TERMS OF REFERANCEenvironmentclearance.nic.in/writereaddata/Online/TOR/0_0...A-166 & F-162-165, in...
Transcript of TERMS OF REFERANCEenvironmentclearance.nic.in/writereaddata/Online/TOR/0_0...A-166 & F-162-165, in...
CONTINENTAL PETROLEUMS LIMITED
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TERMS OF REFERANCE (TOR) We are hereby describing as follows the TOR including Pre-Feasibility Report On
“Modernisation of Existing Hazardous Waste Incinerator” Being Used as CTSDF
Working at our Plant in RIICO Industrial Area, Plot No. A- 166 & F-162-165, Behror
(Rajasthan) mentioning brief conclusion and final recommendations. Additionally we
have also submitted brief report on EIA, EMP, Risk Assessment, Monitoring and
additional Reports for your kind perusal and site visit if required.
1. PURPOSE:
(i) To obtain prior “ENVIRONMENTAL CLEARANCE” in accordance to the
Regulations prescribed by MOEF vide EIA Notification 2006 dated 14-
09-2006 for Project Activity 7(d) falling in Category “A” of the schedule
as per clause 4(ii) i.e. Common Hazardous waste treatment, storage and
disposal facilities (CTSDF’s) i.e. for INCINERATION ALONE.
(ii) Stages in the prior Environmental Clearance (EC) as per rule 7 is not
applicable as ours is “not a new project” as defined in 2 (i) but it is
modernisation as per 2(ii) only, i.e. our existing Incineration System as
it is not a new factory or industry but an Environmental Protection
Facility.
(iii) Location: Plot No. A-166 & F-162-165, in RIICO Industrial Area, Behror
– 301 701 Dist. Alwar (Rajasthan)
(iv) Application duly completed with required enclosures is enclosed in
desired format Form I as per Rule 6 of Notf. EIA 2006.
2. INTRODUCTION ON EXISTING FACILITIES ON INCINERATION:
Continental Petroleums Ltd. (CPL) is a company established a re-refining of
used oil plant employing the B. Meinken’s Technology of Germany during
1987-88 at Plot no. A-166 & F-162-167 admeasuring 20,000 sq. mtr. in RIICO
Industrial Area, Behror i.e. in authorised developed industrial area by RIICO
established during 1981 with all infrastructure facilities to promote industries
in Rajasthan. It is also important to note that the state boundaries viz.
Haryana, U.P, M.P and Gujarat are far more than 15 Kms. away from Behror
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where the existing facility is located. CPL has had a captive incinerator
operating since 1987-88 utilised to incinerate the acid sludge and spent clay
generated during re-cycling of used oil. As a result of switching over of
technology as per the directions issued by CPCB during the year 2004 for re-
refining of used and waste oil by acid – clay process to total distillation
process, the captive incinerator became redundant in our plant. We
approached to Rajasthan State Pollution Control Board (RSPCB) to permit us
to deploy the captive incinerator as CTSDF having feed capacity of incineration
at 375 Kg/hr which was allowed and Authorisation under HW Rules was
granted in December 2003 after completion of some modification. The latest
authorisation is enclosed as Annexure – 1. Thus accordingly since then we
have been using the captive incinerator to incinerate the hazardous waste
generated and received in our factory from industries in Rajasthan. The
authorisation granted by RSPCB to continue using incinerator as CTSDF has
been renewed until 28-02-2017 Since the existing incinerator has static
rectangular primary chamber with no auto feeding system as per guidelines
prescribed by CPCB for Common Waste Incinerator vide HAZWAMS/30/2005-
2006 during June 2005, RSPCB asked us to modernise or upgrade the same by
providing Rotary Kiln Incinerator as primary chamber and in such
circumstances we have no option except to modernize or upgrade the existing
working captive incinerator. Although all other systems and records etc. as per
CPCB guidelines have been strictly followed by us and also we have been
complying with various regulations stipulated by MOEF, CPCB and RSPCB.
The basic purpose of converting captive incinerator in CTSDF has been to
provide hazardous waste management system to the industries in Rajasthan
by collecting, transporting, storing and disposing by incineration such
hazardous waste. This has helped our industry to earn some revenue and also
provided direct employment to about 15 to 20 people of Behror and indirect
employment to about more than 100 persons and also providing the revenue
to the Government by way of service tax etc. By way of such deed the
environment is automatically protected.
