Dr V Nehru Kumar, Professor and Director, Centre for Environment, Health & Safety, Annamalai University talks about the environmental norms required to check while setting up a cement plant in India.
Cement as a commodity majorly contributes to infrastructural developments. Despite rapid infrastructure development, the per captia consumption of cement remains 150 kg against 380 kg of the developed nations. The scope for the growth of cement sector in India is vast and multi fold. The burgeoning demand is made CAGR to assess the growth rate of cement sector in India at 12 per cent in 2013-14, wherein it is presently 8-10 per cent.
India has an installed capacity for 324 mtpa, February 2013 and the operating plants are performing with 75-80 per cent production and it is forecast by RNCOS for 303 mtpa by 2014. Many existing plants are planning for augmentation to improve the production and many more are being proposed. There are 42 major corporate players, operating 140 large plants (>200 tpd) and 365 mini cement mills (<200 tpd). New strategies and corporate plans are at anvil for major augmentations of the existing plants and for new plants.
The material balance of cement mill is negative with 1.45 tonne of raw materials for 1 tonne of cement production. Suspended Particulate Matter (SPM) in emission and extensive use of water are historically known as major environmental concerns of cement industry.
Recently, SPM is rechristened for Repairable particulates as PM 2.5 and PM10.The SO2, NOx and CO2 (and CO) are the other major concerns in the ambient air quality around the cement plants. The use of coal or pet coke do make SO2 (0.50Kg/tonne in the dry process and up to 5.9 in the wet process) in objectionable concentrations in the emission. Cement manufacturing is energy intensive. Around 400 kcal/kg is required for clinker production and the power requirement is an average of 82 kwhr/ tonne. The fugitive dust is the major concern for the ambient air quality with respect to Particulate Matters (PM 2.5 and PM 10). Apart from the primary air pollutants from the stack, VOC, PCDDs/PCDFs, HF, HCl and few metal oxides could be the concerns in the air quality which warrants occupation health of the workers in jeopardy. A comprehensive Health Surveillance Monitoring is always recommended.
Cement plants are classified RED category industries for their requirement of natural resources, combustion process, calcination chemistry of clinker, requirement of more energy and historical impact on the ambient air quality.
The cement industry is one among the highly polluting 17 category industry and require consent for establishment and operation under Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981. However, it is the umbrella Act of Environment Protection Act, 1986 which brought Environmental Standards and the EIA Notification, 1994 brought Cement under its purview and mandate Environmental Clearance (EC) by Ministry of Environment & Forests, Government of India before any approval by state or UT.
Environmental Impact Assessment (EIA) Notification, 14th September, 2006 which supersede the 1994 Notification, brought the Cement Plant under its purview of Activity 3b and made stringent regulations to mandate Environmental Clearance (EC) for establishing new plants and as well for expansion of the existing plants.
EIA Notification classified the Cement plant under Category A for plants exceeding 1 mtpa as their production capacity and requires taking EC from EAC/MoEF/Delhi in the sequence of activities starting with ToR clearance, Draft EIA and Public Hearing before final EIA reporting and Clearance. Those plants which produce less than 1 mtpa are classified under category B and required the EIA process in the same line but EC from State or UT Environmental Impact Assessment Authority (SEIAA/UTEIAA) of the respective State/UT. Perhaps, the allied stand alone grinding units are also classified as B Category and require EC to be obtained from SEIAA/UTEIAA.
Technical EIA Guidance Manual (TGM) published by MoEF in August, 2010 is of great help in understanding the Prior Environmental Clearance required for establishing any new cement plant or expansion proposal of existing cement plants.
The protocols of the Decrees at National and State level approvals are enlisted in the Table1.1.
