green chemistry module i

7/29/2019 Green Chemistry Module i

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WWF-India

Secretariat172-B Lodhi Estate

New Delhi-110 003Tel: +91 11 41504770Website: www.wwfindia.org

under HSBC Climate Partnersh

Green Chemistry

Series

Module 1 : Solid Waste

Management & Handlin

Organised by

WWF-India's

Written & Compiled by:

Dr. Alka Tangri & Dr. Subhash Awasthi

Designedby:Mr.AshishRohilla


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1.0 Introduction

2.0 Current Legal Status: Dumping of Hazardous Waste (CPCB's Gu

3.0 Operations at Treatment, Storage and Disposal Facility (TSDF)

4.0 Incineration

5.0 Leachate Treatment and Disposal

2.1 Introduction

2.2 Definition(s) of Hazardous Waste

2.3 Characteristics of Hazardous Waste

2.3.1 Corrosivity

2.3.2 Reactivity2.3.3 Ignitability

2.3.4 Toxicity

2.3.5 Acute Toxicity

2.3.6 Infectious Property

3.1 Introduction

3.2 Responsibilities of Hazardous Waste Generator

3.2.1 Collection and Transportation of Hazardous Wast

3.2.2 Test Report and Information

3.3 Responsibilities of the Hazardous Waste Transporter

3.4 Responsibilities of the Operator of TSDF

3.5 Waste Disposal into a Landfill

3.5.1 Operations at a TSDF

3.5.2 Waste TSD Options3.5.3 Pathway of Waste Accepted for Direct Disposal

3.5.4 Comprehensive Analysis for Waste Acceptance fo

3.6 Pathways for not Accepted Hazardous Wastes for Direct Dispo

3.6.1 Waste Treatment / Stability

3.6.2 Identification Parameters for Waste Treatment / St

3.6.3 Analysis Protocol to Confirm Treatment / Stabiliz

3.7 Waste Storage

3.8 Acceptance/Rejection of Waste Consignments for Storage

4.1 Introduction

4.2 Incinerable Waste

4.3 Guidelines for Incineration

CONTENTS

Green Chemistry SeriesModule I: Solid Waste

Management and Handling

Conceptualized by:

Ms. Arundhati Das

Dr. Anjana Pant

Edited by:

Mr. Anshuman Atroley

Published 2011


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6.0 Banthar Leather Technology Park's Secured Landfill Project 19

6.1 Industrial areas of Unnao

6.1.1 UPSIDC Industrial Area, Unnao

6.1.2 UPSIDC Leather Technology Park Banthar, Unnao

6.2 Background

6.2.1 Hazardous Waste from Tanneries

6.2.2 Current Situation

6.3 Hazardous Solid Waste Disposal/Storage arrangements of Leather

Industries of Unnao

6.4 Other Techno-commercial study issues of the project when it was

submitted as DPR in the ministry of Commerce & Industry,

Government of India

6.4.1 Common Hazardous Waste Disposal Project component

proposed under IIUS and cost estimates

6.4.2 Proposed Means of Finance

6.4.3 Sustainability of Project Components

6.5 Common Hazardous Waste Disposal Facility

6.5.1 Component Description - Summary

6.5.2 Component Analysis - Technical

6.6 Project Cost Estimates

6.7 Means of Finance

6.8 Details of Development of CHWDF

6.8.1 Development of CHWDF for hazardous waste industries

of Banthar and Unnao

6.8.2 Inventorization and characterization of HW

6.8.3 Layout of CHWDF

6.8.4 Detailed Design and Engineering of CHWDF

6.8.5 Detailed Capital and Operating Cost Estimates

6.8.6 Financial Implications

6.8.7 Expected life of Landfill

6.8.8 Design Decision

6.8.9 Revenue Model

6.8.10 Implementation Framework

6.8.11 Financial Analysis

6.9 Project Risks

Table 2.3.4. Toxici ty Char acter is ti cs L each ing Procedure (TCLP) Test

Table 3.6.3 Analysis Protocol for Treatment/Stability of Waste

Table 6.4.1 Proposed project component and cost estimates

Table 6.4.2 Proposed Means of Finance

Table 6.4.3 Proposed User Charges for different project components

Table 6.5.2 Typical Characteristic of CETP sludge from tannery

Table 6.5.3 Quantum of Hazardous Waste generated at LTP Banthar-U

Table 6.5.4 Characteristics of Hazardous Waste generated at Kanpur-U

Table 6.5.5 Design Criterion for CHWDF

Table 6.6 Cost Estimates for CHWDF in Rs Million

Table 6.7 Means of Finance for CHWDF

Table 6.8.2 (a) A break-up of other HW

Table 6.8.2 (b) Characterization of HW

Table 6.8.6 (a) Financial Cost of the Project

Table 6.8.6 (b) Broad break-up of cost of construction

Table 6.8.7 Expected life of a Landfill

Table 6.8.11 (a) List of Key Assumptions

Table 6.8.11 (b) Impact of Disposal Charges on Project Financials

Table 6.8.11 (c) Profit & Loss Statement for CHWDF

Figure 1 The typical cross-section of the foundation

Figure 2 The typical cross-section of the liner system

Fig 6.8.5. Suggested Project Implementation Plan for industries

Annexure I Comprehensive Analysis Requirement for Hazardous

Wastes-Generator/TSDF Operator

Annexure II Fingerprint Analysis Requirement for Hazardous

Wastes-TSD Facilities

Annexure III Concentration Limit /Criteria for Acceptance of Hazardou

Wastes for Direct Disposal to Secured Landfill

Annexure IV Emission Standards for Common Hazardous Waste Incine

List of Figures

List of Annexures

List of Tables


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BDAT Best D emonstrated Available Technology

BOT Build Operate Transfer

CAGR Compounded Annual Growth Rate

CETP Common Effluent Treatment Plant

CHWDF Common Hazardous Waste Disposal Facil ity

CLRI Central Leather Research Institute

CPCB Central Pollution Control Board

CRHSMC Common Raw-Hide Storage and Management CenterCRU Chrome Recovery Unit

DoIP P Depar tment of I ndus tri al Po li cy & P romotion

DRANCO Dry Anaer ob ic Compos ting P rocess

DSCR Debt Service Coverage Ratio

DSRA Debt Service Reserve Account

ETP Effluent Treatment Plant

FY Financial Year

GDP Gross Domestic Product

GoI Government of India

GoUP Government of Uttar Pradesh

HAZWAMS Hazardous Waste Management Series

HW Hazardous Waste

IISTEM International Institute of Saddlery and Export Management

IIT-K Indian In stit ute of Technology Kanp ur IIUS Industrial I nfrastruct ure U pgradatio n Scheme

IL &FS I nfr as tr ucture Leas ing & Financ ia l Se rv ice s

IDC Infrastructure Development Corporation

IRR Internal Rate of Return

KL Kilolitre

Km Kilometer

LTP Leather Technology Park

M Meter

MLD Million litre per day

Mn Million

MoC&I Mini stry of Commerce & Industries

MoEF Ministry of Environment & Forest

MT Metric Ton

NH National Highway

NPV Net Present Value

OPEX Operation and Maintenance Expendit ure

PAT Profits After Tax

PBDI T Profi ts Be fore Depreciat ion I ntere st and Tax

PBT Profits Before Tax

PCC Pollution Control Committee

PWD Public Works Department

RCC Reinforced Cement Concrete

SLF Secured Landfill Facility

SME Small & Medium Enterprises

SOR Schedule of Rates

SPCB State Pollution Control Board

SPV Special Purpose Vehicle

STP Sewerage Treatment Plant

T CL P Toxici ty Cha racteri st ic s L each ing Pr ocedur e

TREM Transport Emergency

TSDF Treatment, Storage and Disposal Faci lity

UPL IA Uttar Pr adesh L eather Indust ri es As sociat ion

UPP CB Uttar Pr adesh P ol lu tion Cont ro l Boa rd

UPSIDC Uttar Pradesh State Industrial Development Corporat

USE PA Uni ted States Envi ronment Pro tect ion Act

List of Abbreviations


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important to build capacities within the industry to implement and mainstrview to do this WWF-Indias Living Ganga Programme team set up a stakeindustry leaders, Banthar Industrial Pollution Control Company, Pro IEnvironment Management, Central Leather Research Institute and Urban L

In one of our initial interactions with the leading Tannery units from Unnao /Banthar Industrial Pollution Control Company held on June 10, 2010, a needEnvironmental Managers in tannery units both existing and potential wawaste management, bio/phyto-remediation and cleaner tanning technologiissues, WWF-India through its Living Ganga Programme is organizing a tChemistry Series for the current and potential workforce of the leather in

first step towards it.

Living Ganga Programme under HSBC Climate Partnership aims to develofor sustainable energy and water resource management within the Ganga change. Specifically, the programme works on key sites and a criticapproximately 800 kilometers from Gangotri in Uttarakhand to Kanpprogramme brings together components of climate adaptation coupled withmanagement of water flow and energy. The programme aims to estabstakeholders with a focus on river restoration, community education and government involvement and biodiversity conservation. The programme cocomponents viz: Sustainable Water management, Climate Adaptation, PoEnergy Co-management, Sustainable Hydropower, Biodiversity Conservand Business Engagement.

