From UN/SBC Technical Guidelines on Co-processing of Hazardous Waste in ... · From UN/SBC Technical Guidelines on Co-processing of Hazardous Waste in Cement Kilns To a Co-processing

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From UN/SBC Technical Guidelines on Co-processing of Hazardous Waste in Cement Kilns To a Co-processing Legal Frame in India

Jean-Pierre Degré Cementis August 2013

Cement Manufacturers’ Association

CMA-IIP INTERNATIONAL CONFERENCE ON ENHANCED USAGE OF ALTERNATE FUELS & RAW MATERIALS (AFR) -

CO-PROCESSING IN CEMENT PLANTS

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Jean-Pierre Degré ([email protected])

Chemist & Geologist Engineer, 41 years experience with Holcim.

> September 2011: Partner Cementis… (www.cementis.com)

1970-2011: Holcim Belgium

1997 – 2011 : Senior Vice-President – Head of the Alternatives Resources Division Holcim Group Support

In charge of the worldwide “Wastes to Resources” strategy

Implementation in more than 40 countries

At the base of the worldwide development and recognition of the co-processing concept: using wastes as Alternatives Resources in Resource’s Intensives Industries

Expert in the development of low/neutral CO2 cementitious binders production

1991 - 1997: Development Manager Holcim France and BNL

1984 – 1991: BD Manager Holcim FrBNL and development of the “co-processing concept”

1974 - 1984: Expert in Clinker & Cement production processes, thermal efficiencies and environmental strategies

Some other assignments:

Expert delegate to the UN/SBC

Expert in waste management to the European Commission

Consultant as world expert for energy efficiency in clinker process

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Summary

2 Co-processing: Definitions and Position within the WMH

1 The UN/SBC Guidelines on “Co-processing” • History • International acceptance

3 Co-Processing legal frame & permitting processes • Home work and wastes / AFR acceptances criteria’s • Environmental, end-product monitoring & external audits

4 Co-processing in India: “The way to go …”

5 Conclusions @ Discussions

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Unep / Basel Convention

The Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and their Disposal is the most comprehensive global environmental treaty on hazardous and other wastes. Basel Convention was negotiated in the late 1980s, and entered into force in 1992. Basel Convention acts is based on : • International and validated agreements,

facilitating sound waste management. • Technical Guidelines submission, to

promoting regulation and control of sound technologies for waste treatment / disposal.

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COP 9 : Bali 2008.

DECISION IX/17: Review of other selected technical guidelines

pursuant to decision VIII/17, e.g., on incineration on land (D10),

specially engineered landfill (D5) and wastes collected from

households (Y46)

International Recognition of the Co-processing Concept Process started in 2008 – achieved in 2012

Specific co-processing guidelines are considered. A voluntary country is needed to draft and propose guidelines to the rest of Basel Convention community (more than 190 countries).

COP 10: Cartagena 2011

The draft proposal from Chile, Volunteer Country, has been fully

endorsed by all the members countries

Guidelines for Co-processing of Hazardous Wastes in Cement Kilns

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www.basel.int

Co-processing Technical Guidelines are now the OFFICIAL RECOMMENDATION of United Nations: Co-processing is officially validated as a

sound and recommended technology for hazardous and non-hazardous waste management, pop’s related wastes included

Co-processing is consolidated as recovery operation in the waste management hierarchy,

International and technical criteria / references are now available for local legal frames,

Minimum standards are now defined, limiting informal and non-low standard players.

UN/SBC TG’s

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International validity

Technical Guidelines on Co-processing are based on Best Available Technologies (BAT) and Best Environmental Practices (BEP). Main references:

GIZ – Holcim European Union

US EPA

Between others….

Stockholm Convention

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Co-processing … Now fully recognized !!!

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Example 1 - South Africa - National policy

Key definitions

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Example 2 - Chile – National policy now integrating “co-processing”

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Co-Processing is…

…the use of waste materials in RII’s (Resources Intensives Industrial processes) such as cement, lime, steel, glasses, power generation etc.

