control Board in Modified Form 1. Applicant shall enclose

copies of CTE, valid CTO. A Self certified compliance report shall be

enclosed in case of renewal application.

» State Pollution Control Board shall grant authorisation in Modified Form 2

after ensuring technical capabilities and equipment complying with the

Standard Operating Procedures or other guidelines specified by CPCB

through site inspection.

» The authorisation granted shall be accompanied with copy of field

inspection report signed by that Board.

» Handing over of the hazardous and other wastes to the authorised actual

user shall be only after making the entry into the passbook of the actual

user

» Includes Authorization for recycling of Other wastes listed in Schedule - III

Rule-9 : provisions of Recycling and Utilization of HW

(1) SPCBs/PCCS may grant authorisation to actual users for utilization or

recycling of Hazardous Wastes for which Standard Operating

Procedures (SoPs) or guidelines have been provided by CPCB

(2) Where SoPs or guidelines are not available, the applicants shall

approach CPCB for grant of approval, which may be given by CPCB on

the basis of trial runs.

Upon completion of successful trial run, CPCB shall prepare SoPs for

such Utilization and circulate the same to all SPCBs.

(3) No trial runs are required for co-processing once the co-processing

standards are notified.

However, till the time the standards are notified, the procedure as

specified at (2) above shall be followed.

» The sender of the waste shall obtain ‘No Objection Certificate’from the SPCB of both the States for transportation of waste incase of final disposal to a facility existing in a State other than theState where the hazardous waste is generated.

» In case of transit of waste for recycling, recovery, reuse orutilisation through a State other than the State of origin ordestination, the occupier shall intimate the concerned SPCBbefore he hands over the hazardous wastes to the transporter.

» The authorisation for transportation shall either be obtain by thesender or the receiver on whose behalf the transport is beingarranged.

» Gray color Manifest – shall only be sent to the SPCB of the senderin case sender is in another State

S. No. Type of Waste generated Quantity of Waste

generation

Area of utilization

/ recycling / reuse

1. Fly ash from thermal power

plant

200 Million Tonnes

Per Year (600 MTA

by 2030)

Fly ash pozzolona

cement, increase of

ash dyke height,

road construction,

brick manufacturing

2. Blast furnace slag from iron

and steel plant

10 MTA Slag cement

3. Steel melting shop slag (SMS)

from steel plant

- Slag cement after

removal of iron

4. Phospho gypsum 8 MTA Cement making

5. Distillery spent wash About 100 distillery

in operation

(capacity 60-600

KLPD)

Concentrated spent

wash for power

generation

Contd…

S. No. Type of Waste generated Quantity of

Waste

generation

Area of utilization /

recycling / reuse

6. Spent pot lining (aluminium

industry waste)

- Carbon portion of SPL can

be used as fuel in cement

kiln

7. Pharmaceutical / pesticide

industry (distillation

residue, process residue,

mixed waste solvent, high

COD waste)

200,000 TPA Can be used as partial fuel

in cement kiln

8. Municipal solid waste 1,30,000

Tonnes /day

RDF from MSW can be

used as fuel in cement kiln

/ boiler

9. Plastic waste 15,500 Tonnes

/day

Can be recycled / used as

a fuel in cement kiln

10. Municipal waste water 35,000 Million

litres /day

Treated water can be used

in industrial process /

irrigation etc.

11. Used tyres 83,000 TPA Shredded tyres can be

used as fuel in cement kiln

Most Promising Alternate Fuels

RDF from municipal solid waste [ MSW ]