1.1 Background

Tanning is an ancient craft in India practiced for many centuries as an industrial operation at the communitylevel which has today acquired the status of a mature industry playing and important role in the country'seconomy. The Indian leather industry is one of the most vibrant sectors of the country's economy. Wellrecognized in the international market, the Indian leather goods constitute about 7 per cent of India's exportearning. Besides being a significant earner of foreign exchange, the leather industry generates employment,ensuring jobs for over 2.5 million people. India, with an output of Rs.186.56 billion (3.354 billion Euros) andexports of Rs.125.46 billion (2.225 billion Euros), is placed third, while developed markets such as the US aremajor consumers of leather products. It is now poised for a big leap to double its global share from the present3%. The industry covers a vast spectrum of inputs, activities, skills and products i.e. livestock, hides and skins,tanning, leather products and exports. The Indian leather industry is growing by leaps and bounds apparentlybecause leather wear still enjoys a great demand abroad and now-a-days even the domestic market is developingand consuming the offering of this industry.

Although the tanning industry has been in existence for long, the problem of environmental pollution hasreceived attention only in the recent years. The considerable damage caused to water bodies particularly theGanges in Kanpur and Unnao due to the considerable odour and dyes and other chemicals like chromiumcompounds used in the tanning process complicates the wastewater treatment operation. Besides substantialimpairment of the quality of t he nearby surface waters, there is an enrichment of the hazardous substance in thesoil and possibly also in the groundwater as shown by some studies. This necessitates measures regardingdisposal and treatment of industrial wastes. The development of the tanning industry and attempt to manageindustrial waste should go hand in hand for maintaining proper ecological balance and to ensure unpollutedwater courses. There are various solid, semi-solid wastes likeEffluent treatment plants waste, fleshings, chromeshavings, buffing dust, leather cuttings and empty containers which are still posing problems for safe reuse ordisposal.

1.2 The Need

We all know that the generation of solid waste is inherent to manufacture of leather from skin and hide. Solidwastes generated at various unit operations of the tanning process considerably vary in quantity andcomposition. For instance,fleshings are animal tissue waste generated during the preparatory leather processingstage in relatively larger quantities as compared to ot her types of solid waste in t he tanning industry.Fleshingmainly contains fat and protein and residual chemicals such as lime and sulphide used in the 'unhairing' processof beam house operation. Another type of solid waste in tanning industry which requires safe disposal is theprimary sludge from tannery wastewater treatment plant. Industrial processes generate waste varying incomposition and quantity at various stages, and disposal of such waste has become more and more difficult,particularly in view of stringent environmental pollution control standards stipulated by statutory authorities.

There are better management practices available within the industry both nationally and globally. CentralLeather Research Institute (CLRI) has also done various research studies and published papers on Solid WasteManagement. While it is important to demonstrate the impact of these b est management practices in the industryset up which is usually done by scientific research organizations and some leading industries, it is equally

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1.0 Introduction


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b) Wastes, which consist wholly or partly of substances indicated in Scconcentration of the substances is equal to or more than the lischedule, and

c) Wastes indicated in Lists A and B of Schedule-3 (Part-A) applicableexport of hazardous wastes in accordance with Rules 12, 13 and 1hazardous characteristics listed in Part (B) of the Schedule.

Explanation: For the purpose of the clau se: i) all wastes mentioned in cohazardous wastes irrespective of concentration limits given in Schedindicated and Schedule 2 shall be applicable only for wastes or waste

under column (3) of Schedule 1. ii). Schedule 3 shall be applicable onexport.

Definition of hazardous wastes its applicability

From the viewpoint of application of the HW (M&H) Rules, waste can be cla

Waste substance is solid, semi-solid or non-aqueous liquid which concentration or characteristics in terms of physical, chemical, infectious qu

(a) can cause or significantly contribute to an increase in mortalityirreversible or incapacitate reversible illness, or

(b) pose a substantial present or potential hazard to human health or improperly treated, stored, transported, disposed of or otherwise ma

Thus, a waste is hazardous if it exhibits whether alone or when in cosubstances, any of the characteristics identified below:

CorrosivityReactivityIgnitabilityToxicityAcute toxicityInfectious property

2.3 Characteristics of Hazardous Waste

2.3.1 CorrosivityA waste exhibits the characteristics of corrosivity if a representativeither of the following properties:

(a) any liquid which has a pH less than or equal to 2 or greater than or eqthe standard test procedure; or

(b) a waste, which can corrode steel at a rate greater than 6.35 mm per

55 C as determined by the standard test procedure.

2.1 Introduction

Hazardous waste generated due to industrial and other activities are required to be properly disposed of, in casethe same cannot be recycled or reused. The facility for hazardous waste disposal may comprise secured landfillwith or without treatment facility or may be integrated one having incineration facility as well. Disposal ofhazardous wastes has to be done in a manner that does not pollute air, water & soil and does not cause any harmto human beings and habitat in the surroundings, during operative period and also after closure. The States ofUttar Pradesh, Andhra Pradesh, Maharashtra and Gujarat have promoted development of common facility in theprivate sector, for management of hazardous wastes in an environmentally sound and techno-economically

viable manner. The services of treatment, storage and disposal facility (TSDF) are particularly useful for thehazardous waste generating units not only in the large category of industries but also for small and mediumenterprises (SMEs), who on their own may not afford and are unable to provide on-site facility for properdisposal of hazardous wastes.

Where the hazardous waste comes from similar type of cluster of industries and also the waste is conditionedand does not need any treatment then treatment part is ignored and only Secured Landfill Facility (SLF) wouldbe sufficient and in this case TSDF may be regarded as SLF. In the same manner first time in Uttar Pradesh a SLFis developed by a SPV of Industries at Leather Technology Park Banthar which is receiving only ETP wastefrom various cluster of leather processing industries. M/s Industrial Infrastructure Services (India) Ltd. is theSPV which developed and operating this facility un der GOI assistance under IIUS scheme through Departmentof Industrial Policy & Promotion (DoIPP). This project is operational since October 2008 and serving at presentabout 50 tanneries and their two CETPs.The CPCB guidelines aim at establishing the standards, which define the requirements for management ofhazardous wastes (HW) at TSDF operating in the State. These guidelines shall apply to the generators of HWand the operators of the TSDF facilities.

Following aspects have been illustrated in this document:

Definition of hazardous wastes for TSDFMethodology for classification, identification and characterization of hazardous wastesOperating procedures for TSDFRequirements for handling, collection and transportation of hazardous wastesApplicable standards for compliance of regulationsAdditional information on regulatory requirements for managing hazardous wastes

2.2 Definition(s) of Hazardous waste

Regulatory definition of hazardous wastes as given i n the Hazardous Wastes (Management & Handling) Rules,1989, and further amendments made there under, is reproduced below:

Hazardous WastesHazardous wastes (HW) have been defined to include:

a) Wastes, which are generated in the process, indicated in Column-2 of Schedule -1 and consist of wholly

or partly of the waste substances, referred to in Column-3 of the same schedule

2.0 Current Legal Status: Dumping of Hazardous Waste(Cental Pollution Control Board's Guidelines)


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2.3.2 Reactivity

A waste exhibits the characteristics of reactivity if a representative sample of the waste has any of the followingproperties:

(a) It is normally unstable and readily undergoes violent change without detonating

(b) It reacts violently with water

(c) It forms potentially explosive mixture with water

(d) It is Cyanide or Sulfide bearing waste which when exposed to pH conditions between 2 and 12.5 cangenerate toxic gases, vapours or fumes in a quantity sufficient to pose danger to human health or theenvironment.

(e) It is an explosive.

2.3.3 Ignitability

A waste exhibits the characteristics of ignitability if a representative sample of the waste has any of thefollowing properties:

(a) It is a liquid other than an aqueous solution containing less than 24% organic solvents by volume and hasflash point less than 60 C as determined by a Pensky Martins closed cup t ester using the standard testmethod.

(b) It is not a liquid and is capable, under standard temperature and pressure, of causing fire throughfriction, absorption of moisture or spontaneous chemical changes, and when ignited burns sovigorously and persistently that it creates a hazard.

(c) any oxidizing substance, when in contact with moisture or other materials/wastes, results inspontaneous fire or combustion.

2.3.4 Toxicity

A solid waste exhibits the characteristics of toxicity if the leachate from the representative sample by ToxicityCharacteristics Leaching Procedure (TCLP) test method (as followed by USEPA, vide No: S.W 846, t ill Indianstandards are notified by MoEF / CPCB) contains any of the contaminants listed in Table 2.3.4 below in excessof the concentration limits mentioned thereupon.

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S.No Contaminant

01. Arsenic

02. Barium

03. Benzene

04. Cadmium

05. Carbon tetra chloride

06. Chlordane

07. Chlorobenzene

08. Chromium

10. o-Cresol

11. m-Cresol

12. p-Cresol

13. Cresol

14. 2,4-D

15. 1,4-Dichlorobenzene

16. 1,2-Dichloroethane

17. 2,4-Dinitrotoluene

19. Endrin

20. Heptachlor (and its epaoxide)

21. Hexachlorobenzene

22. Hexachlorobutadiene

23. Hexachloroethane

24. Lead

25. Lindane26. Mercury

27. Methoxychlor

28. Methyl ethyl ketone

29. Nitrobenzene

30. Pentachlorophenol

31. Pyridine

32. Selenium

33. Silver

34. Tetrachloroethylene

35. Toxaphene

36. Trichloroethylene

37. 2,4,5-Trichlorophenol

38. 2,4,6-Trichlorophenol

39. 2,4,5-TP (Silvex)

40. Vinyl Chloride

Table 2.3.4. Toxicity Characteristics Leaching Procedure (TCLP) Test Lim


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*Note :1 These limits shall be applicable till the notification of leachate standards (including test method) under

the E (P) Act, 19862. Best Demonstrated Available Technology (BDAT) standards shall be employed for parameters not

mentioned.3. Leachate collected shall be treated and disposed as liquid effluent in compliance of the standards

notified under the E (P) Act, 1986.