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3. GENERATION OF HAZARDOUS WASTE IN RAJASTHAN TO DECIDE THE
CAPACITY OF INCINERATOR:
There are several large, medium and small scale industries in Rajasthan which
are potential source of waste to be treated at the captive facility by
incineration. Enlistment of potential hazardous waste generating units in
different sectors is summarised in table Annexure - 2. It is observed from this
table that textile, engineering, chemical, dye/dye intermediate, Secondary
production of copper / zinc, steel rolling mills, waste oil re-refiners and
petroleum storage sectors constitute maximum number of hazardous waste
generating units. The district wise distribution of potential hazardous waste
generating industries in presented in table Annexure - 3.
Hazardous waste Disposal Practices in potential hazardous waste generating
units is as follows:-
Sl.
No. Hazardous waste Disposal Practices
Quantity
(MTA)
1 SLF (Captive) 513080
2 Reuse in Process 130047
3 Sold to registered re-cyclers / used in cement Kiln 56691
4 Co-incineration/co-processing 28104
5 CTSDF Udaipur / Balotra 43381
6 Incineration 10331
7 Bioremediation 134
8 Storage 26
TOTAL 781794
NOTE: The hazardous waste generation are based on the authorization issued
under Hazardous Waste (Management, Handling & Transboundary
Movement) Rules, 2008 but shall vary depending upon the actual production
by the unit.
(* As per report of RSPCB – 30th June 2012)
In view of above position and to ensure compliance of hazardous waste
(MH&TM) Rules 1989 and subsequent amendments, it was felt necessary to
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develop common treatment, storage and disposal facility (CTDF) for the
scientific disposal of hazardous waste depending upon the nature of the waste
either through secured land fill (SLF) or by incineration at controlled
combustion of the same at very high temperature followed by cleaning and
cooling of flue gases and thereafter incinerated ash is then required to be
disposed in secured land fill (SLF) disposal directly or after solidification and
stabilisation. As reported, the Hazardous waste Generation is as follows:-
Hazardous Waste Generation Quantity (MTA) Land Disposal (SLF) 5,56,621 MTA Incineration / Co-Incineration * 38,435 MTA Re-Processors / Re-Cyclers 1,86,738 MTA ------------------ 7,81,794 MTA ------------------
* Includes 10,331 MTA waste capable for Incineration.
The above figures shows the total generation made by the industries as per
authorisation granted by RSPCB therefore such figures relates to 100%
capacity utilisation of respective industries which may not be normally the
case. In view of above position we have considered the safe availability of
around 4200 MTA of waste out of 10331 MTA as some of the units have their
own captive incinerator facility. (Annexure - 4)Hence the capacity of our
modernised incinerator would be 500 Kg/hr x 24 hours per day x 350 days an
year = 4200 MTA capacity which is considered as reasonable. By way of our
past experience we have assumed that above 5% to 7% liquid hazardous
waste is included in the figure of 10331 MTA. The above capacity considered
is also reasonable due to many industries are forwarding their Incinerable
hazardous waste for co-incineration to the cement kilns and such activity is
encouraged by RSPCB.
4. EXISTING SITE LOCATION:
We have been operating our captive incinerator since 1988-89 and the same
as CTSDF since December 2003 is installed at plot no. A-166 & F-162-165, in
RIICO Industrial Area, Village - Behror having population of about 30000 (in
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2011) is well developed with quality infrastructural facilities like good road
network of all the roads of national highway, state highway and district roads
(NH8), water supply from tube wells, electricity form 220 KV GSS at NIC(M)
and main sewerage system parallel to the internal roads of the industrial area.
Top 20 industrial houses running in the industrial area are Green ply, SPM
auto, GS pharmaceuticals, Apex Tubes, Manu Tiles, etc. This area also falls
within Delhi – Mumbai investment corridor area belt.
RIICO has also undertaken social responsibility in this industrial area by
transferring village amenity fund and constructing rain water harvesting
structure. RIICO has acquired and developed 280.81 acres of land in which
259 numbers of plots have been planned covering an area of 187.19 acres.
This industrial area was developed by RIICO in the year 1981 and had around
more than 100 industries. The ground water depth in the area varies from 50
mtr. to 100 mtr. below ground level in the most monsoon season. The salient
data related to above mentioned site is as follows:-
(a) No religious place within 500 mtr radius.
(b) No river within 2000 mtr. radius and no water bodies existing.
(c) No human population within 2000 mtr radius.
(d) No under forest or preservation Act.
(e) 309 mtr above sea level.
(f) Forest is almost 10 kms away.
(g) Nearest Railway station is Rewari in Haryana and Alwar in Rajasthan
which is 53 kms and 59 Kms respectively away.
(h) Nearest Airport is T-3 in Gurgaon and Jaipur which is 130 kms and 133
Kms respectively away.
(i) There is no resettlement happening because no habitation exists within
the premises and more than 1 km of the proposed site.
(j) There is no wildlife including blue bull in the area,
(k) There is no bird century and National park around.