..instead of fossil fuels & natural resources

Applied locally Co-processing benefits to:

• Upgrades waste management within the waste hierarchy • Reduces wastes health & environmental impacts • Maintains and improves the industrial sector's competitiveness • Decreases (largely) the costs of waste management • Improves all human and technical-economical factors

Co-processing is a THE alternative to save our environment and improve industry ecological footprint

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Co-processing must be specifically positioned in the Waste Management Hierarchy as a combined option to recover mineral and organic parts of the wastes

Avoidance & Reduction

Reuse

Recovery

Co-processing

Incineration / co-incineration with energy recovery

Landfilling

100 % Energy recovery

100 % material recovery

Recovery

Disposal

Main drivers: - Life Cycle Assessment - Decision tree process

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UN/TG’s on Co-processing: A complete value chain approach.

• Acceptance criteria. • Waste pre-qualification • Quality Control minimum requirements • Waste acceptance and reception • Storage requirements • Pre-processing

• Operational and environmental controls • OH&S • Design Safety

• Co-processing • Operational • Environmental controls • OH&S • Design Safety

• End product quality

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How to proceed in India ….. ? Some Recommendations.

• Co-processing represent a huge opportunity in India The lack of high quality limestone and fossils fuels will request the Indian

Cement Industry to diversify its resources needs towards LGR – Low Grade Resources - as Wastes !!!

• At federal and local levels, India must adapt the UN TG’s to local conditions So far, the co-processing permitting process is a nightmare, long and complex. It must be “simplified” without compromise on OH&S, Environment, Product

and process quality

• The Cement industry must anticipate the future legal frame Start wastes – to – AFR QC systems – investing in specific environmental lab’s Start emission monitoring with systematic reporting to public and authorities. Promoting communication and sensitization activities with key stakeholders

(Communities, NGOs, Academics, etc.). Implementing external auditing system by independent experts: for example

to edit and publish, for each site, a yearly report on pre and co-processing activities

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Co-processing legal frame & permitting Proposed bases for implementation (1 / 4)

Plant Homework Prior Permit demand …

• Wastes to AFR organization on place • Wastes markets overview • Clinker process know-how and assessment done • Pollutants balances on traditional fuels and RM known and published • Emission monitoring on place

• Generic AFR acceptance criteria’s fixed based on market possibilities and process capabilities (Pollutants balances & process audit / optimization)

• Wastes to AFR pre-processing activities foreseen and regulated if needed • DRE trial burn if pop’s related wastes are concerned

• Continuous emission monitoring for dust, Nox, SO2, VOC • Emission detailed control at least once a year by an agreed lab: all

pollutants, HM, D/F etc…

• Leaching test on place for end-product to prove their acceptance for drinking water application

• Yearly site specific audit and report on wastes (pre & co-processing) activities done by an expert accepted by all stakeholders (population, authorities, etc…)

• Audit publication to all stakeholders

Permit key topics

• Wastes / AFR acceptance criteria’s

• Environmental Monitoring

• End-product control

• External Audit and

Reporting

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Co-processing legal frame & permitting Proposed bases for implementation (2 / 4)

1 – Prerequisites – Homework

• A strong “Wastes – to AFR” organization on place • Environmental performances on track, known and published • Pollutants baselines balances known and published

Baseline: Pollutants concentration and comportment using fossils fuels and natural RM.

• Permitting process for generic AFR families (solid, liquid, sludge's …..) When a trial burn will be requested: only for pre-processed AFR – not

for each type of waste. A trial burn will be site / process specific.

• Yearly independent external audit for all wastes management activities • A communication strategy on place and started

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Element

Examples for Stricter Limit values (kg/ton.cl)

E = environmental equilibrium H = occupational health P = industrial process Q = quality of clinker

Antimony (Sb) Arsenic (As) Beryllium (Be) Cadmium (Cd) Chromium (Cr) Fluorine (F) Cobalt (Co) Mercury (Hg) Lead (Pb) Nickel (Ni) Selenium (Se) Tellurium (Te) Thallium (Tl) Vanadium (V) Zinc (ZnO) Strontium (SrO) Baryum (BaO) Phosphorus (P2O5) Titanium (TiO2) Copper (Cu) Sulphur (SO3) Chlorine (Cl) Na2O-cq

