India - Hazardous Waste Management Project - sectoral environmental assessment (Vol. 2 of 2)

V0I . 2 Public Information and Consultation on Sectoral Environmental Assessment Report India - Hazardous Waste Mangement Project Submitted to The World Bank By Minintry of Environment and Forests New Delhi September 1997  This Report has been prepared by the Environmental Management Centre, Mumbai for Ministry of Environment and Forests, Government oflndia. The co-operation extended by the Ministy ofEnvronment and Forests, World Bank, State Pollution Control Boards ofAndhra Pradesh, Gujarat, Maharashtra, Tamil Nadu is gratefully acknowledged.  Public Information and Consultation' on Sectoral Environmental Assessment Report India - Hazardous Waste Management Project rDn Submitted to the World Bank By Ministry of Environment and Forests, New Delhi 'September, 1997  Table of Contents Executive Summnary 4 1.0 Background and Objectives 6 1.1 Sectoral Environmental Assessment 6 1.2 Public Information and Consultation (PIC) of SEAR 7 1.3 Objective of the PIC for SEAR 7 2.0 Organization of the PIC 8 2.1 Methodology and Approach 8 2.2 Non-Technical Summary (NTS) 8 2.3 Draft Sectoral Environmental Assessment Report (SEAR) 9 2.4 Public Announcements 9 2.5 Participants for PIC 9 2.5 Post PIC Activities I0 3.0 Public Information and Consultation at GPCB 11 3.1 Obsevaions at the PIC at GPCB 12 4.0 Public Infomation and Consultation at APPCB 17 4.1 Observations at the PIC at APPCB 18 5.0 Public Infonnation and Consultation at MPCB 21 5.1 Observations at the PIC at MPCB 23 6.0 Public Wormation and Consultation at TNPCB 29 6.1 Observations at the PIC at TNPCB 31 7.0 Public Information and Consultation at MOEF 35 7.1 Observations at the PIC at MOEF 36 8.0 RecommIendations of the PIC 42 PlC on SEAR 2  List of Annexes Annex 2-i - Guidelines issued for conduct of the Public Information and Consultation Annex 2-2 - Non-Technical Summary of the Sectoral Environmental Assessment Report Annex 2-3 - Copies of the Non-Technical Summary in local languages Annex 2-4 - Newspaper Inserts and Articles Pre and Post PIC Annex 2-5 - List of Paticipants Annex 2-6 - Format used for Recording Questions / Comments during PIC PICoan SEAR 3  EXECUTIVE SUMMARY The Sectoral Environmental Assessment (SEA) is a tool recommended for planning environmentally sound sector-wide investments. SEA avoids the inherent limitations of project specific EAs by moving upstream in the planning process to a stage where major strategic decisions have not been made. The Ministry of Environment and Forests prepared a draft SEA Report on the proposed Hazardous Waste Management Project under the assistance of the Enviromnental Management Centre (EMC), Mumbai. This draft report led to development of the project design (in terms of components and sub-projects) and the associated process guidance framework, recommended to eliminate, mmimize and contain any residual risks/impacts. The preparation of SEAR itself was a consultative exercise and was an outcome of four strategic planning workshops at the State Polution Control Boards (SPCBs), a workshop on Identification and Management of Riis, Procurement related meetings and several missions of the World Bank with the stakeholders. In February, 1997, a draft SEAR (version 1.0) was prepared and was subsequently reviewed and commented by the World Bank. A second draft of SEAR was prepared in August, 1997 (version 2.0) in response to these comments and to absorb the evolving project design. PIC is an integral part of the Environmental Assessment (EA) process. However, the level of the PIC activity is governed by the type of the EA process being conducted. Since SEA normally covers an entire sector (in a national or sub-national context) and is conducted before concrete investment decisions are made, it may not always be possible to consult representatives of al potentially affected people during preparation of the SEA. Often it is more feasible and appropnate to carry out consuations with national NGOs (for example, for natural protection) scientific experts, relevant government agencies, and perhaps also indusial and commercial interests. A successfully implemnted consultation process also helps ensure public support for the final sector program. With these objectives in mind, the MOEF under the assistance from the EMC organized PIC of the draft SEAR (version 2.0) at Gandhinagar, Gujarat; Hyderabad, Andhra Pradesh, Mumbaa, Maharashtra; Chennai, Tamil Nadu and New Delhi The PlC meetimgs were organized between the period of August 14 to September 4, 1997. On the whole, the PIC meetings were well received and in all 222 participants attended representmg NGOs, Government bodies. Research and Academic Institutions, Financing Institutions, Consultants, Media Persons, Environmental lawyers. This report summarizes the approach followed, documents prepared as well as the observations made in the meetings along with salient recommendations. PIC on SEAR 4  The PIC exercise helped in many ways. First of all, it made a clear delivery of the project and its concept to the critical mass of the stakeholders. In this process, some of the initial apprehensions towards the project and its concept got resolved due to discussions and better communication. Secondly, PIC gave an opportunity to serve as a sounding board to the project design strategy and process guidance famework as evolved in SEAR. Many of the recommendations made were in fact supportive to the overall project content, implementation anagements as wel as the process guidnce framework. Tidly, the PIC led to some addiional recommendations and suggestions which were very useful in finalizg the project design as well as the SEAR. Most of the these recommendations have been reflected in the final SEAR to lend a final shape to the project design and the process guidance frvaework. PIC on SEAR 5  1.0 BACKGROUND AND OBJECTIVES 1.1 Sectoral Environmental Assessment The Sectoral Environmental Assessment (SEA) is a tool recommended by the World Bank for planning environmentally sound sector-wide investments. SEA avoids the inherent limitations of project specific EAs by moving upstream in the planning process to a stage where major strategic decisions have not been made. The Operational Directive 4.01 of the World Bank states that SEA is particularly suitable for reviewing (a) sector investment altematives (b) the effect of sector policy changes; (c) institutional capacities and requirements for environmental review, implementation and monitoring at the sectoral level; and (d) the cumulative impacts of many relatively small, sirmla investments that do not ment individual project specific Environmental Assessments. The objective of SEAs is also to strengthen the environmental management capability of the sectoral or other relevant agencies. In accordance with the requirements of the World Bank, the Ministiy of Environment and Forests (MOM, New Delhi prepared a SEAR, with the assistance of Environmental Management Centre (EMC), New Delhi for the proposed Hazardous Waste Management Project. The objective of the Hazardous Waste Management Project, supported by the World Bank, is to assist Govemment of India in the mplemetation of a modem and sustainable hazardous waste management system in the country. The project wM help in modeizing the regulatory framework, strengthening the institutions in cnarge of enforcement and monitoring, and financing prionity investments in hazardous waste mitigation, treatment, and disposal. The specific goals are to: (i) promote the development of a comprehensive monitoring and enforcement system for timely implementation of the hazardous waste rules and other legislation concerning the management of hazardous wastes; (ii) assist in the implementation of priority investments in hazardous waste management; and (iii) provide technical assistance for the tramining, technology development, and awareness programs in hazardous waste management and support for the development of background data for policy-making. PIC on SEAR 6  1.2 Public Information and Consultation (PIC) PIC is an integral part of the Environmental Assessment (EA) process. However, the level of the PIC activity is governed by the type of the EA process being conducted. The EA Sourcebook update of the World Bank on SEA' states the folowing. "since SEA normallv covers an entire sector (in a national or sub-national context) and is conducted before concrete investment decisions are made, it may not alwrys be possible to consult representatives of all potentially affected people during preparation of the SEA. Often, it is morefeasible and appropriate to carry out consultations wtth national NGOs (for example. for natual protection) scientific exp ers, relevant government agencies, and perhaps also industrial and commercial interests. A successful1y implemented consultation process will help ensure public supportfor thefinal sectorprogram." The PIC of SEAR was conducted at four state SPCBs viz., Andhra Pradesh, Gujarat, Tamil Nadu and Maharashtra, and the Mnistry of Environment and Forests (MOEF). Since, at this stage, the details of the individual sub-projects have not yet been find, selected representatives were invited to participate in the PIC. The recommendations emerging from the PICs have been appropriately reflected in the SEAR. 1.3 Objective of the PIC for SEAR The main objective of the PIC for SEAR was to convey the spirit, design and content of SEAR with specific reference to the management of hazardous wastes in India. The focus of the PIC was on the project as a whole rather thm on ind ual sub-projects as at the stage of SEA, details on the sub-project are not avaiable. independent public participation activities would require to be conducted for each of the sub-projects after the PIC for the SEAR, as and when each sub-project is planned and designed. While. this rTeport provides the proceedings and minutes of the PIC, some of the usefill suggestions and recommendations made, have been reflected appropiately in the SEAR. This has benefited to a significant extent the project design and the associated process guidance framework. 'Envue=m l Asmesant Sourcebook Update No. 4, Sctoral Envro=a Asesn, Envi Quem Depaunment, le World BanrA, October :993. PIC on SEAR 7  2.0 ORGANIZATION OF THE PIC 2.1 Methodology and Approach The PIC was designed to be a half day long programme and its conduct involved three stages of activity which were undertaken by the SPCBs, MOEF and the Environmental Management Centre, (EMC) Mumbai. At the outset, EMC prepared guidelines for the PIC which were sent to the four SPCBs and the MOEF. A copy of the guidelines is enclosed as Annex 2-1. The three stages of activity for the PIC were: * Preparation for PIC which included identification of the communication techniques, list and composition of the participants, * Conduct of PIC which led to a practical plan for implementation of the PIC programme; - Reporting of the PIC included recording the discussions and reflecting them appropriately in the fialization of the SEAR. The preparatory stage involved preparation of the relevant documents, identifying the critical participants and makig logistic arrangements for the conduct of PIC. Group meeting with handouts was considered as the public participation technique suitable for meeting the objectives. 