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(l) Air cargo port and dry port (inland container depot) are also
approachable from this industrial area. Nearest air cargo port at New
Delhi and nearest dry port at Rewari.
(m) State boundaries viz. Haryana, U.P, M.P and Gujarat are far more than 15
Kms. away from Behror where the existing facility is located.
Note: We have around 100 numbers of various large trees growing in our
factory area. Additionally sufficient green area and garden with many small
green plants are already existing and growing in our factory premises.
It may be noted that Rajasthan State Industrial Development and Investment
Corporation popularly known as RIICO incorporated in 1969 is a premier
agency of Govt. of Rajasthan and apex body mainly engaged in site selection,
acquisition of land and development of industrial area for promoting small,
medium and large industries in Rajasthan. It is 100% Govt. of Rajasthan body
who has been duly legally authorised to develop such industrial areas
complying with various State and Central Govt. regulations. RIICO has so far
developed 321 industrial areas by acquiring about 59084 acres (239.10 Km.
Sq.) of land. More than 26633 industries are in production with the industrial
area developed by RIICO in Rajasthan.
Since we have been operating our incinerator as CTSDF from December 2003
in the area described as above in Behror and in view of the various
circumstances studied we feel that we may be granted exemption from public
hearing for the proposed modernization of Incinerator.
5. INCINERATION SYSTEM PROCESS DESIGN
5.1 The Incineration system is designed to handle the following
characteristics of wastes and other practical requirements:
Solids, semi-solid and tarry drummed wastes as made available in
packets of definite size and weight.
Pump able high energy content liquid organic wastes free from
suspended solids.
The Rotary Kiln is designed for ashing mode operation only.
Incineration Feed Rate: Due to non-homogeneous nature of the
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waste, characteristics including the feed rate through the kiln,
system heat of combustion, moisture, ash content, and bulk density
will vary. All these factors will affect/influence the feed rate and
auxiliary fuel requirement
Kiln design exit gas temperature 800°C to 900°C.
Temperature at secondary Combustion Chamber will be 1200°C for
wastes with chlorine contents over 1%. The same will be 1050°C
when chlorine contents will be within 1%.
Gas residence time at post combustion chamber will be 2 seconds.
5.2 INCINERATION DESIGN TO MINIMIZE THE EMISSIONS OF FURANS
AND DIOXINS:-
Dioxins and furans are formed from the thermal breakdown of
organic materials combined with transitional metals and chlorinated
compounds. It is also known that dioxin are chemically formed at
temperature above 200°C but completely destroyed at 800°C.
Modern incinerator plants are be designed and operated to achieve
nearly complete destruction of the combustible portion of the waste
with very low emission of furans and dioxins under normal operating
conditions. Following are the practical measures that will be adopted
to reduce emission of dioxin and furnace from incinerator:
Proper segregation of waste. PVC in garbage affects the amount of
dioxin formation.
Chlorine input will be completely avoided.
Wet garbage win not be incinerated until such time it is dried
through solar drying.
Combustion chamber will be designed to optimize the supply of air
for achieving more complete destruction of waste.
Quick cooling of flue gas to minimize dioxin reformation between
200°C to 400°C. The rotary kiln incinerator will be installed with a
spray drier or a heat recovery unit, which will ensure that the
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temperature after Secondary Chamber is brought down to less than
250°C from 1100°C.
This will minimize the possibility of formation of furans and dioxins.
Monitoring of stack/chimney for flue gases including dioxin
emissions.
5.3 The common Hazardous waste incinerator shall be required to comply
with the gaseous emission norms notified under the Environment
(Protection) Fifth Amendment Rules 2008 dated 26th June 2008 (As per
Annexure – 5)
6. DETAILS OF MODERNISED INCINERATOR / PROJECT DESCRIPTION.
6.1 INCINERATOR: Incineration is an ultimate treatment process, applied
to certain wastes that cannot be recycled, reused or safely deposited
into a landfill. The ANNEXURE – 6 mentions the list of hazardous
characteristics responsible to make the material hazardous. The
incineration is high temperature, thermal destruction oxidation process
in which hazardous wastes are converted in the presence of oxygen in
air into gases and incombustible solid residue. The gases are vented into
the atmosphere after cleaning as deemed necessary while the solid
residue in sent to landfill for disposal. The modernised incinerator will
cater for the disposal/destruction of the following wastes or as per the
authorisation granted by RSPCB:-
Spent Solvents
Waste Oil, Oil Emulsions and Oil mixtures
Pesticides Wastes
Pharmaceutical Wastes
Phenolic Wastes
Grease and Wax Wastes
Organic wastes containing halogens, sulphur, phosphorus or nitrogen
compounds
Solid material contaminated with oils
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Organics with high calorific value.