EIA and cement industry
EIA is the best available environmental decision making tool which sail the proposal through a rigorous real time observations, monitoring, collation of data, interpretation and impact prediction studies. EIA will redefine the project in its location specific environmental dimension. The best part of the EIA process is that it takes the views of proponent, experts, public, all line departments of Government and statutory authorities, in to it while getting finalised before implementation. Eventually, a comprehensive Environmental Management Plan will be the product of EIA, which will provide guidance to proponents and as well for the approval authorities, a framework for implementing the project with least impact on environment and better management strategies for resources to ensure sustainable development and foster inclusive growth of every stakeholder.
The provisions of Notification in 2006, its amendments on 1st December, 2009 and subsequent Executive orders from time to time, have streamlined the sector specific EIA process and today we have general Terms of Reference (ToR) to run EIA process for cement plants and prepare reports on EIA and EMP.
The requirements of additional ToR are largely location and project specific ,which are to be taken as ToR Clearance before set in the process of EIA conductance. For all recent updates by the organisation, please refer www.envfor.nic.in.
EIA study evaluates the environmental contours of the project location with reference to proposed project activities within the purview of the approved ToR. EIA makes a detailed collation of data and subjective analysis of environmental due diligence on all environmental attributes viz., micrometeorology, ambient air, water (waste water), geology (also solid waste streams), biology (flora, fauna and marine biota, if required) and socio-economics of the project location of 10 km radius around it as Impact area. Also, project specific risk analysis, emergency situations and hazard conditions are also required evaluation and management plans.
The expansion project of any existing cement plant without any incremental increase in pollution is practically not achievable. Any such proposal can never be categorised as B2 and hence any proposal, new or expansion, will require EC, from SEAC/SEIAA or EAC/MoEF, as the case may be, either A or B1.
Hence, the complete EIA process viz, ToR approval (from SEAC of the state EIAA or EAC/MoEF/New Delhi), Conducting Environmental Survey (for all attributes as per ToR in the project impact area of 10 km radius from the project location), Preparation and submission of Draft EIA, Conducting Public Hearing (with due Advertisement in Daily Newspapers to enable all stakeholders to take part), incorporation of public concerns in the draft to get final EIA. The final EIA must be submitted to where ToR approval was taken to get EC for the proposal.
Central Pollution Control Board (CPCB) has made at least four different sets of Guidelines for the operation of Cement Plants. Industry specific Standards, with respect to Dust and Suspended Particulates are specifically mandated. Another Guidance Document was made exclusively to manage dust in Cement Industry and it was dealt section wise. Probes 118/2007, from the document series on Environmental Standards has provided all Guidelines for fugitive dust control in the cement industry. Corporate Responsibility for Environment Protection (CREP) is specifically drafted and mandated for corporate sectors of cement manufacturing. There is another Guidance Document has been mandated by CPCB on co-processing of Hazardous Waste in Cement Kilns. For more details please refer www.cpcb.nic.in.
MoEF has already qualified a list of EIA organization through Quality Council of India (QCI) under National Accreditation Board for Education and Teaching (NABET) scheme. The list of accredited EIA Consultants has been already posted in the web of MoEF and QCI. The website www.qcin.org and www.envfor.nic.in gives all the details of the same.
GHGs and cement plant
In the ambit of environmental concerns with respect to GHGs and climate change, cement industries require major technological changes in handling CO2 from the stacks. Chemistry of clinker manufacturing can have no change. However, the emission can be handled better without leaving it as CO2.
The process of calcinations is a major source of CO2. The Cement Industries have been characterised for more than 5 per cent of the global anthropogenic CO2. One tonne of calcination gives 0.44T CO2. One tonne of cement production is learnt to cause anthropogenic CO2 from 0.85 to 1.15 tonne. The Cement Sustainable Initiatives (CSI) of the global platform continues to chant GHGs as holy mantras without taking them into business rationale. However, the National and Global Standards are forging the Environmental issues into the production line of cement with requirements for State of the technologies, clean fuel and better monitoring and operation protocols. Cement Industries should appreciate the need and challenges for clean technologies and work beyond the mandate mechanisms to have low carbon development to sustain its unprecedented growth, now in India.