2.3.5. Acute Toxicity

A waste exhibits the characteristics of being acutely hazardous if a representative sample contains any of the

following:

(a) wastes generated in the manufacturing process of halogenated phenols and other halogenatedcompounds

(b) wastes generated in the manufacturing/formulating process of pesticides or pesticide derivatives

(c) wastes generated during the manufacturing process of halogenated benzene under alkaline conditions

(d) off-specification or discarded products generated from the above processes, and

(e) containers used for handling hazardous / toxic substances / wastes

2.3.6 Infectious Property

Wastes containing viable micro-organisms or their toxins which are known or suspected to cause disease inanimal or humans fall under this category.

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3.1 Introduction

All operations involving treatment, storage and disposal shall comply withissued by CPCB/MoEF as may be adopted by the SPCB/PCC and stipulateRule 5 of the Hazardous Wastes (Management & Handling) Rules, 1989,should ensure that the wastes from the generators are accepted at the famanifest notified under the said rules. Additional requirements regardiprocedures at TSDF are outlined in this section so as to help the TSDF in pro

3.2 Responsibilities of the Hazardous Waste generator

In order to optimize and facilitate proper operations at TSDF, the hazardoresponsible for managing hazardous wastes before sending to TSDF for furCertain responsibilities are listed as under:

waste minimization, re-use of wastes to the maximum extent before sendwaste characterization (Annexure I)segregation of hazardous and non-hazardous wastes to reduce the quanTSDF (referAnnexure II)proper handling of wastes at the sourcelabelling and packaging of the wastes according to procedures indi(1992) and Chapter 6 of the Motor Vehicles Act, 1988, as amended.provide information on precautions for waste handling during transportcompliance of manifest for tracking of wastes.

3.2.1 Collection and Transport of Hazardous Wastes

(a) The generator of the hazardous waste shall ensure that wastes are pafor safe handling, storage and transport. Labelling on packaging is used for packaging shall withstand physical conditions and climatic

(b) The generator shall ensure that information regarding characteristterms of being Corrosive, Reactive, Ignitable or Toxic is provided on

(c) Transport of hazardous wastes shall be in accordance with the provthe Central Government under the Motor Vehicles Act, 1988 and otime to time.

(d) All hazardous waste containers shall be provided with a general Hazardous Waste (Management & Handling) Rules, 1989, as amend

(e) Transporter shall not accept hazardous wastes from an occupier (with colour codes) of the manifest (Form 9) is provided by the genegive a copy of the manifest signed and dated to the generator an

copies to be used for further necessary action prescribed in the Haza& Handling) Rules, 1989, as under:

3.0 Operation at Treatment, Storage, and Disposal

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Copy 1 (White) : To be forwarded to the SPCB/PCC by the occupierCopy 2 (Yellow) : To be signed by the transporter and retained by the occupierCopy 3 (Pink) : To be retained by the operator of a facilityCopy 4 (Orange) : To be returned to the transporter by the operator of facility after accepting wasteCopy 5 (Green) : To be forwarded to SPCB/PCC by the operator of facility after disposal.Copy 6 (Blue) : To be returned to the occupier by the operator of the facility after treatment & disposal

of HW.

(f) The generator shall provide the transporter with relevant information in Form 10, i.e. TransportEmergency (TREM) Card regarding the hazardous nature of the wastes and measures to be taken in caseof an emergency.

3.2.2 Test Report and Information

Generators sending hazardous waste to the facility for treatment, storage or disposal are required to providenecessary test report of hazardous waste to the operator along with the information on the process(s) of itsgeneration, so as to facilitate the determination of pathway for treatment and disposal. Test report shall besubmitted to the operator along with a copy marked to the SPCB.

Based on the analysis report/waste characterization, TSDF operator shall decide the suitable pathway fortreatment/storage/disposal.

3.3 Responsibility of the Hazardous Waste Transporter

Transporter of hazardous wastes shall be responsible for:

Obtaining permission from SPCB/PCC for transport of hazardous waste [in addition to any otherpermission that may be required under the Motor Vehicles (Amendment) Act of 1988].Suitably designing the transport vehicles to handle and transport the hazardous wastes.

Maintaining the manifest system as required.Transporting the wastes in closed containers at all times.Delivering the wastes at designated points.Informing SPCB/PCC and other regulatory authorities immediately in case of spillage, leakage or otheraccidents during transportation.Cleaning up in case of contamination.

3.4Responsibilities of the Operator on TSDF (Transport, Storage & Disposal Facility)

The operator of TSDF would be responsible for:

Accepting hazardous wastes at TSDF from the generators authorized by SPCB/PCC.Establishing a system for optimal movement of hazardous wastes transportation, treatment and disposaloperations, which may include resource recovery/ recycling as the case may be.Fingerprinting analysis to confirm the wastes shall be the responsibility of the operator (Annexure II of thereport).Operating the TSDF as per conditions stipulated in the authorization.Ensuring waste treatment and/or disposal as per Hazardous Waste (Management & Handling) Rules, 1989,

as amended.

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Undertake cleanup operation in case of contamination resulting from TSDPollution and the odour arising out of TSDF operations and subsequent abCompliance of regulations concerning occupational safety and health of T

3.5 Waste Disposal into a Landfill

Landfills shall have to be designed and constructed as a secured facility to cleachate generated during the process. To meet these requirements, the baslandfill shall have to be designed and constructed as per the guidelines of MoEup of Operating Facility- Hazardous Waste Management, HAZWAMS/11/9Waste Landfills, HAZWAMS/17/2000-01), and the conditions stipulated by S

operate TSDF while granting consent to establish. Prior to the placement of wthe surface shall be placed after completion of work daily so as to minimize the

The base liner and capping shall be a composite system comprising commembrane as may be approved by the SPCB/PCC. A leachate collection drainbase of the landfill, immediately above the liner to ensure that the head of during any season of the year.

The following objectives have to be considered i n the design of an engineered l

Minimization of the possibility of contamination of surface and / or grounControl over gaseous emissions, if any.Prevention and control of any other possible adverse impact(s) on the enviUtilization of excavated soil as cover material.Harvest of upstream rainwater flowing into the land fill.Preferred use of clay which is well-graded having at least 30% passinplasticity index between 10-30. Clay fraction shall be kept at greater thfraction shall be < 50% of clay lining.

Clay having clod size less than 50 mm should be compacted to optimum mroller.

Placement of wastes into a landfill would have to be done jud iciously as it maactive life of the waste in the landfill. Therefore, waste disposal into the concentration limits/criteria for acceptance of hazardous waste in landfill as pthe restrictions for waste placement into landfill stipulated by the SPCB/PCC.

Placing bulk, containerized, or non-containerized liquid hazardous wastes conot adsorbents have been added) in any landfill shall be prohibited by SPCB/P

3.5.1 Operations at a TSDF (Transport, Storage and Disposal Facility)

Suggested sequence of the operations at TSDF is presented below:

Operator from the generator shall receive a comprehensive report on analyThe operator of TSDF shall examine the report and plan pathway for wasteUpon confirmation of the same by the operator of TSDF to the generator, t

TSDF accompanied by transport manifest.


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Upon receipt at the facility, the wastes shall be weighed and properly logged.Waste shall then undergo a visual inspection to confirm the physical appearance.A representative sample of the waste shall be collected and sent to the on-site laboratory for fingerprintinganalysis (Annexure II).The results of fingerprinting analysis shall be compared with the results of earlier analysis.Upon confirmation, waste shall then be sent for TSD operations according to the identified pathway.

3.5.2 Waste TSD (Transport, Storage and Disposal) Options

Waste at TSDF could be handled in different ways as follows:

Direct disposal into landfillTreatment/stabilization of wastes and then disposal into landfillDirect incinerationPre-treatment and incinerationPre-treatment, incineration and disposal of incineration ash in landfillWaste processed for fuel/industrial by-products for recyclingOthers

3.5.3 Pathway of Waste Accepted for Direct Disposal

Wastes accepted for direct disposal shall conform to the concentration limit/criteria stipulated by theSPCB/PCC (Annexure - III).

3.5.4 Comparative Analysis for Waste Acceptance for Direct Disposal

Generators of hazardous wastes shall identify and provide analysis report including CRIT criteria of the wasteconsignments. TSD facility should require that the generator provides such information regarding:

The throughput and process that generates the waste with qu antitiesThe physical and chemical description of the waste as per parameters given in Annexure IThe analytical procedures and interpretation of results used t o characterize the waste or process knowledgedocumentationHazardous waste codes are placed as per Schedule 1 & 2 of the Hazardous Waste (Management andHandling) Rules, 1989, as amended.

The operator at TSD, so as to ascertain direct disposal into a landfill, shall perform the following fingerprintinganalysis:

Free liquid content (Paint Filter Liquids Test and Liquid Release Test)pHCalorific valueFlash pointReactive sulfideReactive cyanideChemical compatibilityAny other specific parameter, which may be decided on merit of each case.

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The waste shall be placed at the toe of the working face and spread evenapproximately 0.5 meter layers. Spreading and compaction is an importmaximum waste density within the landfill. After every day's operation, soil cshall be placed over the waste. The placement and compaction is continued cell. At the point of reaching the final design height, the final cover is placproceeds.

