India can certainly adopt the 'polluter pays' principle
What are the challenges you face in the use of alternative fuels and raw materials (AFR)? Also what were the challenges faced in terms of cost-investment and operational?
AFR utilisation in the Indian cement industry is a need of the hour. Our country is generating large quantum of industrial, municipal and agricultural wastes which are posing huge environmental concerns today. Cement kilns due to their unique feature of having high temperatures up to 2,000oC and long residence times in the range of 6-10 seconds above 1,100oC, can co-process these wastes as AFRs in an environmentally sound manner.
The New Waste Management Rules notified in 2016 have given preferred technology status to the technology of co-processing in cement kilns and waste generators have been mandated to evaluate and implement the option of co-processing for their wastes before deciding to send them for landfill and incineration options. As per the new Rules State Pollution Control Boards (SPCBs) are required to authorise co-processing of all kinds of hazardous and non-hazardous waste streams without mandating co-processing trial of these waste streams. Only condition is that the cement plants should have appropriate facilities to handle these wastes in an environmentally sound manner and should comply to the emission standards that are notified by MoEFCC for cement kilns undertaking co-processing.
These rules have also mandated that Central Pollution Control Board (CPCB) must publish appropriate guidelines for environmentally sound pre-processing and co-processing of wastes.
As these guidelines are not yet published by CPCB, SPCBs are posing difficulty in granting following authorisations:
1.To waste generators to implement co-processing of their wastes.
2.To pre-processing facilities to pre-process different kinds of wastes into processed AFRs.
3.To cement kilns for implementing co-processing.
Several applications of waste generators, pre-processors and cement plants are therefore pending for action in different SPCB offices. This is leading to a large quantum of waste still getting disposed in landfills and incinerators without recovering the resource value present them. As these authorisations are still pending for action, the development of pre-processing facilities for converting wastes to AFRS and the implementation of co-processing facilities for utilising these AFRs are not still taking place.
This delay in action is impacting the management of Segregated Combustible Fractions (SCF) from the Municipal Solid Waste and hazardous wastes substantially. Large quantum of SCF and hazardous waste is still getting disposed in the landfills or incineration facilities rather than getting them utilised as a resource. Due to difficulties prevailing in the regulatory processes, the investments in pre-processing and co-processing also are yet not flowing in at the pace that is feasible. Only companies with commitment to the sustainability goals are currently implementing the desired investments.
In terms of operation of these facilities, almost all the agencies in our country associated with pre-processing and co-processing are going through the learning curve. The capacity building of the skilled personnel for these operations are required to be implemented on the job as these are not a part of any curriculum yet.
How do you define the extent of AFR use in the cement industry? By this yardstick, where do you stand as a company and your targets for 2020?
AFR utilisation in cement kiln is defined conventionally in terms of Thermal Substitution Rate (TSR), which is the ratio of the energy utilised from AFR to the total energy used in the cement kiln. This parameter defines the quantum of fossil fuel substituted with AFR in the kiln. The other parameter is the extent of replacement of natural raw material with alternative raw materials.
The utilisation of AFR in our country in year 2016 is >4 per cent. With so much waste still around for tapping the resource value present in it, there is large opportunity to increase the AFR consumption of our country. Based on the low technology road map prepared for the Indian cement industry, the forecast on the waste becoming available to use, the expected ease in permitting processes and the infrastructure that will be created to pre-process and co-process wastes as AFRs, it is expected that Indian cement industry can target and achieve a TSR of about 25 per cent in 2025 - the '25-25 GOAL' of the Indian cement industry. The required skilled man-power also is an essential requirement for successful implementation of this goal and it is expected that a clear focus that this initiative will receive in future will drive academic institutions and professional agencies to built suitable manpower development programs for the same.
What is the scope of AFR and what are the steps initiated by your company?
