Approach and Methodology for Developing the BREF for the Indian Textile sector

Dr. Harald Schoenberger

International expert on integrated industrial pollutionprevention and control

The objective of this new project on BAT is the ‘development of a

BREF/COINDS Document for the textile industry covering the Best Available Techniques adapted to the Indian context’.

Basis:1.) Sector-specific Comprehensive Industry Documents (COINDS)2.) Best Available Techniques REFerence Document for the Textiles Industry (2003) (BREF Textiles Industry)…. additional key documents (IFC, OECD, CPCB, GPCB, etc.)

New project in India on best available techniques (BAT)

supported by the German Agency for Technical Cooperation

1. Preparatory activities:

2. Sensitisation workshop

3. Defining the scope and contents of BREF document

4. Data/information collection

5. 1st draft BREF document

6. Comments on 1st draft

7. 2nd draft BREF document

8. Comments on 2nd draft

9. Final draft BREF document

10. Review of the final draft BREF:

11. Approval of the BREF document

Key steps involved in preparing the BREF document for the textile sector

Best available techniques – definition - 1

‘Best available techniques’ means the most effective and advanced stage in the development of activities and their methods of operation which indicates the practical suitability of particular techniques for providing the basis for emission limit values and other permit conditions designed to prevent and, where that is not practicable, to reduce emissions and the impact on the environment as a whole:

(a) ‘techniques’ includes both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned;

Best available techniques – definition -2

(b) ‘available techniques’ means those developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not the techniques are used or produced inside the Member State in question, as long as they are reasonably accessible to the operator;

at industrial scale – at least one timemust be accessible (available) in the country concerned

(c) ‘best’ means most effective in achieving a high general level of protection of the environment as a whole;

does not mean best of the best technique as economic viability is also taken into account (technical feasibility and economic viability)

Best available techniques reference document – definition

‘BAT reference document’ means a document, resulting from the exchange of information organised pursuant to Article 13, drawn up for defined activities and describing, in particular, applied techniques, present emissions and consumption levels, techniques considered for the determination of best available techniques as well as BAT conclusions and any emerging techniques, giving special consideration to the criteria listed in Annex III (see next slide).

Reference: Industrial Emissions Directive (IED) issued in 2010

The conclusions are legally binding and have to be implemented by the Member States and there by the competent authorities

IED – ANNEX III: Criteria for determining best available techniques

1. the use of low-waste technology; (ink jet for printing)2. the use of less hazardous substances; (fatty alcohol ethoxylates instead of APEO)3. the furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate; (NaOH, synthetic sizing agents, indigo)4. comparable processes, facilities or methods of operation which have been tried with success on an industrial scale; (cold pad batch dyeing of cotton knitwear)5. technological advances and changes in scientific knowledge and understanding; (ZLD)6. the nature, effects and volume of the emissions concerned; (emissions to air from stenters)7. the commissioning dates for new or existing installations;8. the length of time needed to introduce the best available technique; 9. the consumption and nature of raw materials (including water) used in the process and energy efficiency; (natural/synthetic size ng agents)10. the need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it;11. the need to prevent accidents and to minimise the consequences for the environment;12. information published by public international organisations. (IFC, UNEP, OECD, EC a.o.)

Look for frontrunners in a certain sector

Selection procedure and justification of BAT -Frontrunner approach – well/best performing plants

Frontrunner approach

Study and describe the front-runner technique

Possible future: Followers of the frontrunner techniques

Bath 1 83.5 °C

Bath 2 91.4 °C

Bath 3 82.0 °C

steamer102 °C

scouringliquor

Bath 1 81.5 °C

Bath 2 79.5 °C

Big squeezer

Bath 3 83.1 °C

Bath 4 82.0 °C

Securon AN Ruco Acid

Freshwater consumption: ca. 2.5 l/kg

steamer102 °C

ww fromdesizing

Bath 2 81.2 °C

Bath 4 79.8 °CBath 1

86.0 C

Bath 5 75.3 °C

ww frombleaching

and scouringwashing waterfrom merceri-

sation

hot freshwater

Legend:

fabric

water

waste water (ww)

Improvement of continuous pre-treatment of woven cotton fabric

Zero liquid discharge (ZLD)

or

The progressive or aspirational level of ZDHC Wastewater Guidelines

What is BAT?:

rule of thumb

about 10-20 % best performers (best performingplants or techniques) of a sector where sufficientdata is available (see examples) but could be just one or very few reference plants (often, there are not enough data to carry out statistical considerations)

may be, India decides to go for averageperforming plants(by the way: China intends to go beyond European BAT)

0 5 10 15 20 25 30 35 40 45

Installations

Rep

ort

ed

em

issio

n l

evels

of

ind

ivid

ual

insta

llati

on

s

best performing installationsinstallations which need

to improve.

well performing

installations

potential range to conclude on BAT

BAT: about 10-20 % best performersDust emissions from 45 sinter plants

Range of VOC emissions from 65 car paintshops in Europe

BAT: about 10-20 % best performers

best performingplants

plants with needto improvement

Wellperfor-minge

xcep

ti. Car paint shops

VO

C e

mis

sio

ns

in [

g C

/m

2]

Technical working groups (TWGs)

•Expert judgement to conclude on BAT (there is no„algorithm“ or certain (scientific) procedure)!!

