ORDER

1. The issue for consideration is the absence of proper management of End-of-Life Tyres/Waste Tyres (ELTs) in accordance with the Environment (Protection) Act, 1986, Environment (Protection) Rules, 1986, Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, CPCB Guidelines for Environmentally Sound Management of End of Life Vehicles, 2016 and Standard Operating Procedure (SOP) issued by the MoEF&CC on the subject.

2. The matter has been earlier considered and dealt with by several orders in the last three years, particularly orders dated 19.09.2019 and 25.10.2021. By order dated 19.9.2019, the Tribunal considered the CPCB report dated 30.07.2019 mentioning the data of such units and their compliance status. The report inter alia suggested that non complying units should take specified measures viz. those following ‘batch process’ should switch over to ‘continuous process’, feed to the continuous reactors should be in the form of tyre chips and mechanical feeding system should have air lock arrangements so that no air enters in the reactors. The units should install packed bed scrubber for control of gaseous emission and reduction of odour. The tyre pyrolysis units should strictly follow the Standard Operating Procedures (SOPs) issued by MoEF& CC for continuous process and the consent conditions issued by SPCBs/PCCs. Considering the report, the Tribunal directed remedial action against non-compliant units, including levy of compensation on ‘Polluter Pays’ principle.

3. Accordingly, CPCB issued directions dated 04.12.2019 and 30.12.2019 to the State PCBs/PCCs to close down non-compliant units, to maintain vigilance and to monitor compliance. It also initiated study through NEERI and IIT Delhi for further safeguards. Considering the matter, the Tribunal vide order dated 06.01.2020 directed further action and completion of pending study. The study report, alongwith further action taken report, was filed by CPCB before the Tribunal on 23.10.2021. Vide order dated 25.10.2021, the Tribunal directed acceptance of observations and recommendations in the report of CPCB which were as follows:-

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7.0 RECOMMENDATIONS OR THE STUDY ON ADEQUACY OF TYRE PYROLYSIS PLANTS TO MEET ENVIRONMENTAL CONCERNS i. All the existing batch Tyre Pyrolysis Plants to install additional features like PLC based control arrangement, bypass arrangement for pyro gas from reactor door to primary condenser, installation of gas sensors, pressure, temperature gauges at reactor & storage tank, alarm system, flaring of entire pyro gas during emergency, arrangement for re-circulation of pyro gas for reactor’s heating, provision for flaring of pyro gas, suction hoods over the gate of reactor and carbon black powder bagging area, water sprinkler system and mechanized arrangement for removal of carbon black powder and steel scrap and arrangement of Nitrogen(N2) purging.

ii. Initial firing of reactor and heating of the reactor to be done either by using pyro gas generated by the plant itself or by use of purge water (oil mix water)/oil water emulsion, or by tyre pyrolysis oil or any other fuel approved by concerned SPCBs /PCCs. After generation of pyro gas, the same is to be used for the purpose of heating reactor. Plants to install adequate APCD for controlling flue gas emissions.

iii. Feed to tyre pyrolysis plants has to be full waste tyre or two piece cut waste tyre with steel for better operational control in existing batch tyre pyrolysis plant.

iv. It has been observed that unloading of steel scrap from the reactor results into spillage of carbon black around the reactor area and generates fugitive emission. Plants to ensure no such spillage occurs by using suitable trays with wheels for transporting the steel scrap within the premise from generation points to storage points. This operation can be made cleaner by use of vacuum cleaner after each batch operation.

v. Unloading of carbon black powder from the rea