terms of referanceenvironmentclearance.nic.in/writereaddata/online/tor/0_0...a-166 & f-162-165,...

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


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


(O) CAUSTIC TANK - Provided 500 Ltr with fitting

(P) PACKED BED SCRUBBER

Quantity - 1 No.

MOC - Mild Steel


Baffle - Fitted

Water Re-Circulation Pump - 3 HP

(Q) MIST ELIMINATOR

Quantity - 1 No.

MOC - Mild Steel/ 5 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 housekeeping

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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terms of referanceenvironmentclearance.nic.in/writereaddata/online/tor/0_0...a-166 & f-162-165,...

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