3.6 Direct Disposal Pathways for un accepted Hazardous Was

Wastes not accepted for direct disposal into landfill shall have to either be treata landfill, or would have to be incinerated, or otherwise managed as per

SPCB/PCC.

3.6.1 Waste Treatment / Stability

Waste treatment / stabilization is a process designed to convert hazardous wliquids, semi-solids or reactive solids into less leachable solids that can thesecured landfill in compliance with the concentration limits/criteria stipulatetreatment/stabilization operations will be carried out for all wastes identified their contaminant leaching potential. This wil l change the nature of these waTreatment/stabilization involves immobilization of leachable materials byreduction of volume, reducing contaminant level of organic/inorganic comwould depend on the nature of waste, physical properties, options for teSuggested flow chart for screening the wastes going to treatment/stabilizationgiven in CPCB - document: HAZWAMS/17/2000-01. The treated wastes befassessed for compatibility with other wastes as well as with liner system

The term treatment/stabilization is intended to cover a number of mechanisms

Immobilization/Chemical fixation - the chemical binding of contaminanreduce the mobility or leachability of the waste constituents

Encapsulation-the occlusion or entrapment of contaminant particles with

Solidification-the conversion of slurries that do not readily de-wasolidification and adsorption agents.

Typical reagents that would be used for the stabilization process may includcement, saw dust etc., in combination with sodium silicate solution, if requproperties of the wastes.

General operations for waste treatment/stabilization shall include:

Receiving waste for its storage in appropriate/designated placeAdding of reagents as per the pre-estimated quantitiesMixing and curingThermal treatment to remove moisture, organics etc.

Analysis of the stabilized sample (TCLP)Transfer of stabilized material to landfill


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The above process operations generally have the potential to create gaseous and particulate emissions into theair. This can be controlled by various management practices as stipulated by SPCB/PCC including masking(and would have to be properly managed).

Also ambient odour near facility coming from the industrial wastes has to be neutralized in the followingmanner by the operator:

As indicated at Section 3.5, placing bulk, containerized, or non-containerized liquid hazardous wastescontaining free liquids (whether or not absorbents have been added, liquids that have been absorbed inbiodegradable materials and liquids that have been stabilized by sorbents but will release liquids whencompressed under normal pressure that might occur during and after land-filling) in any landfill is prohibitedregardless of the length of time, presence of liners or leachate collection system.

Hence, TSDF shall use the paint filter liquid test (PFLT) to comply with this requirement. This test determineswhether the waste can be accepted to landfill subject to its passing the PFLT. The waste is not subject to a ban ifit passes the PFLT. However, it if does not, it must be treated before it can be placed in the landfill.

Waste treatment/stabilization would have to be performed on all wastes that find their final disposal into alandfill but do not meet the landfill disposal criteria. Typical analysis protocol for waste treatment/ stabilizationwould be as indicated in Annexure I (comprehensive analysis). Finger printing analysis for the same woul d beas indicated in Annexure II.

3.6.2 Identification Parameters for Waste Treatment / Stability

Waste treatment/stabilization parameters shall include both physical and chemical tests. Physical tests shall beperformed to characterize wastes before and after stabilization/solidification/treatment. The chemical testsshall primarily be the leaching tests, which will be conducted to evaluate the performance of specific treatmentprocesses. The analysis shall be in line with the parameters as indicated inAnnexure I.

3.6.3 Analysis Protocol to confirm treatment/stabilization of waste

Physical Tests

The TSDF operator has to conduct and document the results of the following physical tests applicable toincoming waste as well as on treated/stabilized hazardous waste.

The physical tests shall be classified into the following categories:

TEST PURPOSE

Index Property Tests

Particle size analysis (PSA) To determine the particle size distribution of a material

Moisture Content

Paint filter liquid test (PFLT) To determine the presence of free liquids in a

representative sample of bulk or non-containerized waste.

Density Testing

Bulk Density To determine the in-place densCompaction testing

Moisture density relations To determine relation betweendensity of the waste

Permeability Testing

Falling head permeability To measure the rate at which w

/cons tant head ( FHP/CH) stab il iz ed was te

Strength testing

Unconfined compressive To evaluate how cohesive the strength (UCS) under mechanical stress

Flexural s trength (FS) To evaluate the s tabilized wasloads over a large area

Cone index (CI) To evaluate a stabilized wastescapacity

Durability Testing

Wet and dry durability To determine how the stabilize(WDD) degrades after repeate

Table 3.6.3 Analysis Protocol for Treatment/ Stability of Waste

Chemical Tests

Leaching tests shall be used in evaluating t he performance of treatment/stabfor wastes as per the recommended TCLP procedure for the identified chemwaste. The waste stabilized should meet the Best Demonstrable Available TUnites States Environment Protection Agency (USEPA) before their dispostandards are notified/stipulated under th e Environment (Protection) Act, 198

3.7 Waste Storage

Owner/operator of TSDF shall store such wastes in lined containers solely forof such quantities of hazardous waste as necessary to facilitate proper recovereconomically viable treatment/disposal techniques are presently not availablcontainer shall be clearly marked to identify its contents and the date(s) of accinformation for each consignment is recorded and maintained in the operating


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Separate area should be earmarked for storing the waste at TSDF. The storage area may consist of different cellsfor storing different kinds of hazardous wastes. In designing these cells, the following points may be taken intoconsideration:

Those ignitable, reactive and non-compatible wastes shall be stored separately.That wastes containing volatilesolvents or other low vapour pressure chemicals should be adequately protected from direct exposure tosunlight.

The storage area should have a proper containment system. The containment system should have a collectionarea to collect and remove any leak, spill or precipitation. It should be designed in such a way t hat the floor levelof the storage area is at least 150 mm above the maximum flood level

The operator of the TSDF should put in place a system for inspection of the storage area to check the conditionsof the containers, spillages, leakages etc., and maintain proper records as may specified by the SPCB/PCC in theauthorization to operate TSDF.

The hazardous wastes should not be stored for more than two weeks at this temporary storage area.

In case of waste is not in accordance with the authorization issued by the SPCB/PCC to the generator, the TSDFoperator shall reject the waste for the waste for further treatment and disposal. Information to this effect shall beimmediately sent to the SPCB/PCC for advice.

3.8 Acceptance / Rejection of Waste Consignments for Storage

Owner/operator of TSD facility shall store such wastes for upto two years(s) unless MoEF / CPCB / SPCB/PCCdemonstrates that such storage is not solely for the purpose of accumulation of such quantities of hazardouswaste as are necessary to facilitate proper recovery, treatment or disposal. Otherwise, such wastes shall be storedat the facility beyond the stipulated period and owner/operator of the facility bears the burden of proving thatsuch storage is solely for the purpose of accumulation of such quantities of hazardous waste as are necessary to

facilitate proper recovery, treatment or disposal.

The operator of TSDF shall accept the hazardous wastes as per the authorization issued by SPCB/PCC to thegenerator and then undertake the operations for treatment/stabilization and disposal as per the conditionsstipulated by the SPCB/PCC to the operator of TSDF.

4.1 Introduction

Incineration is an ultimate treatment process, applied to certain wastes that candeposited in a landfill. It is a high temperature, thermal oxidation process converted in presence of oxygen in the air into gases and incombustible solid rthe atmosphere through gas cleaning system as may be necessary while thedisposal into the landfill. Applicability of incineration of hazardous waste deillustrated as under:

The waste is biologically hazardousIt is resistant to biodegradation and persistent in the environmentIt is volatile and therefore easily dispersedIt cannot safely be disposed into a landfill even after stabilization/treatmenVolume reduction of waste is necessary

Incineration may take place either in dedicated, custom-built facility or in suprocess plants which maintain the required temperature for complete incinequipped to control air emissions as per the norms stipulated by the SPCB/PCC

4.2 Incinerable Waste

In general, if the waste is organic, then it has a high potential for incineration inTypical wastes that would need to be incinerated by the operator of TSDF may

Solvent wastes (spent solvents)Waste oils, oil emulsions and oil mixturesHospital wastes of categories 1,2,3,............and 10 of the Schedule I of tdated 20th July 1998, of MoEF, GOI, subject to authorization by the SPCBPesticide wastesPharmaceutical wastesRefinery wastesPhenolic wastesGrease and wax wastesOrganic wastes containing halogens, sulphur, phosphorous or nitrogen coCapacitors containing PCBsSolid materials contaminated with oilsOthers with calorific value >2500 Kcal/Kg.

Whether or not these wastes can be properly incinerated depends on the choicits gas cleaning system - an important qualification, since the act of disposal sthe environment.

4.0 Incineration

3


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4.3 Guidelines for Incineration

The primary aim of incineration is completely destroy the toxicity of wastes and to get products (solids andgases) of combustion that are harmless. To achieve these aims, attention must be given to the Three Ts ofCombustion:

TemperatureTimeTurbulence

Availability of oxygen is an additional parameter, which forms an integral part of the incineration system.

When the waste is burnt at the higher temperature destruction would be complete and formation of un-burntwaste, formation of organic by-products etc. would also be eliminated. The longer the waste is held at hightemperature, the greater will be the degree of destruction and the less-likelihood of formation of Products of In-complete Combustions (PICs).

Turbulence relates to the degree of mixing between the waste and oxygen in the combustion air and to theabsence of temperature gradients within the furnace. Greater turbulence provides better control, better accessto air and more complete oxidation destruction of the waste being burnt.

Finally, availability of oxygen is important for combustion of material.

CPCB publication No. HAZWAMS/30//2005-2006 on Guidelines for Common Hazardous Wasteincineration may please be referred. The recommended standard for tail gas & operating conditions are placedat Annexure IV for reference.