Treatment of textile wastewater – 60 % recycling (technically feasible) not concluded to be BAT due to excessive costs (not economically viable)

This conclusion was drawn in 2003, but itmay be different today see for instance ZLD plants

18

Zero liquid discharge plants:

developped in Tirupur due to

Supreme Court decisions

excess

sludge

Storage and

Equalisation Tank

Activated sludge

tanks

Filter PressChlorine Contact

Tank

reco

ve

red

wa

ter

for

reu

se

(RO

pe

rmea

tea

nd

co

nd

en

sate

)

Secondary

ClarifierSludge

Thickener

bio sludge for

disposalQuarz Filter

Ultrafiltration

System

Decolourant Resin

Filter (not in Use)

Softener Filter

Resin Regenerate

Waste Collection

Tank

Reactor

Clarifier

Sludge

Thickener

Filter Press

lime sludge to

cement Industry

for co-processing

Reverse Osmosis

(4 stages)

Additional Stage

RO

MEE (FEE)

MVR-E

Pusher

Centrifuge

Glauber salt for

reuse in member

dye houses

MEE (FCE)

Solar Evaporation

Pond (SEP)

ATFD

waste mixed salt

for disposal

Brine Treatment

System

brine for reuse at

member dye

houses

Raw effluent

from member

textile wet

processing units

Ba

ck W

ash

/CP

/CE

B E

fflu

en

ts

Example: CETP Arulpuramin Tirupur

MVR-E: Mechanical Vapour Recompression Evaporator FFE: Falling Film Evaporator MEE: Multiple Effect EvaporatorFCE: Forced Circulation Evaporator ATFD: Agitated Thin Film Dryer

19

Zero liquid

discharge plants:

Characterisation of theCETP Arulpuramin Tirupur

20

Zero liquid discharge plants:

The approach of ZLD plants is broadly accepted in India and otherAsian countries

This means that ZLD is considered to be BAT (may be not in Europe – we will see the revision of the BREF for the Textiles Industry)

21

First step to Zero liquid discharge plants: this approach is applied in

areas with high water scarcity (e.g. in the South of Pakistan (Karachi))

Example: Yunus Textile Mills Ltd. in Karachi/Pakistan

Equalization Tank

Anoxic TankNeutralisation

(optional)

Activated Sludge

Tank

Activated

Sludge Tank

Additional

Fine Screen

Excess SludgeCentrifuge

Centrifugate

94 %

Process

Wastewater

Flue gas neutralization

Fine Screen

(Fibre

Removal)

Heat

Exchanger

External Ultrafil-

tration for sludge

separationPermeate Tank

3-Stage

Reverse

Osmosis

PermeatTank

Permeate

Reuse in

Textile Wet Processing

RO

Concentrate for Disposal

Sludge for Disposal

Re

turn

S

lud

ge

22

First step to Zero liquid

discharge plants:

this approach is applied in

areas with high water scarcity

(e.g. in the South of Pakistan

(Karachi)) to recover water

Example: Yunus Textile Mills Ltd. (YTML)in Karachi/Pakistan

23

Conclusion

ZLD goes beyond existing European BAT (BREF for the Textiles

Industry issued in 2003)

24

The new ZDHC Wastewater Guidelines

ZDHC: Zero Discharge of hazardous chemicals

Parameter Unit Foundational Progressive Aspirational

Conventional parameters

Temperature*1 °C Δ15 /max. 35 Δ10 or 30 Δ5 or 25

Total suspended solids (TSS) mg/L 50 15 5

Chemical oxygen demand (COD) mg/L 150 80 40

Total Nitrogen mg/L 20 10 5

pH

Colour (spectral absorption

coefficients at following wave

lenghts: 436 nm; 525 nm; 620 nm)

