LANDFILLS DECONSTRUCTED TECHNOLOGY, MANAGEMENT AND EXPERIENCES TOXICS LINK August 1998

About Toxics Link We are group working together in India for environmental justice and freedom from toxic pollution. We have taken it upon ourselves to collect and share information about the source and dangers of poisons in our environment and our bodies, and about clean and sustainable alternatives for India and the rest of the world. We are an information exchange, which provides information (electronically and on-paper)and networking Group working on environmental toxicity issues. Author: Madhumita Dutta Acknowledgement : Ravi Agarwal, Deepika Pawar, Nityanand , Ann Leonard. Prof. Manoj Dutta for their comment and suggestion. Special thanks to March Carroll Of Multinationals Resource Centre.Washington DC, for researching and sending international information and case studies on landfills. Information in this document may be used with proper acknowledgement. Other Toxics Link report, published and forthcoming:

‘Not so inert after all1’- Fly ash: an environment and health perspective. A Toxics Links Briefing paper, September 1997. Aluminium smelting: Environmental and health implications, Common Effluent Treatment Plants: Technology, management and experiences. State wise compilation on the status of hazardous waste generation in the country.

Toxics Link H-2, Jungpura Extension New Delhi 110014 Tel: 11 24328006/24320711 Fax:+91 11 24321747 Email:srishtidel@vsnl.net and tidelhi@vsnl.com

Foreword

Waste cannot be wished away. Especially if it is hazardous or toxic – it could be a death wish. Not only for living beings, but for all which is life sustaining – water, air, soil, food. And waste is almost always produced, whenever we convert a natural resource into a product, though its nature and quality can be variable. Tucked between sheaves of our national environmental Acts, are the Hazardous Waste Management and Handling Rules, 1989. These few pages of legislation are actually meant to ensure that our life-sustaining resources are kept pure and uncontaminated from the indiscriminate dumping of such wastes. Why then did it take a Supreme Court to determine that not even in a single case had this law been actually applied? Of the over 8800 known hazardous waste producing industries, not one was disposing waste in a contained manner, i.e. in “secured” landfills. Even by conservative estimate, over 5 million tones of poison are already being spread each year. What has already been contaminated can hardly be cleaned up. Even if it were possible, the cost would be astronomical and unaffordable. The immediate response is to contain the poison. And the way to do is to secure it into landfills. What are landfills? How secure are they in actual practice? Are they the final answer to keeping our water and soil clean? Can we afford the technology? And what is the responsibility of industry in all this? What about communities, where these landfills will be sited? How secure are they? As part of current laws, communities have a right to ask and be given information through a public hearing process. But do they even know what to ask, or what dangers could lurk in their backyards? These are complex questions, relating to technology, management and experiences with landfills. To find these answers needed much research and information sorting. A task which Madhumita undertook with glee. This paper is an outcome of such concerns. It is meant to inform the common man, as well as raise the level of debate in more informed circles, about0 what is normally couched in scientific rhetoric, but is basically very simple – how to make a hole in the ground so that it contains something which is hazardous and unwanted – preferably forever. We felt that this information was especially urgent in light of the large investments being proposed for landfills currently, and the absence of any standards for them. We do not wish to be landed with mere leaking holes in the ground a decade from now, which could happen if the issues, which this paper raises are not taken into consideration. Ravi Agarwal Toxics Link

Contents Forward What is a Landfill? 1 Why are they being proposed in India? 1 Who generates the waste? 2 What is the government policy? 3 Landfill design 5 What does Landfill siting mean? Components of an engineered Types of landfill and liner system Liner material Liner systems Leachate collection system Standards for hazardous waste landfill liner systems Costs of a landfills 12 Fiscal costs Social costs and principles of environmental justice Environmental costs What does a public hearing for a landfill mean? 16 Questions to ask in a public hearing for hazardous waste landfill Annexe 1 : Maximum concentration of contaminants for the toxicity for toxicity character Annexe: 11 Waste Criteria for landfill disposal in Germany Annexe: 111: Off site Disposal/Treatment costs in the US Annexe: 1V: US EPA regulation for hazardous waste landfill liner system Annexe: V: Case study-The children of love canal Schematic diagram of hazardous waste landfill Glossary Readings List if contacts for information on Landfill

1.What is a Landfill? A Landfill is a facility used for the disposal of solid waste on the ground. An ‘engineered landfill” on the other hand is a carefully designed depression in the ground (or built on top of the ground) into which solid wastes-municipal or industrial, are sought to be contained. 2.Why are they being proposed in India? India, ranked the world’s eighth largest economy and arguably tenth most industrialized nation, during the past few years of economic liberalization has, witnessed a major rise in industrial production. Industrial output in the last 30 years has been growing at an average annual growth rate of about 5.5 percent1 with the highest recorded in 1995-96 at 12.1 percent2

While the industrial growth in the last 30 years has grown four fold, consequent Toxic Releases has grown six folds3 The central Ministry of Environment and Forests (MoEF) has estimated a conservative figure of 5 million tones of hazardous waste generation every year in India.4 Where does all this toxic and hazardous wastes go? In absence of any mechanism to tackle such huge and rapidly growing wastes, currently mot of it finds its way into land and water bodies. Despite laws, there has been complete absence of any monitoring and disposal mechanism of these waste by pollution control agencies. Studies conducted by Pollution Control Boards (PCBs), MoEF and institutions like National Environmental Engineering Research Institute (NEERI) and National productivity Council (NPC) indicate that the disposal methods currently practiced (or not practiced) for hazardous and industrial wastes management are not environmentally compatible5Fig. 1: Toxic Pollution and Industrial Growth, 1963-91

Fig 1: Toxic Pollution & Industrial Growth

0100200300400500600

1963, 1968, 1973, 1978, 1983, 1988, 1991,

Years

Toxic Emissions Real Output GDP

Source: World Bank, 1996. “India’s Environment:Taking stock of Plans. Programs and Priorities. An Assessment of the Environment Action Program-India”.p-138

1. World Bank, 1996, “India’s Environment: Taking stock of Plans, Programs and Priorities, An Assessment of the Environment Action Program – India. P. 138. 2. Anindya Sen, et al. 1997. “Industry: Coping with new challenges” In India Development Report, 1997. Edited by

Kirit S Parikh. Oxford University Press, Delhi.p124 3. Reference 1. 4 Ministry of Environment and Forest. 1997, “ India-Hazardous Waste management Project Sectoral Environmental Assessment Report (Draft version 2.0). Submitted to the World Bank.” New Delhi. 5 . Ministry of Environment and Forest, Hazardous Substances Management Division. 1991. “Guidelines for Management and Handling of Hazardous Waste.” New Delhi.

In India, till now there are only a few known landfills for hazardous or industrial wastes disposals, mostly constructed by industries for their own use, even though this is contrary to the law. So far there are no commercial or common landfills. On the face of it seems India does not have much option but to dispose the hazardous waste on land-that is in ‘engineered landfills’. The current practice of indiscriminate land and water disposal of waste will cost both economically and environmentally. The costs of remediation or clean up of hazardous wastes contaminated sites are astronomical. “The costs may vary between US$501 to $5,000 per tonne depending on the type of pollutant and soil or water medium which needs to cleaned up. In the US, where 275 million tones of hazardous waste is generated in a year, the clean up costs of past improper disposal have been recently estimated anywhere between $20 million to as high as $ 200 million per site. Therefore if India is generating 5 million tones per year of hazardous waste, at an average cost of $ 400 per tonne, the liabilities to clean and restore the contaminated site would be more than $ 2 6billion” Can India afford such remediation costs? Of course it needs to be said that no remediation is ever complete, in view of the toxics and complex nature of the wastes involved. A landfill is only an end-of-pipe solution, By dumping the waste in a landfill, the problem is only deferred, not solved. Land disposal of waste should ideally be the last option when all other efforts or options of waste disposal and minimization like recycling and reuse, treatment processes are done. There are ways in which many processes can minimize their toxic output, through consciously adopting cleaner production practices. Some of them can be more expensive than original production processes since environmental costs are not built into the processes. However if one accounts for the cost of landfilling and treating waste, then the equations change and such accounting could be an important motivation to reduce waste. 3. Who generates the waste? Major waste generators in India are petrochemical, pharmaceutical, pesticide, paint and dye, petroleum, fertilizer, asbestos, caustic soda, inorganic chemicals and general engineering industries. For the purposes of implementing a remedial program, ‘Toxic hot spots’ have been identified in the State of Andhra Pradesh, Gujarat, Maharashtra and Tamil Nadu which generate more than 60% of all hazardous wastes. The hazardous wastes include heavy metals, cyanides and pesticides, complex organic compounds such as H-acids, aromatic

compounds like Poly Chloro bi-phenyls.7

Fig 2: Share of Toxics Release(%)

44%

23%

6%

6%

1%2%1%

6%

3%8%

Industrial Chemicals

Iron and steel

Nonferrous metals

Other chemical

Food products

Paper and pulpprpducts2Nonmetaiiic mineralproddducts1Petroleum refineries

Textiles

Others

Source: World Bank 1996. “India’s Environment: Taking stock of Plans, Programs and Priorities. An Assessment of the Environment Action Program – India”. P.139

.6 Reference4 7 . Reference4.

