Hazardous Waste Minimization : Recycle and Reuse

Dr. Rakesh Kumar

Paradigm Shift in Business Scenario

• Competition is Global• Competencies are Global• Technology and Finance will

become lesser Issues• Speed gives competitive

advantage• Global Outsourcing

Business Scenario

• Fast changes in structures• Management Technology is

within the reach of every one• Knowledge improvements are

high• Intelligent Work Force• Growing Customer

Expectations• Brands disappearing

Changing Business Scenario

• Env. Aspect: element of an organization’s activities, products or services that can interact with the environment

• Env. Impact: any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products or services

Polluter Pays Principle

Precautionary Principle

THE HAZARDOUS WASTES : (MANAGEMENT AND HANDLING) RULES, 1989, (as amended, May, 2003)

 (14) “hazardous waste” means any waste which by reason of any of its physical, chemical, reactive, toxic, flammable, explosive or corrosive characteristics causes danger or is likely to cause danger to health or environment, whether alone or when in contact with other wastes or substances, and shall include-

(a)        wastes listed in column (3) of Schedule-1;

(b) wastes having constituents listed in Schedule-2 if their concentration is equal to or more than the limit indicated in the said Schedule; and

(c) wastes listed in Lists ‘A’ and ‘B’ of Schedule-3 (Part-A) applicable only in case(s) of import or export of hazardous wastes in accordance with rules 12, 13 and 14 if they possess any of the hazardous characteristics listed in Part-B of Schedule 3.

Explanation: For the purposes of this clause, -

(i) all wastes mentioned in column (3) of Schedule-1 are hazardous wastes irrespective of concentration limits given in Schedule-2 except as otherwise indicated and Schedule-2 shall be applicable only for wastes or waste constituents not covered under column (3) of Schedule-1;

(ii) Schedule-3 shall be applicable only in case(s) of import or export;

IN THE SUPREME COURT OF INDIA CIVIL ORIGINAL JURISDICTION

WRIT PETITION NO. 657 OF 1995

 Research Foundation for Science Appellant (s)Technology National Resource Policy

Versus

Union of India & Anr. Respondent (s)

 (With SLP (C) No. 16175/1997 & C.A. No. 7660/1997)

ORDER

October 14, 2003

70.13. (13) RE: National Policy Document on Hazardous Wastes:-

MoEF is directed to either itself or through the CPCB or any other agency draft a policy document on hazardous waste generation and its handling within the country. While examining this aspect the following recommendations of the HPC would be kept in view:

“The policy document should emphasise a commitment to the recycling of wastes an materials, and propose incentives for encouraging and supporting recycling. Industries must be given a clear message that they must show concrete and tangible results as far as prevention and reduction of wastes are concerned. If they do not, they should be made to pay a waste generation tax. The policy document should enunciate a doctrine of partnership between SPCBs, entrepreneur and other stakeholder like the community, which will involve working together on monitoring, preventing and reducing hazardous waste generation. The policy should review further growth of non-ferrous metallic waste, waste oil and used lead acid battery recycling in the SSI sector.”

What is Hazardous Waste?

• Anything that contains some inherent property that renders it dangerous

• Commonly:

– Toxic

– Corrosive (pH under 2.5, and over 12.5)

– Ignitable (flash point <100F)

– Listed by As Hazardous

Raw Materials & Labour

Energy

Industrial Process

Products

Money

Waste heat

Waste water Water

Business Definition of Waste

“Anything other than the minimum amount of materials, parts, space, equipment and worker’s time which are absolutely essential to add value to the product.”

Changing Scenario

Raw Materials

Energy

Water

Industry

Products

Beneficiation Plant

Market

Waste WaterMoney

Waste Heat

Waste Minimization

Improved business practices, procedures, and processes which increase the probability of survival and reduce any type of waste.

“By Any Other Name...”

• Pollution Prevention

• Waste Reduction

• Cleaner Production

• Source Reduction

Tools

Environmental Planning

Environmental Management System

Environmental Audits

Environmental Audit

A systematic, documented verification process of objectively obtaining and evaluating evidence to determine whether specified environmental activities, events, conditions, management systems, or information about these matters, conform with audit criteria, and communicating the results of this process to the client.

Types of Environmental Audits

• Compliance Audits• Environmental Management Audits• Due Diligence Audits• Supplier audits (such as waste contractors)• Programme Audits (such as waste

minimization or energy)• Single Issue Audits (such as noise or waste

management)• Risk Audit

Compliance Audits

• Verifying compliance with:

– Applicable Regulations

– Standards & Guidelines

– Corporate Policy and Objectives

– Control and Monitoring Procedures

• useful precursor for full environmental audits

Due Diligence Audits

• Typically carried out for prospective buyer or seller of industrial land (particularly mergers, acquisitions and divestitures)

• Liabilities discovered by audit can:– reduce properly value– lead to exclusions– cancel deal

• Auditors task is to uncover bad practice or discover environmentally damaged areas

Supplier Audits

• Reviews environmental practices and permits

• Confirms that suppliers conform to customers requirements

• Ensures that suppliers maintain records and may lead to the adoption of controls which would not ordinarily be implemented

Programme Audits

• Systematic review of progress and achievements

• An audit of a waste minimization programme would:– examine waste generated by a site

Programme Audits Cont...