Having considered leachate quantity, quality and the variations associated pidentify the components of the leachate that are t o be treated or removed such a

Removal of high concentrations of degradable organic compounds

Removal of high concentrations of non-degradable organic compounds

Removal of varying concentrations of specific hazardous organics

Removal of varying concentrations of specific hazardous inorganics

Removal of ammonia

Denitrification of nitrates/nitritesRemoval of odours including sulphides

Removal of suspended solids and

Disinfection (if required)

TSDF operations shall comply with the consent conditions stipulated by the of the Water (Prevention and Control of Pollution) Act, 1974, with referendisposal of leachate originating from the secured landfill (ReferAnnexure - II

5.0 Leachate Treatment and Disposal

4


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CETP Unnao and CETP Banthar including other similar waste generating uniregistered company Industrial Infrastructure Leasing & Financial Services (the proposed secured landfill at Banthar. The MoEF, GoI, has sanctioned a projwith the help of UPSIDC under 'Industrial Infrasatructure Upgradation Schetheir first contribution into an escrow account as per guidelines of Ministry of Cof the site was already done and environmental clearance from MoEF, GoI &from UPPCB already received for the project site. A Draft Project Report (Dexclusively for this secured landfill project to UPPCB & MoEF for their apprproject came in operation in October 2008.

6.3 Hazardous Solid Waste Disposal/Storage arrangements

UnnaoThere are two Common Effluent Treatment Plant (CETP) companies in the Un

1. M/S Unnao Tanneries Pollution Control Company - looking after wasthis location since 1996 and,

2. Banthar Industrial Pollution Control Company - recently formed as pproject leather technology park at Banthar in Unnao. This Common Ehas been set up as per the environmental clearance by MoEF, GoIagreement with UPSIDC, BIPCC & CLRI. Currently, there are no actiPark (LTP) Banthar and only Common Effluent Treatment Plant (CET

6.4 Other Techno-commercial study issues of the project DPR in the ministry of Commerce & Industry, Government of

6.4.1 Common Hazardous Waste Disposal Project component proposed u

Based on the diagnostic study and discussions with the various stakeholders tidentified and prioritized for implementation with assistance from IIUS. Tabproject components and their cost estimates.

The project is proposed to be implemented in a phased manner:

Table 6.4.1: Proposed Project Component and Cost Estim

S. N. Project Component Estim

Phase I

I Construction of Common Hazardous 179.2Waste Disposal Facility (CHWDF)

6.1 Industrial areas of Unnao

6.1.1 UPSIDC Industrial Area, Unnao This is a planned industrial area developed by UPSIDC in the year1986 on the NH-25 about 30 kms from Kanpur. The area comprises of two parts, site 1 & site 2 which are oneither sides of NH 25 and a third part, site 3 of Kundan Road side units. Unnao industrial area is a mixedcluster which includes tanneries, leather processing & leather products manufacturing units as well as alliedchemical, fertilizer & manure, steel, engineering and paper & packaging units. There are 30 tanneriesoperational in this industrial area which is spread over an area of 421 acres.

6.1.2 UPSIDC Leather Technology Park Banthar, Unnao This area has been developed by UPSIDC as aLeather Technology Park in the year 2001 on the NH 25 about 9 kms from Kanpur. The industrial area isplanned for 45 tanneries and 150 leather goods producing units. All the plots in this industrial area have beensold. Currently, about six tanning industries are awaiting the individual clearances from Ministry ofEnvironment and Forests (MoEF) for commencing their operations. Twenty leather goods producing unitshave started operations. The total area of the Leather Technology Park is about 286 acres. The CombinedEffluent Treatment Plant (CETP) has been commissioned and awaiting supply of raw effluent from themember units for treatment.

6.2 Background

6.2.1 Hazardous Waste from TanneriesThe management of hazardous waste (HW) is of extreme importance in view of its constituents, which maypose a threat to the environmental & human health, if left un-managed/improperly managed. In order tomanage these wastes properly, the Ministry of Environment & Forest, Government of India underEnvironmental Protection Act, 1986 has formulated Hazardous Waste (Management & Handling) Rules,1989, amended in 2000 and 2003. The Hazardous Waste (Management and Handling) Rules, 2003 specify theprocesses generating HW (in Schedule I) as well as types of HW based on concentration limits (in Schedule II).As per rules, waste conforming to any of the schedules has to be considered hazardous and thus managed as perthe requirements given under the rules and guidelines. The concerned State Department, Industry associationand the Occupier are responsible for identification of disposal sites for disposal of HW. The identified siteneeds to be developed as a secured landfill facility.

The waste produced by tanneries and leather industries falls in the category of hazardous waste too. In view ofthe above, the Industries in Unnao decided to develop a Common Raw-Hide Storage and Management Center(CRHWDF) to ensure that HW is disposed off in an envi ronmentally safe manner and these industries are ableto comply with the HW (M&H) Rules.

6.2.2 Current SituationBefore implementation of a common Secured landfill Facility (SLF), CETP Banthar developed a securedlandfill capsule for hazardous waste disposal in 2 acres of land within its premises based on double liner systemof CPCB as conceived by CLRI's Environmental Impact Assessment (EIA). The expected life of this cell was3-5 years. CETP, Unnao has already got a temporary storage facility in accordance with the parameters ofUPPCB. All industries have their own pucca tanks in their premises to hold 6-12 months waste temporarilybefore they dispose it in a Secured Landfill Facility at Banthar. All the units of Unnao get timely authorization

from UPPCB for hazardous waste storage/disposal in order to comply with the guide lines of the board.

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6.0 Banthar Leather Technology Park's Secured Landfill Project


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6.4.2 Proposed Means of Finance

In accordance with the IIUS guidelines the proposed means of finance for different project component issummarized at Table 6.4.2 As per the guidelines of the IIUS the user contribution in the project should be 25%of the total project cost. The industries have agreed to contribute 10% of total project cost as equity in t he SPV,the balance 10% of the project cost would be put by GoUP on behalf of the ind ustries as support to the projectand the remaining amount would be funded by IL&FS.

Table 6.4.2: Proposed Means of Finance

Pr ojec t GoI Grant I ndustry GoUP s upport UPSIDC Debt Tota l Cos tunder I IUS Contr ibut ion v ia UPSIDC s upport IL &FS ( in Rs Mil lions)

Constructionof Common 129.2 17.9 17.90 0.00 14.1 179.5Hazardous (72%) (10%) (10%) (0%) (8%) (100%)WasteDisposalFacility

The contribution of GoUP through UPSIDC would be 10% of Project Cost. However, since cost of land cannotbe financed through IIUS, UPSIDC would contribute Rs.24.38 Million i.e. 26% of project cost for theCRHSMC component, in the form of support to the project. The total contribution of 36% of Project Costwould finance the cost of land required for CRHSMC component. The support from GoUP/UPSIDC would berepaid by the SPV. In case of CRHSMC it would be repaid in three equated annual installments from the start ofoperations and for CHWDF the support would be repaid in two equal installments during the 8t h and 9th yearof operations.

It may be noted that as per the guidelines of IIUS, the one-time grant requirement estimated for the proposedproject component under the IIUS scheme does not include the cost of land.

6.4.3 Sustainability of Project Components

The projects have been structured on sustainable format with levying of user charges for operation andmaintenance of the assets created. Provision for a Maintenance Reserve Fund which would set aside funds forfuture expansion & growth of the cluster is also included.

Tables 6.4.1 & 6.4.2 present the user charges & profitability projections proposed for the various projectcomponents.

Table 6.4.3 : Proposed User Charges for different project component s

Sl. Project User Charges

I Common Hazardous Wast e Di sposal Facilit y Rs. 1000/ MT of waste disposed

6.5 Common Hazardous Waste Disposal Facility

6.5.1 Component Description - Summary

Solid Waste generated in tanneries and leather finishing processes are clacategory and require appropriate storage, handling and disposal. Tanneries getrimmings, splitting, fleshing, buffing dust, shavings and finished trimminbiological sludge generated by the CETP.

The hazardous waste generation of the Kanpur-Unnao Leather cluster is estim(source UPSIDC-Tetratech report on Hazardous Waste Management). Predisposal of the hazardous waste generated by the tanneries and leatherEnvironment and Forest (MoEF) has given a conditional consent for establiPark (LTP) at Banther subject to provision of proper Hazardous Waste Disposa

Based on this assessment a site of 33 acres has been identified as secured lanrequirement. The site is located at the Leather Technology Park Banther adjoat Bather. The proposed facility would have a capacity to accommodate 4,22,7proposed CHWDF would be a common facility for the tanneries and leatherregion.

6.5.2 Component Analysis - Technical

The hazardous waste from processes like trimming and fleshing contain orprocesses like liming/deliming generate inorganic wastes. Post-tanning procedust which contain chemical constituents like chromium, dyes, pigments and f

The solid waste generated at primary clarifier of CETP consist inorganic wasteat the secondary clarifier is organic in nature. The typical characteristics of s

tanneries are presented at Table 6.5.2

Table 6.5.2 Typical Characteristic of CETP sludge from tann

S. No. Parameter

1. pH

2. Moisture Content

3. Dry Solids

4. Volatile Solids

5. COD (Dry Solids weight basis)

6. Cr, Total

7. Chlorides

8. Sodium

9. Calcium

Source: Comprehensive EIA Report for LTP-Banther, CLRI


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Table 6.5.5: Design Criterion for CHWDF

S. No. Parameter

1. Quantum of Waste to be managed

2. Land Required

3. Moisture Content, allowed

4. Design Life of Landfill

Source: Comprehensive EIA Report for LTP-Banther, CLRI

Some of the salient features of the proposed design for the CHWDF have been

23 24

The solids from the processing yards of the tanneries should be collected in forms containing 30%-60%average moisture content. They can be solar dried and stored for manufacturing by-products. On-site storage ofsolid wastes in wet form/dry form could be planned for maximum period of 90 days and/or a maximumquantity of 10 tonnes at any time, in accordance with guidelines of MoEF.