Table 1: Status of Hazardous waste generation four ‘toxic hot sports’ – Andhra Pradesh, Gujarat, Maharashtra and Tamil Nadu.8 State No. of districts

inventoried Quantity of Hazardous Waste generated (million tones/annum)

Categories in which maximum waste is generated

District/Region showing maximum generation

Andhra Pradesh All districts 0.10 Cat.12-30% Cat.6-16%

Ranga Reddy

Gujarat All districts 0.50 Cat.12- 45% Cat.9-43%

Vadodara

Maharashtra All districts 1.60 Cat.12-78% Cat.17-12.8%

Thane, Pune Raigad, Mumbai

Tamil Nadu

All districts 1.40 Cat.12-41.4% Cat. 10-28%

North Ascot, Anna, MGR, Colmbatore

Note: Cat.6-Halogenated hydrocarbons including solvents; Cat.9-Wastes from dyes and dye intermediates; cat.10-Waste oil and oil emulsions; Cat.12-ETP Sludge; Cat.17-Off-specification and discarded products. (The categories of wastes as specified under ‘The Hazardous Wastes (Management and Handing) Rules, 1989) 4. What is the government Policy? In India the only rule even remotely governing hazardous waste disposal sites (landfills), is The Hazardous Wastes (Management and Handling) Rules, 1989 under The Environment (Protection) Act, 1986. Under sector 8 of these Rules, the state government is responsible for identifying, carrying out environmental impact assessment study and publishing inventory of disposal sites within the state for disposal of hazardous wastes. Under this rule, the state government should also gather “information relating to the amount, nature and toxicity of hazardous wastes at each such site as may be associated with such site” 9Guideline have also been published by the Ministry of Environment and Forests entitled “Guidelines for Management and Handling of Hazardous Waster, 1991” which deals with the siting criteria for disposal facilities.

Box 1 : India Hazardous Waste Management Project

Increased pressures from environmental groups, individuals, concerned communities and judiciary actions have led the authorities to come up with some initiatives to manage the hazardous waste disposal in the country. One major response in the proposed Rs. 1000 crore ($ 290 million) India Hazardous waste Management Project to be financed with a World Bank loan, domestic debt from financial institutions, equity contribution from industrial units.10 The project has various components like ‘Enforcement and Compliance Component’ meant to strengthen the monitoring and enforcement capacities of the State Pollution Control Boards (SPCBs) in the four ‘hot spot’ States, and a ‘Technical Assistance Component’ to provide training in waste minimization, analyses, detection and storage of hazardous wastes, besides the development of an information management system. The third is an ‘Infrastructure Development Component’ to provide financial assistance to industrial units for waste avoidance and minimization as well as for the establishment of Common Hazardous Waste Treatment and Disposal Facilities (CHWTDF). The CHWTDF includes storage transportation, minimization, reuse, recycle, recovery, treatment and disposal. S11ites are being identified in the four states for constructing “secured” or engineered landfills for disposal of hazardous for disposal of hazardous waste on land. To begin with, India doesn’t even have published standards for constructing landfills. The landfills to be constructed will follow the US EPA standards according to the World Bank.

So far, India has not prescribed any standards for hazardous waste landfills. Nor is there any comprehensive data on the amount of hazardous waste generated in India. Infact the concerned authority’s knowledge of the quantity of hazardous waste generated, its treatment and disposal methods and the dangers posed to the public is very nebulous. So are the Government’s policies on hazardous waste management. State Pollution Control

8 . Reference 4. 9. The Hazardous waste (Management and Handling)Rules, 1989. 10 . V.M Sathish “ Rs 1,000-cr waste management project.” Times of India5 september 1997. Mumbai 11 . Reference 4.

Boards entrusted with power to enforce and govern the generation, treatment, transport, storage, disposal and import of hazardous wastes under the Hazardous Wastes (Management and Handling) Rules, 1989, are yet to implement it effectively. This is evident from the fact that out of approximately 8800 known hazardous waste generating units almost 200 units are operating without any valid authorizations.12

Table 2 : Status of implementation and various provisions of Hazardous Wastes (Handling and Management)

Rules, 1989 13(the data is for October 1996) S.No State Number of

Hazardous waste generating units

Methods of treatment and disposal Disposal sites Identified

NORTHERN REGION 1. 2. 3. 4. 5. 6. 7.

Punjab Chandigarh Uttar Pradesh Rajasthan Haryana Himachal Pradesh Madhya Pradesh

442 7 658 301 55 63 208

No treatment, land disposal and dumping in lined pits after packing into polythene bags Reprocessed No treatment, land disposal Incineration/Reprocessing Land disposal NA Adopted the recommendation of the study report

1 Nil 8 1 Nil 1 Nil

NORTH EASTERN & EASTERN REGION

8. 9. 10. 11.

Assam Bihar Orissa West Bengal

15 22 112 98

No treatment Physical treatment No treatment No treatment

Nil 2 2 1

WESTERN REGION 12. 13

Gujarat Maharashtra

1346 864

Dewatering and incineration, incapsulation Physical treatment /incineration/landfills

7 3

SOUTHERN REGION 14. 15. 16 17

Tamil Nadu Andhra Pradesh Karnataka Kerala

825 233 452 62

Reclamation, De-toxification & Incineration Incineration and land disposal NA Industry wise details provided

9 2 14 nil

TOTAL 5763 51 5. Landfill design While designing and constructing landfills we have to adopt a principle of precaution to avoid taking any chances and act on the basis of the worst case scenario. The concept of an engineered landfill is to have a “multi-barrier approach”. Barrier can be of different types, not just physical barriers like liner systems, and can exist at various stages of the waste stream. Broadly they are-pre-treatment of wastes, waste characterization, geological barrier like selection of a site which has desired water table level desired soil conditions, ‘seepage barriers’ like liners systems and liner material. Another key factor to be considered while siting and constructing landfill, though mostly overlooked, is the social acceptance of a landfill.

12 . Reference 4. 13 . Affidavit of Secretary , of Ministry of Environment and forest, October 1996. Filed in Supreme Court.

It was earlier believed that engineered landfills could contain or isolate wastes indefinitely. In fact the term ‘secure’ landfill, which is still commonly used, is a misnomer. As experience in the west has shown, even the state-of-the-art landfills eventually leak after a certain period of time (30 to 50 years), and landfill design must account for this. “It is more appropriate to design (landfill) for controlled release rather than attempt indefinite isolation because all containment systems will eventually allow passage of water beyond the design period.”14 What happens when landfills leak and hazardous waste finds its way into the ground water and soil? They can be especially dangerous, since it could contain not only untreated sludge, but sludge which is mixed with other unknown chemicals at the dump, producing combinations unknown and unpredictable. There is thus no way of designing a landfill which could be deemed ‘safe’ forever. 1. What does Landfill siting mean? Site selection is one of the major considerations while constructing landfills. The idea is to avoid any contact between the wastes and the surrounding environment, especially ground water. As a thumb rule there always has to be a difference of 1m (meter) between the base of the landfill and the ground water table15

Selecting of a site is governed by two major factors: economic and environmental factors. People’s participation and acceptance in the site selection is also crucial. Under the section on “siting of hazardous wastes treatment and disposal facility” in the MoEF guidelines a set of 34 attributes, broadly categorized as - receptor related, pathway related, waste characteristics and waste management practice related, has been considered for ranking of hazardous waste treatment and disposal site alternatives. For each of the attribute a four level sensitivity scale has been considered ranging from 0 (indicating no potential hazard) to 1 (indicating a highest potential hazard). [The sensitivity scale is divided in 0.0-0.25, 0.25-0.5, 0.5-0.75, 0.75-1.0 respectively] The value of sensitivity index is multiplied by the corresponding weightage (arbitrary value). This gives the score for each of the attributes. The site with the least score is less sensitive, in other words most suitable site for a disposal facility and vice versa. According to the guidelines “the results of ranking should be put to general public to finalise the site.”16 Attributes for site selection 17 Receptor related Population within 500 meters, distance to nearest drinking water well, use of

site by nearby residents, distance to nearest off site building, presence of major transportation routes, land use/zoning, critical environments.

Pathway related Distance to nearest surface water, depth to ground water, type of contamination, precipitation, soil permeability, bedrock permeability, depth to bedrock, susceptibility to erosion and runoff, climatic feature with respect to air pollution, susceptibility to seismic activity.

Waste Characteristic Toxicity, radioactivity, persistence, ignitability, reactivity related corrosivity, solubility, volatility. Waste management Physical state, hazardous waste quantity per annum, waste Practice related incompatibility, co-disposal with municipal wastes, use of liners, incineration

with off-gas cleaning, leachate treatment, site security, safety measures.

14 . Manoj Dutta.1997 “Waste generation and disposal on land,” Waste Disposal in Engineered Landfills. New Delhi: Narpsa Published House.p10. 15 . Dr jochen Vida. Advisor Hazardous Waste Management. Indo-German Coopertion Project (GTZ), “Industrial Pollution Control”,(perspnal interview). 16 . Reference5. 17 . Reference5.