3.3 0.27 0.091 0.0078 0.10 0.53 0.10 0.0016 0.37 0.13 0.077 0.45 18x10-6 0.66 10 5 5 10 10 1 7.5 0.25 10

E E E E H E H E E E E E E E Q Q Q Q Q Q P P P

Radioactivity (Ra-226+Th-232)

260 Bq/kg

E

To be noted: • Figures to be considered

as examples (5 stage preheater – precalciner kiln)

• Those limits must be fixed In-situ, case by case during the permitting process based on pollutants baselines analysis

• So, case-by-case, it will be possible to estimate criteria’s for AR acceptance for a specific kiln.

Example for Mineral Pollutants Limits Order of magnitude …for E-H-Q-P factors

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Co-processing legal frame & permitting Proposed bases for implementation (3 / 4) 2 - Wastes to AFR: Acceptance criteria’s

• Full traceability: from Cradle to Grave • No compromise on OH&S, Environment, Product and Process quality • Same acceptance processes for non hazardous and hazardous wastes • All types of wastes potentially acceptable • Banned wastes list fixed in the TG’s • Pre-processing is a prerequisite

Specific legal frame and boundaries to be fixed for pre-processing activities Avoiding for example to play on “dilution” effect to reduce the environmental

performance of the waste treatment

• Acceptance criteria’s fixed case-by-case via In-Situ pollutants balances • For pop’s related wastes: a DRE will be required prior permitting • A specific process to “certify” Cement operation for pop’s related wastes

treatment should be envisaged

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Pre-Processing: Key challenges is to transform inhomogeneous waste into homogenous AFR for co-processing…

Waste

AR

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From Waste to AFR: The Pre-processing operations are generally mandatory and must be regulated

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3 - Emissions limits, monitoring & reporting • Emissions Monitoring systems

Continuous for dust, Nox, SO2 and VOC At least once a year for all other parameters (HM, D/F ...) Compliance analysis & Reporting

• For pop’s related products a DRE trial burn is requested with results > 99.9999 % destruction efficiency

• Emissions limits similar to wastes incinerators – Exception for clinker process specific parameters as Nox … fixed by the clinkering process conditions (BAT around 500 mgr./Nm3) CO, Sox, VOC: as those emissions are specifically coming from raw materials, the local

authorities must fixed limits values based on in-situ baselines realized with traditional fuels and raw materials.

4 - End-Product Control • Cement End-product must fulfill criteria's applicable for drinking water

applications

Co-processing legal frame & permitting Proposed bases for implementation ( 4 / 4 )

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Emissions limits – EU example … for “co-incineration” “co-processing”

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AFR Waste-based Alternative Fuels and

Raw Materials

Co-processing: a win-win-win solution for Indian Cement sector

Clinker Manufacturing

Cement Manufacturing

Concrete and Building Products

Production

AAgg. (CDW for CP)

Synthetic MIC from LGR & waste

New binders AR & waste-based with low CO2

Advanced waste processing - BAT - thermal (gas/py) - Upgraded pre-proc.

…..

Alternative aggregates - Urban quarrying - CDW - IBA

......

AMICO BFS, fly ash, nat. Pozzolana,

limestone

AR

Binder

1. To decrease its environmental footprint using Alternatives and Low Grade Resources 2. Increasing its competivity. 3. Provide Locally Wastes Management Solutions including for hazardous wastes and pop’s

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• Cementis and partners as Alterros have more than 25 years of experiences in Industrial Ecology, wastes and low grade resources management, preparation and use of wastes as Alternatives Fuels, Alternatives Raw materials and Alternatives binders

• For Cement operator, we can propose, develop and support their strategy and business development on AR

• For countries, regions or collectivities levels, we are able to offer a safe, secure and environmentally sound way of solving wastes concerns, from MSW to highly hazardous wastes as pop’s

• To propose, promote and implement specific legal frame, lobbying and communication

www.cementis.com www.alterros.com

Thanks you … Do you have some question ?