2.2 Non-Technical Summary (NTS) To facilitate public dissemination of the contents of the SEAR, a Non-Technical Summary (NTS) of the SEAR, was prepared by EMC and sent to SPCBs and the MOEF. A copy of the NTS is enclosed as Annex 2-2. The NTS is a summay of the main findings and conclusions of the study and how they were reached. The NTS avoids to the extent possile, technical terms, lists of data and detailed explanations. The objective of the NTS was to convey the spirit, design and content of the SEAR The NTS was made avaiable in Englsh and was translated into Maratbi, Telugu and Tamil at Mahaashra PCB, Andhra Pradesh PCB and Tami Nadu PCB respectively. The copies of the NTrS m these local languages are enclosed as Annex 2-3. Copies of the NTS were sent to all the intees and additional copies were made avaiable at the SPCB and MOEF offices for anyinterested citizen for review and making anywritten comments. PIC on SEAR 8  2.3 Draft Sectoral Environmental Assessment Report (SEAR) A copy of the draft SEAR (Version 2.0), prepared by MOEF with the assistance of EMC, was provided to the SPCBs. Copies of this SEAR were made available at the office of the SPCBs and MOEF to all stakeholders who might be interested in reviewing the entire SEAR. 2.4 Public Announcement For the dissemination of NTS and obtaining comments, a public announcement of the project was made in: * the Times of India on August 16 and Sandesh, a regional daily in Gujarati on August 14, 1997, by GPCB * the Hindu on August 16, 1987 and Vartha, a iegional daily in Telugu on August 13,1997 by APPCB * the Times of India on August 26,1987 and Saamna, a regional daily in Marathi on August 13, 1997, by MPCB - the Nes Today, Indian Express and Financial Express on August 22, 1997; in regional dailies in Tamil viz., Dina Thanthi, Malai Munsu, Dinamalar on August 22, 1997, by TNPCB. Copies of the inses, as they appeared in the four states is placed in Annex 2-4. Several izens made requests to SPCBs to issue the NTS based on these public notices. Some citizns sent written comments to the SPCBs based on the review of the NTS. 2.5 Participants for PIC Selected re tatives were invited to participate in the PIC. These stakeholder included representatives from Government Agencies such as, State Department of Environment, Industrial Development Corporations, Dirtorate of Industi Safety and Health" Customs department. and Transport Commssioner's Office; Industry Associations/ Industries; Research Institutions / Academe/ Health Professionals; Reputed Waste Management Consultans; Media persons; Leading NGOs Envronmental awyers and Financing Insdtutions like Bank of Baroda (BOB). Industrial Credit and Investment Corporation of India (ICICI) etc. A ist of the participants at all the five PICs is enclosed in Annex 2-5 with their signatures for attendance. In all, across all fte five PICs, 222 participants attended. PlC on SEAR 9  2.6 Post PIC Activities All the SPCBs allowed three days after the PIC for written responses/ suggestions from the participants on the NTS as well as the SEAR. Prior to and Post PIC, cormmunications were received in writing from Mr. AK Ratdi, Director, Dept. of Forests and Environment, State of Gujarat; Dr. KS. Sivasubramaniuo, Manager GIS, Fugro-Genoics, Navi Mumbai and Bharat Jairaj, Legal Coordinator, Citizen's Action Group, Chennai The Times of India covered the PIC at Mumbai and featured two articles called hMajor Waste Disposal Project to start Soon August 28, 1997 and "Maling the Polluter Pay and Prosper September 1, 1997". These two pieces have been included in Annex 2-3. Many of the recommendations made in the PIC were already incorporated in the second draft of the SEAR. Any additional recommendations which were considered to be useful and effective within the scope of the program were compiled and have been appropriately reflected in the fial version of the SEAR. PIC on SEAR 10  3.0 PUBLIC INFORMATION AND CONSULTATION AT GPCB The PIC was conducted at Hotel Haveli, Gandhinagar on August 14, 1997. The participants for the PIC at GPCB primarily included representatives from the NGOs, government agencies and research insiutes. The progamme of PIC was as follows, 10.30 hr. Opening Remarks and Welcome Mr. J.M. Barot, Member Secretary, GPCB Mr. P.S. Bhatt, Chainnan, GPCB 10.45 hr. Presentation of the Sectoral Enviromental Assessment Report Dr. Prasad Modak, Environmental Management Centre (EWC) 11.30 hr. The Hazardous Waste Management Project - A State Perspective Mr. J.M. Barot, Member Secretary, GPCB 11.40 hr. Address by Mr. Rang8durai, Additional Chief Secretay, Environment and Forest Dept., Government of Gujarat. 11.45 hr. Question and Answer Session 13.30 hr. Close In their opening remarks, both the Chairman and Member Setary emphasized on the need to keep the publc mformed and imvolve the community at large in maaging the problem of hazardous waste. Creatmg awaress amoug industies regardig the costs of clean up or remediation was recognized as an area that needed attention. An appeal was made that there is a need for NGOs and other stakeholders to cooperate with the GPCB in managMg a complex problem such as hazadous wastes. An increasig concern of the Board with respect to the illegal import of hazardous waste was also expressed. The SEAR was presented by Dr. Prsad Modak of the Environmental Management Centre. This focus of this brief presentation of the SEAR was maintained on the philosophy of sectoral assessment being used as a means of designing an environmentally susainable option for hazardous waste mangement. Tlis presentation provided a pespective of the project and incuded a brief description of the sectoral context which provided information on the preset status of hazdous waste manageme - legal; institonal and technical - ia the country and the need for the project. It also inchlded a biefnote on the key envom ntl and health impacts due to the preset status PlC on SEAR  of hazardous waste management; a brief project description together with the major potential benefits and risks from the project; an out'ine of the process guidance framework and the strategies proposed to mitigate the risks/impacts due to the project. A summary of the project costs and implementation arrangements were provided byway of conclusion The state's perspective of the Hazardous Waste Management Project was provided by Mr. Barot, the Member Secretary. He spelt out the various initiatives taken by the GPCB in preparation for the project. A summary of the components and the budgetary estimtes submitted by GPCB to the World Bank for the project was also briefly indicated. The session was subsequently thrown open for discussiom To ensure effective recording of the proceedings, a format (refer to Annex 2-6) was provided to all the participants to record their questions and comments. 3.1 Observations at the PIC at GPCB The proceedings of the PIC were conducted in English and the question and answer session was co-ordinated by the Chairman GPCB. NGO participation during this PIC was very strong. The comments, queries and corresponding clarifications provided during the course of the PIC are detailed below. Policy related issues * It was suggested that management of municipal solid waste and medical waste should be considered in addition to hazardous waste. * NGOs felt that a proactive approach is required on the part of the GPCB and information on management of hazardous waste and its status in the state, should be provided on a regular basis by the Board rather thian only when requested by the public. * The J.J. Mehta Commission had recommended guidelines for siting of industries. ln these guidelines, it was recommended that no habitation should be allowed within a radius of I km in the case of high disaster industries and 2 km in the case of low disaster industries. It was observed that these recommendations have not been implemented. GPCB clarified that the siting guidelnes specified by the MOEF for industries are being adopted. In the case of hazardous waste management GPCB will follow the guidelines specified by MOEF for siting of common facilities for treatment and disposal of hazardous wastes. PIC on SEAR 12  Need for accurate information on quantity of hazardous waste generated in each sector and industry wise was strongly recommended as a pre-requisite to any activity on hazardous waste management. A reliable inventory was essential for planning tools needed for management of hardous wastes. The Chairman, GPCB stated that initiatives on the part of GPCB are in progress to ensure validity of the inventorization. Waste generation factors were developed by the National Productivity Council from the types of industrial processes and products for various industrial sectors. These factors were validated through sample field studies in repesentative industries of each sector. Additionaly, GPCB together with the National Productivity Council (NPC) and a consultant, prepared a data sheet to obtain information from the 8500 hazardous waste generating iadustries in order to update the State's hazardous waste inventory. Response from industry beng poor even after two attempts to elicit information through these data sheets, GPCB was compelled to use powers granted to Cbairman under section 5 of the EP Act, 1986 and legal notices were issued. 'he flow of information upon serving this notice has improved. LegislaaVon * Most of the participas fek tat the definition of hazardous waste is not clear. It was clarified that presently hazardous waste is defined in the Indian legislation as those wastes which fall within the 18 categories specified in the Hazardous Waste (Management and Handling) Rules, 1989. However, revisons have been proposed in these Rules whereby hazardous wastes are defined with respect to ther ongm, presence m the waste stream and properties. ' The need to develop standards atnd define acceptable limts with respect to end -of-the pipe emissions from hazardous waste treatment and disposal facilities was expressed. It was clarified that the standard setting acdvity has been aleady initiated at the Central Pollution Control Board (CPCB) and under the assistance to MOEF/CPCB, these standards wil be fialized very shortly. * Disaster management systems to be considered in hazardous waste management particularly with resPect to Common Hazardous Waste Treatment and Disposal Facilities (CHWTDFs). PIC on SER 13  One of the eligibility criteria for investments under the Infrastructure Development Component or for demonstration projects under the Technical Assistance component required any investor / proponent should be registered under the Companies Act. By virtue of this all the laws and regulations mandatory for an industry are applicable on investors in this project, such as the requirement of a Disaster Management Plan. Common Hazardous Waste Treatment and Disposal Facilties * Management of landfills was considered as a significant issue. Hence site selection, design and operation must be very carefully done. * The likely exhaustion of disposal sites and hence need for additional land is an issue which needs to be considered in management of hazardous waste. In the hazardous waste management project, GPCB proposes to, prepare manuals for waste minimization, treatment and disposal site design. Exhaustion of the sites can be delayed by promoting waste minimization and by laying down pohcies regardig which waste wi go to the common sites and which waste wil have to be treated on site. The latter is especially critical for high volume low hazard wastes such as the sludges from effluent treatment plants. * It was observed that use of incinerators as a treatment option should be considered with precaution and there is a need for emission standards for incinerators. Exclusionary factors have been specified in the eligibility critena for the project, as explained in the SEAL. wherein it is specified that wastes contining halogenated compounds or mercury shall not be incinerated. * Satellite imagery may be useful in site selection for treatment and disposal facilities. * NGO representatives observed that in keeping with the Polluter Pays Principle, industry - the polluter, must contribute to the cleaning of the illegal dump sites. This maybe along the lines of the Superfunds Act enacted in the USA to remediate dump sites. It was clarified that one of the guiding principles of the Project design has been Polluter Pays. In keeping with this, the project supports only the development of a strategy for clean-up of dump sites. The onus of the actual cleaning of the sites will be on industry. * Transportation of hazardous wastes is also a significant issue and hence a strict vigilance system needs to be established. PlC on' SEAR 14  The GPCB informed that under another World Bank assistance, efforts for establishing Geographical Information System (GIS) based tracking system are already underway. Industry initiatives There is a need for industry to take proactive initiatives in providing information to the public regarding the nature of the processes in their units, the potential risks and the safety measures to be taken to alleviate these risks. Public Partcipaton * The NGOs expressed that GPCB should be proactive at the subsequent stages of the project as far as public partcipation was concerned. They should ensure that the criical sections of the community be present at public participation actvities. NGO involvement should be high since they are not adversaries but partners in developmnt. They expressed their wilingness to participate in the process of hazardous waste management and offered the services of their laboratories for any anayical work, especialy for independent assessment. However, finmcial assistance was required by NGOs, It was informed that onc of the sub-projects of the Enforcement and Compliance Component of the present project includes assistance for community outreac Training and Awareness * Need for emergency preparedness programmes to protect against potential risks due to accidents in areas where hazardous