Example of ranking of site for hazardous waste treatment and disposal facility18

Affributes Score Max. Site A Site B Site C Site D Receptor related 320 287 134 159 252 Pathway related 280 246 106 250 227 Waste Characteristics 220 155 110 179 185 Related Waste management 180 80 82 118 146 Practice related Total score 1000 778 432 706 810 Rank III I II IV

ii. Waste characterisation Waste characterisation is an important step before hazardous waste is dumped in a landfill. The reason being some wastes when mixed together can produce violent reactions, explosions, toxic fumes, gases and fire. US EPA has selected four characteristics as inherently hazardous in any substance ignitability, corrosivity, reactivity and toxicity. 19The MoEF guidelines on hazardous waste management (1991) also gives a list of wastes which are potentially non-compatible and care should be taken while disposing these wastes in landfills. One of major concerns in a hazardous waste landfills is leaching of toxics into the ground water. There are number of cases in the US where toxic chemicals from the hazardous wastes landfill sites have leached into the ground water and effected the neighbouring community. (see box: on cases of human health effects from leaking landfills) When water infiltrates into a landfill, or is there is any moisture left in the wastes, it dissolves some of the constituents of the wastes through chemical reaction. This leads to the generation of leachate, which is “a contaminated liquid that contains a number of dissolved and suspended materials.”20

Table below lists certain types of wastes, which should not be dumped in the landfills directly Box 2: List of Wastes not allowed to be disposed off directly into the landfill facility. (as per German standards)21

which is a fluid, slurry or waste which is delivered under pressure or under vacuum which has an obnoxious odour which reacts with moisture to produce considerable amount of heat or gases which is highly inflammable (flash point <40 deg. C) which contains shock sensitive substances which contains very strong oxidising agent which contains volatile substance of significant toxicity which contains more than 10 mg/kg cyanide in the original sample which contains more than 10 mg/kg chromate in the original sample which contains more than 0.5% (wt) mercury which falls below a pH value of 2 if eluted 1/10 which contains more than 10 mg/l of water soluble arsenic in a 1/10 eluate which contains more than 10 mg/l of soluble mercury in a 1/10 eluate which contains more than 3% solvents free from halogen which contains more than 0.5% halogenated solvents which contains more than 0.1% polyhalogenated substances of significant toxicity (PCBs)

18 . Reference5. 19 . P.V.SiVpullIh. 1997 “Waste Characterization,” in Waste Disposal in Engineered Landfills,p27 20 . Manoj Dutta.1997. Generation and control of leachate and landfill gas.” In Waste Disposal in Engineered and fills. New Delhi : Narosa published house,p88. 21 . Dr A.K Sexena. 1998, National Productivity Council. New Delhi .(personal interview)

To detect wastes likely to leach “hazardous concentrations of particular toxic constituents into the groundwater as a result of improper management” the Toxicity Characteristic Leaching Procedure (TCLP) test is carried out. The US EPA has given a regulatory level for maximum concentration of contaminants in wastes for the TCLP test. (Annex no: 1) In the TCLP test, constituents are extracted from the wastes and tested. If the extract contains any of the contaminants at a concentration equal to or greater than the respective value as specified by the US EPA, then the waste exhibits toxicity.22According to the officials of Tamil Nadu Pollution Control Board (TNPCB), one of the four states selected for India-Hazardous waste management Project “TCLP test will carried out before and waste is dumped in the landfills. If the wastes are found to be non-conforming with the US EPA standards (TCLP standards), then they have to be re-treated to attain the desired standards.” iii. Components of an engineered landfill Landfill design and liner specifications varies with the type of wastes to be disposed in the landfill, but the basic components are23

• A liner system at the base and sides of the landfill which prevents migration of leachate or gas to the surrounding soil. Liner materials usually comprise of compacted clays or geomembranes.

• A leachate collection facility which collects and extracts leachate from within and from the base of the

landfill and then treats the leachate.

• A gas control facility which collects and extracts gas from within and from the top of the landfill and

then treats it or uses it for energy recovery. (Gas collection is usually done for municipal wastes landfills)

• A final cover system that enhances surface drainage, intercepts infiltrating water and supports surface

vegetation. The final cover system comprises of multiple layers of soils and/or geomembrane materials.

• A surface water drainage system that collects and removes all surface runoff from the landfill site.

• An environmental monitoring system, which periodically collects and analyses air, surface water, soil-

gas and ground water samples around the landfill site.

• A closure and post closure plan which lists the steps that must be taken to close and secure a landfill site once the filling operation has been completed and the activities for long-term monitoring and maintenance of the completed landfill (typically 30 to50 Years.)

iv. Types of landfill and liner system In the US, there are three types of landfills-type l Landfills: Hazardous waste; Type ll Landfills: Designated waste; Type 111 Landfills: Municipal solid waste.24 Germany also has three types of landfills-non-hazardous or less hazardous wastes, municipal wastes and hazardous waste landfills respectively. In India, National Productivity Council (NPC) has been actively involved in designing and constructing “secured” landfills for industries. Central Pollution Control Board along with NPC has published recommendations for constructing

22 . P.V.Sivapullaiah .1997. “Waste Characterization.” In Waste Disposal in Engineered Landfills.p31 23 . Reference 14. 24 . Reference.14

engineered landfills for Aluminum Industry to dispose the Spent Pot Lining (SPL) waste generated during electrolysis of Alumina.25 (see section on liner systems) a. Liner material Liners are the crucial components of a landfill and act as “seepage barrier”. Therefore the liner material chosen should have – “low permeability or hydraulic conductivity, adequate strength for stability of liner under compressive load, minimal influence of leachate on hydraulic conductivity.”26 Liner materials are usually of the following types27

Natural clay. “Wherever suitable low permeability natural clay materials are available they provide the most economical lining material. A competent liner made of compacted clay should have hydraulic conductivity of 10-7 cm/sec and a thickness of 100 cm or more.” If clay is not available, then good quality bentonite enhanced soil / amended soil. “Soil-bentonite

admixtures are commonly used as low permeability amended soil liners. Most high permeability soils can be blended with sodium bentonite to achieve hydraulic conductivity less than or equal to 1 x 10–7 cm/sec.” Synthetic geomembranes: flexible membrane with amended soil or geosynthetic clay liners (GCLs).

The most commonly used geosynthetic material for hazardous waste landfill in the western countries is High Density Poly Ethylene (HDPE).

In India, NPC is constructing landfills for hazardous waste disposal using asphalted concrete liner as per the German standards. Asphaltic concrete is basically the material that is used for lying of roads made of bituminous, gravel, stones chips, and fines. “Materials used for asphalt layers are mixtures, of which around 95% of the weight is made of aggregates (from rocks quarry, sand, gravel) and 5% bituminous binding agents” 28Reasons for using asphaltic concrete is “it is low cost, raw material is indigenously available not much expertise is required for installation of the liner and it can be supervised by experts in India”, said Dr A K Saxena of NPC

Box 3: Ankleshwar landfill29

NPC is making a landfill using asphaltic concrete liner in Ankleshwar, Gujarat, for disposal of industrial wastes from Ankleshwar, Jagadhia and Panoli industrial area (These areas come under Gujarat Industrial Development Corporation). 16 acres of land has been allotted for construction of the landfill within the Ankleshwar GIDC area. Capital costs of the landfill is Rs. 20 crores with a life time of 10 years. It will be operational from April 1998 and 50,000 tonnes/year of wastes will dumped in the landfill from the three estates. A tipping fees of Rs. 385 per tonne plus transportation costs will be charged from the industries using the landfill. According to Ashok Panjwani of United Phosphorus Ltd. “it might work out to be Rs. 1 lakh a month for a industry depending upon the tonnage and type of wastes generated.” A private limited company named Bharuch Enviro Infrastructure Limited has been formed by the industry association of the three industrial estates to oversee the landfill. The company will be responsible for proper construction, monitoring, operation of the landfill, collecting tipping fees and will also be liable if there is any accident or disaster due to the landfill. Most of the industries in these areas, especially in Ankleshwar are chemical industries like fertilizers, pesticides, dye and dye intermediates.

25 Central Pollution Control Board. 1997. “Spent Pot Lining Waste Aluminum Industry.” Comprehensive Industry Document, Series: COINDS/51/1994-95 26 . Monoj Dutta and Ashish Juneja. 1977, “ Landfill liners: Compacted clays and amended soils .” In Waste Disposal in Engineered landfills. New Delhi: Narosa publishing house.p120 27 . Reference 26. 28 . Reference 15. 29 . Ashok Pankwani, united Phosphorus Ltd, Anklshwer , Gujarat. 1998. (Personal interview)

In the US, Germany and other European countries HDPE liners are used in combinations with clay and soil for hazardous waste landfills. In Germany, since 1996, German Institute of Civil Engineering, the authorizing agency, gave a ‘general permit’ to use asphaltic concrete liners as a basal liner or as the base for the class II sites, that is landfills for disposal of municipal wastes and selected hazardous wastes, like sludge from effluent treatment plants. NPC is adopting the standards used by Germany with “some modifications” for hazardous waste landfills. “In Germany the regulations are very stringent, that is why they do not allow the use of asphaltic liners for disposal of hazardous waste. Though asphaltic liners can be used for hazardous wastes” said Dr Jochen Vida, a German expert on hazardous waste management.30 b. Liner systems According to experts liner systems are usually “tailor-made” or made according to the type of waste that is going to be disposed in the landfill. A Liner system comprises of leachate drainage and collection layers and barrier layers31 In the western countries there are separate specifications and standards for liner systems for each type of landfill-design, types of liner material, leachate quality of the waste to be disposed. Usually three types of liner systems are adopted.32:

• Single layer liner system: This system has a single primary barrier overlain by a leachate collection system with an appropriate separation/protection layer.

• Single composite liner system: This system has two barrier layers, made of different materials, placed

one above the other, without any air space between them. Usually a flexible geomembrane is placed over a clay or amended soil barrier. A leachate collection system is placed over the composite barrier.

• Double Liner systems: In this, the same barrier layer is placed twice. The top barrier or the primary

barrier is overlaid by a leachate collection system. Beneath the primary barrier, another leachate collection system is placed followed by a second or secondary barrier. This type of system is usually adopted for industrial wastes landfills or hazardous wastes landfills.

v. Leachate collection system A leachate collection system comprises of a drainage layer (made of gravels), a perforated pipe collector system, sump collection area, and a removal system. The perforated pipes and sumps are provided within the drainage layer.33 The leachate is collected in the sump from where it is pumped out and sent for treatment. In India, the quality of the treated leachate has to be as per the standards stipulated under the Water Act (1974) before it is disposed. The drawbacks of a leachate collection system are-it can clog up easily due to a) silt and mud, b) microbial growth (common in municipal landfills), c) chemical reaction leading to the precipitation of minerals in the pipes. The pipes can be weakened by the chemical attack (acids, solvents, oxidising agents, or corrosion) and crushed by tonnes of wastes dumped on the landfill.34 vi. Standards for hazardous waste landfill liner systems a. German Standards for hazardous waste landfills-Class III site In Germany for hazardous waste landfills a composite liner system is used35.

