STATUS OF CO-PROCESSING OF

WASTE IN CEMENT PLANTS AS PER

HAZARDOUS AND OTHER WASTES
MANAGEMENT RULES, 2016

Dr B Sengupta,
Former Member Secretary,
Central Pollution Control board
bsg161@gmail.com

Presented at 3rd International Conference on Alternate Fuels & Raw

Materials in Cement Industry – Towards Realising Swachh Bharat Dream
on 23rd & 24th March 2017 at New Delhi, India
 CO-PROCESSING

“Co-processing” The use of suitable waste

materials in manufacturing processes for the
purpose of energy and/or resource recovery and
resultant reduction in the use of conventional
fuels and/or raw materials through substitution.
» Environmental damage is getting out of control.
» Climate change is impacting us all.
» Communities are objecting to implementation of
landfills and incineration facilities for waste
management.
» Landfill is building liabilities for the business &
society.
» Industries are shifting to Green procurement
processes.
» Importing countries are demanding compliance to
sustainable waste management practices.
» 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 360 MT/Annum 750 MT/Annum

production
Coal for kilns and 60 MT / Annum 156 MT/Annum
CPP
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 many
countries around the world
 INITIATING POLICY REFORMS FOR
SUSTAINABLE WASTE MANAGEMENT
THROUGH CO-PROCESSING
Important Recommendations of Basel Convention
Guidelines :

1. The waste management hierarchy needs to be respected.

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

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

kiln through appropriate feed points, in adequate proportions
and with proper waste quality and emission control systems.

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

to produce a relatively uniform waste stream for 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. Fuel Calorific Value
NO. (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 tonnes
per 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 4.5

Sludge)
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
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

B. Alternate Raw Material

Flyash 200 MTA
Blast Furnace Slag 10 MTA

Source : CPCB & Holtec

AVAILABILITY OF OTHER COMBUSTIBLE WASTE
S. Name of fuel Availability Present disposal method
No.
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 ---- Incineration / composting
shell
6. Tire Derived 90000 tonnes / annum Incineration
Fuel
7. Pharmaceutic 0.33 MT / annum Co-processing
al waste
8. Spent wash ---- ----
from distillery
Source: NCBM 2015
GENERAL PRINCIPLE FOR CO-PROCESSING

The important general principles in co-processing are :

1. Additional emissions and negative impacts on human

health must be avoided
2. The quality of the clinker/cement must remain unchanged.
3. Companies that co process must be qualified
• Assure compliance with all laws and regulations
• Have good environmental and safety compliance
records
• Have personnel, processes, and systems in place
committed to protecting the environment, health, and
safety
• Be capable of controlling inputs to the production
process
Contd…
Requirements for undertaking co-processing are
1. Best available technology for air pollution prevention and
control with continuous emission monitoring
2. Exit gas conditioning/cooling and temperature less than
200OC in control devices to prevent dioxin formation.
3. Adequate emergency and safety equipment and
procedures, and regular training
4. Safe and sound receiving, storage, processing and
feeding of hazardous wastes
5. The operator of the co-processing plant should develop a
waste evaluation procedure to assess health and safety of
workers and public, plant emissions, operations and
product quality, variables that should be considered when
selecting waste include:
(a) 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
List of White-papers prepared by Regulatory Forum
consisting of Member Secretaries of 5 SPCBs under
the Chairmanship of MS, GSPCB
1. Amendment of the Hazardous Waste Management Rules,
1989, under the Environment Protection Act, 1986, to
include co-processing in cement plants as a disposal option.
2. Preparation of technical guidelines for setting up
environmentally sound pre-processing facilities to prepare
homogenous waste mixes suitable for co-processing in
cement kilns.
3. Developing emission standards for co-processing alternate
fuel and raw (AFR) material in cement kilns including
hazardous wastes.
4. Increasing the use of fly ash generated by coal based power
plants and refuse-derived fuels (RDF) in cement plants.
5. Developing guidelines for the transport and storage of
hazardous waste
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 government
agency - to earmark or allocate industrial space or shed for
recycling, pre-processing and other utilisation of hazardous or
other waste in the existing and upcoming industrial park, estate
and industrial clusters.

» Submit annual report to the Ministry of Environment, Forest and

Climate Change on integrated plan for ensuring environmentally
Sound Management of Hazardous and other wastes.

» Department of Labour in the State or any other government

agency shall ensure the following in respect of workers involved
in recycling, pre-processing and other utilisation of HW ;
a) Recognition and Registration of workers
b) Imparting industrial skill development activities
c) Monitoring safety and health of workers.
» 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 in
case of final disposal to a facility existing in a State other than the
State where the hazardous waste is generated.

» In case of transit of waste for recycling, recovery, reuse or

utilisation through a State other than the State of origin or
destination, the occupier shall intimate the concerned SPCB
before he hands over the hazardous wastes to the transporter.