waste generators are located or baardous wate is transported/ treated / disposed, was identified. It was suggested that these programes should involve citizens' groups, emergency services and government agencies * Need to develop awareness on the correlation between occupational diseases and industrial processes both for the general public, GPCB officials nd industry. Awareness on technological innovations in hazardous waste management to be brought to industry partcularly medium and smal scale industries. It was clarified here that the project focuses on providig technical assistace to small scale industnes througb sub-projects on Waste Minimization Circles and the demonstration projects. PoC SEAR 15  Project Monitoring * A need to develop performance indicators apnion to monitor the project was identified. Additionally, expected outcomes of the project should also be delineated and the performance indicators linked to these outcomes. It was clarified that MOEF will be developing the performance indicators m consultation with the World Bank. The SEAR however recommends quarterly, semi-annual and annual evaluation reports to monitor the performance of the project. PCon SEAR 16  4.0 PUBLIC INFORMATION AND CONSULTATION AT APPCB The PIC was conducted at the EPTRI Seminar Hall, Hyderabad on August 19, 1997. The programme included: 10.00 hr. Opening Remarks and Welcome Mr. G. V. Raghava Rao, Suptdg. Engineer, APPCB 10.05 br. Introduction of the speakers 10.10 hr. Presentation of the Sectoral Environmental Assessment Report Dr. Prasad Modakl Environmental Management Centre MEA0C) 10.50 hr. The Hazardous Waste Management Project - A State's Perspective Mr. Vlshwznath, APPCB 11.30 hr. Question and Answer Session 13.00 br. Closure of PIC In his opening remarks Mr. Raghava Rao emphasized on the need to consider management of hospital / medical wastes on prionty sir to management of hazardous wastes. The need to verif and authenticate the inventory of hazardous waste in the State was also expressed. It was also emphasized that since inventonzation is a continuous process the Board aims to continuously update it. Mr. Rao also expressed that waste mininizaton and clem technology in hazardous waste management are the focal areas of APPCB. The SEAR was presented by Dr. Prasad Modak of the Environmental Management Centre. This focus of this brief presentation of the SEAR was maintained on the philosophy of sectoral assessment being used as a means of designig an environmentally sustainable option for hazardous waste management. This presentation provided a perspective of the project and incuded a brief description of the sectoral context which provided information on the present status of hazrdous wse mngent - legal istitutional and technical - in the country and the need for the project. it also included a bief note on the key envionmental and beah impacts due to the present status of hazrdous waste management; a blief project description togetber with the major potential benefits and riisks from the project; an outline of the process gidamce framewk and the strategies proposed to miuigate the risnimpacts due to the project. A summary of the project costs and mpmentaton arrangements were provided by way of conclusiot. PIC on SEAR 17  The state's perspective on the hazardous waste management project was provided by the Mr. Vishwanath, Environmental Engineer, APPCB. During the course of this presentation, details were provided regarding the status of hazardous waste generation in the State and the efforts made by the APPCB in identification of suitable sites for setting up of CHWTDFs. The nature of assistance provided by the Australian Aid (AUS-AID) for hazardous waste management in the State was also briefly described. A summay of the proposal together with the budgetary estimates for assistance from the World Bank was also presented. The session was subsequeny thrown open for discussion. To ensre effective recording of the proceedings, a format (refer to Annex 2-6) was provided to al the participants to record their questions and comments. The participants for the PIC at APPCB included representatives from the NGOs, govemment agencies, consutants and press. 4.1 Observations at the PIC at APPCB The proceedings of the PIC were conducted in English and the question and answer session was co-ordinated by Mr. Raghava Rao, Suptdg. Engineer, APPCB. Media, NGO and Industry Participation during this PIC was strong. The comments, queries and corresponding clarifications provided during the course of the PIC are detailed below. Policy Industry representatives felt that incentives shold be provided to small scale industries practicing hazardous waste mmimization t recycle I recovery. These incentives may be in the form of tax benefits or other such fiscal incentives. * NGOs considered urban waste management as an important ise to be considered as pat of hazardous waste management. Legislation and Definition of HazaivJoys Waste * Lack of clarity in the definition of hazardous waste lmder the present legislation as well as the general ambiguity of the legislation was commented upon by a number of participants. Only solids and semi-solids are considered as hazardous wastes while liquid hazardous wastes are not regulated by the Hazardous Waste (Management and Handling) Rules. 1989. * NGO representatives also expressed the view that the present nules for hazardous waste management are ambiguous. Due to the present method of categorization of hazardous PIC on SEAR  wastes, those generated below the specified tbreshold levels are not regulated. However, these are also hazardous due to their properties and need to be managed. APPCB agreed that the definition of hazardous wastes is ambiguous and needs revision. The participants were informed that The Hazardous Waste (Management and Handing) Rules, 1989 are proposed to be revised. The revisions proposed provide a more specific definition and categorization of hazardous wastes. The origin and composition of the waste streams are used to defne whether the wastes are hazardous or not. Additionally the properties of the wastes are also being used as critea to categonze hazardous wastes. The revisions have been sent to al the State Polution Control Boards for their comments and feedback. Hazardous liquid and gaseous wastes ae regulated under the Water and Air Acts. Institutional set-up NGOs expressed the need for improvement m mteraction between goverment deprtmens. Ths was an essenial requirement for success of the project. lnventonizaieon It was obseved by a participant from a commercial laboratory that development of a reiable mventory is difficult because insufficient imformin is avaiable from industry regarding waste generation. This was aributed to the ineffective methods used by APPCB to obtain information. Industry is asked to provide smlr information in various formats to differnt govem t departments. This results in a relutnce on the part of industry to provide information. It WaS also suggested that knoWing the material balace of an ikdusty the APPCB should be able to estimate the extent of hazardous waste generated. It was observed by a represntative of the Anuhra Pradesh Chamber of Commerce that althougb the industril developmt in West Godavari is lower than that m Medak and Ranga Reddy, the quantity of hazardous waste generated was reported as bigher in the forme case. APPCB clarified that the inventorzation is weak and they are m the process of verifyig this data. It was observed that the higher quantity could also be due to the fact that the technology used in some of the industrial units in West Godavari were obsolete and hence generating higher quantlties of waste vis-a-vis the more modem ulits in the other more industrialized districts. PIC on SEAR 19  Ptblic Parcidpation * Need for community involvement in rural areas and small towns rather than only in urban centres was expressed by NGOs. It was clarified that the Process Guidance Framework of the SEAR specifies the need for public involvement at two levels viz., policy leveL which is the current PIC and at the sub- project level which would mclude communites affected directly by the sub-project. In the latter case the public involvement and participation will be sought in mrual and urban areas depending on the location of the sub-project. Project Monitoing * Consulants feh that mid-term evaluation of the project was essential for which the services of NGOs and government agencies should be usd. Response to this concern was that as part of the Process Guidance Framework provided in the SEAR, the moniormg requirements of the project mclude quarterly, semi-annual and annual reports on the progress of the project. Some of the participants felt that any risks associated with the project need to be accommodated and absorbed in the project. It was clarified that the project design as well as the process guidance famework have been developed considering the risks associated with the project. Inclusion of demonstration projects as part of the Technical Assistance ComVponent and support for ome pilot CHWTDF in each of the six select states (Andhra Pradesh, Gujarat, Mabarasbtra, Rajasthan and Uttar Pradesh) rather than under the Infistructure Development Component are some of the means by which the risks in the project are proposed to be accommodated. Financing institutions such as ICICI and BOB and State Intermediaries have been given the responsibility of identification and appraisal of investments (sub-projects) fimded under the project. Provision for training of these fimancing institutions in technical issues related to the project has been included as a sub-project. This will also be useful in absorbing some of the risks associated with the project. Additionally, requirement for extensive public involvement and participation at various levels of the project has been included in the project. PIC on SEAR 20  5.0 PUBLIC INFORMATION AND CONSULTATION AT MPCB The PIC was conducted at the Yashwantrao Chavan Auditorium on August 26, 1997. The programme included: 14.00 hr. Registration 14.35 hr. Opening Remarks and Welcome Mr. C.S. Sangi.to, Member Secretary, MPCB 14.45 hr. Address by Mr. Walter Vergara, Pricipal Chemical Engineer, The World Bank 15.05 hr. Presentation of the Sectoral Environmental Asssment Report Dr. Prasad Modak Enuronmental Management Centre (EMC) 15.40 hr. The HazardOus Waste Management Project - A State's Pespective Dr. S.R. Choudhari, Prncipal Scientific Ofcer, MPCB 16.04 hr. Queston and Answer Sesion 17.00 hr. Closure of PlC In hiS opening remarks, the Member Secretary (MS) observed ta with the liberaition of the economy, dustrial developme nt in bas emerged from the licese and regulatory regime. However, evironm invetm and polution control devices are considered as extenal attachmens by idustry since it apparety does not have economic benefits. The MS stated that waste minimizmon, recycle and waste reduction at source is the order of the day. In keepig with tbis, a large part of the assistance provided by the World Bank through the hazardous waste magement project has bee eamarked for efforts in waste reduction at source. The finacial institutions (in this case Bank of Baroda and ICICI) will play a major role in promoting these efforts. In ther efforts to manage the hadous waste generated in the State, the MS stated that MPCB is adopting a carrot and stick approach and he hoped that through this project hazardous waste reduction at source will be achieved. Mr. Walter Vergara, the Task Manager for this project from the World Bank, in his address expressed the hope that this project wil be an mvestment for the future. He stated that the project philosophy is based on three common sense principles viz, Precautionary, Risk Reduction and Polluter Pays. Although avoidance of bazardous waste gneration is PIC on SEAR 21  the focus and governing principle of the project, complete avoidance is not possible. Hence a hierarchy of recycle > treatment > disposal should be followed. The need to reduce risk to people and the environment was also emphasized. Additionally, since hazardous waste management is recognized as a part of industrial development, the fact that the polluter must pay was stressed upon. Mr. Vergara specified that the key problems facing the country today in hazardous waste management were (i) insufficient information (ii) inadequate vigilance (iii) inadequate awareness of risks and (iv) improper infastructure. The project has been designed as an attempt to solve these problems. During this address, Mr. Vergara informed that the project has been designed with the objective of developing a modem and comprehensive hazardous waste management system