30 . Reference 15. 31. Manoj Dutta.1997. “Generation and control of leachate and landfill gas.” In Waste Disposal in Engineered landfills. New Delhi: Narosa publishing house. p97. 32 . Reference 31. 33 . Reference. 34. Rachel’s hazardous Waste News no. 119. 1989. “Leachate collection system: The Achilles’ Heel of Landfills”. 35 .Reference 15.

Before the basal layer there is a 3 m thick soil layer with hydraulic conductivity or permeability factor not more than 10-7 m/sec.

The basal liner comprises of six layers of mineral sealing layer (clay + soil) with a thickness of 25 cm

(centimeter) each, that is 150 cm in total with a permeability factor of <5x10-10 m/s. Above this, a geomembrane, made of HDPE, of 2.5 mm is placed followed by a protective layer of geotextile (a permeable synthetic textile product in the form of manufactured sheet, may be woven, non-woven or knitted36)o protect the HDPE liner from the drainage layer.

Then comes the leachate drainage and collection layer, with a thickness of 30 cm.

After which comes the wastes.

Once the landfill is full to the earmarked capacity (usually 10-15 years) comes the closure or cover

systems. Over the waste a 50 cm thick transitional layer or the gas collection layer.

Followed by two mineral sealing layers each with 25 cm thickness.

After which comes 2.5 mm thick HDPE sheet,

Above which is 30cm thick lateral drainage layer.

On top of this is 100 cm topsoil. (Annexe it gives the waste criteria for landfill disposal in Germany) b. Asphaltic concrete liner system as adopted by NPC following German standards In India, as adopted from the German standards, the landfill liner system for hazardous waste disposal has following components:37

Base course: 8 cm thick asphaltic concrete layer, with bituminous content of 5.2-6.5%, void content

less than or equal to 5%, grain distribution between 0-16 mm and hydraulic factor of 10-11 m/s. (As per German standards, before the asphaltic concrete layer there are two mineralic layers of 25 cm thickness.)

Asphlatic concrete sealing layer: Above the base course comes 12 cm thick asphaltic concrete sealing

layer, two 6 cm thick layers placed one above the other. With bituminous content of 6.5-7.5%, void content less than or equal to 3%, grain size distribution of 0-11 mm and hydraulic factor of 10∞ m/s.

Leachate detection and drainage layer: This is placed just above the sealing layer. It is 30 cm thick.

Side lining: The sides can be lined either with 3 mm thick polymeric bituminous felt or by asphaltic

concrete. If its of bituminous felt then the base has to be of Reinforced Concrete Cement or Portland Concrete Cement.

Cover system: The cover is made of a thick layer of compacted soil on top of which is a 3mm thick bituminous felt reinforced by synthetic grid material (or polymeric bituminous felt).

36 . G.Venkatappa Rao. 1997. “Landfill liners: Use of Geosynthetics.”In Waste Disposal in Engineered Landfills. New Delhi: Narosa Publishing House. p131 37 . Reference.21

Box 4: How feasible are Asphaltic liner?

There are differences of opinion amongst experts on use of Asphaltic liner for hazardous waste landfills. While one group of experts feel its the “best option for India to adopt-it being economical and technology is indigenous”, the other feel it is “not feasible to use it because it is very difficult to ensure in-situ (or on site) construction quality control in case of asphaltic concrete liners.” Say IIT experts “It is very difficult to do in-situ quality assurance tests in case of asphaltic concrete liners like tests for - porosity, moisture content, longevity, tear, shrinkage, cracks, exact void content.” And also it is difficult to ensure that “no organic solvents” enters the landfill which would damage the asphaltic liner. For every liner system its very important to do on-site test for quality assurance. “For every earth work, after every 1000 cu m (cubic meter) and for each layer, five (approximately) test are done. Like density, moisture content, permeability, porosity, grain size distribution. In case of HDPE and clay it is feasible to do these tests on the field but for asphaltic concrete it is extremely difficult to do so” say IIT experts. As for the argument that “asphaltic liners are cheaper than HDPE”, IIT experts say “to achieve the desired parameters for asphaltic liners like void content, proper mix of the layer material, proper laying of the liner, very good pavers and rollers are needed. Which are not available in India and are very expensive. If we consider the costs of these machineries then the landfill costs automatically goes up and it is equally expensive liner system”. Even Dr Vida agreed that in Germany “they use highly sophisticated rollers with rubber tyres for asphaltic liners”. IIT experts strongly feel that “for hazardous wastes disposal, HDPE liners should be used and there should be a Minimal National Standards for Hazardous Wastes Landfills.” IIT also has reservations on the Spent Pot Lining landfill design as promoted by the CPCB and NPC. In the design of the SPL landfill, it is recommended to use38

Admixture of 15% Bentonite and 85% native soil in four layers of 0.25m thickness each (total 1m)

and hydraulic conductivity of less than or equal to 10-9 m/s as base over 2m thick re-compacted soil. Above which is 4mm think asphalt coated tarpaulin/ canvas.

Above this, 30 cm thick layer of sand followed by a 30 cm thick layer of coarse gravel comes. The

gravel layer is covered by a jute layer, which acts as a “filter layers”.

This is followed by 50 cm thick compacted native soil with hydraulic conductivity between 10-3 to10-5 m/s above which is 10 cm thick layer of lime.

Experts from IIT have reservations on – 1) ‘15% Bentonite’ – it can not be standardized as it will vary from site to site depending on the quality of native soil. For example, “if Yamuna soil is used then the percentage of bentonite should be much higher.” 2) ‘Asphaltic coated canvas’ – it is a no-standardised material on which results on strength, durability

and puncture resistant test have not reported for its use in landfill.

3) ‘Just used as a filter’ – it is a biodegradable material and with time will cease to function as an effective filter. Since all these are biodegradable it is quite “dangerous” to use them as liner material since it might lead to “landfill leakage”.

38 . Reference.25.

Box 5: HDPE liners-are they full proof? Though HDPE liners are considered to be the best liner materials for hazardous waste landfills, looking at the list of chemical that are incompatible with the HDPE liners it is difficult to decide whether it is as good as it is made out to be. To class of chemicals are listed to be most incompatible with the HDPE liners: aromatic hydrocarbons and halogenated hydrocarbons. The few of the aromatic hydrocarbons are – benzene (a major component of gasoline), toluene, xylenes (o-, m- and p-xylene), naphthalene (moth balls), and p-dichlorobenzene. Some of the halogenated hydrocarbons are-carbon tetrachloride, chloroform, DDT, aldrin, dieldrin, lindane, 2,4-D, 2,4,5-T, trichloroethylene, trichloroethane. Apart from these other chemicals that can cause damage to the HDPE liner are: acetic acid (1% to 10% solution), food and food products – vinegar, vanilla extract, household toiletries and pharmaceutical products – detergents, dry cleaners, hair oil, shampoo, hand creams, iodine (tincture), nail polish, shaving lotion. If the above listed chemicals, which are most commonly used, can not be dumped in the HDPE lined landfills, which are supposedly the best liner material available, then what will happen if hazardous wastes is dumped into such landfills? Source: Rachel’s Hazardous Waste News 117, February 21,1989. 6. Costs of landfills i. Fiscal costs Landfills are by no means cheap and final disposal solutions. In the United Kingdon, the Confederation of British Industry estimated an increase in 150% in landfill costs from 1985 to 1991. 39 In Germany, the capital cost of a hazardous waste landfill with a capacity of 200,000 m3/year and a life time of 25 years costs 40 million Deustche Mark (Rs. 868 million).40 The capital costs for the SPL landfill with a total capacity of 1,20,000 tonnes of wastes for 10 years as estimated by the CPCB and NPC is Rs. 2.5 crores, with an annual operating cost of 7.5 lakhs per annum. The total area required for the landfill is approximately 7.5 acres.41 (See Annex III for costs of treatment/disposal of wastes in the US).

The main factor governing the costs of a landfill is its liner system. Almost 70% of the costs of a landfill are spent on the liners. In Germany, out of the 40 million 28DM (Rs. 607.6) is spent on the liner system. An asphaltic concrete liner system in Germany would cost between 69-84 DM per sq. m. (ranging between Rs. 1600-1800) and a composite liner system would cost 114-116 Dm per sq. m. (between Rs. 2500-3000). In case of SPL landfill, out of Rs. 2.5 crores Rs. 1.6 crores is spent on liners. According to Dr A. K. Saxena “cost of asphaltic concrete liner is Rs. 700-1000 per sq. m (square meter) including the installation costs, where as HDPE liners are much more expensive.” The reason for higher cost of HDPE liner according to Dr Saxena is “not only do you have to get the liner from abroad but also experts for proper installation.” However in India, Z-Tech, a Canadian company, is selling HDPE liners with thickness of .75mm at the range of Rs. 160-200 per sq. m (including installation charges), 1.5mm HDPE liners for Rs. 300 per sq. m and 2.5 mm HDPE liners for Rs. 400 (including installation charges).42

Not only construction costs, but also cleaning up of leaking abandoned hazardous waste landfills costs a lost of money and are a major cause of concern in western countries. In the US, the Superfund, a trust fund, was 39 . Jim Puckett. “The Basel Ban: A triumph over business-as usual.” The Ecologist Asia, Vol.5, no.2 ,p5, 1997. 40 .Reference.15 41 . Reference.25 42 . Spokesperson Z-Tech Company, New Delhi. January 1998. (Personal interview)

created under The Comprehensive Environmental Response, Compensation and Liability Act, 1980, to clean up the nation’s worst hazardous waste sites, known as the National Priorities List (NPL) sites. The US Environmental Protection Agency has screened 35,000 potential sites and has placed 1,295 sites on the final NPL list which includes leaking landfills, toxic metals leaching from abandoned mines, contaminated groundwater caused by industrial discharges. 43Super funds costs the United States $ 4 billion annually. A study by the West Management Research and Education Institute at the University of Tennessee, USA has estimated that Superfund would eventually cost the US about $ 400 billion .44Can India afford to have a policy like Superfund with millions to spend on cleaning up leaking landfills on top of first constructing those landfills and also cleaning up sites which have already been contaminated due to the indiscriminate dumping of hazardous wastes.