6.2 The primary objective of this incinerator is to destroy the waste to have
end products (solids/Ash and gases) that are harmless when released
into the environment and to minimize the formation of new hazardous
organic compounds. To achieve the same the incinerator is proposed
with sufficient temperature, residence time, turbulence and adequate
excess air.
6.3 LAYOUT PLAN OF THE INCINERATOR:
The existing incinerator is installed in the covered shed of size 12.65
mtr x 8.48 mtr but to modernise the same we need more space.
Therefore adjacent to existing incinerator and adjacent to the storage of
waste, we propose to make the modernised incinerator facility
according to the CPCB guidelines as per the sketch – drawing Annexure
– 8 showing all the process equipment sequentially placed for complete
incineration of hazardous waste. Such installation will require the floor
area of 30 mtr. x 9 mtr. covered on top by steel sheet shed erected on
steel columns having height of 6 mtr.
The layout and placement area for the modernized incinerator is also
shown as a rectangular box on the south east location of master plant
layout drawing attached as Annexure – 7.
6.4 COMPONENT, DESIGN & SPECIFICATION OF VARIOUS EQUIPMENTS
OF THE MODERNISED INCINERATOR
(A) NAME OF EQUIPMENT - INCINERATOR
Model AR-HW-500
Capacity 500 Kgs/hr
Type Floor Mounted Horizontal
Category of Waste Hazardous Waste
Type of Waste to be Incinerated Solid
Maximum Connected Electric Load of Incinerator - 85 HP / 63.75
KW , 440 V 50 Hz 3 Phase
(B) HYDRAULIC AUTOMATIC WASTE FEEDING SYSTEM
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MOC - Mild Steel
Thickness - 5 mm
Feeding System - Hydraulic Power Pack Capacity 5 HP complete
with 3
Numbers of cylinders, Limit Switch, Hose Pipe, Solenoid Valves
and hydraulic oil reservoir with filter, drain plug, level indicator.
(C) FORCED DRAFT FAN (FD FAN)
Quantity - 2 NOS.
Type - Centrifugal
Capacity - 2200 CFM
Static Pressure - 200 mmwg
MOC of Outer Body - Mild Steel
Balancing - Dynamically & Statically
Motor - 3 HP 1440 RPM each
Air Flow measuring gauges - Fitted
(D) PRIMARY CHAMBER (ROTARY KILN)
Type of Primary Chamber - Rotary Kiln Chamber complete with
Base Frame fitted with 15 HP geared box and motor.
Waste Feeding System - Complete with Belt Conveyor, 5 HP
Motor, supports and Hydraulic Feeding System with 5 HP motor,
power pack and cylinders.
MOC of Outer Body - Mild Steel, 10 mm Thickness
Insulation / Refractory Lining - Complete with refractory lining
and insulation suitable for a temperature upto 1400° C
Operating Temperature : 800°C – 900°C
Ash Removal System - Manual
Temperature Sensors - TC Rod ‘K’ Type
Manometer - Fitted
(E) BURNER FOR PRIMARY CHAMBER
Quantity/ Capacity - 2 NOS
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Fuel - HSD / LDO
Temperature Control - Automatic
Ignition - Automatic
Fuel Pump - Suntec (France)
Blower with Motor - Provided
Sequence Controller - Siemens
Flame View Port - Provided
Pressure Gauge - Provided
Filter - Provided
(F) SECONDARY CHAMBER
MOC of Outer Body - Mild Steel, 5 mm Thickness
Insulation/ Refractory Lining - The refractory lining & insulation
bricks will be of 125 mm thick & shall confirm to IS:8-1983 &
IS:2042-1972 standards suitable for a temperature upto 1400° C
Operating Temperature - 1200-1400 Deg C
Gas Residence Time – 2.5 to 3 seconds
Temperature Sensor - TC Rod ‘K’ Type
(G) BURNER FOR SECONDARY CHAMBER
Quantity - 1 NO.
Fuel - HSD / LDO
Temperature Control - Automatic
Ignition - Automatic
Fuel Pump - Suntec (France)
Blower with Motor - Provided
Sequence Controller - Siemens
Flame View Port - Provided
Pressure Gauge - Provided
Filter - Provided
(H) INTERCONNECTING DUCT
MOC - Mild Steel
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Thickness - 5 mm
Refractory and Insulation - 115 mm thick
(I) QUENCHER
Quantity - 1 SET
Type - Vertical
MOC - Mild Steel
Refractory lining - 115 mm thick
Support - Provided
Re-circulation Tank for Quenching System - Mild Steel with
Rubber lining thickness 3 mm
Re-circulation Pump - 3 HP 1440 RPM
(J) EMERGENCY STACK
Quantity - 1 SET
MOC/ Thickness - Mild Steel/ 3 mm
Operation / Control - Through dampers, in case of power failure
for
emergency
Refractory and insulation - 115 mm thick
(K) LIME TREATMENT SYSTEM
Quantity - 1 Set
MOC - Mild Steel / 3 mm
Refractory lining - Provided
(L) ACTIVATED CARBON SYSTEM
MOC of system/Thickness - Mild Steel / 3 mm
Refractory Lining - Provided
Activated Carbon filter - To remove hydrocarbons, oxides and
odours from the gases.
