Guidelines to prepare Environmental Statement for …

1 Ents Section One t 1 Notification on Eav' .. 1 Why Environment .. 2 2 Steps to prepare Environnie .. 3 Formation of an Environmental Examination Team .. 3 Diagrams .. 4 Material Balance: Process Inputs and Outputs .. ompounds .. 6 6 ste Reduction Measures .. 6 te Reduction Measures .. 8 Waste Reduction Options . 8 Contents of the Environmenta .. Listing of Unit Operations and Constructing Process Flow Synthesis and Iden n of Avenues for Waste .. menting An Actio0 Plan : and Increasing Praduction 9 .. Law 10 45 Ensuring Compli .. 10 The Environmental Statement for Indian Industries .. 11 15 23 Section Two : FORM - V .. Section Three : How to Complete Appendix A : SIC Codes .. 33 Appendix 3 : Waste Type Cod .. 35 Appendix C : Process or rces Codes 1 37 Appendix D : Categ us Wastes .. Appendix E : Economics Keyword Codes .. 39 CESE, JIT Bonibay 1 .O A Notification on Environmental Statement has been published by the Ministry of Environment and Forests on 28* April, 1992 under which every person(s) carrying on an industry, operation or process requiring consent under Section 25 of the Water (Prevention and Control of Pollution) Act, 1974 (6 of 1974) or under section 21 of the Air (Prevention and Control of Pollution) Act, 1981 (14 of 1981) or both or authorization under the Hmdous Waste (Management and Handling) Rules, 1989 issued under the Environment (Protection) Act, 1986 (29 of 1986) shall submit an Environmental Statement for the financial year ending the 31st March in Form V to the concerned State Pollution Control Board on or before the 31st day of May every year, beginning 1993l.

2 Notification on Environmental Statement Why Environmental Statement ? In the present times of increasing resource crunch, stringent Environmental regulations and increasing global competition, industries are forced to optimize the production processes and minimize the pollution, While regulations at the end of the pipe are useful in lending a pressure on the pollttthg industrial units, the administration of Environmental Audits becomes a more effective step Mwe to its preventive or p as well as due to its inherent link with the production technologies. Although, the mandatory ent is limited to filing Form V with the concerned Pollution Con oard, an intensive Environmental examination of the industry precede and form the basis of filling the form, This exercise should be used as an opportunity for self- introspection for the improvement of the industry's operating practices and to identify avenues for waste reduction.

3 'For this year viz. 1992-93,this date has been set to September 30, 1993. Environnienral Statement for Indian Industries 1 CESE, IIT Bontbny Formation of an Environmental Examination Team Process Flow Diagrams rjv Listing of Unit Operations and Constructing us Material Balance: Process Inputs and ms Synthesis and Identification of Avenues for outputs Waste Reduction - Ensuring compliance with law 2 Contents of the Environmental Statement In the Environmental Statement every industry is required to provide information on its production, water and raw material consumptiqn, pollution discharged and hazardous and solid wastes generated along with their disposal practices. The industries are also required to specify the impact of the pollution control measures on the conservation of (natural) resources and consequently on the cast of production. This implies that if the industry is recovering any resour.:es/by-products for reuse through its treatment facilities, which results in conservation of resources (say water, energy or raw material) the same is expected to be reported.

4 For instance, if the industry is reusing the treated wastewater for gardening purposes, this may result in reduction in overall water consumption and thus the unit cost of production will be lowered. The industry is also expected to provide particulars about additional investment proposal (if any) for Environmental protection Le. upgradation/expansion of treatment facilities, modification in production process t educe pollution etc. Steps to prepare Environmental Statement A systematic approach to prepare an Environmental Statement may be described in terms of four distinct phases listed and elaborated below : 2 CESE, IIT Botnbay Formation of an Environmental Examination Team Typically Environmental Examination Team (EET) comprises Environmental Manager, Plant Manager, Safety Officer, Managers and/or Chief Operators from various process sections. This team may be formed with the help of an external consultant and under the direction of the Chief Executive Officer (CEO).

5 In a Small or Medium Scale Enterprise (SME), many of the above responsibilities may be borne by only a few persons and the composition of EET shall be essentially different than that mentioned above. The owner of the SME unit need to take an initiative in such a case to identify the personnel from amongst the staff to form such an EET. The persons identified should be well conversant with the production process and waste generation aspects of it. Listing of Unit Operations and Constructing Process Flow Diagrams This step is strongly recommended as it gives a good insight into the production operations/process vis-a-vis sources of waste generation and hence enables identification of avenues for better operating practices and waste reduction. To develop a good representative block process diagram the EET should undertake a detailed walk-through the works and utilities area. An initial site survey should include a walk around the entire manufacturing plant in order to gain an understanding of all the processing operations and their inter-relationships.