Box 6: What is a landfill tax?45 Who bears the cost of operating a landfill? The obvious answer is that the polluter should. One way of ensuring this, as also to put a cost onto the disposal of waste and simultaneously create an incentive to reduce it, is to impose some sort of a tax or a fee on the usage of a landfill. Such a fee can be administered in many ways, from a central indirect tax, as in the UK to a tipping fee, which is paid to the landfill operator in other countries. In fact the absence of such a cost, which is to be borne by the generator of waste, amounts to a subsidy on its creation. For example in United Kingdom, Australia, Denmark, Austria and Germany landfill taxes have been introduced as key economic instrument for managing wastes. Introduced in 1996 in U.K, the tax is payable by a licensed landfill site operator. The landfill operator can be a licensed (under the Environment Protection Act 1990) private company or individual or the waste disposal authority occupying the landfill site. When the tax was introduced in the U.K., landfilling of active waste (wastes which can react with other wastes or are hazardous in nature) was subjected to a tax of 7 pounds per tonne (almost Rs. 500 per tonne) and inactive or inert wastes was 2 pounds per tonne (Rs. 140 per tonne). Tax for active wastes is proposed to be raised to 10 pounds per tonne (Rs. 700 approx.) from April 1999. The proposed hike in taxes will act as a “deterrent” for waste generators and reduce the amount of wastes sent for landfilling. The objective is to push the industries towards cleaner technologies, waste minimization, boost recycling and reuse. The tax hike has been announced well in advance so that the industries and local authorities have enough time to time of think of alternative strategies for waste minimization. In India, similar taxes can be imposed and waste generators/industries be made liable for bearing the landfill costs. So far the States have been bearing the disposal costs of wastes in the country. ii. Social costs and principle of environmental justice Environmental and social costs are either not considered or not easy to consider, while estimating the costs of a hazardous wastes disposal. One of the most hotly debated issues in hazardous waste disposal facility is the siting of such facilities in ‘impoverished localities’. Environmental and social activists the world over claim that a majority of hazardous waste dumping sites are located in poor and minority communities. In the US, activists charge that

43 . Mercia Carroll (1997). Multinational Resource Centre, Washington D C, USA. (Personal communication) 44 . Philip O’ Leary and patrick Walsh. “Introduction To Solid Waste Landfills.” Solid and Hazardous Waste Education Center, University of Wisconsin-Madison. 45 . T.R Rustagi, Joint Secretary,Ministry of Finance,Govt. of India. August 1998.(Personal interview)

“Superfund sites are an element of ‘environmental racism’, the practice of siting waste facilities in minority communities and that leaving them unremediated is disproportionately injurious to the poor.46

In 1987, the United Church of Christ’s Commission for Racial Justice (CRJ), USA did a study – “Toxic Wastes and Race in the United States” on the “relationship between race and the location of hazardous waste sites” and concluded that “race was the significant factor” in the location of hazardous waste facility. CRJ found that “minorities were five times more likely to live in a community with an off-site commercial hazardous facility (landfill and incinerators) and four times more likely to stay in a community with uncontrolled toxic sites.” The report attributes three factors for location of hazardous wastes dumping sites in backward community areas: availability of cheap and surplus land, lack of any political or resource backing to oppose the facility, inability to migrate to a better place due to poverty and discrimination. n47 the US, opposition and complaints of communities affected by hazardous wastes sites are referred to as “not in my backyard” or the “NIMBY syndrome”. Warren County movement for environmental justice The social discrimination in choosing of the hazardous wastes disposal sites have led to an environmental justice movement in the western countries. The movement came into prominence in the US in 1982 in Warren County. North Carolina, predominantly inhabited by poor and blacks, when the state government decided to construct a landfill to dump 40,000 cubic yards of soil contaminated with polychlorinated biphenyl CPCB). The United Church of Christ’s Commission for Racial Justice organized a non-violent, civil disobedience rally to protest against the disposal facility and “is recognized as the first national protest by African-Americans regarding the siting of a hazardous waste landfill.”48

Environmental racism-Is it true? Countering the claims of environmental and social activists, political scientists state that claims about hazardous waste disposal sites being located in backward and poor area “is based on myth”. John Hird of University of Massachusetts after doing a study of the NPL sites claimed that – “richer the country more likely it is to have a Superfund site and vice versa; countries with the largest numbers of NPL sites had poverty and unemployment rates far below the national average.” Infact he claims “what has never been conveyed is that virtually all Americans are paying for Superfund cleanups, and probably regressively through higher product prices on (mostly) chemical and petroleum products.”49 In Gujarat, the landfill being constructed within the Ankleshwar GIDC was originally sited in a rural village near Rajpardi, Bharuch district. Industrial wastes from Ankleshwar, Panoli and Jagadhia were to be dumped in this landfill. The villagers with help of a local environmental group strongly resisted the project and prevented the landfill to come up in that area on the grounds of potential contamination of the surrounding water bodies. The site was then relocated within the industrial area. (refer box:3) .

One of the sites schosen in Tamil Nadu under India Hazardous Waste Project is Mannelure, where industrial wastes from Manoli, 40 kms away, will be dumped. Mannelure abounds in water bodies-small lakes, has mangrove vegetation and communities residing nearby. Even some officials of the Tamil Nadu state pollution control board (TNPCB) have shown “reservations” for the site. “The landfill will have induced development in that area, and polluting industries might shift near the landfill site as it will save them transportation costs. This can have severe environmental implications” said a TNPCB official. iii. Environmental costs

46 . Reference 44. 47 .Vanderbilt Journal of Transnational Law, “The problem of hazardous waste exportation.” Vol.28:251 48 . Reference.47. 49 . Reference44.

Environmental and human health implications Hazardous wastes landfills have always been and will continue to be a potential threat to the groundwater quality and the community residing in the vicinity of the landfill. “After decades of research, engineering innovations and great expense, the most modern, state-of-the-art landfills are still described as potential time bombs.”50 Experts believe that, “Isolation systems (landfills) are generally effective for the first 10 years and have a retarding effect after 25 years, but are almost comparable to a reference situation (that is no isolation) after 100 years. Thus isolation systems for disposal sites and contaminated soils without contaminant immobilisation may represent a delayed “time bomb” that could pose a danger in future to human health and the environment.”51 Given current industrial practices and types of wastes that are being generated it is quite impossible to say what wastes would be dumped into the landfill five or six years from now. The liner systems that are being designed for present day wastes may not be suitable five years hence. Even with today’s modern liners systems experts believe “Hazardous waste and municipal solid waste dry-tomb landfills represent an ongoing threat to groundwater quality. Because the plastic sheeting used in the composite liners will eventually deteriorate, and because there is virtually no possibility that landfill covers of the type being constructed today will keep moisture out of the landfill for as long as the wastes represent a threat-that is forever-it is inevitable that leachate will migrate through the liner to pollute the underlying groundwater.”52

There are many examples to illustrate the effects of leaking landfill on human health and the environment. Several studies in the US of the industrial dumps and contaminated water supplies during the last decade have reported adverse health effects among exposed human populations. The principal health findings include:

Significantly reduced stature (height) for a given age among children who lived near Love Canal, the chemical waste dump in Niagara Falls, N.Y., compared to a control group of children living further from the dump.

A higher prevalence of birth defects and liver disease among persons living near a thorium waste

disposal site in Wayne, New Jersey, compared to persons living further away from the site.

Low birth weight and birth defects in California children born in census tracts having waste disposal sites.

Enlargement of the of the liver and abnormal liver function tests reported in residents exposed to

solvents from a toxic waste dump in Hardemann Country, Tenn.

Dermatitis, respiratory irritation, neurologic symptoms and pancreatic cancer at 7 waste disposal sites.

Significantly elevated rats of illness, including chronic kidney disease, stroke, hypertension [high

blood pressure], heart disease, anaemia, and skin cancer in a population exposed to toxic metals (cadmium and lead) from mine wastes in Galena, Kansas.

Leukemia among a group of children drinking water contaminated with industrial solvents in Woburn,

Mass. In addition a study of 4936 pregnancies and 5018 residents of Woburn aged 18 or younger revealed significant positive associations between intake of contaminated water and birth defects of

50 . Pat Costner. 1996. “Appropriate technologies for the destruction of stockpiles of persistent organic pollutants and related materials.” Greenpeace International 51 . M.J.Diependaal, A.Eklein, P.Oude Boerrigter, J.L Van der Meij, F.B. de Walle. 1993. “Long-team effectiveness of isolation techniques for contaminated soils.” Waste Management And Research 11:481-492 52 . G.F.Lee, et al. 1994. “A groundwater strategy for lined landfills. Environmental science and technology. 28(13):584A- 585A.

the central nervous system, eye, ear and fact(e.g. cleft palate), as well as abnormalities of the chromosomes.