The SEAR was presented by Dr. Prasad Modak of the Environmental Management Cenre. This focus of this brief presentation of the SEAR was maintained on the philosophy of sectoral assessment being used as a means of designing an environmentally susainable option for hazardous waste management. Tbis preseltation provided a pepective of the project and inchud a brief descrition of the sectorl context which provided information on the present status of hazardous waste *maagement - legaL isiutonal and technical - in the country and the need for the project. it also included a brief note on the key enviromental and healh impacts due to the present status Of hazardous waste management; a brief project deription together with the major potential benefits and risks from the project; an outline of the process guidance framework and the strategies proposed to mitigate the risksimpacts due to the project. A summary of the project costs and implemnaon gements were provided by way of conchsion. The state's perspective on the hazardous waste managemet project was provided by Dr. S.R. Choudhari Prncipal Scientific Officer, MPCB. Durig this presentation, MPCB's proposal together with the budgetary estimates for the project were descnbed. MCB's initiatives in hazardous waste management were also briefly presented. The session was subsequently thrown open for discussion. To ensure effective recording of the proceedings. a format (refer to Annex 2-6) was provided to all the participants to record their questions and comments. The participants for the PIC at MPCB included representatives fom the government agencies, industry associations, consultants and press. PIC on SEAR 22  5.1 Observations at the PIC at MPCB The proceedings of the PIC were conducted in English and the question and answer session was co-ordinated by the Member Secretary, MPCB. Goverment, Industry association, consultants and media particpation during this PIC was strong. The comments, queries and corresponding clarifications provided during the course of the PIC are detailed below. Policy It was felt that the prnciple of polter pays is presently being followed, hence the stress on this as a guidig principle for the present project may not appear to be necessary. The Principal Secretary, State Deparment of Environment (SDOE) was of the view that today polluter pays is not being practiced in Maharashtra and hence an explicit stress should be made. m Industry association representatives stated that if the state govement (viz. Maharashtra Industrial Development Corporation - MIDC) develops ifastructure for management of hazardous waste, industry would definitely pay and use the services provided. The polluter pays principle could thus be maintained. * Represenatives from idustry assocations felt that the location of the sites proposed by MPCB for setting up of CHWTDFs were not optimal and transportation of hazadous wastes could be an issue. Mr. Vergara, World Bank's Task Manager for the project clified that the Process Guidance Framework for the present project had estabshed eligbity criteia for CHWTDFs which required that these facilities should be located in brownfields. These brownfields would preferably be wi industial estates thereby mnmzmg transportation needs. Legislation * The hazardous nature of Effluent Treatment Plant (ETP) sludge was questioned. particularly since 78% of the total bazardous waste generated in Maharashtra state is categorized as ETP sludge. Participants felt that much of the ETP sludge could be non- hazardous. The Principal Secretary, SDOE, clarified that inclusion of ETP sludge as a category of hazardous waste was based on some research and study of the characteics of El? sludges, however he welcomed that addiional investigations coud be taken up. PIC on EAR23  Mr. Walter Vergara, World Bank's Task Manager for the project clarified that international studies also indicated that in special cases ETP sludge could also be hazardous. Hence, a thorough study for analysis and alternative treatment options for ETP sludges is being supported as a national study under the Technical Assistance Component of this project. Institutional set-up * Representative consultants felt that that the project had a strong public sector bias and involvement of private sector was conspicuous by its absence. It was observed that this project ppeared to be targeted at strengthening of SPCBs only, Mr. Vergara, clarified that the project has a large private sector involvement since out of the total project cost of USS 300 milion almost US$ 200 million is being provided for investments through the Infrastructure Development Component. This includes support to efforts in waste mnimization and treatment in individual faciies. This financial assistance can be accessed as a loan by the private sector from financial istiutions such as BOB and ICICI. moreover, establishment of pilot CHWTDFs is also being supported through this component. In this case although the ownership of the facility is with the government, private sector can get involved in the construction, operation and mgement of the facilty since it is required tbat a professional organization carry out these acvites. Aditionally, national studies under the Technical Assistance Component are to be bided out to private consultmts, research instiutions etc. therefore private sector involvement is possible here too. * Regarding the ownership models for pilot CHWTDFs, it was observed that there was no mention of Build Own Operate (BOO), Build, Own, Operate and Transfer (BOOT) or Build Own Transfer (BOT) type of models in the NTS. * Consultants also remarked that drwing from the experience with Common Effluent Treatment Plants (CETPs). the failure of the scheme was not due to technological problems but due to institutional failures. Although a number of models viz., government owned. private sector owned, private consortium owned etc. had been tried out, the problem of managmg common facilities had not yet been sorted out. A related query in this regard was whether the pilot CHWrDFs proposed under this project would be initially managed by the state government and subsequently transferred to the private sector. PIC on SEAR 24  It was clarified that a number of ownership models had been discussed for CHWrDFs and the risks associated with the establishment of CHWTDFs had also been identified during a preparatory workshop on risk management for the project. It was however felt that a pilot effort would assist in understanding and managing the risks associated with CHWIDFs and based on the lessons learnt full scale facilities could be set up anywhere in the country operating on any ownership model suitable for the local condition. The SEAR provides details on the recommended pilot projects on CHWTDF on the principles of reverse BOOT of progressively movmg from Government ownership to Government-Private ownerships as the experience accumulates. * It was felt that if MPCB was involved in the operation of the CHVTFs there woud be a conflict of interest between its regulatory activiies and the need to recover the costs of establishing the CHWIDFs. Mr. Vergara, clarified that no conflict of interest is envisaged with respect to CHWIMFs because MPCB is not involved in the financmg of the investment. its function is only as a regulatory agency whie the finacial assistance is beig provided through MIDC. O One of the queries was regarding the exact nature of the institutional arrangements for implementation of the project. Clarification was required on, * whether the project was state or centre owned * who would be the project operator. ' * what would be the ifastructure for the project and how wl the staff for the project be susained. * Some of the participants felt that only one agency at the State level should be responsible for the implementation of the projea. Involvement of too many agencies results in conflicts. C:larication was provided by the Principle Secretary, SDOE, regarding the institutional arrangements for the project. The World Baik assistance is being provided directly to the MPCB through the MOEF. The State Government does not receive any assistance through this project. The Member Secretary clarified that there wil be only one agency implementing the project in the State viz., the MPCB, while MOEF is the overal project coordiator. Technolov PIC on SEAR 2S  * The participants observed that awareness regarding technology for hazardous waste management was low among industries. * It was felt that the emphasis in this project appeared to be on recycle, reuse and waste minimization while clean technology was not given sufficient focus. Mr. Vergara, clarified that the project supported avoidance of hazardous waste generation which included waste minimization and clean technology. Technical Assistance and Training * Some of the participants wanted to know the agency(ies) who could be approached for obtaing techical assistance and advice by industies regardmg waste minimization and clean technology, technology for treatment and disposal. The Principal Secrety expressed the need to identify local expertise in the area of hazardous waste management. He also stated that industries could use the facility of the Waste Minimization Circles proposed under the Technical Assistance Component of the present project for assisace in hazardous waste minimization. * MPCB proposes to assist in senttig up of Pollution Prevention Centres (not in the proposed Project) for which it wil provide a one time assistance of Rs. 20 lakhs. Some of the participants wanted to know what the eligility criteria were for formig or accessing the facility provided by these Centres. It was also fel that the services of these centres should be readily accessible to interested partes. The Member Secretary, MPCB clarified that the Pollution Prevention Centres are proposed for participatory management of waste and the objective of supporting their establishment is to use them as counseling centres to provide technical assistance in pollution prevention technologies. * Technical assistance in the form of treatment technologies for management of recalcitrant hazardous wastes was observed to be essentiaL Additionally, it was also expressed that the technical information and results that arise out of treatability studies for hazardous wastes should also be made available free of cost. Mr. Vergara clarified that treatability studies were being supported as part of the Technical Assistance Component under the World Bank's earlier intervention in India viz., the Industrial Pollution Prevention Project. However, he emphasized that providing information and its dissenination is very mucb a part of the present project. PIC on SEAR 26  * The need -to educate and train small and medium scale industries in hazardous waste management was emphasized. * Need for trammg and creating awareness about hazardous waste management among NGOs and industry associations was suggested. It was clarified that provision has been made in the project for community outreach and public awareness which mcludes NGOs and other stakeholders. ITis is proposed to be implemented through a sub-project under the Enforcement and Compliance Component of the project. * Representative consutants felt that private sector should also be provided technical taining since their involvemen in the project is high. Financing * The experience of some of the participants with establishment of Common Effluent Treatment Plants (CETPs), fumded by a previous World Bank intervention viz., the Industial Pollion Control Project, was not very good especialy with respect to the loan sanctionig process by the finanmcig isution, viz. Industrial Development Bak of India (IDBI). Some of the participants stated that IDBI's term lnding rate was too high and also it was disciminatory in selecting projects for loan assistance. The pfelt that the fmincg pattern for investments der the Iftretre Developmet Componen of the present project should be simple and uniform. The main query of most of the participnts therefore was whether the loan sanctioning process had been streamlied. Both the Principal Sectary, SDOE ad Member Secretary, MPCB straed on the need to improve and streamline the finmcing patten for the assstance through the Infastructure Development Component of the present project. * Additionally, participants from industrial associations expressed the need to provide more assistance to the unorganized sector. In the case of the earlier credit line of the World Bank viz.. the Industial Pollution Control Project, IDBI, the financial intemdiay did not provide small loans. Tle particiPAs felt that such a practice should be prevented from recurring in the investments