The biomethanation process and land filling of solid wastes are considered as common methods of disposal. Inlandfills, biochemical reactions may take place to release bound water rich in soluble organic and inorganicchemical constituents. The leachate thus emerged from such sites may contaminate land and groundwaterenvironment in the vicinity of the disposal facility. Appropriate leachate collection and treatment systemshould be designed.

Based on the tanning process existing in the various tanneries and feedback received from the industries the

total quantum of hazardous waste generated from the tanneries is estimated to be about 18,000 MT/year. Tables6.5.3 and 6.5.4 present the details of quantum of solid waste generated by the tanneries and leather industries inthe Kanpur-Unnao region and the characteristics of the waste respectively.

Table 6.5.3: Quantum of Hazardous Waste generated at LTP Banthar-Unnao Cluster

1S. No. Region Quantity of Solid Waste generated (in MT/year)

1. LTP-Banther 14,805

2. Unnao Site 1&2 3150

Total 17,955

Source: Report on Hazardous Waste, UPSIDC-Tetratech

Table 6.5.4: Characteristics of Hazardous Waste generated at Kanpur-Unnao Cluster

S. No. Type of Waste Quantity of Solid Waste generated (in MT/year)

1. Lime Sludge 2101.00

2. Buffing Dust 141.50

3. Chemical & Biological 13,753.00

Sludge from CETPs

Total 17,955.50

Source: Report on Hazardous Waste, UPSIDC-Tetratech

The criteria for design of the land-fill are presented at Table 6.5.5 It is proposed that the land-fill would bedesigned for a period of 20 years and the land required for this purpose is estimated to 33 acres.

Figure 1 The typical cross-section of the foundation


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6.6 Project Cost Estimates

Based on the designs as presented in the previous the costs estimates have bTable

Table 6.6: Cost Estimates for CHWDF in Rs Million

S. No. Item

1. Land Cost

2. Site Preparation

3. Earthwork in Embankment & Slope Preparation

4. Preparation of Landfill Bottom, Inner Slope & Berms

5. Laying of Double-liner with HDPE Pipe collection system

6. Leachate Collection & Detection Cell

7. Installation of Leachate Treatment System

8. Laying of Roads and Storm-water drains

9. Provision for Support Facilities

10. Provision of Plantation

11. Sub-Total (A)

12. Detailed Design, Engineering and Development costs

13. Administrative Expenses (@ 3% of (B))

14. Pre-Operative Expenses

15. Contingencies (@ 5% of (B))

Total(B)

6.7 Means of Finance

In accordance with the IIUS guideline, the proposed means of finance for impresented as Table 6.7. It may be noted as per the guidelines of the IIUS scexclude for the purpose calculation of grant from GoI under the IIUS schem10% of Total Project Cost as equity in the SPV. GoUP would provide 10% oindustries as support towards the project the SPV would repay this amount toterm debt in two-equal installments.

Table 6.7: Means of Finance for CHWDF

Source % of Component Cost

Grant from GoI under IIUS 72%

Equity User Contribution 10%

Support from GoUP 10%

Debt Finance IL&FS 8%

Total 100%

(a) Foundation After excavating the soil to the desired depth, a compacted clayey soil to a depth of 1m has tobe laid. The minimum top width of 3m has been considered in order to allow sufficient room for equipmentand personnel movement during liner installation as well as during operation & maintenance period.Figure1 presents the typical cross-section of the foundation

Figure 2 The typical cross-section of the liner system

(b) Liner System A double layer synthetic liner system has been proposed for the CHWDF, the cross-section of the liner system is illustrated at Figure 2. The liner system consists of two layers of geo-textile, sand, gravel and clay.

(c) Leachate Management System In order to prevent leachate migration and contamination a leachatecollection, removal and holding system has been proposed. Figure 2 illustrate the leachatemanagement system.


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6.8.2 Inventorization and characterization of HW

The industries that will be sending their HW for disposal on the proposed Cproducts such as finished leather, leather board, lube oil, and basic chrome sfrom Banthar and Unnao which will be sending their HW for disposal to thfrom most of the industries is sludge from waste water treatment. Apart from thindustries includes heavy metal bearing wastes from Basic Chrome Sulphwaste oil from lube oil refineries. The table 6.8.2 (a) & (b) below provide a bre

Table 6.8.2 (a) A break-up of other HW

S. No. Region Total HW generated/e

1. Banthar 14805

2. Unnao 3150

TOTAL 17955

Source: As per the information received from the industry unit holders

The above generated HW can be characterized as below:

Table 6.8.2 (b) Characterization of HW

S. No. Type of Waste Quan

1. Lime Sludge 2101

2. Buffing Dust 141.5

3. Chemical and Biological Sludge from CETP 13753

Source: As per the information received from the industry unit holders

6.8.3 Layout of CHWDF

The main objective of a secured landfill is to contain the HW, minimize leachamigration to the groundwater and to keep it isolated from the surrounding enthat will be addressed while framing the conceptual plan for CHWDF are:

Type and volume of hazardous wastes to be land filledLife expectancy of the landfill during its active operating periodTopography and soil characteristics at the site and in its vicinityClimatic conditions throughout the yearSurface and groundwater in the vicinityCollection and treatment of surface runoffSoil cover requirements for individual containment cellsAnticipated quality and volume of leachate

In case actual cost of the component exceeds the Estimated Cost of the component then the additional increasein cost would be contributed by increase in equity or raised through additional borrowing from IL&FS

6.8 Details of Development of CHWDF

The construction of a CHWDF is very sophisticated in terms of technology and design. Reliable data on thequantity and quality of hazardous wastes is important for the design of an optimal collection, transportation,and treatment and disposal system. The broad steps in the development of a CHWDF up to its closure include:

1. Selection of site for developing CHWDF2. Environmental Impact Assessment for developing the CHWDF on the selected site and its

environmental clearance from Government of India3. Inventorisation and Characterization of HW generation in targeted industrial areas4. Site investigation including topography survey, geotechnical and hydrogeological survey and

groundwater survey5. Conceptual Plan for CHWDF6. Detailed Design and Engineering of CHWDF including

a. Waste acceptance and management planb. Lab facilities and waste storage systemc. Treatment and disposal Pland. Wastewater treatment Plane. Operation and maintenance planf. Emergency preparedness plang. Surveillance and monitoring planh. Occupational health and safety plani. Closure and post closure planj. Environmental monitoring Plank. Health and Safety Plan

7. Capital and Operating Cost Estimates

8. Construction of CHWDF9. Operation and Maintenance of CHWDF10. Closure of CHWDF11. Post Closure monitoring of CHWDF

The task till development of CHWDF is to b e accomplished in phases.

6.8.1 Development of CHWDF for hazardous waste industries of Banthar and Unnao

Development of CHWDF is being done at Banthar Complex, on a site of 33 acre (18 acre with CETP and rest of15 acre adjoining land) has already been identified. The EIA of the entire Leather Technology Park has beendone by CLRI and MoEF has issued its environmental clearance. As per discussions with CLRI and UPPCB,no EIA would be required for adjacent patch of 15 acre with CETP for Hazardous waste site to be provided byUPSIDC.


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Waste acceptance and management planLab facilities and waste storage systemTreatment and disposal PlanWastewater treatment PlanOperation and maintenance planEmergency preparedness planSurveillance and monitoring planOccupational health and safety planClosure and post closure planEnvironmental monitoring PlanHealth and Safety Plan

6.8.5 Detailed Capital and Operating Cost Estimates

The capital costs would be estimated based on BOQs prepared on the bspecifications. The operating and maintenance costs would be estimated baseplan.

Once detailed design and engineering is completed and cost estimates haveCHWDF will be initiated.

Fig 6.8.5. Suggested Project Implementation Plan for industries

Selection of leachate collection and treatment systemsMonitoring of groundwater and surface water during operations and beyondSelection of membrane linersClosures and post-closure plans

The landfill site will comprise of the area in which the waste will be filled, as well the additional area forsupport facilities. The landfill section would be designed keeping in view the topography, ground water table,high flood level (HFL) and availability of the liner and cover material. The landfill would be operated in phasessuch that at any given time a part of the site will have a final cover, a part getting actively filled, a part gettingprepared to receive waste, and a part undisturbed.