» The authorisation for transportation shall either be obtain by the

sender or the receiver on whose behalf the transport is being
arranged.

» Gray color Manifest – shall only be sent to the SPCB of the sender
in case sender is in another State
S. No. Type of Waste generated Quantity of Waste Area of utilization
generation / recycling / reuse
1. Fly ash from thermal power 200 Million Tonnes Fly ash pozzolona
plant Per Year (600 MTA cement, increase of
by 2030) ash dyke height,
road construction,
brick manufacturing
2. Blast furnace slag from iron 10 MTA Slag cement
and steel plant
3. Steel melting shop slag (SMS) - Slag cement after
from steel plant removal of iron
4. Phospho gypsum 8 MTA Cement making
5. Distillery spent wash About 100 distillery Concentrated spent
in operation wash for power
(capacity 60-600 generation
KLPD)
Contd…
S. No. Type of Waste generated Quantity of Area of utilization /
Waste recycling / reuse
generation
6. Spent pot lining (aluminium - Carbon portion of SPL can
industry waste) be used as fuel in cement
kiln
7. Pharmaceutical / pesticide 200,000 TPA Can be used as partial fuel
industry (distillation in cement kiln
residue, process residue,
mixed waste solvent, high
COD waste)
8. Municipal solid waste 1,30,000 RDF from MSW can be
Tonnes /day used as fuel in cement kiln
/ boiler
9. Plastic waste 15,500 Tonnes Can be recycled / used as
/day a fuel in cement kiln
10. Municipal waste water 35,000 Million Treated water can be used
litres /day 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 PARAMETER MIN MAX
Moisture (%) 0.60 67.4 Cadmium (mg/kg) 0.10 27.6
Ash (%) 0.96 98.70 Chromium (mg/kg) 0.20 36,229.7
VM (%) 0.3 94.9 Copper (mg/kg) 1.00 8,848.6
FC (%) 0.1 45.7 Cobalt (mg/kg) 0.10 176.4
Carbon 0.4 75.6 Manganese (mg/kg) 0.10 7,800.0
Hydrogen 0.2 9.1 Nickel (mg/kg) 0.10 9,300.0
Nitrogen 0 15.5 Lead (mg/kg) 0.10 633.3
Sulphur 0.1 22 Zinc (mg/Kg) 1.00 22,000.0
Oxygen 0 76.3 Arsenic (mg/kg) 0.10 8.1
GCV (Kcal/Kg) 80 7960 Mercury (mg/kg) 0.10 3.8
NCV (Kcal/Kg) 114.8 6042 Selenium (mg/kg) 0.00 8.2
Mineral matter 3.5 34.5 Antimony (mg/kg) 0.10 9.4
Chloride as Cl (mg/kg) 0 14200 Vanadium (mg/kg) 1.00 82,400.0
Fluoride as F (mg/kg) 0 20.1 Thallium (mg/kg) 0.10 1.0
Tin (mg/kg) 0.00 145.6
PARAMETER MIN MAX
VOC (mg/kg) 4.20 207.0 PARAMETER MIN MAX
SVOC (mg/kg) BDL 0.2 PCP (mg/Kg) BDL 1.4
PCB (mg/kg) 0.00 0.5 TOC (%) 0.00 66.0

Source: Dr. Parlikar, Geocycle India

» There is large variation in the characteristics of wastes on day
to day and batch by batch basis.
» Waste streams are required to be mixed in different
proportions to prepare uniform AFRs. Hence, individual
characteristics of the wastes bear no relevance to that of the
waste mix.
» It took 10 years for Indian cement industry to conduct trials of
about 100 waste streams. There are thousands of waste
streams to deal with.
» Although incineration or landfill options are lower in waste
management hierarchy, no trial is required for any waste??.
» Technically, there has to be a mechanism to ascertain safety in
handling & storage of wastes and compliance to co-
processing emission standards.
Source: Dr. Parlikar, Geocycle India
 Appropriate Laboratory for waste qualification
 Adequate waste storage facility with proper facilities to control
fires 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 environmental
compliance to prescribed emission standards.
 Avoiding waste feed when kiln is in light up, shutdown or upset
mode.
35
 Kiln specific trials for materials attracting Stockholm convention.
All wastes, other than the banned ones, can be pre & co-
processed depending upon the availability of the suitable
infrastructure to handle & manage them.
“Banned wastes" not to be pre-processed or co-processed
• Radioactive waste
• Asbestos-containing waste
• Explosives and ammunition / weapons
• Anatomical medical waste
“Banned wastes“ not to be co-processed
• Electronic fraction of electrical and electronic waste (e-waste)
• Whole batteries as a targeted material stream
• Waste of unknown or unpredictable composition, including unsorted municipal
waste
36
˃ These wastes however can be co-processed after pre-processing to remove the
banned portion of the waste
» Waste generator is required to manage his waste respecting the
Waste Management Hierarchy and SPCBs are required to authorize
the same. (Rule 4)
» A facility is required to obtain authorization from SPCB for receiving,
storing and pre-processing of wastes based on the availability of
compliant infrastructure to handle them safely. (Rule 6)
» Co-processing in cement plant is to be implemented based on the
compliance to prescribed emission standards. (Rule 9)
» Interstate movement of wastes for recycling or co-processing to be
implemented by intimation to the respective SPCBs. (Rule 18)
» Pre-processing centers to be developed rather than landfill sites
and convert SCF to RDF and wastes to AFRs.
» Guidelines on penalties for damaging environment while handling
hazardous wastes need to be adhered to.
S.No. Industry Name Hazardous Raw Non- Dolachar / BBD
waste material hazardous carbon
waste black
1. Anjani Cements 23122 2153 -- -- 657
(iron
sludge)
2. My Home industries 13253 -- -- --
3. Kesoram Cements 3528 -- -- --
4. Zuari Cements 11447 -- 12148 (RDF- 2020
848 T+
Biomass -
11300)
5. Keerthi industries 2533 -- -- --