under the present project. BOB representatives claried that the ficing procedure is proposed to be simplified. The rate of interest for loans under the Infstuctu Developmet Component is proposed to be linked with the Profit and Loss Report (PLR). BOB proposes to consider small projects also for loan asstce and woud not restrict only to large projects. PIC on SUR 27  * The Member Secretary, MPCB observed that new and simpler forms may require to be prepared for invitation of proposals for loan assistance under this project. He also recommended that the financial institutions should be provided some technical training to enable them to appraise the proposals. BOB representatives clarified that training of their project officers has commenced and that provision has been made under the Enforcement and Compliance Component of this project to train fimancial istitutions. Public Participahon * Representatives from industry associations felt that NGOs should work together with industry and the MPCB. Need for imparting training to NGOs in tbis regard was also expressed. * It was observed by the representatives of industry associations that participation of bneficiaries is essential for the success of any project and in the case of the present project this was absent. It was clarified that the element of public involvement and participation bas been built into the Project through the Process Guidace Framework whereby the stakeholders / beneficia ies would be involved in public participation activities for the sub-projects where required. Project Design * Some of the participants expressed the need to include management of hazardous wastes emissions in the air as part of the project. It was clarified that management of hazardous air emissions is handled under the Air Act. The present project is imited to hazardous waste definition as per the Hazardous Waste (Management and Handling) Rules under the Environmental Protection Act of 1986. PIC on SEAR 28  6.0 PUBLIC INFORMATION AND CONSULTATION AT TNPCB The PIC was conducted at the TNPCB's Auditorium on September 1, 1997. The programme included: 14.00 hr. Registration 14.30 hr. Opening Remarks Mr. G. Rengasamy, Member Secretary, TNPCB 14.40 hr. The Hazardous Waste Management Project - A State's Perspective Mr. Rohit Kumar, Hazardous Waste Management Cell, TNPCB 14.55 br. Presentation by Mr. Walter Vergara, Principal Chemical Engineer, Tbe World Bank 15.10 br. Presentation of the Sectoral Environmental Assessment Report Dr. Prasad Modak, Environmental Management Centre (EMC) 16.15 hr. Question and Answer Session 18.00 br. Closure of PIC In his opening remarks, the MS observed that hazardous waste mnagement is not only a national but also a global issue. The MS remarked that costs of inaction m terns of the damage to publc heat and the ecosystem, have necessitated the need for development of a compehensive hrdous waste management system in the country. The present hazardous waste managemet project has been designed in iew of this need. The status of hazardous waste geetion and management in the State of Tamil Nadu was presented by Mr. Robit Kumar, TNPCB. During this preseation, the status of hazardous waste generation m the State was presented. Cam techology, recle and reuse initiatives proposed by industries and suggested by TNPCB that can reduce the hazardous waste geneation were also described. The need for the project was emphasized and the crucial role of public participation in the project was presented. Mr. Walter Vergra, stated tbat one of the objectives of this project was to develop a system for credible enforcement of the law. He observed that in view ofthe serious nature of the hazardous waste problem in the country, the Government of India (GOI) felt the PlC on SEAR 29  need for assistance in the development of a proper; modem hazardous waste management system. Mr. Vergara specified that the key problems facing the country today in hazardous waste management were (i) insufficient information (ii) inadequate vigilance (iii) inadequate awareness of risks and (iv) improper infastructure. The project has been designed as an attempt to solve these problems by (i) modernizing the plmnning process (ii) improving the Management Information System (MIS) (iii) supporting the inventorization of waste and identification of proper sites (iv) supporting community outreach activities (v) training (vi) promoting greener technologies, recycle and recovery, treatment and destruction and finally disposaL It was also stated that 65% of the project costs have been allocated for waste avoidance, recovery and recycle efforts. Mr. Vergara drew the attention of the participants to the fact that the project also proposes to support national studies through which areas where sufficient information is not available in the country wi be strengthened. Additionally as pal of the technical assistance component of the project, proposals of innovative technologies will also be supported. The SEAR was presented by Dr. Prasad Modak of the Eomental Management Centre. This focus of this brief presentation of the SEAR was maintained on the philosophy of sectoral assessment being used as a means of designig an environmentally sustainable option for hazardous waste management. lTis presetation provided a pespetive of the project and inclu a brief description of the sectonal contex which provided information on the prese status of hazaxdous waste mnagemmt - legal; i tional and tecbnical - in the country and the need for the project. It also ihded a biefnote on the key evironment ad heat im s due to t present status of hazrdous waste managemnt; a brief project descripfion together with the major potential benefits and risks from the project; an outline of the process guidance fiamework and the strategies proposed to mitigate the ri[mipacts due to the project. A summary of the project costs and unplementation amangements were provided by way of conclusion. The session was subsequently thrown open for discussion. To ensure effective recording of the proceedings, a format (refer to Annex 2-6) was provided to all the participants to record their questions and comments. The participants for the PIC at TNPCB included representatives from the government agencies, industry associations, NGOs, consultants, press and educational and research institutions. PIC on SEAR 30  6.1 Observations at the PIC at TNPCB Policy A representative from Geological Swuvey of India (GSI) observed that the TNPCB had shortlisted sites in the State for CHWTDFs. However a umber of these sites were geologically unsuitable for consideration as potential sites for CHWTDFs. Hence the need to use the services of GSI in this process of site selection was recommended. TNPCB clarified that they would definitely use the services of GSI in future. Legislation * Rpresentative NGOs expressed the need to include medcal wastes under the hazardous waste management legislation. They also stated that although medical wastes are extremely contagious and dangerous, its management has been neglected in the State. It was clarified that the GOI has drafted a separate rule for the management of medical wastes. These rules termed the Medical Wastes (Management and Handling) Rules, 1997 are presently under review. * Some of the participts exprssed the need for strict legislation regarding a ban on impor ofhazardous wastes. TNPCB clarified that the Supreme Court has issued an order bamnig the import of hazardous wases. * It was suggested that hazardous wastes should be classified as -high hazard" and 'low hazard" and specific recommendations may be made for their magemt. Institutional set-up * Some of the NGOs expressed their apprehension at the capacity of the insitutional set-up at TNPCB and in the State Goverment and their ability to imlemt the project. It was clarified that tbrough the Enforcemet and Complance Component of the project the technical and infStuctra capacity of the SPCBs is proposed to be stegthcned to enable effective ImL tation of the project. PIC on SEAR  TNPCB clarified that training for all SPCB personnel. NGOs, customs officials, road transport officers etc. -proposed under the project will enable effective implementation of the Project. Technology for Treatment and Disposal * It was suggested that while selecting technologies for hazardous waste treatment and disposaL care should be taken to select only those which are cost-effective and which generate the least residues. It was also suggested that incineration as an option should be selected with great caution and final disposal should be only in landfills. * Some of the NGOs expressed concerns about the establishment of CHWTDFs particularly the safety of landflls and wanted to know how the TNPCB proposes to ensure that landfills do not leak. Mr. Vergara clarified that even the best designed systems have risks associated with then. However in this project through the process guidance framework and the eligibiliy criteria defied as part of this framework it is attempted to ensure miimization of these risks. Moreover, in comparison to unmitigated release of hazardous waste an organized management of waste can only improve the situation. TNPCB also clarified that in accordance with the Process Guidance Framework (PGF), only brownfields will be considered for site selection for CHWTDFs. Moreover, public information and consultation will be an integral part of the process of selection of sites for the facilities. This is proposed to ensure a minimization of risks. A consultant among the participants clarified that presently lndfill engineering is highly developed in terms of leachate management, durability of the liners used etc. to reach a situation that landfills no more leak. * While some of the participants observed that infdigenous technology for hazardous waste treatment and disposal is not avaiable and there would be a need for international collaboration others differed. The belief was that although indigenous expertise was available, it was not being tapped properly. A case in point was that of Bhabha Atomic Research Centre (BARC) where the expertise was available smce they are managig nuclear wastes safely in the country. Technical Assistance and Training * It was observed that educational and research istitutions which provide the expertise for a number of technology and policy related issues of bazardous waste mnagemnt were not being considered in this project for strengthening. PIC on SEAR 32  It was clarified that this will be considered in the project dcsign. Mr. Vergara also clarified that the World Bank has a large progmmme for education which can be used to strengthen educational institutions. He also stated that the possibility of inclusiOn of educational institution stengthenmg will be explored m this project by discussmg with the Department of Economic Affairs and MOEF. Project Design An NGO representative rgised a query, whether the recommendations of Agenda 21 were proposed to be considred in the implemetation of the hazardous waste management project. It was also suggested that the rcommedations provided by UNEP in a recently rekled environmental guide on hazardous waste management may also be considered in developig the project. Tle TNPCB was informd after the PIC that the proposed project addresses all the pomts made in Ageda 21 under secion 20.8 except for item (c) which is towards promoting and stngtheig intenional cooperation in the management of transboundary movement of hazardous wastes. Project Risks S Some of the NGOs expessed their concern over the isse of liabiliies due to the project Paricularly due to the CHWTPFs. They wated to know if any provisions had bee made to take care of the liaties, along the lies of the Superfund Programme of the Unied States of America. Mr. Vergara clarified that the labilities due to the particulaly the CHWTDFs, will be taken care of through risk sharing contractual agreeme between the various stakeholders. This is to be enforced by TNPCB and imnteatol expece wi be used to develop these contracts. Project Implementation * It was suggested by some NGOs that trainng and capacity strengthening of the SPCBs should be done first, their progrss monitored and only after it is ensured that the SPCB is sufficiently equipped with expertise should the investment componen, particularly the sub-project on the pilot CHWTDF, be imlemented. PIC on SEAR 33  It was clarified that the implementation plan has been staggered so as to strengthen the SPCBs in the early-phase of the project. However, the various activities of capacity building both in terms of strengthening of SPCBs' capacity and pilot infrastructure for treatment and disposal in the form of CHWMFs have to be done