Transcript Hazardous Waste Minimization - Comptroller and Auditor

Hazardous Waste Minimization :
Recycle and Reuse
Dr. Rakesh Kumar
Paradigm Shift in Business Scenario
• Competition is Global
• Competencies are Global
• Technology and Finance will
become lesser Issues
• Speed gives competitive
advantage
• Global Outsourcing
Business Scenario
• Fast changes in structures
• Management Technology is
within the reach of every one
• Knowledge improvements are
high
• Intelligent Work Force
• Growing Customer
Expectations
• Brands disappearing
Changing Business Scenario
• Env. Aspect: element of an organization’s
activities, products or services that can
interact with the environment
• Env. Impact: any change to the environment,
whether adverse or beneficial, wholly or
partially resulting from an organization’s
activities, products or services
Polluter Pays Principle
Precautionary Principle
THE HAZARDOUS WASTES : (MANAGEMENT AND
HANDLING) RULES, 1989, (as amended, May, 2003)
(14) “hazardous waste” means any waste which by reason of
any of its physical, chemical, reactive, toxic, flammable, explosive
or corrosive characteristics causes danger or is likely to cause
danger to health or environment, whether alone or when in
contact with other wastes or substances, and shall include(a)
wastes listed in column (3) of Schedule-1;
(b)
wastes having constituents listed in Schedule-2 if their
concentration is equal to or more than the limit indicated in the
said Schedule; and
(c)
wastes listed in Lists ‘A’ and ‘B’ of Schedule-3 (Part-A)
applicable only in case(s) of import or export of hazardous wastes
in accordance with rules 12, 13 and 14 if they possess any of the
hazardous characteristics listed in Part-B of Schedule 3.
Explanation: For the purposes of this clause, (i) all wastes mentioned in column (3) of Schedule-1 are
hazardous wastes irrespective of concentration limits given
in Schedule-2 except as otherwise indicated and
Schedule-2 shall be applicable only for wastes or waste
constituents not covered under column (3) of
Schedule-1;
(ii) Schedule-3 shall be applicable only in case(s) of import
or export;
IN THE SUPREME COURT OF INDIA CIVIL ORIGINAL JURISDICTION
WRIT PETITION NO. 657 OF 1995
Research Foundation for Science
Technology National Resource Policy
Appellant (s)
Versus
Union of India & Anr.
Respondent (s)
(With SLP (C) No. 16175/1997 & C.A. No. 7660/1997)
ORDER
October 14, 2003
70.13. (13) RE: National Policy Document on Hazardous Wastes:MoEF is directed to either itself or through the CPCB or any other agency
draft a policy document on hazardous waste generation and its handling within
the country. While examining this aspect the following recommendations of
the HPC would be kept in view:
“The policy document should emphasise a commitment to the recycling of
wastes an materials, and propose incentives for encouraging and supporting
recycling. Industries must be given a clear message that they must show
concrete and tangible results as far as prevention and reduction of wastes are
concerned. If they do not, they should be made to pay a waste generation tax.
The policy document should enunciate a doctrine of partnership between
SPCBs, entrepreneur and other stakeholder like the community, which will
involve working together on monitoring, preventing and reducing hazardous
waste generation. The policy should review further growth of non-ferrous
metallic waste, waste oil and used lead acid battery recycling in the SSI
sector.”
What is Hazardous Waste?
• Anything that contains some inherent
property that renders it dangerous
• Commonly:
– Toxic
– Corrosive (pH under 2.5, and over 12.5)
– Ignitable (flash point <100F)
– Listed by As Hazardous
Industrial Process
Raw Materials &
Labour
Products
Energy
Waste heat
Water
Money
Waste water
Business Definition of Waste
“Anything other than the minimum amount
of materials, parts, space, equipment and
worker’s time which are absolutely
essential to add value to the product.”
Changing Scenario
Market
Product
s
Raw Materials
Energy
Industry
Waste
Heat
Water
Money
Beneficiation
Plant
Waste
Water
Waste Minimization
Improved business practices, procedures,
and processes which increase the
probability of survival and reduce any type
of waste.
“By Any Other Name...”
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Pollution Prevention
Waste Reduction
Cleaner Production
Source Reduction
Tools
Environmental Planning
Environmental Management System
Environmental Audits
Environmental Audit
A systematic, documented verification
process of objectively obtaining and
evaluating evidence to determine whether
specified environmental activities, events,
conditions, management systems, or
information about these matters, conform
with audit criteria, and communicating the
results of this process to the client.
Types of Environmental Audits
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Compliance Audits
Environmental Management Audits
Due Diligence Audits
Supplier audits (such as waste contractors)
Programme Audits (such as waste
minimization or energy)
• Single Issue Audits (such as noise or waste
management)
• Risk Audit
Compliance Audits
• Verifying compliance with:
– Applicable Regulations
– Standards & Guidelines
– Corporate Policy and Objectives
– Control and Monitoring Procedures
• useful precursor for full environmental
audits
Due Diligence Audits
• Typically carried out for prospective buyer or
seller of industrial land (particularly mergers,
acquisitions and divestitures)
• Liabilities discovered by audit can:
– reduce properly value
– lead to exclusions
– cancel deal
• Auditors task is to uncover bad practice or
discover environmentally damaged areas
Supplier Audits
• Reviews environmental practices and permits
• Confirms that suppliers conform to customers
requirements
• Ensures that suppliers maintain records and
may lead to the adoption of controls which
would not ordinarily be implemented
Programme Audits
• Systematic review of progress and
achievements
• An audit of a waste minimization
programme would:
– examine waste generated by a site
Programme Audits Cont...