6 The production or plant staff are likely to know about waste discharge points, unforeseen waste generating operations such as spills and washouts, and can give the team a good account of actual operating situation, The information to be collected includes site plan; process description and flow diagram; stores records giving information on raw material consumption; water use data; waste treatment and disposal costs (which in turn may lead to some estimation of quantities of wastes generated) and practices. For instance, the inforination on soild/hazardous waste generation including the sludge generated from Effluent Treatment Plant (ETP) and its disposal practices need to be compiled. Environntental Statetiwit for Indian Iiuiustries 3 By connecting the individual unit. operations in the form of a block diagram, a process flow diagram can be prepared. All the information compiled during this pre-assessment stage should be presented on the block diagram thus developed.

7 The input and output information for each unit operation should be summarized in standard units by reference to the process flow diagram. Standardized color coding may be used to represent raw material inputs say by a black line, products by blue line, wastes by red lines and recycled stream by green lines. Intermittent operations such as cleaning, make-up or tank dumping may be distinguished by using broken lines to link the boxes. Similar notation may be used to distinguish batch and continuous discharges. A typical process flow diagram developed with the foregoing points for a Electroplating Process unit is as presented in Figure 1. The information generated at this stage would enable the Part A of the Form V to be completed. It also serves as pointers for further detailed sampling/data collection required to firm up this information and lend focus on the Material Balance exercise to be taken up next. For example one may judge some industrial unit; say a dyeing unit or paper and pulp after its pre-assessment phase to be more water pollution intensive than the air pollution.

8 In such case more efforts should be put in for accurate material balance in the areas of water consumption and water pollution, whefeas a lesser degree of accuracy may be acceptable as regards the air pollution. Material Balance: Process Inputs and Outputs Inputs to a process or a unit operation may include raw materials, chemicals, water, air and energy. Raw material purchases and storage and handling losses should be recorded in a table in order to derive the net input to the process. Outputs include primary product, by-products, rejects, wastewater, gaseous wastes, liquid and solid wastes which need to be stored and/or sent off-site for disposal and reusable or recyclable wastes. Environtwnml Srulrnienr jor Indion Irultrsitfes 4 CESE. 117 Biiiiibuy I Air I Unile 'I BOARDS I CARTRlOGE FILTERS City Water , - DOyClmg~l)Qll/h Process 1 - ' Droh 2 - 671 3 373 L 31L 1 biviroiiiiunral 1 3610 02 1 2350 5 2220 I Irocess Droin Woler + I 2-STAGESn Pb rc- 3-STAGE t RINSE ELECTROPLATING City Woler 1 RINSE.

9 - 2- STAGE RESIST STRIP - -co3 Sulphuric I - btl city Wotrr Peroxi de city ' 03 Process Dl 4 I t ISobn. Unite 1 BOARDS Oroh BOhRDS 1 3-STAGE RINSE BOARDS 1 I I > 1 t it Droin KEY: ouL(ps a - flowrote - E -Total Copper Concrntrotion Dl - Doily lo Process Sewer 02 - Monlhly lo Holding Tonk 03 - Doily 10 Holding Tonk Ob- Chonpc Flll~ri Ouorterly - -Continuour Dirchorgr --- *- Botch Discharge Figure 1 Process Flow Diagram for 9000 Line (Cu Electroplating Sn /Pb Electroplating Resist Strip and ?Etching ) SIWIIWIU /i,r ~iu~ii~i iirclrurties 5 CESE, IIT Botirbay Selection of Tie Compounds Selection of an appropriate tie compound for checking material balance is an important step. Criteria for selection of the tie coinpound could be - an expensive raw materiahtermediate material common in most processing stage - a substance of hazardous nature - a substancekompound easy to measure/estimate. - A simplest example could be water to account for most wet operations.)

10 But in practical situations more specific tie compounds ( Nickel or Zinc in electroplating shops) would be ideal. Chemical Oxygen Demand (COD) is another very useful tie parameter which sharpens the material balance exercise. EET can estimate contribution of each process department in terms of total COD load in kg/day knowing the volume of wastewater and its COD discharged by each department and cross checking it with the COD load observed at the treatment facilities. One need not be very fussy over the accuracy (of the order of 99%) of the material balance. In practice such high accuracies are rarely achievable and not required also. Material balance within the tolerance range of 10 % should generally be acceptable. However, if the tie compound for material balance is of hazardous nature, the higher order of accuracy should be targeted. Figure 2 shows an illustration of a completed material balance for a wood pulp bleach plant.