concurrently to ensure that the system is in place at the earliest. Mr. Vergara clarified that provision has been made in the project in the form of an unallocated amount for additional capacity building and training activities which may be envisaged in the project at a later stage. It was also stated that as mentioned in the SEAR, the economic costs of inaction even in the case of municipal solid waste were very high, of the order of US $ 1 bilion for India. Hence the costs in the case of hazardous waste would be unaffordable. The need therefore for establishment of a hazardous waste management system, at the earliest was emphasized. Financing * A representative from a research instiution observed that more than 50% of the project costs are available as loan through FIs to industry for hazardous waste minimization, recYcle and treament initaives. The FIs, while evaluating the proposals would place higher priority on credit worthiness of the industry than on the hazardous waste minimization / treatment potential of the industry. The need therefore to msist through the Project, on FIs to place equal weightage on the two aspects. I It was also suggested that the Fmancing Instution (IF) should integrate the aspects of minimization with the treatment and disposal of existing dumps of hazardous wastes on the site in order to lead to a total solution to the problem. Public Participation * NGOs expressed the need for transparency from the TNPCB and welcomed the idea of this PIC. It was also emphasized that information dissemination particularly durng the process of site selection for CHWTDFs should be done through organized community involvement and interactions. A participant consultant suggested that the technical details regarding the treatment and disposal options for e.g., regarding secured landfills, should be disseminated to the public in a form so that they are able to appreciate the extent of risk mitigation possible due to well engineered structures. PIC on SEA3  7.0 PUBLIC INFORMATION AND CONSULTATION AT MOEF The PIC was conducted at the MOEF's Conference Hall on September 3, 1997. The programme included: 10.30 hr. Opening Remarks Mr. Vijai Shamna, Joint Secretary, MOEF 11.00 br. Presentation of the Sectoral Environmental Assessment Report Dr. PrasadModak Environmental Management Centre (EAMC) 114 Ah r. Question and Answer Session 13.00 hr. Closure of PIC In his opening remars, the Joint Seretary (JS) observed that there are about 9000 hazardous waste generating units in the country with 7800 havmg been granted authorizations. However the hazardous waste iventory of these unis is to be verified. The JS stated that through the pesent project, the exact inventory of haadous waste in the Project states wi be verified. The legislation is proposed to be streogthened through this project for which the necessary amendme in the Hazardous Waste (Mmagement and Handling) Rules, 1989 are under discussion Mhe SEAR was presented by Dr. Prasad Modak of the Enionmel Management Centre. This focus of this brief preentation of the SEAR was matained on the pbilosophy of sectoral assessment being used as a means of deiging an entironmetaly sustainable option for hazardous waste management. This presntation provided a pspective of the project and inud a brief deron of the sectoral context which provided iformatio on the present status of haadous waste management - legal; instutional and tochnical - in the country and the need for the project. It also icluded a bnef note on the key envirommental and heakh inpacts due to the presen status of hazardous waste management; a brief project description together wth the major potal benefts and risks from the pect; an outline of the process guidamce framework and the strategies proposed to mitigate the iskslacts due to the projc A summary of the project costs and wmplementation airangements were prvided byway of conlsion The session was subsequently thrown open for discussion The partipatMs at the PIC included representatives from the Mbiistry of Petroleum, Ministry of Commerce, MOEF, PIC on SE4R 35  ASSOCHAM. FICCI, industry, NGOs, consultants, press and educational and research mstitutions. 7.1 Observations at the PIC at MOEF 1nventorization * A representative from the Ministry of Petroleum observed that the inventory figures particularly in the case of Tamil Nadu need to be checked as the reported quantity of oily sludges per annum was higher than the annual oil consumption by the State. It was clarified that this issue will definitely be commumicated to TNPCB for verification. Project Design * It was observed that due to improper hazardous waste management in the country, groundwater, among other components of the environment, has been extensively contaminated. The need therefore was expressed for inchlsion of groundwater remediation a; the hazardous waste management project. * One of the queries was regardimg how the proposed World Bank assisted Capacity Building Project compares with the hazardous waste management project. It was clarified that the projects focus is only on capacity steghening for hazardous waste management. Moreover, the former project is still under discussion. However, the design of the capacity biling project will consider the inputs provided by the hazardous waste management project towards capacity buidig to avoid any overlap. * Some of the participants were of the view that a major share of the project costs should be for CHWVTDFs rather than capacity building of SPCBs. It was clarified that the focus of this project was waste avoidance with a high priority on minmization, recycle and reuse. CHWTDFs cannot be the sole solution for hazardous waste management. * A query was raised regarding the method proposed to ensure waste supply at CHWTDFs and would industries have to send their wastes to CHWTDFs. It was clarified by MOEF that there was no compulsion on industrial units to send their wastes for off-site treatment and disposal. The compulsion was only for compliance with legislation. PIC on SEAR 36  Additionally it was also clarified that there were several options before industry for management of hazardous wastes viz., new technologies ensuring waste minimzation and cleaner production, on site treatment in industry's individual. facilities and / or use of off-site CHWrDFs. * It was recommended that waste exchange may be considered as an effective way to minimize hazardous wastes. Examples of possible waste exhnges were given such as recycle of gypsum sludges to cement industry and Nickel catalysts in the vegetable oil industry. Financing * There was a query on the financing pattern proposed in the project particularly the lending rates likely to be adopted by financing institutions for investments under the Infrastructural Developmet Component. It was clarified that the term lending rates wil be linked to the financial status of the Proponent i.e. the Profit and Loss Report. The repayment period is proposed to be 12 years with a 3 year grace period. It was also stated that assistace for the individual subprojects under the Technical Assistance Component an under the Infrastructure Development Component is applicable across the couty whereas the Enforcement and Complance Component is restricted to six select states (Andbra Pradesh, Gujarat, Mabarsa, Tamil Nadu, Uttar Pradesh and West Bengal). Public Panipation D One of the queries was whether there would be PIC done for all the sub-projects. It was clarified that PIC will be done for the sub-projects wherever applicable. * Some of the participants were of the view that information to the public should be provided only after partial implementation of the project. If information is provided upfront there is a likelihood that this will create more apprehensions among the public and exacerbate the risk of public rejection. MOEF clarified however that for long term sustainability of the project PIC is essential and Will be an integral part of the project. It Was also emphasized, that as far as the Project was concerned, public apprehensions could be reduced by informng the public that almost 65% of the project costs are for waste minimization and inhouse treatment initiatives. Additionally, PIC on SEAR 37  the experience of APPCB under the AUS-AID project was cited wherein extensive public involvement lead to a successful selection of a site for a CHWTDF. Project Monitoring * One of the queries was regarding the modus operandi proposed for monitoring the performance of sub-projects. It was clarified that performance monitoring indicators will be developed by MOEF for the sub-projects which will be used for project monitoring. This wil entail technical environmental and financial monitoring. Representation of local NC-Os is also proposed i monitoring. PIC on SEAR 38  .00, l\\f i' />>S PIC at Gujarat State Pollution Control Board, August 14,1997 < w._*: < t PIC at Andhira Pradesh State Pollution Control Board, August 19, 1997 PIC on SEAR 39  PIC at Mahautshtra State Pollution Control Board, August 26,1997 PIC on SEAR 40 Pl nSAR  ~~~~~~~~~~~~~~~~~~~ir * - ~ i- i'-u PIC at Tamil Nadu State Pollutiou Control Board, September 1, 1997 YE \s_ ' ~~ - X PIC on\ SER4 PI a teMiisl o Eviomet n Frets epeme 3 19 PIC~~~~~~~~~" onSER 4  8.0 RECOMMENDATIONS OF THE PIC Many of the recommendations made in the PIC were already incorporated in the second draft of the SEAR. These recommendations are listed below, * A need to develop performance indicators apriori to monitor the project was stressed. * Project outreach should be done by the SPCBs and MOEF on a regular and proactive basis * here is a need to modernize the existing hazardous waste management related regulations. The definitions should be clear to communicate and unambiguous for enforcement. * Standards should be set for the residues and emissions arising from the treatment and disposal of hazadous wastes. Monitoring procedures needed for the purpose of vigilance should also be spelt out. * Inventorization of hazardous waste should be a continued exercise. Guidelines should be evolved for the inventorization. * It was observed that use of incinerators as a treatment option should be considered with precaution. * Sludges from the effluent treatment plants form a major portion of the state wide hazardous waste inventory. Studies should be undertaken to tackle this problem. * Awareness on technological innovations in hazardous waste management to be brought to industry particularly medium and smal scale industries. * Since the States may eventually manage a multiple number of CHWTDFs, strategic considerations need to be made to evolve the policy of on-site and off-site handling of the hazardous wastes, which would lead to prolonged life of the CHWTDps. * There is a need to update the existing Guidelines regarding site selection, site ranking criteria, design, operstion and closure of the CHWTDF. Further to above. following additional recommendations were made as essentially emerged from the PIC. Most of these recommendations were considered to be useful and effective to PIC on SEAR 42  include them in the scope of the program. The project design as well as the process guidance famework in the fnal SEAR reflects this consideration. * Incentives should be provided to small scale industries practicing hazardous waste minimization/recycle/recovery. These incentives may be in the form of tax benefits or other such fiscal incentives. For instance, the small and medium scale units should be subsidized for usage of CHWTDFs. Guidelines for developing charges, specifically for these units, need to be developed. * Development of national mdustry specific waste generation factors should be taken as an extnsion of the exercise of hazardous waste inventorization. These waste generation factors can be used as indicators for benchmar3cing. * The activities on Waste lmmization Circles should be more.proactive, wel publicized and accessible to a larger fraction of the smal and medium industries. Roundtables should be set up on waste minimization as well as when reports to monitor the project performance are discussed. Waste exchange should be studied and promoted by identfying probable by-products/ recyclable wastes in various industrial units. Formation of waste exchange bureaus are recommended at SPCBs or in partnership with Industry Associations. The MOEF should develop guidelnes for insrance related to risks associated wih the waste exchange process and the taxation policy for waste exchange. * Provisions may be made in the prest projet to constute awards and provide incentives for practice of hazardous waste min tion. - NGOs may be invited to assist in the tasks related to publc consutation and partcipation. NGO mivolvement