(M) VENTURI SCRUBBER (AIR POLLUTION CONTROL DEVICE)
Quantity - 1 SET
Type - High Pressure Jet with spray nozzles
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MOC - Stainless Steel Grade 316 L
Type - Cylindrical
MOC of Nozzles - SS 316 L
Pipeline & Fitting - SS
Flanges SS
Manometer - Provided
(N) RE-CIRCULATION TANK AND DROPLET SEPARATOR
Quantity - 1 No.
MOC - Mild Steel
Rubber Lining - 3 mm
Support - Provided
Re-circulation Pump - 5 HP 1440 RPM
Pressure Gauge - Provided
(O) CAUSTIC TANK - Provided 500 Ltr with fitting
(P) PACKED BED SCRUBBER
Quantity - 1 No.
MOC - Mild Steel
Rubber Lining - 3 mm
Baffle - Fitted
Water Re-Circulation Pump - 3 HP
(Q) MIST ELIMINATOR
Quantity - 1 No.
MOC - Mild Steel/ 5 mm
Rubber Lining - 3 mm
Gas Cleaning Media - Sheet
(R) INDUCED DRAFT FAN (ID FAN)
Quantity - 1 No.
Type - Centrifugal
Capacity - 8500 CFM
Static Pressure - 250 mm wg
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MOC of Outer Body - Mild Steel
MOC of Impeller - Mild Steel
Rubber lining of Housing - 3 mm
Balancing - Dynamically & Statically
Motor - 40 HP 1440 RPM
Drive - Belt Driven
(S) WASTE HEAT RECOVERY SYSTEM – Heat exchanger attached to
the existing boiler for steam production.
(T) FUEL TANK
Quantity - 1No.
MOC - Mild Steel
Capacity - 3500 Ltrs
Label Indicator / Pipeline & Fitting - Provided
(U) CHIMNEY
Quantity - 1 SET
MOC - Mild Steel
Height - 30 Mtr. Minimum.
Ladder - Provided upto top
Sampling - Platform Provided
Gyrope - Provided
(V) CONTROL PANEL
Quantity - 1 NO.
MOC - Powder Coated Pre-wired
Tamper Proof Programmable Logic Controller (PLC) - Provided
Temperature Indicator for Primary & Secondary Chamber -
Provided
Temperature Controller - Provided
Flue Gas Temperature Indicator - Provided
Hooters /Alarms Audio –Video Alarms - provided for any
abnormal operation.
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Interlocking - Provided for safe operation
Contactors, Overload Relays, MCB etc - Provided
Timer, Selector Switch, Volt Meter - Provided
Complete Internal Wiring of Control Panel inside the Incinerator
Room – Provided
6.5 STAKE MONITORING AND ONLINE DISPLAY REQUIEMENT:
The sampling platform as provided in the existing stake emitting gasses
from the incinerator shall be used for taking stack samples for monitoring
the air pollutants as and when required as per the directions issued by
CPCB / RSPCB in accordance to the Authorisation granted. Holes have
been provided on chimney as per standard of CPCB norms. The various
parameters as per ANNEXURE – 5 of CPCB guidelines of common
hazardous waste incinerator shall be observed to online stake emission
monitoring system (CSEMS) and we shall regularly do maintenance and
operation of the same as per the direction issued by Govt. Authorities.
7. POWER REQUIREMENT AND SOURCE OF SUPPLY:
We need about 70 KW of power which is already available from State
Electricity Board. In addition to above, we have one captive stand by DG set of
125 KVA already installed at site duly covered by acoustic lining.
8. WATER REQUREMENT:
We need about 500 Ltrs. to 1000 Ltrs. of water daily for top up of quencher
and scrubber system of the incinerator. The water is available from main
supply of RIICO’s water source from where we have authorised water
connection. We have also a captive bore well (permitted by RIICO) to meet the
emergency requirement.
9. DISPOSAL OF WASTE GENERATION:
Two types of waste are generated:-
(a) The incinerated ash which is being forwarded to Rajasthan Waste
Management Project (RAMKY Enviro Engineers Ltd.), Village – Gudli in
Udaipur who’s our company is a member with Membership No. RWMP-
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99. Such ash is being disposed to secured land fill by RAMKY as per the
authorisation granted to us by RSPCB.