Used tyres

Hazardous waste

Industrial plastic waste

Hazardous Waste

Barriers

Technical Barriers

Non uniform quality due to varying sources

Presence of high moisture and Chlorine

Lack of pre-processing facilities

Limited technical knowledge and skilled manpower

Financial Barriers

Time consuming and expensive trial runs needed for each

new stream

High capital cost for setting pre-processing platforms

Huge competition for HW, impacting gate fee

Contd…

PARAMETER MIN MAX

Moisture (%) 0.60 67.4

Ash (%) 0.96 98.70

VM (%) 0.3 94.9

FC (%) 0.1 45.7

Carbon 0.4 75.6

Hydrogen 0.2 9.1

Nitrogen 0 15.5

Sulphur 0.1 22

Oxygen 0 76.3

GCV (Kcal/Kg) 80 7960

NCV (Kcal/Kg) 114.8 6042

Mineral matter 3.5 34.5

Chloride as Cl (mg/kg) 0 14200

Fluoride as F (mg/kg) 0 20.1

PARAMETER MIN MAX

Cadmium (mg/kg) 0.10 27.6

Chromium (mg/kg) 0.20 36,229.7

Copper (mg/kg) 1.00 8,848.6

Cobalt (mg/kg) 0.10 176.4

Manganese (mg/kg) 0.10 7,800.0

Nickel (mg/kg) 0.10 9,300.0

Lead (mg/kg) 0.10 633.3

Zinc (mg/Kg) 1.00 22,000.0

Arsenic (mg/kg) 0.10 8.1

Mercury (mg/kg) 0.10 3.8

Selenium (mg/kg) 0.00 8.2

Antimony (mg/kg) 0.10 9.4

Vanadium (mg/kg) 1.00 82,400.0

Thallium (mg/kg) 0.10 1.0

Tin (mg/kg) 0.00 145.6 PARAMETER MIN MAX

VOC (mg/kg) 4.20 207.0

SVOC (mg/kg) BDL 0.2

PCB (mg/kg) 0.00 0.5

PARAMETER MIN MAX

PCP (mg/Kg) BDL 1.4

TOC (%) 0.00 66.0

Source: Dr. Parlikar, Geocycle India

» There is large variation in the characteristics of wastes on dayto day and batch by batch basis.

» Waste streams are required to be mixed in differentproportions to prepare uniform AFRs. Hence, individualcharacteristics of the wastes bear no relevance to that of thewaste mix.

» It took 10 years for Indian cement industry to conduct trials ofabout 100 waste streams. There are thousands of wastestreams to deal with.

» Although incineration or landfill options are lower in wastemanagement hierarchy, no trial is required for any waste??.

» Technically, there has to be a mechanism to ascertain safety inhandling & storage of wastes and compliance to co-processing emission standards.

Source: Dr. Parlikar, Geocycle India

35

Appropriate Laboratory for waste qualification

Adequate waste storage facility with proper facilities to controlfires and spillages.

Environmentally sound facilities for waste Handling, pre-processing and feeding into kilns.

Skilled and trained manpower for waste management

Adequate systems for EHS and Medical Surveillance

Emergency Response Plan.

Online emission monitoring to ascertain environmentalcompliance to prescribed emission standards.

Avoiding waste feed when kiln is in light up, shutdown or upsetmode.

Kiln specific trials for materials attracting Stockholm convention.

36

All wastes, other than the banned ones, can be pre & co-processed depending upon the availability of the suitableinfrastructure to handle & manage them.“Banned wastes" not to be pre-processed or co-processed

• Radioactive waste

• Asbestos-containing waste

• Explosives and ammunition / weapons

• Anatomical medical waste

“Banned wastes“ not to be co-processed

• Electronic fraction of electrical and electronic waste (e-waste)

• Whole batteries as a targeted material stream

• Waste of unknown or unpredictable composition, including unsorted municipalwaste

˃ These wastes however can be co-processed after pre-processing to remove thebanned portion of the waste

» Waste generator is required to manage his waste respecting theWaste Management Hierarchy and SPCBs are required to authorizethe same. (Rule 4)

» A facility is required to obtain authorization from SPCB for receiving,storing and pre-processing of wastes based on the availability ofcompliant infrastructure to handle them safely. (Rule 6)

» Co-processing in cement plant is to be implemented based on thecompliance to prescribed emission standards. (Rule 9)

» Interstate movement of wastes for recycling or co-processing to beimplemented by intimation to the respective SPCBs. (Rule 18)

» Pre-processing centers to be developed rather than landfill sitesand convert SCF to RDF and wastes to AFRs.

» Guidelines on penalties for damaging environment while handlinghazardous wastes need to be adhered to.

S.No. Industry Name Hazardous

waste

Raw

material

Non-

hazardous

waste

Dolachar /

carbon

black

BBD

1. Anjani Cements 23122 2153

(iron

sludge)

-- -- 657

2. My Home industries 13253 -- -- --

3. Kesoram Cements 3528 -- -- --

4. Zuari Cements 11447 -- 12148 (RDF-

848 T+

Biomass -

11300)

2020

5. Keerthi industries 2533 -- -- --

6. Sagar Cements -- -- -- --

7. India Cements,

Nalgonda District

1273.19 -- -- --

8. India cements, Tandur -- -- -- --

9. Orient Cement,

Mancharial.

15,555 25

Total 55156.19 2153 27703 2045 657Source: Telangana SPCB

Sl.No

.

Industry Name Hazardous

waste

Raw

material

Non-

hazardous

waste

Dolachar

1. Ultratech Cements, Tadipatri, AP. 4530.16 -- -- --

2. Zuari Cements, Erraguntla, AP. 8000 -- -- --

3. Bharathi Cements, Erraguntla, AP. 4674 -- -- --

4. Dalmia Cements, Erraguntla, AP. 2500 -- -- --

5. M/s Chettinadu Cements, Kalburgi,

Karnataka

271 -- -- --

6. M/s Rajashree Cements,

Gulbarga, Karnataka.