– identify viable actions for reuse, recycle, or reductions

– make recommendations for prioritized programme

• Return audits would confirm whether objectives and targets were achieved

Single Issue Audits

• Detailed examination of a particular issue

• A noise emissions audit could

– identify all noise sources– establish whether emissions were in breach of

law

Waste Reduction Audits:

• Question: How can waste be minimized?

• Steps in a waste reduction audit:

– First: Target individual processes

– Second: Analyze processes

– Third: Identify reduction alternatives

– Fourth: Consider the cost/benefit ratio for each alternative

– Fifth: Select the best options

Establish Audit Team

• Team Leader: Highest Level Possible Broad-based Support

• Champion: Visible within Prod. Area Respected and Trusted

• Team: Technical/Business Expertise

Environmental Manager Process Engineer Production Supervisor Line Workers Purchasing & Accounting Quality Control Health & Safety R&D Legal Outside Assistance

Collect Pre-Assessment Information

• Process Flow & Equipment Layout• Production Information• Information on Raw Materials & Quantity• Environmental & Regulatory Information• Wastes & Costs

– Full or Life-cycle Cost• Handling Disposal• Liability Treatment• Lost Raw Materials

Process Analysis• Create a simple diagram of the process by

talking to process engineers

• Follow the process from beginning to end

• For each unit operation, identify material inputs, products, and waste products; procedures; schedules; policies; etc.

• Obtain quantitative info on materials and costs

• Talk to operators: ask questions; explore their ideas for ways to do it differently

• Ask why? why? why? why? why?

Plant Tour

• Monitor Operations• Interview Operators and Supervisors• Document Findings with Notes,

Drawings, and Photos• Observe Housekeeping• Assess Organizational Structure and

Coordination• Assess Administrative Controls

Develop Process Flow Diagram

• Show Manufacturing Processes

• Show Order & Relationship of Steps

• Show Raw Materials & Quantities

• Show Wastes & Quantities

Brainstorm Waste Reduction Options

• Team Process• Collect All Ideas Without Criticism• Use All Resources

– Employees– Trade Associations– Vendors– Publications & Trade Journals– Technical Assistance Programs– Consultants

Waste Minimization Techniques

Good OperatingPractices

TechnologyChanges

InputMaterialChanges

Use &Reuse

Reclamation

RecyclingOn-site/Off-siteSource Reduction

ProductChanges

SourceControl

Source Reduction

Inventory Control

EmployeeTraining

Spill Control

SegregatingWaste Streams

EfficientProduction Scheduling

Good Oper.Practices

Input Mat’lSubstitutions

ProductChanges

TechnologyChanges

ProcessChanges

EquipmentChanges

Evaluate Each Stream for:

Substitution of non toxic materials Substitution of less toxic materials Reformulation to eliminate toxics Modification of production process Changes in material usage

inventory control preventive maintenance program

Source Reduction - PurchasingLimit the amount you order.Do not stockpile chemicals.Rotate stocks to use chemicals before shelf-life expires.Keep up-to-date inventories and avoid ordering chemicals.

Waste Minimization

Source Reduction - PurchasingDo not accept excess chemicals or “free” chemicals.

Investigate use of pre-weighed packages from chemical vendors.

Waste Minimization

ReclaimationIf waste contains precious metals waste stream may be a valuable byproduct. i.e. Silver recovery systems. Consider installation of reclaimer.

Waste Minimization

Waste Minimization

Mixed Wastes It is much easier to dispose of individual wastes streams.

Do not mix wastes i.e. radioactive, hazardous, nonhazardous or RMW. Do not mix halogenated with non-halogenated solvents.Do not mix solvents with aqueous waste.

Technical Feasibility Questions To Be Asked

• Is the equipment available commercially?• Are there other successful applications of this

equipment similar to yours?• Can the vendor provide referrals that you can

contact?• Will product quality be affected?• Is the problem just being shifted to another

medium or location?

Economic Feasibility Capital Costs

Purchased Equipment ______ Materials ______ Installation ______ Utility Connections ______ Engineering ______ Start-Up and Training ______ Other Capital Costs ______

Total Capital Costs ______

Incremental Annual Operating Costs Disposal Costs ______ Raw Material Costs ______ Other Costs ______

Operating Cost Savings ______

Payback Period (in years) ______ (Total Capital Costs/Annual Net Operating Cost Savings)

Include All Costs

• Waste Disposal (That’s Obvious)• Cost of Raw Material Replacement• Compliance Costs

– Permitting Record keeping– Reporting Monitoring

• Insurance• Workman’s Compensation• Potential Liability and Penalties• Less-Tangible Benefits

– Example to Industry– Employee Relations

Audit Report: Identification of types & amounts of

waste. Description of the process that

generates it. Amount of waste generated per unit of

production. Estimate of costs for managing waste. List of technically feasible measures.

Audit Report: Estimate of anticipated waste reduction

achievable using technically feasible measures.

Implementation schedule. Research & Development programs Estimate of waste transferred to other

media. Facility Waste Reduction Policies. Description of Training Program.

Life Cycle of Waste Reduction

Sustain & Expand Waste Reduction

Sustain & Expand Waste Reduction

Investigate Opportunities

Investigate Opportunities

Identify Options:

Identify Options:

Assess Options::

Assess Options::

Implement Options:

Implement Options:

Remember

Try your best to integrate environment into business practices

Resource efficiency is the route and not goal for environmental compliance