1/m 7; 5; 3 5; 3; 2 2; 1; 1

Biochemical oxygen demand (BOD5) mg/l 15 5

Ammonium-N mg/L 10 1 0.5

Total phosphorous (P) mg/L 3 0.5 0.1

Adsorbable Organic

Halogen (AOX) mg/L 5 1 0.1

Oil and grease mg/L 10 2 0.5

Phenol mg/L 0.5 0.01 0.001

Coliform bacteria

/100 mL400 100 25

Persistent foam not visible

6.0 - 9.0

Conventional parameters showing foundational, progressive, and aspirational limits

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Foundational, progressive, and aspirational limits for anions and heavy metals

Anions

Cyanide mg/L 0.2 0.1 0.05

Sulphide mg/L 0.5 0.05 0.01

Sulphite mg/L 2 0.5 0.2

Metals

Antimony*2 mg/L 0.1 0.05 0.01

Chromium, total mg/L 0.2 0.1 0.05

Cobalt mg/L 0.05 0.02 0.01

Copper mg/L 1.0 0.5 0.25

Nickel mg/L 0.2 0.1 0.05

Silver mg/L 0.1 0.05 0.005

Zinc mg/L 5.0 1.0 0.5

Arsenic mg/L 0.05 0.01 0.005

Cadmium mg/L 0.1 0.05 0.01

Chromium (VI) mg/L 0.05 0.005 0.001

Lead mg/L 0.1 0.05 0.01

Mercury mg/L 0.01 0.005 0.001

Alkylphenol (AP) and alkylphenol

ethoxylates (APEOs): including all

isomers

Reporting limit: 5 µg/L

Groups of individual organic pollutants (for all the individual compounds see the ZDHC Wastewater Guidelines)

Sampling points for facility with own WWTP and direct discharge

Sampling points for facility with indirect discharge; WWTP is managed by third-party, and, optionally, company has pre-treatment (fluff removal, neutralization, equalisation, etc) on-site

Schedule - 1

(1) Foundational limits for conventional wastewater parameters should already be met by suppliers. If the foundational limits are more restrictive than the supplier’s legal, permitted limits, suppliers are expected to meet compliance with foundational limits within a period of one year from publishing date of these guidelines.

Schedule - 2

(3) All facilities are expected to meet aspirational or progressive limits as early as possibleand share best practices on how to achieve it.

(4) Aspirational limits for conventional wastewater parameters are expected to be met by January 1, 2020. Suppliers are encouraged to continuously improve to achieve one of

the following:4.1 Attain and demonstrate performance that meets or exceeds aspirational

performance; or4.2 In the absence of aspirational performance, attain and demonstrate progressive

performance, and have a plan with milestones in place to achieve continuousimprovement.

Parameter

Unit Concentration Remarks

Suspended solids

(textile fibres)

mg/l 200 - 950 The higher values are for cotton woven fabric whereas the

lower values are for knitwear

pH 5 – 13 Usually textile wastewater is alkaline. High values occur in

case of cotton mainly due to scouring and mercerization. In

case of very high values (around pH 13), the recovery of

caustic soda for mercerization is missing or insufficient. The

low value is exceptional and may happen in case of dyeing

polyamide with acid dyestuffs.

Conductivity µS/cm 300 – 9000 Directly correlates with the content of neutral salts,

especially of sodium chloride and sulphate

COD mg

O2/l

400 – 4000 The lower value is for very diluted waste water whereas the

higher value is for water-efficient finishing of woven fabric

with a high add-on of sizing agents

TOC mg C/l 150 – 1500 see the remarks for COD

BOD5 mg

O2/l

80 – 1200 see the remarks for COD (in case of high BOD5, the sizing

agents are easily biodegradable)

COD/BOD5 2.3 – 7 The COD/BOD5 ratio is a rough indication for the

biodegradability of wastewater but there are exemptions

(compounds which are biodegradable under certain

conditions (low F/M, adaptation))

Ranges of analytical results of textile wastewater

ZDHC Wastewater Treatment Technologies - 2018

It was intended that thisreport does provide thetechnical background forachieving the different levels BUT it does not

Pretreatment

Primary treatment

Biological treatment

Tertiary treatment

Advanced techniquesto recycle wastewater

Zero liquid discharge(ZDL) with/without

salt recovery

Today, textile WWT usually consists of a sequence of techniques

Fluff/fibre removal, heat exchange, neutralisation, equalisation

Usually not required; e.g. in case ofstone wash

Mainly activated sludge

Precipitation/flocculation, ozonation, activated carbon

Combination of membranetechniques, including reverse osmosis

Listen to the presentation of Mr Sajid Hussain

Can ZDHC Wastewater Guidelines be achieved and how?

- COD removal in case of precipitation/flocculation: about 50 % (often not there in practice)

- COD removal biological treatment (usually activated sludge): 85 % in case of prior precipitation/flocculation (as the non-biodegradable compounds which adsorb to the sludge are already removed) and 90 % in case there is no prior precipitation/flocculation. This elimination rate is high and can only be achieved at low F/M.