457 -- -- --

7. M/s Sree Jayajothi Cements Pvt.

Ltd., AP.

30.01

8. JSW Cement, Kurnool, AP 108.02

Total 20570.19 -- -- --

Source: Telangana SPCB

Source: Gujarat SPCB

Sr.No Industry Name Hazardous

waste(MT)

Raw material

(MT)

Non-

Hazardous

waste(MT)

Dolachar/carb

on black(MT)

BBD

1 M/s. Ambuja Cement Ltd

Gir Somnath299574 1255619 1308307 885

_

2 M/s. Ultratech Cement Ltd

– Kovaya Works163726 65472.2 767921 0

_

3 M/s. Ultratech Cement Ltd

– Jafrabad Works0 5673.5 129806 0

_

4 M/s. Ultratech Cement

Ltd–Sewagram Works-

Kutch

2745 329249 347784 0

_

5 M/s. Gujarat Sidhee

Cement Ltd – Junagadh12323 116451 153963 0

_

6 M/s. Sanghi Industries Ltd

– Kutch121533 334283 228755 0

_

7 M/s. Shree Digvijay

Cement Co. Ltd –

Jamnagar

4152.15 101770.2 137024 0

_

8 M/s. Recycling Solution

Pvt. Ltd – Panoli18442 0 1949.3 0

_

9 M/s. Saurashtra Cement

Ltd – Porbandar19337 210805 255970

_

TOTAL 641832.15 2419323 3331479.3 885

Source: Gujarat SPCB

Sr.No Industry Name Hazardous

waste(MT)

Raw

material

(MT)

Non-

Hazardous

waste(MT)

Dolachar/ca

rbon black

1 GNFC Dahej Unit 1134 _ _ _

2 GNFC Unit : 2 Bharuch 1180 _ _ _

3 Alembic Pharmaceuticals

Limited, Panelav

342 _ _ _

4 Novel Spent Acid

Management, Vatva,

Ahmedabad

_ 69650 _ _

5 Gujarat Paper Mills

Association, Vapi

_ 4531 _ _

TOTAL 2907 74181

1. For hazardous waste management following

hierarchy should be followed:-

a) Prevention – Waste generation can be prevented

using clean technology

b) Minimization – waste generation can be Minimized

by using good practices

c) Reuse;

d) Recycling;

e) Recovery, utilisation including co-processing;

f) Safe disposal.Contd…

2. For chemical industry (pharma, pesticides, dye

and dye intermediates etc.) the waste

minimization scheme as prescribed by CPCB

should be followed.

3. After following waste minimization scheme the

high COD waste to be segregated and high CV

waste should be co-processed in cement kiln.

4. The spent solvent / mix solvent generated by

chemical industry should be co-processed in

cement kiln.

5. Setting of pre-processing plant to be

encouraged either at cement plant site or at

TSDF site.

Contd…

6. Co-processing emission standards to befollowed by Cement plant who are engaged inco-processing of waste as fuel in cement kiln.

7. Rule 9 of hazardous waste management rulesincluding SOP given by CPCB to be followed.

8. Fly ash / bottom ash, RDF, Phospho-gymsum,lime sludge and other industrial waste shouldbe co-processed in cement plant for itseffective utilization.

9. SPCB / PCC should play a catalytic role topromote co-processing in their respectivestate.

10. Data on inventory of waste both hazardous andnon-hazardous should be made available bySPCB / PCC in their website.

Contd…

11. For setting of co-processing plant, SPCB / CPCB/ MoEF should play important role by providingnecessary technical and financial assistance (asgiven for CETP and TSDF).

12. SPCB / PCC to build-up capacity for monitoringemission of toxic pollutants including dioxine /furan in cement kiln emission.

13. Risk assessment for storing of hazardous wastein co-processing plant to be done and allprecautions to be followed as recommended byCPCB in its guidelines on storing of hazardouswaste.

14. RDF from MSW to be used as partial fuel incement kiln. This may be included as a part ofCSR programme to manage the MSW disposalproblem. Contd…

15. Coke oven sludge / distillation residue / mixedwaste solvent, spent carbon etc. should beused as partial fuel in cement kiln

16. Oily sludge from oil refinery / petrochemicalindustry should be used for co-processing incement plant

17. Spent pot lining (carbon portion) fromaluminum industry should be used as partialfuel in cement kiln.