– identify viable actions for reuse, recycle, or
reductions
– make recommendations for prioritized
programme
• Return audits would confirm whether
objectives and targets were achieved
Single Issue Audits
• Detailed examination of a particular issue
• A noise emissions audit could
– identify all noise sources
– establish whether emissions were in breach of
law
Waste Reduction Audits:
• Question: How can waste be minimized?
• Steps in a waste reduction audit:
– First: Target individual processes
– Second: Analyze processes
– Third: Identify reduction alternatives
– Fourth: Consider the cost/benefit ratio for each
alternative
– Fifth: Select the best options
Establish Audit Team
• Team Leader: Highest Level Possible
Broad-based Support
• Champion:
Visible within Prod. Area
Respected and Trusted
• Team:
Technical/Business Expertise
Environmental Manager
Production Supervisor
Purchasing & Accounting
Health & Safety
Legal
Process Engineer
Line Workers
Quality Control
R&D
Outside Assistance
Collect Pre-Assessment Information
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Process Flow & Equipment Layout
Production Information
Information on Raw Materials & Quantity
Environmental & Regulatory Information
Wastes & Costs
– Full or Life-cycle Cost
• Handling
• Liability
• Lost Raw Materials
Disposal
Treatment
Process Analysis
• Create a simple diagram of the process by
talking to process engineers
• Follow the process from beginning to end
• For each unit operation, identify material
inputs, products, and waste products;
procedures; schedules; policies; etc.
• Obtain quantitative info on materials and costs
• Talk to operators: ask questions; explore their
ideas for ways to do it differently
• Ask why? why? why? why? why?
Plant Tour
• Monitor Operations
• Interview Operators and Supervisors
• Document Findings with Notes,
Drawings, and Photos
• Observe Housekeeping
• Assess Organizational Structure and
Coordination
• Assess Administrative Controls
Develop Process Flow Diagram
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Show Manufacturing Processes
Show Order & Relationship of Steps
Show Raw Materials & Quantities
Show Wastes & Quantities
Brainstorm Waste Reduction Options
• Team Process
• Collect All Ideas Without Criticism
• Use All Resources
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Employees
Trade Associations
Vendors
Publications & Trade Journals
Technical Assistance Programs
Consultants
Waste Minimization Techniques
Source Reduction
Product
Changes
Input
Material
Changes
Source
Control
Technology
Changes
Recycling
On-site/Off-site
Use &
Reuse
Good
Operating
Practices
Reclamation
Source Reduction
Inventory
Control
Good Oper.
Practices
Employee
Training
Spill Control
Segregating
Waste Streams
Efficient
Production Scheduling
Input Mat’l
Substitutions
Product
Changes
Technology
Changes
Process
Changes
Equipment
Changes
Evaluate Each Stream for:
Substitution of non toxic materials
Substitution of less toxic materials
Reformulation to eliminate toxics
Modification of production process
Changes in material usage
 inventory control
preventive maintenance program
Waste Minimization
Source Reduction - Purchasing
Limit the amount you order.
Do not stockpile chemicals.
Rotate stocks to use chemicals before
shelf-life expires.
Keep up-to-date inventories and avoid
ordering chemicals.
Waste Minimization
Source Reduction - Purchasing
Do not accept excess chemicals or “free”
chemicals.
Investigate use of pre-weighed packages
from chemical vendors.
Waste Minimization
 Reclaimation
If waste contains precious metals waste
stream may be a valuable byproduct. i.e.
Silver recovery systems. Consider
installation of reclaimer.
Waste Minimization
Mixed Wastes
It is much easier to dispose of individual
wastes streams.
Do not mix wastes i.e. radioactive,
hazardous, nonhazardous or RMW.
Do not mix halogenated with nonhalogenated solvents.
Do not mix solvents with aqueous waste.
Technical Feasibility Questions To Be
Asked
• Is the equipment available commercially?
• Are there other successful applications of this
equipment similar to yours?
• Can the vendor provide referrals that you can
contact?
• Will product quality be affected?
• Is the problem just being shifted to another
medium or location?
Economic Feasibility
Capital Costs
Purchased Equipment
Materials
Installation
Utility Connections
Engineering
Start-Up and Training
Other Capital Costs
Total Capital Costs
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Incremental Annual Operating Costs
Disposal Costs
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Raw Material Costs
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Other Costs
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Operating Cost Savings
Payback Period (in years)
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(Total Capital Costs/Annual Net Operating Cost Savings)
Include All Costs
• Waste Disposal (That’s Obvious)
• Cost of Raw Material Replacement
• Compliance Costs
– Permitting
– Reporting
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Record keeping
Monitoring
Insurance
Workman’s Compensation
Potential Liability and Penalties
Less-Tangible Benefits
– Example to Industry
– Employee Relations
Audit Report:
Identification of types & amounts of
waste.
Description of the process that
generates it.
Amount of waste generated per unit of
production.
Estimate of costs for managing waste.
List of technically feasible measures.
Audit Report:
Estimate of anticipated waste reduction
achievable using technically feasible
measures.
Implementation schedule.
Research & Development programs
Estimate of waste transferred to other
media.
Facility Waste Reduction Policies.
Description of Training Program.
Life Cycle of Waste Reduction
Assess
Options::
Identify
Options:
Investigate
Opportunities
Implement
Options:
Sustain & Expand
Waste Reduction
Remember
Try your best to integrate
environment into business practices
Resource efficiency is
the route and not goal
for environmental compliance