(b) Effluent water: The water so generated from quencher and scrubber is
sent to our ETP where after cleaning the same is being re-circulated for
cooling in cooling tower. Further any carbon particles if available are also
disposed along with ash to SLF at Udaipur or re-incinerated by us as per
the quality of the carbon particles.
(c) There is no discharge of any effluent water outside the factory compound
wall as the entire effluent water is treated and re-used and therefore our
unit is a ZERO DISCHARGE UNIT.
(d) STORAGE AREA: We have built and is available various covered sheds
and storage rooms of total area 520 Sq. Mtr. capable of storing about
2100 MT at our plant to store flammable, ignitable, reactive and non
compatible waste separately to receive and keep the Incinerable
hazardous waste. The total storage capacity is about 50% of the annual
capacity of the hazardous waste incinerator. Storage area is designed to
withstand the load of material and slop tanks are made to take care of any
spillage. The areas are provided with spillage pits / collection pits,
ventilators / exhaust fans wherever required. We have installed required
FF & FP systems by installing fire extinguishers, waste hydrant lines
(water ring), flame detectors,, smoke detectors, sirens/sounders, sand
buckets, hydrant valves, flexi line hose pipes, water monitor, pumps and
motor etc. with provision of underground and overhead water tanks in
addition to captive bore well. We have also installed “No Smoking”
Boards, provided the first aid box and worker’s safety items viz. helmets,
goggles, safety shoes etc. Mock drill and training of workers are observed
periodically. Proper maintenance of incinerator, and good house- keeping
of the plant and maintenance of incinerator log book are ensured by us.
The public liability insurance policy is enclosed as ANNEXURE - 9. All the
buildings, sheds & storage sections etc. are properly designed at the plant
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premises to avoid any damage or accident etc. to man, machine and
incoming resources.
We also ensure good housekeeping around the storage area and no
smoking is strictly observed. Further in compliance to the regulation for
storage of hazardous waste we shall restrict maximum of six months for
storage of Incinerable hazardous waste subject to obtaining approval as
per HW (MH&TM) Rules 2008 and amended thereof.
10. TRANSPORTATION OF HAZARDOUS WASTE
(a) The transport is required for the transport of waste from waste
generating member unit to the CTSDF facility at Behror. The vehicle
especially designed for the safe and leakage proof transport of hazardous
waste as per CPCB transport Rules and in line with international practice
shall be used for transport of hazardous waste in the state of Rajasthan.
(b) The vehicle will be fitted with required communication facility, first aid
facility. Spill collection system etc. The vehicle will be labelled as per
requirement.
(c) Packing of wastes primarily will depend upon the physical and chemical
characteristics of wastes. The liquid waste packed in suitable leak proof
MS and or HDPE drums where as solid hazardous wastes packed in
suitable water proof bags shall be accepted for transportation. TREM
card and Manifest Form No. 13 system as mentioned in MOEF Rules,
providing information on emergency management shall be followed in
strict compliance. The MSDS (Material Safety Data Sheet) of Chemical
constituents of waste will be used for deciding action in case of
emergency. The frequent unplanned mock drills will be carried out for
accessing and improving the effectiveness of the system.
(d) Communication systems shall be provided to drivers of transport
vehicles carrying hazardous wastes. The driver shall be well equipped to
contact CTSDF and the waste generator, while transport.
11. HAZARDOUS WASTE ANALYTICAL R&D FACILITY (ENVIRONMENTAL
LABORATORY)
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(i) ANALYSIS OF HAZARDOUS WASTE:
The analysis of hazardous waste is a very important and ongoing
activity at the facility. The analysis of waste is carried out for the
following purpose.
(a) The fingerprint analysis for each type of waste, when the industry
registers as per ANNEXURE – 10.
(b) The quick check analysis when the waste is received.
(c) The waste analysis for compatibility tests and for smooth
operation.
However the generator of hazardous waste has also to prepare the
comprehensive analysis of hazardous waste generated by them as per
parameters. ANNEXURE – 11.
(ii) LABORATORY: The laboratory therefore is being provided which will
consist of office area, sample storage area and general stores with
adequate system of exhaust and fire fighting facilities. The design of
laboratory is to ensure safety and security of apparatuses and the
persons working there. The prime function of laboratory will be:-
(a) To sample and analyse the waste for establishing and re-evaluating
finger print prints and establishing the treatment and disposal
options.
(b) To sample and analyse the waste shipment for quick checks.
(c) To sample and analyse the ambient air and flue gas samples from
the stake.
The laboratory will comprise of the following major instruments:
(a) Digital Analytical Balance.