After conceptual planning, preliminary engineering drawings will be prepared covering the following details:

Storage of waste: compatible/Incompatible,UtilitiesPrimary treatment facilitiesLaboratoryWeighing facilityGreen beltSafety equipment/amenitiesMonitoring stationsGeneral arrangement drawings for the landfill and its components

6.8.4 Detailed Design and Engineering of CHWDF

It will cover detailed specifications of the following:

Linear SystemEmbankmentLeachate collection & treatment System (LCTS)Strom water drainage system

Pumping & Piping System alternative methods for taking leachate & run off effluent from the land fill siteto ETPIntermediate CoverFinal CoverMonitoring wellsSpecification for civil, mechanical, instrumentation and electrical itemsConstruction DrawingsPlan & Sections of different phases of the landfillBottom and side liner detailsSection of leachate management systemIntermediate and final cover for the landfillDetails of embankmentDetails of anchoring trenchMembrane Panel LayoutPipe boot and pipe joint details

The detail of liner system and embankments are provided in Fig 1 & 2. The design and detailed engineering ofthe facility would conform to the guidelines issued by CPCB. Other activities that will be addressed as part ofcomplete design of CHWDF include:

Decision by industries to take up developmentCHWDF to comply with the legislation

Industries to form SPV for taking up this proje

SPV to organize funds for the study -Complie

SPV to identify organisation/expert(s) for conducting EIAHW landfill site and seek environmental cleara

SPV to identify organization/expert(s) forDetailed Design and Engineering of CHWDF

SPV to receive drawings and management plans from torganization/experts(s) for developing and running the

SPV to float tenders for selection of private operfor construction and management of the CHWD

Selected Operator to construct the CHWDF and

receiving HW from industry on per tonne fee b


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6.8.6 Financial Implications

The financial estimate has been done with the assumption that in 33 acre site, 3 acre will be used for developingsupport facilities and 30 acre area will be used for developing the l andfill facility. The height of landfill pondhas been taken 7m in which HW will be filled upto the height of 6.5 m. Based on the above design parameters,the financial cost attached with the project is subdivided into following heads (excluding cost of the land):

Table 6.8.6 (a) Financial Cost of th e Project

S. No. Description Cost ( in INR) Remarks

1. Cost of conducti ng EIA 3,00,000 6,00 ,000 If required again for adjoi ning land

to CETP

2. Cos t o f detai led des ign and 13,00 ,000 18,00 ,000 T his would include s it eengineering of the CHWDF investigation work involving(including detailed cost topography survey, geotechnicalestimates and management plans and hydrogeological surveyfor operation and maintenance and groundwater surveyof CHWDF)

3. Construction of CHWDF 11,00,00,000 In this case volume availablea. Using Earthwork embankment and double liner system

for filling HW willbe nearly 1,60,000 Cu.m.

b. Using RCC embankment and 17,00,00,000* In this case volume availabledouble liner system for fillingHW will be nearly 2,50,000 Cu.m.

4. Operation and maintenance cost 75,00,000 per year Approximately 5% escalation wouldbe applicable on the cost on yearlybasis.

5. Cost of closure 1,50,00,000

*Without provision for contingency

Table 6.8.6 (b) Broad break-up of cost of construction

S.No. Descriptions Cost (INR) Remarks

A. Using Earthwork Embankment and double liner system

1. Site preparation including clearing of vegetation; 20,40,000

stripping, grading and removal of top soil, and

compacting of area

2. Earthwork in embankment and slope protection

3. Preparation of landfill bottom, inner slopes and berms

of embankment using clay foundation

4. Laying of double liner system including HDPE Pipes

for leachate collection

5. Leachate Collection and Leachate Detection Sump

6. Installation of leachate treatment system

7. Laying of road and storm water drain and site fencing

8. Providing support facilities such as Chemical House,

MCC Room, Administrative Building, Temporary Storage

Area, Pretreatment Raea, Laboratory Building, Security Room,Car Parking Area, Truck Parking Area, Truck Washing Area

and other Accessories

9. Providing Plantation

10. Contingency (10%)

B. Using RCC Embankment and Double Liner System

1. Site preparation including clearing of vegetation;

stripping, grading and removal of top soil, and compacting

of area

2. Civil work for embankment

3. Laying of double liner system including

HDPE Pipes for leachate collection

5. Leachate Collection and Leachate Detection Sump

6. Installation of leachate treatment system

7. Laying of road and storm water drain and site fencing 8. Providing support facilities such as Chemical House,

MCC Room, Administrative Building, Temporary

Storage Area, Pretreatment Raea, Laboratory Building,

Security Room, Car Parking Area, Truck Parking Area,

Truck Washing Area and other Accessories

9. Providing Plantation

10. Contingency (10%)

* Above cost estimates are budgetary and can change depending upon the chmaterial, equipments and labour cost.

Note: The cost of common SLF as revised by industries and Government

only


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6.8.7 Expected life of landfill (assuming that density of waste in Landfill is 1.1 MT/Cu. m)

Table 6.8.7 Expected life of a landfill

S. No. Landfill Design Expected Life

1. Using earthwork embankment and double liner system 11.5 Years*

2. Using RCC embankment and double liner system 17 Years*

* Here quantity of HW generation per annum is taken constant for calculation purpose. It is expected that HWquantity will increase with increase in production.

While calculating the expected life of the landfill it has been assumed that initially for 1-2 years HW quantityreceived on site will be approximately 2000 Tonnes per annum. The HW quantity received will increase upto18000 Tonnes per annum within three years and will stabilize at this level.

6.8.8 Design Decision

We shall start in the first phase with the first option of the Earthen work embankment design of CHWDF as perdesign recommendations of CPCB as also given in the environmental clearance given by MOEF, GoI forCETP/tannery complex at UPSIDC leather Technology Park Banthar.

In case we find any practical problems with the option, next cells of CHWDF will be made using the secondoption depending upon financial grant availabilities too under IIUS of MoC&I, GOI.

6.8.9 Revenue Model

Different strategies for revenue collection and cost recovery were examined, these include:

Disposal charges based on number of hides/production capacity The SPV could levy user charges linkedto number of hides/production capacity processed. Although this may be an indicator of the totalhazardous waste, but difference in production method and technology results in difference in quantum ofwaste. Moreover, disclosure of number of hides processed/production for levy of disposal charges may bea sensitive issue and may be difficult for the SPV to monitor.

Disposal charges based on quantum of waste disposed with a Take-or-Pay arrangement SPV would levya disposal charge for handling, management and disposal of hazardous waste. This would ensure thatdirect users and beneficiaries of the facility pay for availing the service. The SPV would enter into anannual take-or-pay arrangement for levying of disposal charges. The arrangement could be renewed at theend of each year.

Capacity based charges & Recurring charges - Alternate tariff structures could be examined and finalized.This could be include capacity based fixed charge and a recurring monthly charge to cover monthly costs.Suitable tariff structure would have to be evolved at a later stage

6.8.10 Implementation Framework

UPLIA proposes to implement the CHWDF component with assistance frthrough a Special Purpose Vehicle incorporated for this purpose. The SPV isCompanies Act, 1956.

For construction and operations & maintenance two approaches have been pro

Separate contracts for construction and operations & maintenanceBoT contract for construction and operations & maintenance or Annuity mBoT-Concession

It is felt that the latter would be advantageous for the SPV, since it would trawell as operations & maintenance to a private sector developer.

The proposed CHWDF would be constructed, operated and maintained throHowever, the SPV would retain the responsibility for collection of dispothrough a take-or-pay contract.

Figure 3 presents the indicative implementation structure for CHWDF.

6.8.11 Financial Analysis

Financial analysis has been undertaken to structure the roads componenrequirement from sustainability perspective. Financial analysis has bimplementation as a stand-alone component without any cross-subsidy elemecomponents. Some of the key assumptions used for this analysis are presented

Table 6.8.11 (a) List of Key Assumptions

Variable Description

Date of First Disbursement April 01, 2005

Construction Start Date October 31, 2005

Construction End Date October 31, 2006

Operations period(excl uding 20 years

construction period)

Year of base Cost Estimates FY2006

Average Rate of Inflation 6.50% per annum

Capital Costs As presented in Table 7.2.6 (a) &

Operation & Maintenance Costs Operation & Maintenance Cost

Post-Closure Costs Lump-sum

at FY2006 prices

Debt Terms IL&FS Applicable Annual Interest Rat

Tenor 7 years

Moratorium period 2 yearDebt Service Reserve Fund

34


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Based on the above findings it is felt that the CHWDF could be implementcomponent.

6.9 Project Risks

Delays in construction Delay in construction may result in increase offinancial closure and hence could affect project sustainability. Selection otrack record and timely construction, appropriate contractual framewcompletion and provision of disincentives for delayed completion and l iqthis risk.

Design Risk The CHWDF has been designed for an annual hazardouswith change in process-technology or use of cleaner production techniq

waste characteristics. This risk is allocated to the SPV.

Demand Risk The demand risk for CHWDF has been mitigated thagreement which would be based on Take-or-Pay contract with the indusdisposal of hazardous wastes. Moreover, with the recent Supreme Court denvironmental regulation this occurrence of this risk event is minimgeneration may be expected due to cleaner production or optimizationprocess.

Post-Closure risks The closed landfill areas have to be regularly monitof leakage of hazardous wastes from the closed landfill especially duringborne by the SPV.

Regulatory risks The existing facility would have to meet with requirements as stipulated from time to time. There would therefore bestringent requirements being imposed with regard to treatment and/or disThe need for performance monitoring is envisaged to meet compliance req

Variable Description

Support Terms GoUP Total Support Amount to be repaid in two-equal ins tallmentsafter servicing of Senior Debt

Quantum of Hazardous Waste As presented at Tables above

Tax As applicable

Depreciation Tax Depreciation Rate 10%

Reserves General Reserves: An annual appropriation of 10% of PAT.Maintenance Reserve: An Annual appropriation of 10% of PAT -To meet major maintenance & repair expenses as well as create afund for future capital requirements.