should be high since they are not adversaries but partners m development. NGOs may also participate in the independent assessment, especialy for the assessment of the CHWTDFs. * Agencies like Geological Survey of India, National Remote Sensing Agency. BARC should be pat of the technical committee during the process of site selection for CHWTDFs. Satellite imagery may be useful in site selection for treatment and disposal facilities and even for detecting the contaminated dump sites. * Disaster management plans should be requested in the appraisal of the CHWTDFs as well as for the infiastructure development projects at the individual facilities, if found relevant. These plans should involve citzens' gouPs, emergency services and government agencies PIC onSEAR 43  * Insurance is an issue which needs to be examined for compensations with respect- to the liabilities and risks associated with CHWTDFs. MOEF should develop guidelines for insurance and associated compensations for the various risks. * A corpus, sinilar to the Superfimd may be developed keeping with the Polluter Pays Principle, for making contnbutions to the cleaning of the ilegal dump sites. * Wherever applicable, site selection for CHWTDF and for disposal of industrial solid waste may be done simultaneously in adjoining sites. * The eligibility criteria for CHWTDF should clearly state that only -brownfields" should be considered durng site selection. A rider must be attached in the eligility criteria to ensure that "greenfielWs" acquired and termed -brownfields" should not be used. * During the site selection process for CHWIDFs, the area of land to be acquired should consider area required for green belt and buffer zone. It should also be linked to land use or developmemt policy. In other words a minmmum size should be prescribed for CHWTIDFs considerig all these aspects. * Durig collection of hazardous waste for transortation to CHWIDFs a chlster approach is recommended for small and medium scale industial Units to ensure lower transportation costs. * The fincing procedure at the BOB/ICICI should be simplified to the extent possible. The PIs should conider small projects also for loan assistance as well and should not restrict only to large infrastructure developmet projects. - The Fls, while evaluating the proposals should place equal weightage on the credit worthiness of the industy as weLl as the hazardous waste mitigation potential. * The FIs should integrate the aspects of minimization with the treatment and disposal of existing dumps of hazardous wastes on the site in order to lead to a total solution to the problemL * Technical committees should be formed at the FIs for appraisal of proposals seeking assistance under the Infiaructure Development Component. Representation of NGOs is essential on these technical committees to ensure public participation and consultation at the sub-project level. PIC on SEAR  * Strengthening of educational and research institutions may be considered through the hazardous waste management project. This may include strengthening of (a) laboratories and (b) technical capacity of the institutions in the area of hazardous waste management through training. Educational institutes should be able to offer advanced courses related to management of hazardous wastes. * An information package should be created out of the information ftat emerges from the national studies. These information packages (databases, reports etc.) should be made accessible to any interested person/istituton * Plamning workshops that were conducted at the four SPCBs as preparation for the project should be also conducted at CPCB and at the other two SPCBs, folowed by public information and consultation exercises. PIC on SEAR 45  Annex - 2-1 Guidelines issued for conduct of the Public Information and Consultation  ANNEX 2-1 GuIDELIEs FoR coNDucT OF TE PUBLIC LNFORMATION AD CONSULTATION OF TKE SEcToRAL ENVIRONMENTAL ASSESSMENT REPORT OF THE HAZARDOUS WAsTE MANAGEMENT PRoJECT SUPPORTED BY THE WORLD BANK (Vesion 1.1) drafted by Enwronmental Management Centre, Msumbai, India 19 July 1997 PlC on SUR 46  1.0 Introduction The Sectoral Enviromental Assessmet (SEA) study as defined by the World Bank's Opcrational Directive (OD) 4.01, 1991' is used for the (enmrronmna21ly sound) design of sector investment programmes. SEA avoids the inherent limitatons of project specific EAs in adressg issues related to policy and plning and the legal and instiuional famework. By movmg upstram in the plning process to a stage whee maor strategic decisions bave not bee made, SEA offers better opporunties not only for analyzing aesting policies, stutio and development plms, in terms of environmental issues; but also for supporting environmelly soud seor-wide invesm strategies. The OD 4.01 quotes that -SEA is parkrly suitable for rviewing (a) secor investment ahtioawi 4)) the effct of sector policy changea; (c) iional capatis and reprmeiransJfor envonamnal review, implemetation and monitorng at the sectoral lewel; and (d) the cumulathe impacts of my relivey small, simkr ivtmens that do not merift individal project spcfc Environmental Assemet. The objective of SEAs is aio to strengthen the environmeal managemena capabfilty of the sectorml or other releiwit agencies.' The findings of such a study are present in the form of a Sectoral ometal Assesm Repor (SEAR). MoEF. under assisanc from the m Maagt Cente (EMC), Mumbui developed a daft SEAR of Hazadous Wase Mangeant Proje, supported by the Wor Bank in Mab 1997. Ths docum has ben now rviwwd and a with neessuy updates is under prepara Public informtion and consultatim (PIC) is an itegal part of the enl as t (EA) process. Howeve, the klvel of the PIC actit is govened by the type of the EA Pocess being conducted. The EA Sourebook updae of the World Bank on SEA2 swtes.. "'since SEA nonnall cove an entire sector (in a national or sulbnatonal contea) and is conducted fore concrete investment decisions are made, it may not aways be possible to consult representatives of all potenally affected people dinng Preparation of the SEM. Often. it is morefeasible and appropriate to coay out consltations with national NGOs (for example. for natural protecton) sciefic cxpels, relevant government agencies. and perhaps also industrial and commercial inteasts. A s bUsIY implemeted consultion process %ill help ensure public swpportfor thefinal sectorpromram/' In keePing with the guidelines provided in the OD 4.01 and the sourcebook update refared above. this note bas been prepared to provide guidelines on the prepation ad conduct of te Tbe WOdN Bk Opa&*W Dimnie, OD 4.01, OMi 1991. 2EnviR=W AenOAm S _U=bO* Updae No. 4, SecWl E _nvizin AM mi, E Im Dqmeuunut, Mhe Wodd Bank, OcW 1993. PlC on SEAR 47  PIC of t6e SEAR of the Hazardous Waste Management Project. While, the proceedings and minutes of the PIC of SEAR are to be made available as records, any useful suggestions emerg from the outcome of the PIC of SEAR may be considered for incorporation in the SEAR. In order for the PIC of the SEAR to be effcwtive, the following elements need to be addressed: Unerstaning Components of the Hazardous Waste Mamagement Project; * Dineation of the objectives of the PIC of the SEAR; * Idenification of the sAkeholders esni to be involved; * Develome of a plan for conducng the PIC. PIC is to be thus done using public paricipation tecniques tat are most appropiate (such as group meeting wih handouts) for meting the objecmives. 2.0 Components of The airdous Waste Management Project The otjective of the project is to assist in the mp tat of a moden and sustainable hazdous waste magemt system in the country. Te project wi assist in modenizg the regulatory fimework, srngthening the isttutons in charge of enforcement and mnitoring, and financing priority invesmes in haadous wast mitigation, treatment, and disposal. The specihc goals are to: (i) promote the developmen of a compehesive monitoring and enforcemn system for timbly implementation of the hazadous waste rules and otber legislation concenimg the m ge of these residus; (n) assist in the imp ati of priority invesm s in hazardous waste management; and (id) provide tehnical assistance for the mpl o of training, technology developme_t, and awareness programs in haadous waste mangemem and support for the devdeopmt of bacround data for polcy- making. Componens of the project are descbd in the following tea. The Enforcment and Monitong C This component has been designed to support a program of actvities aimd at stngthenmg the monitoring and enforcement capacity of the State Pollution Control Boards m those States where the most serious hazrdous waste concerns have aisn These are the States of Andbra Pradesh, Gujarat. Maharsbtr and Tamil Nadu. In additon, an alocation has been made to serve the needs of another 2 State Polluion Control Boards, as yet not identified. Key themes are presented below: *Strengthenig of Analytical Capabiliy. tC on SEU 48  * Institutionalization of the Planning Process. * Improvmg the Information Management Process that includes GIS (Geographical infonmation System), and development of a Toxic Release Inventory (TRI) covering key generators of hazardous waste in the State * Inventories of Hazardous Waste. * identificaton and Nodfication of Sites for Secure Destruction and Disposal of Residues. * Organztion of a Commuity Outreach Effort. . Training * Support to MOEF and CPCB in its policy making role. The kf=cCmmtu DmR2 * Prm , this project w assist in the avoidance and tion of hazardous waste geneain The emphbais is on pVenting fute discbarges of hardous waste by promot actons that wil resut in the avoidance, recycle or recoey of oterwise 3 However, in some cases g aion of bazadous waste can not be avoided and s destuton aDd or, u r,atelY, disposaL For those cases, whe destutn ad diposal is requed by medium and sal e enratos the proposd projet wil assist in the intoduction of istiutoa models and tochologies to be used for e poperm desructo and safe disposd of bh dous resdus. Mhe =WM to be upported comngisof So cn&&Flrd fahlaty teacch the project Parcipating sate, owned at kast in part by sdected Ste Agies. Purpose of the projet is to apprai the viability of gtablsh ingfasnmm for hazardous waste tnspoz storage, teul, nd disposaL Moreo, the povisim of treatment and disposal sevims by the Se Agedes will reslt in the gneation of come through the ease agrem s with the sdetd opetors. This inme wM be rycl by the State agencis for the famcing of addiona Commo Haardous Waste Treatment and Diposal Facilties (CHWIDFs), makig the vestmen sustable m the lonlg term The Technia Asir }he Nauonal SbUdie and TecnlSolgy pgyMo C0mon This compont wi support actvies desge to complement the Boards' and mprove the pAripation and access of the genal pubic to informaion regadig the management of haadous waste m the country and ote acuvts of techncal nature. hese consist of national studies for: PlC on SR 49  * Support for the expansion of the Waste Minimization Circles, already initiated by MOEF, to focus- on small scale generators of hazardous waste; * Development of a strategy for containment and disposal of polychiorinated by-phenols (PCBs) in the power industry; * Development of an approach to clean contaminated sites; * Idiifcation and assessment of long-term altenatives for containment and disposal of halogen and mercury contang waste and other technical studies. * The project wM also support a limied effort to promote the development of innovative technologies for waste minimization and prevention of generation of hazardous residues. * Support to dose-response anaysis of bh dous waste and pernicious organic pollutants. * Techimcal Atenatives for Disposal of Sludge from Waste Water Treatment Plants. Fe shows budgetary allocaton for the various project componens UPu&UNMepb r4ft sM NW X W " RcuaSwwy..-d TmsIuusri * Tim Acrho t cOsh Ue in WS Ulffin Towa l*ct Cow is 290 LS illion Figure 1: Budgetary Allocation for the project components PlC on SER 50  3.0 Objective of the PIC for SEAR The main objective of the PIC for SEAR is to convey the spiri, desip and content of SEAR with specific reference to the Hazardous Waste Magemnt Sector. The focus is therefore on the project as a whole rater than on ivid su-projects. In fact at the stage of SEA, detas on the sub-project are not avaiable. independent pubhc participation actvies would require to be conducted for each of the sub-projects after the PIC for the SEAR, as and when each sub-project is planmed and deigned. This becomes a part of the Process Guidance Framwork (PGF) diected by the SEAR iself. 