In Lowell, Mass., a group of 1049 people living 1200 feet from a large chemical waste dump was

higher in self-reported complaints of wheezing, shortness of breath cough and persistent colds; irregular heart beat; constant fatigue and bowel dysfunction, compared to people living 2 and 3 times as far from the dump [9]. This study examined the possibility of recall bias (people selectively remembering health problems, or chemical exposures) and concluded that recall bias did not explain the findings.

In Hamilton, Ontario, a study of people who lived and/or worked near an industrial dump revealed

significantly elevated rates of the following conditions: bronchitis; difficulty breathing; cough; skin rash; arthritis; heart problems (angina [chest pain] and heart attacks); muscle weakness in arms and legs; tremors, cramps and spasms; headaches; dizziness; lethargy; balance problems; and mood symptoms (anxiety, depression, insomnia, irritability, and restlessness) compared to populations living further from the site.

A survey of 2039 persons in 606 households living near the String fellow Acid Pits in Riverside

Country, California revealed significantly elevated rates for the following conditions: ear infections; bronchitis; asthma; angina [chest pain]; skin rashes; blurred vision; pain in the ears; daily cough for more than a month; nausea; frequent diarrhoea; unsteady gait; and frequent urination.

In Tucson, Arizona, a study of 707 children born with heart defects revealed that 35% of them were

born to parents living in a part of the city where the water supply was contaminated with industrial solvents (trichloroethylens [TCE] and dichloroethylene). The rate of birth defects of the heart was three times as high among people drinking the contaminated water, compared to people in Tucson not drinking contaminated water.

A study of 296 women experiencing a spontaneous abortion during the first 27 weeks of pregnancy,

compared to 1391 women having live births, revealed an association between spontaneous abortion and drinking water contaminants (detectable levels of mercury, or high levels of arsenic, potassium and silica).

Residents of Bynum, North Carolina, drinking raw river water contaminated by industrial and

agricultural chemicals, have developed cancers 2.4 to 2.6 times more often than expected. Epidemiological studies cannot prove a cause and effect relationship. Nevertheless, available information indicates that hazardous waste dumps can harm, and have harmed, humans living nearby. Likewise, contaminated water supplies have harmed people. The problem of waste dumps is continuing to grow. As the National Research Council of the National Academy of Sciences, USA said in 1991, “A limited number of epidemiological studies indicate that increased rates of birth defects, spontaneous abortion neurologic impairment, and cancer have occurred in some residential populations exposed to hazardous wastes. We are concerned that other populations at risk might not have been adequately identified.” And the Council said, “Millions of tons of hazardous materials are slowly migrating into groundwater in areas where they could pose problems in the future, even though current risks could be negligible.” Source: Rachel’s Environment & Health Weekly # 371, January 6, 1994 7. What does a Public hearing for a landfill mean? A powerful legal tool with the community for protecting their environment from projects which might endanger it, is the public hearing process. Where the community is empowered to reject, accept, present “facts and views” on a proposed project. “Public hearing are an excellent tool for focusing on issues of environmental concern, to educate the community and to bring the community (whether local or state-wide)

together. They are also good from a political perspective, since they force decision makers on every level to take a stand.”53

____

In India, public hearing are a new concept and more often than not the public is not informed about it beforehand, though the law says otherwise. In January 1994, public hearing was made mandatory under Environmental Impact Assessment (EIA) Notification dated 27 January 1994, for 29 different classes of industries/activity, chosen for the hazardous nature of the industries/projects. These industries where required to obtain the prior permission of the Central government before beginning work on the project. But due to strong lobby from the industries, within 4 months of the notification public hearing was made optional. Result. No public hearing was held between May 1994 – March 1997.54

On 10th April 1997, the then government once again amended the EIA notification and made public hearing mandatory for environmental clearance of a project.55 Under the notification State Pollution Control Boards are responsible to “cause a notice for environmental public hearing… Suggestions, views comments and objections of the public shall be invited within thirty days from the date of publication of the notification,’56 This enables community to investigate and gather information on the proposed project and ask the right questions at the public hearing, which should be at the site of the proposed project. However, the notification says only an executive summary of the EIA need to be supplied to the public.57 “All persons including bona fide residents, environmental groups and others located at the project site/sites of displacement/sites likely to be affected can participate in the public hearing.” According to the notification, the assessment of the project should be done within 90 days “from receipt of the requisite documents and data from the project authorities and completion of public hearing and decision conveyed within thirty days thereafter.58

There are no specific “rights of a person at a public hearing” – except the right to be heard. And the right to receive a copy of the executive summary of the EIA of the project. The irony of the whole process is – there is no requirement for the majority decision at the public hearing to influence the final decision.59

The only follow up action to a public hearing is to go on a appeal to the National Environmental Appelate Authority if one is aggrieved by the decision to grant clearance to the concerned project.60

Questions to ask in a public hearing for hazardous wastes landfill

• How much will be the total area of land used for building the landfill?

• How much acreage will be used for disposing the wastes and how much will remain unused?

• How much land will be used for the buffer zone, it there is one?

• What is the ground water level? Location of ground water aquifers?

53 . Itzchk E. Kornfeld, et al. 1990. “How to win in public hearings.” Centre for health, environment and justice, Falls Church, VA 54 . T. Mohan.1998. “Of participatory democracy, public hearings and project” in CAG Reports may –June 1998, a bimonthly newsletter published by Consumer Action Group , Chennai. 55 . Reference 54. 56 . Ministry of Environment and Forest (Notification). 1997. “The Gazette of India, Extraordinary. 10th April 1997.” 57 . Reference 54. 58 . Reference 56. 59 . Bharath Jairaj. 1998Condumar Action Group, Chennai. (Personal interview) 60 . Reference 59.

• What is the present land use of the site?

• What is the design of the landfill-basal and top liner system?

• What is the liners made of?

• Does the liner system and the cover system follow a national standard? If no national standard exists,

then does it follow any international standard?

• What will be the land use of the landfill area after closure?

• What type of wastes will be disposed in the landfill?

• How much tonnage of wastes will be disposed in a day?

• Will there be a minimum tonnes per day of wastes to be disposed in the landfill? If so, how much will it be? And who will ensure that additional tonnage is not dumped or if there is any money which is to be charged in lieu of the additional tonnage?

• What will be the waste characteristics and standards for disposal of wastes?

• What tests will be done to ensure the quality of wastes is according to the standards?

• Will there be a laboratory/testing facility near the site?

• Who will be responsible for monitoring the wastes that would be disposed in the landfill?

• What happens in case of an accident or leakage in the landfill?

• If there is an accident, will the landfill be closed? What will happen to the waste already dumped in

the landfill? And also what will happen to the waste meant to be disposed? Will there be an alternative arrangement?

• Who will be held liable/responsible in case of an accident? Name and complete address, contact

numbers of the person/s, department/body incharge.

• Who and how much will be the compensation? On what basis the compensation will be given?

• How will the community prove that something has gone wrong?

• Will the groundwater be tested regularly by the concerned authority? How oftern, periodicity? Will the results of the test be published or made public? And how oftern will it be published?

• What are the tests/parameters that will be checked for the groundwater quality?

Annexe I : Maximum concentration of contaminants for the toxicity for the toxicity characteristics (TCLP test)61

Contaminant Regulatory Level (mg/I) Arsenic 5.0 Barium 100.0 Benzene 0.5 Cadmium 1.0 Carbon tetrachloride 0.5 Chlordane 0.03 Chlorobenzene 100.0 Chloroform 6.0 Chromium 5.0 o-Cresol 200.0 m-Cresol 200.0 p-Cresol 200.0 Cresol 200.0 2,4-D 10.0 1,4-Dichlorobenzene 7.5 1,2-Dichloroethane 0.5 1,1-Dichloroethylene 0.7 2,4-Dinitrotoluene 0.13 Endrin 0.02 Heptachlor (and its epoxide) 0.008 Hexachlorobenzene 0.13 Hexachlorobutadiene 0.5 Hexachloroethane 3.0 Lead 5.0 Lindane 0.4 Mercury 0.2 Methoxychlor 10.0 Methyl ethyl ketone 200.0 Nitrobenzene 2.0 Pentachlorophenol 100.0 Pyridine 5.0 Selenium 1.0 Silver 5.0 Tetrachloroethylene 0.7 Toxaphene 0.5 Trichloroethylene 0.5 2,4,5-Trichorophenol 400.0 2,4,6-Trichlorophenol 2.0 2,4,5-TP (Silvex) 1.0 Vinyl chloride 0.2

61 .40 Code of Federal Regulations Parts 260 to 299. Revised as of July 1, 1996. Protection of Environment, USEPA.pg 52

Annexe II: Waste Criteria for landfill disposal in Germany62

Limiting Values Parameter Leachate Quality pH

Class I site (non hazardous/less hazardous wastes) 55.5-13.0

Class II site (municipal wastes) 5.5-13.0

Class III site (hazardous wastes) 4-13

Conductivity <10 000mS/cm <50 000mS/cm <100 000mS/cm TOC <20 mg/L <100 mg/L <200mg/L Phenols <0.2mg/L <50mg/L <100mg/L Arsenic <0.2mg/L <0.5mg/L <1mg/L Lead <0.2mg/L <1mg/L <2mg/L Cadmium <0.05mg/L <0.1mg/L <0.5mg/L Chromium (VI) <0.05mg/L <0.1mg/L <0.5mg/L Copper <1mg/L <5mg/L Nickel <0.2mg/L <1mg/L <2mg/L Mercury <0.005mg/L <0.02mg/L <0.1mg/L Zinc <2mg/L <5mg/L <10mg/L Fluoride <5mg/L <25mg/L <50mg/L Ammonia-N <4mg/L <200mg/L <1000mg/L Chloride - - <10 000mg/L Cyanide, Amenable To chlorination

<0.1mg/L <0.5mg/L <1mg/L

Sulphate - - <5000mg/L Nitrite - - <30mg/L AOX <0.3mg/L <1.5mg/L <3mg/L Water-soluble Content <3w.% <6 w.% <10 w.%

62 .Reference 15.