(b) TOC Analyzer with SSM (Solid Sample Module)
(c) AOX Analyser.
(d) Extractors (TCLP) for volatile and non volatile compounds.
(e) Bomb Calorimeter.
(f) Hot Air Oven.
(g) Muffle Furnace.
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(h) Ph Meter.
(i) Sampling Devices.
(j) Toxicity Bio Assay Test.
(k) UV – Visible Spectrophotometer.
(l) Atomic Absorption Spectrophotometer (AAS) with Graphite
Furnace.
(m) ION meter with electrodes.
(n) Flash point, fire point apparatus.
(o) TSS Filtration Kit.
(p) Water Purification Kit.
(q) BOD Incubator.
(r) Karl Fisher Titrator.
The laboratory shall also take care of the online stack monitoring
system.
12. SUPPORTING INFRASTRUCTURE
(a) Factory totally compounded by boundary wall and main gates and
internal roads / pathways.
(b) Network of approach roads already exists in RIICO Industrial Area.
(c) Security Cabin.
(d) Workshop.
(e) Waste water Treatment plants.
(f) Vehicle parking facility.
(g) Administrative building comprising of office and training centre.
(h) Record keeping and record room.
13. WASTE HANDLING AND ACCEPTANCE
(i) Waste handling process and waste acceptance criteria at the CTSDF shall
be based on the MOEF rules for HW (MH & TM) Rules and or as per the
authorization granted by RSPCB would expect this facility to be equipped
to handle the following:
Waste streams described in Schedule-I of HW ((MH&TM) Rules or as
revised. ANNEXURE – 12.
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Waste described in Schedule-II with exceeding concentration limits
mentioned thereupon. ANNEXURE – 13.
Waste not meeting the criteria mentioned.
(ii) WASTE ACCEPTANCE CRITERIA
Waste acceptance for incineration shall be based on the existing laws
and regulations. Thus the waste acceptance criteria will be as per the
CPCB norms or as per the authorisation granted by RSPCB.
The following waste acceptance process will be followed:
Generator will provide information on waste type, constituents and
process (if acceptable to generator).
Facility will request the generator to provide technical lab test
required CPCB certified laboratory or a competent research
laboratory;
Facility shall review the lab tests and information provided by the
generator as above. Facility will also request the generator to
provide 1 kg or 1 liter waste sample for inspection and internal lab
tests by the Facility.
If waste constituents are Incinerable then a formal business
arrangement will be reached between Facility and Generator.
It would be mandatory for the generator to inform and seek consent
from the facility prior to sending HW to the facility.
Facility may transport the waste from generator to facility or
generator to facility or generator may use licensed transporters to
transport the waste to the facility depending upon the business
agreement.
Facility will inspect the waste including conducting lab test again to
ensure that waste is same as sample provided and lab reports
provided during acceptance qualification process. If the waste
constituents are within +5% of specifications provided then waste
will be accepted by the facility to incinerate else it will be returned
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back to the generator. If the waste cannot be incinerated treated by
the facility, then also it will be returned to the generator.
14. RECORD KEEPING
We ensure to maintain proper records with respect to the industry – wise,
type of waste of receipts, characteristics as well as the location of the wastes
that have been stored in the facility accordingly.
15. REGULATORY REQUIREMENTS
Government develops and supervises the implementation of policy programs
to manage wastes, which is an essential and integral part of managing human
health, the environment and sustainability of natural resources. We have
considered the Indian regulations and standards and the guidelines applicable
for common hazardous waste treatment, storage and disposal facilities for the
hazardous waste incineration as mentioned in Annexure – 14.
16. PROJECT SCHEDULE AND COST EXTIMATE
(a) Cost of up-gradation / modernization of incineration as CTSDF: The
total cost of such work is envisaged as Rs.120 Lakh including civil work,
procurement all equipments as per Para 4 as above and installation
commissioning thereof. The cost is lowered due to existing infrastructure,
facilities and existing equipment of the captive incinerator available in
plant.
(b) Duration of installation etc.: After obtaining the prior EC and final
approval from RSPCB for the incineration system to be deployed as
CTSDF we shall take around 12 months towards completion of the
modernization work.
(c) Economic Viability: Keeping in view the generation of hazardous waste
in Rajasthan we believe that we shall be able to operate the unit at least at
50% of the installed capacity providing BEP i.e. shall receive about 200
Tons per month of hazardous waste from industries in Rajasthan. The
total generation of Incinerable hazardous waste in Rajasthan is 10331
MTA (as reported in June 2012) which will increase every year due to
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growth of industries in Rajasthan. Hence we do not expect any problem to
operate the CTSDF on commercially economic basis.