4.0 Pla for conducting the PIC The PIC is proposed to be a half day long progamme and the conduct of PIC woud involve three stages of actvity to be unultke by the SPCBsl MOEF. Distribution of rpoWnsibiities between SPCB's, MoEF and EnviI Magent Centre in Public Information and Consultation (PIC) of So v ml Assessmen Rxport is shown in Annex 1. * PreParatio for PIC wbich would idefy the techniques to be used to adhieve the objective as well ident the public anici to be invohled in th PIC for the SEAR. * Conlducet of PIC which would pwvide a prcia plan for impltatin of the PIC proSiamme. 3 Reporting of the vies epressd by the stakeholders and rlcting them apprpraty in the finhltiom of the SEAP. 4.1 Preparaton St Ths stage entails prep of necessary documents, idntifYig the ct participants and mking logistic angemens for the conduct of PIC. 4.1.1 Documents * Non-Technical Summary MM: A Non-Techicd Summary (NTS) of fte SEAR, shal be provided to the SPCBs. The NTS is a amny ofte mai fnding and concluons ofthe study and bow they wee reaced The NTS avoids to the e t possl tccl tam, lists of data and detafied explnations. he NMM mt how r convey the p, desig and content of the SEAR It is ncssmy th the tet of tbeN IS is translated in the local laguage for the benefit of the local stakeholders. Ths NTS is to be made availble to any interesed citizens of India. PIC .O. 51  NTS wil include: . an itoduction which will describe the philosophy of sectoral environmtal assessment vis-a.vis this project, * a bief descpon of the sectoral conet which wil provide informatin on the present stus of haz.dous wase management - legal; ittioal and techncal - in the country and nee for the project Ths will also indue s I-f uOWe OfD Yo evvmv.=mw bmit mpas due to the present status of hazardous waste management. * a bief project description togehe with the major potential bnefts and risks from the project * an outline of the process gudance famwik and the pubic conuatn process proposed to mgate the risks due to the project and the sub-projects included. *summay of the project fiamc Full SEAR: Few stakeholders may be interested to review the entire SEAR. To enable this, a Master Copy of the full SEAR will be provided to the SPCBs. Duplication of this SEAR is to be made by the SPCB for malking the same avaiable to any interested stakcehokier. (M.Waitr VYa of the World Bank has mrvided each of tbe four Boards a draft cpy of fte Sectoral Enimdmienta Auteomen 2i00r (SEAM, -. This opn -is -to uv yo a mndican fthe tpcol conent oftlie VAL Pleme no-tc howefver c'SEARil under flte revImC right now and yo would be Mcig by A s 1st a con wbich can be used for the pose of duDlicaton. Please do not duplcate rore the coy presentldy made available to o by Mr. Walter VeA.) 4.1.2 Public Announcement For the dissemination of NTS and obtaining commeuts, a public amnouncement of the project is to be made in the newspaper. The newspa insert is to be placed in at least one national daily and one regional daiy amnouncmg the project. The insert should be placed atleast twice. In the case of Andra Pradesh care nay be taken that both Urdu and Telugu dailies are covered. There may be a 2 day gap between sccse inserts. A samle of the text is placed in the box 1, below for your consideration. PIC on SEAR 52  Box 1: A Sample of the Newspaper lnseil The. Sae Pollution Control Boar&MoEF, *ith the amstanoe of dth World Bank is indiating Hawdos Wate Mtanagument Prdje in -Order40 mplement a moden and wunabke hardos wemanowse..wnl :te. T'he ape4ji nhianrnat ofw*wornm,act- (.) assis in =a =1 _e (f) pbfkroWad9aforfor.akI _ A Noeha mr f*e tp qfhe project ii the Boar&/MEF whc *, be mad 0lab *.on'iqueM A c oyf thef Sf ctora E*wironmem Anmsmwn Repxr is rnavlabk with *1a- -SPCB1 MOFY for -.,fte,wn. alleresgqd dtizes of Inda m welmcm *o giamge , !w ft llAgst 28, 1997. .... &da Polha&m CoMu BDoWMOEF Name of theCtaStf -2F~~~~~... ...* 4.13 Paripants for PIC * Seled stacholders ae to be in d to paticipte in the PIC. * The total number of crl miees may be about 35. For an effective pardtcpai this umber should not be exceeded We I tifDg sebolders, am optimm distribution of rpesax e from vraious intktsorganiatkons needs to be ensured (Refer to Table 1) A-9w*e- letter for invitation to the paticpt iS given in the box 2 for your con5ertiaon. PlC., SL4R ~~~~~~~~~~~~~~53  Tablel: Suggested Composition of Stakeholders for the PIC of SEAR I | | | | Organkzaion I1 l |,i ivi | | GOv X en~Ae s such as State Department ofEnvomnent, IndUstridl Development Corporations, Directorate of Industrial Safety and Headth, Cusoms department, and Transport Commissioner's Office. : , ,,-, olmsoe' iliio .tr .. ...............I1||- -.nn,"-- Indstry Associationel Inustries Resrch Instiutons Academe Health . . ? Professional s. .... -. * ReP-puted Waste M g wCoiat Membeas of the Press (Newspaper and .:.''''..-Magazines) . ' '. ''. Leadin NGOas Envonmenaul ml awyer N_>~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~... ...... .. . Financing Instuons Mike Bank of Baroda, ICICI etc. who bave a stake in the projec Importa tesbid Staff of thee Hazardousuwaste Mget~kj Cell pglanif Plg of tfie ................ -.> Note: The SPCBs may kindly ensw that the participants at te Risk Maagement Workshop held at Hydeabad on Juwary 17-18. 1997 are among the anvitees for the PlC A list of the participants at the Risk Managenent Workshop held at Hyderabad on January 17-18, 1997 is attached as Anna 2. PlC on SEAR  Box 2: Sample letterfor invtation to the participants Date Sub: Pblfic h#foationid Cx=i.dtn* of of -the 'Hwnrdus Waste MAvwgmem Plqeu. - 27w.- S&O S- The... &P h lB w i 4e S fIh Ui Ikhewka&*Wst Mb w~-4gwwt wet aa ,1~~~~P &71w andii mobe of MR*to OugMW* aiqemem; and dM awiA cpatoud pf SEAR whbe MID* m w oe# :1 Was* of.ge PeC j.~w NGOa media per xie c uqes ..,dw_t mwmm gve and Iuarlacmwcab,~7poe _h l xc s ,i ,e ,*IJ ,PlC of SEAR Witob PIC on SWmaitfs&Z~p"Sa D he uw ;p i te LEAk I Wth. )W hbd cooperaotio eWpnicipa_iov,~ wc, hope io ew Xw ~objecr, of L PIC avdthe SPBMOEF PlC,,.~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ .ER5  4.1A Logistics * The anrangements for the venue for the PIC with facilities for visual presentation, is to be made by the SPCBs * The invitation for the PIC should reach the participanS at les 8-10 days prior to the date of conduct of the PIC. * The NTS (in Engsh and/or local language) should be dispatched to the mnvitees to reach them 3-4 days prior to the date of conduct of the PIC. 4.2 Conduct of PIC A suggested programme for conduct of the PIC is proposed The Boards may kindly finalise an the suggested programme. 10.00 hr. Opening Remarks and Welcome MoEF/Serey (Environment) of the State Chairman / Member Se:nwy of the SPCB (The oping rwa, way include a brief ins,w idicaig the bakrvad and the pipose of Ike PC) 10.15 hr. Psno of the Sectoral vrmental Asesme Report Dr. Prasad Modak, E,nwiunmeodaMolMgeent Centr (EMC) (A briefpretao of the SME w*h tiefoas b iannted on the philosopky of seeoral aswnt ben wed a a maew of duigin an envonenaldy sstainabl option for hzrdws e managexent. 17 pomton wlpre the ntowna papeiv of the projea and w inclde a brwf d=ptwi of te seoal cont w*ich wil provid inoava on the praet saa of hmwdow cwe mngenew - lgal; armial and techical - an tie aoy and neefr the project. 1, wll aLso inchd a bnefnote on the key nmemal and hah npacs due to thepraen st mw of harMw w%L, wagmet a nefproec dartptn together with the rajorpoteninal benefis and ish fisvm te proect; a aiin of the pcess gdance fcew* and the public couaioprocspposed to udtigate the ris due tD theproqca mnamy oftheprojec finace and ipl"emmao owcangenen) 10.30 hr. The Hazardous Waste Managemet Project - The State's perspective Swctary (Enwnnmet) of the Ste Member Secvty of SPCB/ A Senior Official of the SPCB PlC on SEAR 56  (ahis presentation should cover, the present status of hazardous waste management in the State which wl include all the ongoing initiatives in the State for hazardous waste management; the magnitude of the problem in the state; the needfor the project; the State specifc details for each component such as the kind of institutional srengthening, technical assistance proposed etc. and the cost distrtion betwen the various components; the stages oftheproject wherein pubiieparticpation is envisaged) I 1.00 hr. Coffee Break 11.15 br. Question and Answe Session To be chaired by the Mmber Scetwy/Sereay (EnvWrnmenn) of the State 13.00 br. C(losureof PIC 71w aendOr medta s to be coouilwtedje:RCB/MOEF 1iw mhwu andp ro a Fs oftlw PlCm toC we so.wb d e_ #.ohe]Pye". d 43 Pn PIC Te SPCB shod aow tee days afte th PIC for writ =onse suggeon from the patcias on he NTS as wel as th SEAL In addto, the may be wrte commnts s to the SPCWBMOEF buod on the NTS. A rq tative a the SPCB/ MOEF who is iolvd with the Haadou Wse Mnagemet Project my co-ordt nd conple hse weiten respos. Al these co s should be se to EMC for final compilation and prdutio of a complete rTeo on the PIC ofthe project The SPCBs may s use this opportuiy to pvide any addion informato on project such as the updated ivt ai figurs, proposd e ts m the instu al compont ac. for fa incorporatim in the SEAR. This may be the fil opportnity avaiable for inorportion of infomation in the SEAL 4A Antdptory PannIg The folowig aspects may be requred to be considered i anticipaton of the ikely queies that may arse dig the PIC. PICon SEA 57  * The SPCBs may also require to make available to the public, information on the present facilities (institutional and technical) that the SPCB holds with respect to hazardous waste management. * Some sample anticipated questions for which the SPCBs may need to be prepared to provide clarifications for are: * Why has management of medical wastes bee excluded from the project ? How does the state PCB propose to handle this problem? Why medical waste is exchldd in the MoEF hazadous waste classification? * Are hazardous waste mnation technologies locally or indigenously available? How wil the SPCB's outrach the industries to inuce on minimization of waste? * What has been the progress so far of the Wastne Minization Circles as under the Industrial Peentio and Pollution Control (IPPC) Project prsety coordinatd by the Nationl Poductiy Council, New Deli * When wil te proposed chnges m the hazardous waste magement rles be mplemented? What are the specific chages emnvisagd? Wm the Boards be in a postim to adapt to the new rules? WiD there be diffrence in pois to tackle hazardous waste generators and small hazardous waste gxentors? * Wi there be any itere movemet of hazardous waste? ie. Wil therm be a common hazardous waste uutme and disposal fcily common to say two states? * The inventories of haZrdous wastes show that the contrition of category 12 (via sludges from Effluent Treant Plant) is the highest amongst other categories. What is the strategy to address this problem? Is all sludge arising out of the ETP hazrdous? Are there any possibilities to mmize its generation at source? * What is the policy regarding waste exhange le. selling of waste to interested parties for reuse, recycle and recovery? How will the sharig of responsibiiies wth respecto riss wi be done in this case? PIC SUNR 58  * What are the specific roles played by the Customs departmt regarding the control on the import of the hazardous wastes? * What is the responsibity of the tnsporter of the hazardous waste? Who will be responsible i case of accidentl spm of hazwdous waste? * What is the plan for ckan-up of contaminated legal bh dous waste dump sites? How wi the pollter pays priciple be implemened in case of iegal dump sites? * How is hazardous waste proposed to be maged in the State in the intenm penod between piot de projects for common hazardous ws treamnt amd disposd facities and the establsment of ful scale facilities? hoJd a half day brhnvwwdq qf~w CJ uats che _Jm -s psiwrAoPIC PlCon. SUAR 59  Annex I Distribution of Responsibilities Between SPCB's, MoEF and Environmental Management Centre (EMC) in Public Information and Consultation of Sector Environmental Assessment Report EMC D Develop guidelnes for PIC for the Boards of SEAR and send a copy to the Member Secrtaies and MoEF. * PrePare a Non-Technical Summary of 10 to 12 pages of SEAR and send to the Boards and MoEF. * Send daft SEAR to SPCBs and MoEF (one master copy) for the purpose of reproduction. * Be present at the SPCB and MoEF one daybefore the PlC witb theTeam * Make a presenuation on SEAR in the PIC. * Record the discussions carefuly and prepar minutes of the meeting. * Compe the mmiutes at each PIC and the feedbadcs (on PIC and NTS) and prepare a report for MoEF. * Incorpoaec the findins i fidlising the SEAR. SPCBs and MoEF * SPCBs to orgaize the PIC on SEAR based on the guidelines developed by EMC. * Trnmslate the NTS developed in local language