6. Sagar Cements -- -- -- --
7. India Cements, 1273.19 -- -- --
Nalgonda District
8. India cements, Tandur -- -- -- --
9. Orient Cement, 15,555 25
Mancharial.
Total 55156.19 2153 27703 2045 657
Source: Telangana SPCB
Sl.No Industry Name Hazardous Raw Non- Dolachar
. waste material hazardous
waste
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, 271 -- -- --

Karnataka
6. M/s Rajashree Cements, 457 -- -- --
Gulbarga, Karnataka.
7. M/s Sree Jayajothi Cements Pvt. 30.01
Ltd., AP.
8. JSW Cement, Kurnool, AP 108.02
Total 20570.19 -- -- --
Source: Telangana SPCB
Sr.No Industry Name Hazardous Raw material Non- Dolachar/carb BBD
waste(MT) (MT) Hazardous on black(MT)
waste(MT)
1 M/s. Ambuja Cement Ltd _
299574 1255619 1308307 885
Gir Somnath
2 M/s. Ultratech Cement Ltd _
163726 65472.2 767921 0
– Kovaya Works
3 M/s. Ultratech Cement Ltd _
0 5673.5 129806 0
– Jafrabad Works
4 M/s. Ultratech Cement _
Ltd–Sewagram Works- 2745 329249 347784 0
Kutch
5 M/s. Gujarat Sidhee _
12323 116451 153963 0
Cement Ltd – Junagadh
6 M/s. Sanghi Industries Ltd _
121533 334283 228755 0
– Kutch
7 M/s. Shree Digvijay _
Cement Co. Ltd – 4152.15 101770.2 137024 0
Jamnagar
8 M/s. Recycling Solution _
18442 0 1949.3 0
Pvt. Ltd – Panoli
9 M/s. Saurashtra Cement _
19337 210805 255970
Ltd – Porbandar
TOTAL 641832.15 2419323 3331479.3 885
Source: Gujarat SPCB
Sr.No Industry Name Hazardous Raw Non- Dolachar/ca
waste(MT) material Hazardous rbon black
(MT) waste(MT)
1 GNFC Dahej Unit 1134 _ _ _
2 GNFC Unit : 2 Bharuch 1180 _ _ _
3 Alembic Pharmaceuticals 342 _ _ _
Limited, Panelav
4 Novel Spent Acid _ 69650 _ _
Management, Vatva,
Ahmedabad
5 Gujarat Paper Mills _ 4531 _ _
Association, Vapi
TOTAL 2907 74181

Source: Gujarat SPCB

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

Contd…
11. For setting of co-processing plant, SPCB / CPCB
/ MoEF should play important role by providing
necessary technical and financial assistance (as
given for CETP and TSDF).
12. SPCB / PCC to build-up capacity for monitoring
emission of toxic pollutants including dioxine /
furan in cement kiln emission.
13. Risk assessment for storing of hazardous waste
in co-processing plant to be done and all
precautions to be followed as recommended by
CPCB in its guidelines on storing of hazardous
waste.
14. RDF from MSW to be used as partial fuel in
cement kiln. This may be included as a part of
CSR programme to manage the MSW disposal
problem. Contd…
15. Coke oven sludge / distillation residue / mixed
waste solvent, spent carbon etc. should be
used as partial fuel in cement kiln
16. Oily sludge from oil refinery / petrochemical
industry should be used for co-processing in
cement plant
17. Spent pot lining (carbon portion) from
aluminum industry should be used as partial
fuel in cement kiln.