17. OBSERVATION AND EFFECTIVE MEASURES ADOPTED TOWARDS RISK
ASSESSMENT
The details of Risk Assessment are separately mentioned under heading “RISK
ASSESSMENT” however general measures adopted are given below.
We have been operating the captive incinerator as CTSDF since 2003 wherein
we have had no mishap till today as our plant is totally provided with
boundaries at all sides having approaches for the vehicles to enter and exit
together with easy worker’s man escape (Safe movement of workers)
provisions. Sufficient parking spaces for trucks have been provided to reduce
nuisance due to disorderly parking and movement of trucks and also litter
around by the driver / others. Additionally fire fighting and fire protection
system are installed where necessary, water hydrant hoses etc placed at
various locations in the plant to protect of entire assets and raw materials in
case of fire. Hazardous wastes are stored in the covered space on pakka
concrete floor with provision of spill pit etc.
We have designed and laid various sections of the plant together with all
infrastructure facilities including roads, buildings, water supply, drains, solid
waste handling air and water quality so as to have not ignored environmental
resources and features.
The industrial site and good drainage system is in place without causing any
standing or stagnant waste to avoid breeding grounds for insects and to avoid
attraction for insects, rodents and birds which ultimately do not carry diseases
and human health problems.
Since the factory area is in a well developed Industrial Estate, hence there is no
environmental impact from human settlement. No human settlement has been
observed during last 25 years at our plant site. In fact the above industrial area
developed since 1980 accommodating more than 100 industries have been
providing hassle free orderly working of industries.
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The workers are provided with all safety items such as goggles, helmets, hand
gloves, aprons, shoes, mouth masks, reflective jackets, uniform etc. while
working in the plant. First aid facilities are also provided. Regular medical
check-ups of the workers is being carried out in the factory.
We have been taking the Public Liability Insurance Policy under Public
Liability Insurance Act 1991 as per regulation for the activity of Incinerator as
CTSDF. (Copy Enclosed as Annexure -9).
We also commit to ensure the preparedness maintenance by frequent and
periodically carrying out the mock drills and testing towards successful
operation and working of fire fighting and fire protection system. We also
make regular checks for critical equipment of the factory so as to ensure their
normal trouble free working in the plant.
18. CONCLUSION AND FINAL RECOMANDATIONS
The primary objective of the CTSDF is to provide a facility for incineration to
cater to emerging needs for management of industrial hazardous waste in the
state of Rajasthan where there is at present no exclusive hazardous waste
incinerator facility operating as CTSDF. The incinerator is located in
authorised RIICO’s industrial area at Behror where almost more than 100
small and medium industries are operating and where all infrastructures of
water, power, drain, approach road, communication system etc. are available.
The existing environment setting has also been examined where our system of
incineration of hazardous waste has been operating since 2003 and hence we
feel that NO DETAILED EIA is needed (however a brief report on Pre-
feasibility report, TOR, EIA, EMP, Risk Assessment, Monitoring and additional
reports are enclosed) nor the public hearing is required as the unit is located
in authorised industrial area. It is neither an industry nor a new project but is
the case of modernization of existing incinerator being utilised as CTSDF to
provide services to the generators of hazardous waste.
Based upon the observed information and circumstances, socio economic
position and given the state of art of technology to be procured towards
modernisation and operation of incinerator and our deep commitment
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towards the environment and society shown by us, it is concluded that no
adverse and incremental impact on any of the Environmental components is
envisaged due to the proposed modernised facility as CTSDF for incineration
of hazardous waste which shall be analysed for finger print analysis,
compatibility test to ensure smooth, efficient and safe operation of facility as
per legal requirements. We further commit to ensure the compliances as
follows:-
(a) We commit to take care of waste gases, waste water, noise and solid
waste as per guidelines of MOEF, CPCB and RSPCB.
(b) We commit to additionally expand and develop green area inside the
factory premises.
(c) We commit to encourage water conservation through water re-use and
re-cycling.
(d) We commit to provide qualified safety officer to build an emergency
preparedness and to implement suitable measures to prevent and control
an accident hazard.
(e) We commit to organise frequent mock drill exercises to check the
preparedness towards emergency.
(f) We commit to monitor the emitting gasses from the stack through online
stack monitoring system and also to make available the information on
the server installed in CPCB and RSPCB.
(g) We commit to comply to the various regulations issued by MOEF, CPCB
and RSPCB in respect of collection, Transportation, Storage and Disposal
by incineration of hazardous waste and finally to dispose the ash to SLF at
Udaipur. All as per Rules and regulations mentioned in Annexure – 14.
We therefore strongly feel that the prior EC for the modernization of the
existing incineration system may kindly be granted as early as possible for
operation as CTSDF at Behror in Rajasthan.
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