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