- COD removal efficiency of tertiary treatment varies. As tertiary treatment is usually “polishing” to remove dyestuffs and some other heavily biodegradable, the COD removal efficiency is usually not high (20 – 30 %). Depending on the dosage of adsorbents or oxidizing agents, up to 50 % COD removal efficiency can be achieved.

Only COD is considered

Finisher of cotton yarn – COD concentration after pretreatment: 1000 mg/l

a) Treatment: Activated sludge at low F/M with 90 % COD removalEstimation: 1000 x 0.1 = 100 mg/L, this value would exceed the progressive and aspirational level

b) Treatment: Precipitation/flocculation with 50 % COD removal and activated sludge with 85 % COD removalEstimation: 1000 x 0.5 x 0.15 = 75 mg/L, even with prior precipitation/flocculation, the progressive value can just be achieved and the aspirational value would be exceeded

Finisher of polyester yarn - COD concentration after pretreatmentincluding equalisation: 2000 mg/l

Treatment: Precipitation/flocculation with 50 % COD removal and activated sludge with 85 % COD removal.Estimation: 2000 x 0.5 x 0.15 = 150 mg/L, this value would just comply with foundational but would significantly exceed progressive and aspirational. Even tertiary treatment would not be associated with compliance with progressive and aspirational.

Finisher of cotton knitwear, COD concentration after pretreatment including equalization: 1500 mg/L

Treatment: The sequence is taken from an exemplary case with measured removal efficiency: Activated sludge with lignite coke particles (about 80%), precipitation/flocculation (about 50 %), adsorption to lignite (about 50 %), sand filtration (about 20 %). However, this plant is no more in operation.Estimation: 1500 x 0.2 x 0.5 x 0.5 x 0.8 = 60 mg/L; this four-stage treatment does achieve the progressive value but not the aspirational one. This treatment is the so-called ITV Process.

It is described in the Reference Document on Best Available Techniques for the Textiles Industry (Textile BREF, 2003) but, due to excessive investment and operating costs, it was not concluded to represent best available technique, i.e. this treatment was considered to be technically feasible but not economically viable.

Finisher of cotton and cotton/polyester woven fabric; COD concentration after pretreatment including equalization: 3500 mg/L

Treatment: Precipitation/flocculation (50 %), activated sludge at low F/M (85 %), adsorption to activated carbon or lignite (50 %), ozonation (20 %), sand filtration (20%). This is an extremely advanced treatment which can hardly be found in a textile finishing industry on this planet so far. Estimation: 3500 x 0.5 x 0.15 x 0.5 x 0.8 x 0.80 = 84 mg/L; even with such a sophisticated sequence of treatment techniques, the progressive value cannot be reliably met.

Conclusion - 1

Today, the standard layout of textile wastewater treatment plants comprises of pretreatment including equalization and activated sludge. With this approach, polyester yarn finishers, cotton knitwear finishers and woven fabric finishers cannot even comply with foundational.

For achieving progressive, it requires advanced treatment with a well-designed and well-operated wastewater treatment plant with precipitation/flocculation, activated sludge with low F/M and effective tertiary treatment such as ozonation or adsorption.

Conclusion - 2

In case of plants with high water recycling rate, the concentrate from reverse osmosis has a COD in the order of 1000 – 2000 mg/l which is far from foundational, progressive and aspirational. Today, this concentrate is usually discharged without further treatment. In case of zero liquid discharge plants, it is evaporated in at least two stages. Then, all ZDHC standards are complied with. But worldwide, this is achieved in only a very few cases so far.

Conclusion - 3

The ZDHC Wastewater Guidelines are challenging. For water-efficient companies, it is extremely difficult to achieve progressive and it is almost impossible to achieve aspirational; the latter appears to be only achievable by means of zero liquid discharge plants.

So far, ZDHC did not demonstrate the technical approaches to achieve progressive and aspirational. However, this is very much needed and remains a task to do asap.

Technical working groups (TWGs)

• BATIS – BAT Information System which is a platform formembers of TWGs (restricted access) – all documentsprovided and considered during BREF elaboration are placedthere

Information exchange tool: BATIS

• TWG scattered around Europe => infrequent face-to-face interactions

• Electronic tool: BAT Information System (BATIS)

BATIS – example: Textile BREF

BATIS – example: Textile BREF

BATIS – example: Textile BREF

BATIS – example: Textile BREF

Let‘s share a

dream

To convert rivers like this….

…. or this

... into clear, healthy rivers ...

Benzene

53

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Thank you very much