As elaborated above, the scope for co-processing wastes as AFRs in the cement industry in our country is very large. With a clear commitment to the causes of environmental betterment, climate change mitigation, resource conservation, and sustainability targets, we are implementing several activities related to use of wastes as AFRs in our kilns of ACC Limited and Ambuja Cement Ltd., through our Geocycle India initiatives.
The most important activity that we have implemented in the recent past was to achieve proper recognition of co-processing option in our Waste Management Policy Framework. It is very important to note that our country's new policy framework of 2016 for waste management is based on the principle of sustainability rather than the principle of disposal in which co-processing option has been granted higher preference of implementation than landfill and incineration.
The other important initiative of ours was the implementation of large number of co-processing trials - more than 60 - in our different cement kilns spread across the country. These trials were carried out to demonstrate the suitability of co-processing technology for environmentally sound management of different kinds of waste streams. These waste streams were both hazardous and non-hazardous and were having substantially varying waste characteristics from one another. The results of all these trials, which were evaluated by CPCB demonstrated that cement kiln co-processing of these wastes does not influence the cement kiln emissions and the cement product quality.
We also designed and proposed the business model for undertaking co-processing of non-recyclable wastes derived from industrial, agricultural and municipal activities to the National Task Force on co-processing that was constituted by CPCB. This was substantially deliberated and the same was accepted as sustainable.
We have also set up state of co-processing facilities with Continuous Emission Monitoring Systems in all our cement plants and also set up seven pre-processing platforms in our different plants that meet the stringent requirements for environmentally sound management of hazardous and other wastes. These platforms have AFR laboratories, pre-processing facilities, adequate storage with impervious floor and leachate collection and management system, fire control and fire water management systems, trained personnel in the area of waste management and pre and co-processing, These platforms have the capability of processing different kinds of hazardous and non-hazardous wastes having varying physico-chemical characteristics into a uniform quality AFR for utilising as a resource in our cement kilns.
Do you think that India can adopt the principle of 'polluter pays first', especially when it comes to waste generation?
India can certainly adopt the polluter pays principle. For this proper policy framework needs to be put in place. This involves levying prohibitive tax on the options of waste management that are not environmentally acceptable. Further, the policy framework also needs to encourage environmentally sound options by either mandating them as the first priority as only acceptable options for waste management or by giving suitable fiscal or other incentives to the implementing agencies.
With regard to hazardous material used, what are the challenges in terms of safety?
As per the definition given in HOWM Rules 2016, 'hazardous waste' means any waste which by reason of characteristics such as physical, chemical, biological, reactive, toxic, flammable, explosive or corrosive, causes danger or is likely to cause danger to health or environment, whether alone or in contact with other wastes or substances.
While handling these wastes - particularly in cement plants - proper care needs to be taken by implementing adequate processes, systems and infrastructure that ensures required level of safety in operation. The design and implementation of these processes, systems and infrastructure needs to be complying to the specifications provided by CPCB. While handling these wastes, care needs to be taken to ensure that the incompatible wastes are not mixed, waste for which the designed infrastructure is not designed should not be used, man power with proper skills and capabilities are trained and engaged in the operational activity, Proper Disaster Management measures are designed, implemented and kept up-to-date to deal with likely emergencies, etc.
What kind of legislation is there in developed countries for the industry to make long term investments to reach very high levels of TSR like 60-80 per cent? What is the Indian scenario?
The legislation in the countries that have cement plants operating at a TSR lever of 60-80 per cent is similar to the one that we have put in place in our country now. The major difference is that their legislation is mature and has additional provisions that facilitate clarity and ease in permitting. Hence the implementation is at a very high level. Their legislation framework has also higher clarity in terms of the dos and don'ts and its awareness and understanding is substantially high in the stakeholder segment. Further, the waste availability, its quality considerations and transportability are substantially better due to maturity in waste market.
There are pre-processing operators who convert wastes into AFRs having desired quality, etc. The stakeholder segment also is highly mature and the other disposal options are more expensive which directs the waste for co-processing.