Sustainability of the project is based on its ability to meet the operation & maintenance expenses as well asservice debt and equity. Furthermore, from sustainability perspective a provision of Maintenance Reserve hasalso been made, in order to meet major maintenance expenses as well as provide funds that could be used tomeet the funding requirement for closure of the CHWDF. Based on the abovementioned assumptions,financial analysis was carried out to assess the average disposal charge that would be levied on the industries. Asummary of impact of different disposal charges on project financials have been presented at Table 6.8.11 (b)

Table 6.8.11 (b) Impact of Disposal Charges on Project Financials

Project IRRParameter (on Post-tax basis) Min. DSCR

Disposal Charge of Rs.900/MT 6.21% 2.78



The above analysis suggests that disposal charges between Rs.900/MT and Rs.1000/MT could be considered

which would be necessary for financial sustainability of the component. Table below presents the profitabilityprojections for the CHWDF component.

Table 6.8.11 (c) Profit & Loss Statement for CHWDFAll Figures in Rs. Million

FY ending 31st

March 2008 2012 2016 2020 2024 2027

Revenues 18.25 24.62 33.25 44.92 60.75 76.22OPEX 6.21 8.54 11.75 16.17 22.29 28.36PBDIT 12.04 16.09 21.50 28.75 38.46 47.86Depreciation 8.83 8.83 8.83 8.83 8.83 8.83(By SLM)

Interest 1.55 0.47 0.00 0.00 0.00 0.00Other Income 0.32 2.10 3.42 6.44 9.75 6.63PBT 1.98 8.89 16.09 26.36 39.39 45.66Tax 0.00 0.00 1.90 2.69 16.84 19.54

PAT 1.98 8.89 14.19 23.67 22.54 26.12Post-Tax IRR ~8%

Revenues calculated at Rs.1000/MT as Disposal Charge


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USEPA; SW-846; 9010, Sulphur (elemental)9011, 9012

USEPA; SW-846; Concentration of In-organics [as pVol. 1A, 1B, 1C and Vol. 2 (M&H) Rules, 1989, as amended]

Organ ic Pa rame te rs Analysi s Oil & Greas eExtractable Organic (in special cas% Carbon% Nitrogen% Sulphur% Hydrogen

USEPA; SW-846; Vol. 1A, Concentration of individual organi1B, 1C and Vol. 2 of HW (M&H) Rules, 1989, as am

USEPA; SW-846; Toxicity Characteristics Leaching Method 1311, 1330 parameters identified in Section 2,

listed parameters as presented in M846; USEPA)

Annexure IComprehensive Analysis Requirements for Hazardous Wastes Generator /TSDF Operator

Method o f Ana lysi s Com pre he ns ive Ana lysi s to be submitted by theGenerators of Hazardous Wastes

Physical Analysis Physical State of the waste (liquid / slurry / sludge / Semi-solid / solid: inorganic, organic, metallic)

Description of different phases of the wastes (in cases ofsolid wastes slurries and sludge) contained in aqueous /non-aqueous liquids / solutions

Colour and Texture

Whether the waste is multi-layered (Yes/No)?If yes, quantify each layer

Specific Gravity

Viscosity

Calorific Value

USEPA, SW-846; Method Flash Point1010 and 1020

% Moisture content loss on ignition at 105C

% Organic content loss on ignition at 550 C

USEPA, SW-846; Method 9095 Paint Filter Liquid Test (PFLT)

Chemical Analysis

USEPA, SW-846; Methods ph9040, 9041 and 9045

Method o f Ana lysi s Com pre he ns ive Ana lysi s to be submitted by theGenerators of Hazardous Wastes

Inorganic Parameters Analysis

USEPA; SW-846; Vol. 1C Part II; Reactive Cyanide (ppm)Test Method to determine HCNreleased from Wastes

USEPA; SW-846; Vol. 1C Part II; Reactive Sulfide (ppm)Test Method to determine H2S

released from wastes

Annexure III


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Annexure IIFingerprint Analysis Requirements for Hazardous Wastes - TAD Facilities

Method o f Ana lysi s Finger pr int Ana lysi s by the Oper ator s o f T SD Faci li ti es

Physical Analysis Physical State of the waste (liquid/slurry/sludge/semi-solid/solid: inorganic/organic/metallic)

Identification of different phases of the wastes (in casesof solid wastes contained in aqueous/non-aqueousliquids/solutions for slurries and sludge)

Colour & Textures

Whether the waste is multi-layered (yes/no)? If yes,quantify each layer

Specific Gravity

Viscosity

USEPA, SW-846; Method 1010 Flash Pointand 1020

Loss on ignition at 105 C

Loss on ignition at 650 C

USEPA, SW-846; Method 9095 Paint Filter Liquid Test (PFLT)

USEPA, SW-846; Method 9096 Liquid Release Test (LRT)

Chemical Analysis

USEPA, SW-846; pHMethod 9040, 9041 and 9045

USEPA, SW-846; Vol. 1C Part II; Reactive Cyanide (ppm)Test Method to determine HCNreleased from Wastes

USEPA, SW-846; Vol. 1C Part II; Reactive Sulfide (ppm)Test Method to determine H2Sreleased from Wastes

Annexure IIIConcentration Limits/criteria For Acceptance of HDirect Disposal To Secured Landfill

Leachate Quality * Conce

pH 4 - 12

Total Phenols < 100

Arsenic < 1

Lead < 2

Cadmium < 0.

Chromium-VI < 0.

Copper < 10

Nickel < 3

Mercury < 0.

Zinc < 10

Fluoride < 50

Ammonia < 1,00

Cyanide < 2

Nitrate < 30

Adsorbable organic bound Chlorine < 3

Water soluble compounds except salts < 10%

Calorific value < 250

Strength

Transversal strength (Vane Testing) > 25 KUnconfined Compression Test >50 KAxial Deformation < 20 %

Degree of Mineralization or Content of Organic Materials (Original

Annealing loss of the dry residue at 550C < 20%

(for n

< 5%

(for

Extracti ble Lipo philic contents (Oil & Grease) < 4%

*Leachate quality is based on Water Leach


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Annexure IVEmission Standards For Common Hazardous WasLeachate Disposal Standards

S. No. Parameter Standards (mg/l)Inland Surface STP CETP Marine

(See not e) Coastal Areas

Additional Parameters Recommended

1. Adsorbable Organic 0.50 - - 0.50

Halogens (AOX)

2. Poly Aromatic 0.059 - - 0.059

Hydrocarbons (PAH)

(each)

3. Benzene 0.14 - - 0.14

4. Toluene 0.08 - - 0.08

5. Xylene 0.32 - - 0.32

(sum of o, m,p-xylene)

Note :

1. In addition to the above, General Standards for discharge of environment pollutants Part-A: Effluentsnotified, vide G.S. R. 422 (E), dated 19.5.1993 and published in the Gazette No. 174, dated 19.5.1993under the Environment (Protection) Act, 1986, and rules made thereunder, shall also be applicable fordisposal of leachate into sewage treatment plant, common effluent treatment plant, Inland surface waterbodies or coastal areas.

2. For each CETP and its constituent units, the SPCB/PCC shall prescribe standards as per the local needs and

conditions; these can be more stringent than those prescribed above. However, in case of clusters of units,the SPCB/PCC may prescribe suitable limits.

3. Leachates having high COD shall be concentrated through evaporation (forced) and fed to the incineratorof the integrated TSDF in view of its high calorific value, and the residue ash shall be disposed off in theirsecured landfill.

4. The Bioassay test shall be substituted by 'Fish Toxicity' test, and a dilution factor of 2 (two) may beconsidered.

A. Flue Gas Emission Standards

Treated flue gas emissions discharge through stack to atmosphere shall athe following parameter-specific emission standards:

Parameter Emission standard

3Par ticulates 50 mg/Nm Standard refers to half hourly ave

3HCl 50 mg/Nm Standard refers to half hourly ave

3So 200 mg/Nm Standard refers to half hourly ave2

3CO 100 mg/Nm Standard refers to half hourly ave

350 mg/Nm Standard refers to daily average v

3Total Organic 20 mg/Nm Standard refers to half hourly aveCarbon

3HF 4 mg/Nm Standard refers to half hourly ave

3No (NO and 400 mg/Nm Standard refers to half hourly avexNo2 expressedas NO )2

3Total dioxins 0.1 ng TEQ/Nm Standard refers to 6-8 hours samp

and furans 17 concerned congeners for toxictotal toxic equivalence.

3Cd + Th + 0.05 mg/Nm Standard refers to sampling time atheir compounds and 8 hours.

3Hg and its 0.05 mg/Nm Standard refers to sampling time acompounds and 8 hours.

3Sb + As 0.05 mg/Nm Standard refers to sampling time a+ Pb + Cr and 8 hours.+ Co + Cu+ Mn + Ni+ V + theircompounds

Note: All values corrected to 11% oxygen on a dry basis.


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B. Operating Standards:

I. All the facilities shall be designed to achieve a minimum temperature of 1100C in secondary combustionchamber and with a gas residence time in secondary combustion chamber not less than 2 (two) seconds.

II. The incineration facilities after initial operation of minimum one year, as per the guidelines andstandards, can submit a proposal for relaxation in temperature and retention time requirement if it canbe demonstrated that the flue gas standards and operation standards can be complied with at lowertemperatures and residence times. The State Pollution Control Board / Pollution Control Committee,upon successful demonstration of compliance with flue gas standards by the facility, can recommendthe proposal made by the incineration facility for relaxation in temperature and residence time, but inany case not less than 950 C and 1.5 seconds, for the consideration and approval o f the Central Board.

III. Incineration plants shall be operated (combustion chambers) with such temperature, retention time andturbulence, so as to achieve Total Organic Carbon (TOC) content in the slag and bottom ashes lessthan 3%, or their loss on ignit ion is less than 5% of the dry we

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