Annexe III: Off site Disposal/ Treatment costs in the US63 Disposal/Treatment Costs/Volume Limitations Class 2 & 3 – Landfill $25-$35/box $5-$15 ton $5-$10/yd3 Class 1-landfill $15-$25/ton Hazardous-Landfill $1,000-$2,000/drum Mercury wastes $20/Ib PCB wastes $1/Ib Non-hazardous-lab pack $2-$3Ib Hazardous-lab pack $5-$20/Ib Non-hazardous-deep well $.25-$.75/gallon Less than 2% organics Hazardous-deep well $.50-$1.25/gllon Less than 2% organics Non-hazardous waste water $50-$100/thousand gallons Less than 50ppm TOC/BOD Non-hazardous-inceneration $50-$100/drum Non-hazardous-fuel blending No charge >5,000BTU/Ib Hazardous-incineration $200-$300/drum $4-$5/gallon Hazardous-fuel blending $60-$150/drum $1-$3/gallon >5,000 BTU/I b

63 . Richard F. Grote. TNRCC/OPPR. 1996. (Persona; communication.)

Annexe IV: US EPA regulation for hazardous waste landfill liner system In the 40 CFR (Code of Federal Regulations) Parts 264 under Subpart N-Landfills, following standards have been stipulated for hazardous wastes landfill liner system:

A top liner designed and constructed of materials (e.g., a geomembrane) to prevent the migration of hazardous constituents into such liner during the active life and post-closure care period.

A composite bottom liner, consisting of at least two components. The upper component must be

designed and constructed of materials (e.g., geomembrane). The lower component must be constructed of at least 3 feet (91 cm) of compacted soil material with hydraulic conductivity of no more than 1x10-7 cm/sec.

A leachate collection and removal system immediately above the top liner. (The Regional

Administrator will specify design and operating conditions in the permit to ensure that the leachate depth over the liner does not exceed 30 cm (one foot).

The leachate collection and removal systems between the liners, and immediately above the bottom

composite liner in the case of multiple leachate collection and removal systems, is also a leak detection system.

Note: In the US, the Resource Conservation and Recovery Act 1976 (RCRA) regulates the management of solid waste (e.g., garbage), hazardous waste, and underground storage tanks holding petroleum products or certain chemicals. RCRA focuses only on active and future facilities and does not address abandoned or historical sites. RCRA gave EPA the authority to control hazardous waste from the cradle-to-grave. This includes the generation, transportation, treatment, storage and disposal of hazardous waste. HSWA, The Federal Hazardous and Solid Waste Amendments are the 1984 amendments to the RCRA that required phasing out land disposal of hazardous waste. The provisions of subtitle C of RCRA, in Sections 3001 though 3020, establish the criteria for managing hazardous waste from point of generation to ultimate disposal. Although the regulations set out in 40 CFR (Code of Federal Regulation) Part 260 to 279 are the primary reference for information on the hazardous waste program, the statute provides important background information and provides the legal authority to EPA for promulgation of the regulations. (Source: RCRA Statutory Overview, EPA530-R-97-067, PB98-108 228, “DISCLAIMER” – document developed by Booz, Allen & Hamilton Inc. under contract 68-W0-0039 to EPA.) Source: 40 Code of Federal Regulations Parts 260 to 299. Revised as of July 1, 1996. Protection of Environment, USEPA.

Annexe V: Case study-The children of love canal Love Canal, in Niagara County, New York, is the place where the modern toxic movement began. In 1942, a chemical company began using the abandoned canal as a dump, burying 19,000 cubic yards of toxic waste in the long trench. Some time after 1953, ownership of the land was transferred to the Niagara Falls Board of Education, which built a school on top of the dump. In 1977, tests revealed toxic chemicals seeping into the basements of homes near the canal. Two hundred and forty eight different chemicals were identified, 30 of them embryo-toxins or feto-toxins, and 18 suspected teratogens. At least 34 of them cause cancer. For 100 of the 248 chemicals, no toxicological data could be found. In 1978 the state of New York found a high rate of miscarriages among families in the first tier of homes fronting on the canal; authorities declared a health emergency, closed the school on top of the dump, and evacuated 235 families. The following year New York state authorities evacuated families with pregnant women, or with children under 2 years of age, from the southern half of the Love Canal neighborhood, which was considered most heavily contaminated. In May, 1980 the federal government offered evacuation to everyone in Love Canal. Later in 1980, health researchers began formal studies of the children living within a few hundred yards of Love Canal. The levels of a few chemicals were measured in homes; the levels were 1% or less of the allowable occupational standards. But occupational standards are not set to protect the general public; they are set to protect young, healthy males in the prime of life! The general public comprise of large number of people who do not fit the profile of employed males: many old people, many children many people with chronic illnesses with allergies with poor diets, and so forth. This is why, for the general public, occupational standards are entirely inappropriate as a measure of acceptable exposure. Two different studies of the children of Love Canal reveal ill effects among those who lived near the Canal vs. those who lived further away. Two groups of people were studied: 239 children born to mothers exposed to Love Canal chemicals while pregnant, and 707 controls (children from the same city whose families were similar to the Love Canal families in every respect except where they lived). The two groups were specifically matched for socio-economic status, smoking, alcohol consumption and medication taken during pregnancy. Unfortunately, the study was begun too late to include the 235 families who were the first to be evacuated from Love Canal. In addition, children who had died were excluded from the study. For these reasons, it is very likely that the study underestimates the true effect of living near Love Canal. Nevertheless, the study shows that low birth weight babies were 2.3 times as likely to occur among home-owners living near Love Canal, compared to the control group (11.1% vs. 4.8%). Serious birth defects were twice as likely to occur among those living near the Canal (12.1% vs. 6.2%). The study found seizures 2.5 times as prevalent among Love Canal children as among controls; learning disabilities were 1.5 times as prevalent; hyperactivity was almost 3 times as prevalent; eye irritation was twice as prevalent; skin rashes occurred twice as often; abdominal pain was twice as prevalent; incontinence occurred three times as often. SCIENCE magazine (Vol. 212 [1981], pg. 1404-1407) reported that lung cancer among Love Canal men was up 70% compared to the average of New York State (excluding NY City), and among Love Canal women it’s up 100% Source: Rachel’s environment and health weekly #104, November 21,1988.

Glossary Acid: Any chemical, which undergoes dissociation in water with the formation of hydrogen ions. Acids have pH values between 0 to 6. They have sour taste and may cause severe burn injuries. Amended soil: When additives in the form of natural clays or commercially available clays are mixed with local soils to make it a suitable landfill liner material (low permeability), they are called amended soil. Asphaltic Concrete: Asphaltic concrete is basically the material that is used for laying of roads made of bituminous, gravel, stones chips, sand and fines. Materials used for asphalt layers are mixtures, of which around 95% of the weight is made of aggregates (from rocks quarry, sand, gravel) and 5% bituminous binding agents. Aquifer: A natural underground supply of water, usually found permeating porous rock. Biodegradation: A biochemical reaction that is mediated by microorganism. Corrosivity/corrosives: Substances or wastes which, by chemical action will cause severe damage when in contact with living tissues, or in the case of leakage, will materially, damage, or even destroy other goods or the means of transport; they may also cause other hazards. Engineered Landfill: An ‘engineered landfill’ by definition is a carefully designed depression in the ground (or built on top of the ground) into which solid waste-municipal or industrial in dumped. Environment Impact Assessment (EIA): EIA establishes quantitative values for selected parameter which indicate the quality of the environment before, during and after the proposed action. EIA serves as a valuable tool for identification, prediction and evaluation of impacts arising out of proposed projects. Epidemiology / Epidemiological studies: The scientific study of the pattern of disease in a population. Determination of the incidence (rate of occurrence) and distribution of a particular disease (as by age, sex or occupation) may provide information about the causes of the disease. Halogenated solvents: The solvents that contain halogens (chlorine, fluorine, bromine and iodine). The most commonly used halogenated solvents are the chlorinated ones. Though halogenated solvents are less apt to catch fire, explode, or corrode tanks and pipelines than non halogenated organic solvents, most of them are toxic. Hazardous waste: Hazardous waste is defined as a waste, or a combination of wastes, that because of its quantity, concentration, or physical, chemical, or infectious characteristics may pose a substantial or potential hazard to human health or the environment when improperly treated, stored transported, or disposed off. They can be radioactive substances, chemicals, biological wastes, flammable wastes, explosives. Hydraulic Conductivity: The ease with which water flows through soil is quantitatively expressed in terms of coefficient of permeability or hydraulic conductivity (k) of the soil. Landfill: Landfill is a facility used for the disposal of solid waste on the ground. Leachate: Any liquid, including any suspended components in the liquid, that has percolated through or drained from hazardous waste. (40 CFR ch. I (7-1-96 Edition, USEPA) Leach/Leaching: To dissolve and move substances though soil with percolating water/liquid. Leak detection system: Means a system capable of detecting the failure of either the primary or secondary containment structure or the presence of a release of hazardous waste or accumulated liquid in the secondary containment structure. (40 CFR ch. I (7-1-96 Edition, USEPA)

Liner: A continuous layer of natural or man-made materials, beneath or on the sides of a surface impoundment, landfill, or landfill cell which restricts the downward or lateral escape of hazardous waste, hazardous waste constituents, or leachate. (40 CFR ch. I ( 7-1-96 Edition, USEPA) NIMBY Syndrome: In the US, opposition and complaints of communities affected by hazardous wastes sites are referred to as “not in my backyard” or the “NIMBY syndrome” Non-compatible/ incompatible waste: Waste which could cause dangerous reactions from direct contact with another waste/s in the landfill. Oxidising: Substances or wastes which while in themselves not necessarily combustible may, generally by yielding oxygen cause or contribute to, the combustion of other materials. (Basel Convention, 1989, Annex III: List of Hazardous Characteristics) Permeability: Measure of the ability of a liquid or gas to pass through a given substance or medium. pH value: The symbol relating to hydrogen ion (H-) concentration to that of a given standard solution. A pH of 7 is neutral. A pH value between 7 to 14 indicate alkalinity and between 7 to 0 indicate acidity. Poisonous: Substances or wastes liable either to cause death or serious injury or to harm human health if swallowed or inhaled or by skin contact. (Basel Convention, 1989, Annex, III: List of Hazardous Characteristics) ppb: Parts per billion; a unit for measuring the concentration of a gas or vapour inair-parts (by volume) of the gas or vapour in a billion parts of air. Usually used to express measurements of extremely low concentrations of unusually toxic gases or vapours. Also used to indicate the concentration of a particular substance in a liquid or solid. ppm: Parts per million; a unit for measuring the concentration of a gas or vapour in air – parts (by volume) of the gas or vapour in a million parts of air. Also used to indicate the concentration of a particular substance in a liquid or solid. Solvent: A liquid capable of dissolving other substances. Sump: Means any lined pit or reservoir that serves to collect liquid drained from a leachate collection and removal system or leak detection system for subsequent removal from the system. (40 CR ch. I (7-1-96 Edition, USEPA) Superfund: A federal trust fund used for cleaning up toxic waste sites in the US. Toxic: Substances or wastes which, if they are inhaled or ingested or if they penetrate the skin, may involve delayed or chronic effects, including carcinogenicity. (Basel Convention, 1989, Annex. III: List of Hazardous Characteristic) TCLP: Toxicity Characteristic Leaching Procedure (TCLP) test is carried out to detect wastes likely to leach hazardous concentrations of particular toxic constituents into the groundwater as a result of improper management. The US EPA has given a regulatory level for maximum concentration of contaminants in wastes for the TCLP test. In the TCLP test, constituents are extracted from the wastes and tested. If the extract contains any of the contaminants at a concentration equal to or greater than the respective value as specified by the US EPA, then the waste exhibits toxicity. Toxicity: The harmful effects produced by a substance or the capacity of a substance to cause any adverse effects, as based on scientifically verifiable data from animal tests or epidemiology.

Readings Affidavit of Secretary, Ministry of Environment and Forests, October 1996. Filed in Supreme Court. Amalendu Bagchi.. Wisconsin Department of Natural Resources. Design, Construction and Monitoring of Sanitary Landfill. A Wiley-Interscience Publication. New York. Anindya Sen, at al. 1997. Industry: Coping with new challenges. In India Development Report, 1997. Edited by Kirit S, paeikh. Oxford University Press, Delhi. p 124. Anne Jones-lee et al. Groundwater pollution by municipal: leachate composition detection and water quality significance . published in proceedings of CISA Sardinia’93 IV International Landfill Symposium. Sardinia, italy,p. 1093-1103, October 1993. Concepts Processes Technologies & Operation. proceedings of Sardinia,95,Fifth international Landfill symposium..Environmental Sanitary Engineering Centre, Cagliari Council Directive of 20 March 1978 on Toxic and Dangerous Waste(78/319/EEC) Council Directive of 20 March 1978 on Toxic and Dangerous Waste.(78/319/EEC) Europe Environment. European Commission: New Draft Directive on Landfill of Waste, Document supplement. to Europe Environment No. 496 March 251997, Europe Information Service. Finance Act 1996. United Kingdom. Landfill Tax, Chapter 8, part 111. G.E.Lee, et al. 1994 A groundwater strategy for lined landfills. Environmental Science and Technology.28 (13):584A-585A. Ing. Rainer Stegmann et al. Mechanical-Biological Pretreatment before landfilling of Municipal solid waste. UTA International 1/96. P 51-58. Itzchak E. Kornfeld, et al. 1990. How to win in public hearings. Center for health, environment and justice, Falls Church, VA. James V. Walters at al. Use of Elevated, concrete buildings for long term management of hazardous waste. Environmental progress, vol.7.no,4, November 1998. James V. Walters at al. Use of elevated, concrete buildings for sanitary landfills, hazardous waste landfills Monofills, and cogeneration facilities. Journal of Resource Management and Technology, vol,17.no. 2, April 1989. Jim Puckett. The Basel Ban: A triumph over business-as usual. The Ecologist Asia, vol. 5, no,2,p5, 1997. John T. Pfeiffer. University of Illinois at Urbana-Champaign. Solid Waste Management Engineering. Prentice Hall International Series in Civil Engineering and Engineering Mechanics. Prentice Hall. New Jersey. K.Westlake. Landfill. In Waste treatment and disposal. Issues in Environmental Science and Technology. R.E.Hester and R.M.harrison.vol. 3.Published by The Royal Society of Chemistry, UK Luis F. Diaz. Composting and recycling: Municipal solid waste. London: Lewis Publishers. Manoj Dutta. 1997. Waste disposal in Engineered Landfills.New Delhi: Narosa Publishing House. M.J.Diependaal, A.E.Klein, P. Oude Boerrigter, J.L.Vander Meij, F.B.de Walle. 1993. Long-team effec- tiveness o isolation techniques for contaminated soils, Waste Management And Research 11:481-492 Ministry of Environment and Forest (Notification).1997. The Gazette of India, Extraordinary. 10th April 1997.

Ministry of Environment and Forests, Hazardous Substances management Division.1991. Guidelines for management and Handling of Hazardous Waste. New Delhi. Ministry of Environment and Forest. 1997. India-Hazardous Waste Management Project. Sectoral Environmental Assessment Report (Draft versio9n 2.0). Submitted to the world Bank. New Delhi. N.G.Ashar. Navdeep Enviro & Technical Services Pvt. Ltd, Mumbai. Minimisations of wastes through waste audits and waste recycling. Offical Journal of the European Communities. Council Directive of 12 December 1991 on Hazardous Waste (91/689/EEC). L377,vol.34,31 December 1991. Pat Costner. 1996. Appropriate technologies for the destruction of stockpiles of persistent organic pollutants And related materials. Greenpeace international. Phillip O.Leary and patrick Waish. Introduction To solid Waste Landfills. Solid and Hazardous Waste Education Center, university of Wusconsin-Madison. Rachel’s Hazardous Waste News no. 119.1989Leachate collection systems: The Achilles’ Heel of Landfills R. Swaminathan. Scientist, NEERI principles of Landfill. T. Mohan. 1998. Of participatory democracy, public hearings and projects in CAG Reports May-June 1998 A bimonthly newsletter published by Consumer Action Group, Chennai. The Hazardous waste (Management. and handling) Rules, 1989. U Holzlohner, H August, T Meggyes, M Brune. 1995. Landfill Liner Systems: A state of the art report. Penshaw press. USEPA.40 Code of Federal Regulations part 260to 299.Revised as of july1. 1996. Protection of Environment ,.pg 52. Vanderbilt Journal of Transnational Law , The problem of hazardous waste exportation, vol.28:251. World Bank. 1996. India’s Environment: Taking stock of plans, programs and priorities. An Assessment of the Environment Action program-India.p138.

List of contacts for information on Landfill 1. Prof. Manoj Dutta

Civil Engineering Department Indian Institute of technology Hauz Khas, New Delhi 110016 Tel:686 1977 – 85 ext. 4025

2. Dr Dliip Biswas East Arjun Nagar, New Delhi 110032 Central Pollution Control Board Tel.+91 11 2217213 (4lines) Parivesh Bhavan C.B.D.-cum0office complex Tel.+91 11 2204948, 2227233 3. Dr A.K.Saxena

National Productivity Council 5-6. Institutional Area, Lodi Road New Delhi 110003 Tel + 91 11 4625447/4690331-3

4. Dr.R.Swaminathan Ex, Scientist, NEERI Nagpur No.66, Third Street, Anjugam Nagar Jafarkhanpet, Chennai 600 083 Tel. +91 44 4899475 Fax 091 444893731 5. Dr Jochen Vida

Advisor Hazardous Waste Management Indo-German Cooperation Project “Industrial Pollution Control (GTZ) National Productivity Council 5-6, Institutional Area, Lodi Road New Delhi 110 003 Tel. +91 11 4622359/4611243 Fax+91 116140653

6. Dr. B. Sengupta

Member Secretary Central Pollution Control Board Parivesh Bhavan C.B.D-cum-office complex

7. Mr. Vijay Sharma Jt, Secretary Ministry of Environment and Forest Paryavaran Bhavan, CGO complex Lodi Road, New Delhi-110003 Tel +91 11 4360634 8. Mr. Ashok Panjwani

President Operations United Phosphorus Limited 117, GIDC, Ankleshwar 393002 Gujarat Tel: +91 2646 50336/51223 Fax +91 2646 50297

9. Jane Metcalfe Program manager US Environmental Protection Agency Office of International Activities 1300 Pennsylvania Ave N.W. Washington DC20460 Tel: 202 5646451 Fax2025652411 10. Subijoy Dutta

Environmental Engineer US Environmental Protection Agency

401 M.St. S.W Washington DC 20460 Tel: 703 3083852 Fax 703 305 6309