REQUEST FOR COMMENTS
The public and other institutions including SPCBs/PCCs are invited to provide
comments if any, on draft protocol for conducting a study on trial utilization of
hazardous waste i.e. Aluminum Chloride mixed with HCl and halogenated
aromatic/aliphatic compounds. The enclosed draft protocol is for utilization of waste
aluminum chloride by heating followed by addition of fresh alumina powder.
The objective of such trial utilization is to develop standard operating procedure
for utilization of Aluminum Chloride to manufacture Poly Aluminum Chloride.
UTILIZATION PROCESS DISCRIPTION
The process relates to utilization of Halogenated Aluminum chloride solution
containing hydrochloric acid. This hazardous waste is generated during manufacturing
of benzene derivatives by adopting Friedal Craft reaction. The waste contains 1, 2Dichlorobenzene, 1, 4-Dichlorobenzene which are listed in schedule II of Hazardous and
Other Waste (Management and Transboundary Movement) Rules, 2016, (category no.
A15, A16 and Serial No.-10 listed at item No. - 7 of the note of the said schedule). The
characteristics of the waste are given below:
Appearance
Specific gravity
pH
Assay Al2O3
Havey Metals
Light yellow
1.25
1.0
8-10%
Not Detected
The unit is proposing utilization of the aforesaid hazardous waste to produce
Poly Aluminum Chloride which can be used as a bonding agent in Pulp & Paper
industry. Poly Aluminum Chloride can also be used as coagulant in various applications.
The utilization process includes heating of aluminum chloride solution at 120 °C
in a glass lined reactor followed by the slow addition of alumina powder and water.
After the 3 hrs Poly Aluminum chloride is formed as product. Alumina reacts with
residual HCl and generates AlCl3, which may also feed to polymerization to produce
Poly Aluminum Chloride. The Poly Aluminum Chloride thus formed may contain traces
of HCl as well as halogenated aromatic/aliphatic compounds.
Protocol of Trial Run for Utilization of Aluminum Chloride
Part – A

Ambient Air Quality Monitoring
Parameters
:
Duration
No. of Samples
:
:
PM10 and NOx, Benzene (Near
boundary wall, one in upwind and
two in down wind direction)
24 hrs
2
Results to be compared with National Ambient Air Quality Standard notified by Central
Pollution Control Board vide notification Date 18/11/2009.

Fugutive Air Quality Monitoring
Parameters
:
PM10, 1, 4-Dichlorobenzene, 1, 2Dichlorobenzene, Chlorobenzene,
Ethyl benzene, Xylene.
Duration
:
No. of Samples
:
The following OSHA standards may be applicable
:
PM10
1, 4-Dichlorobenzene
1, 2-Dichlorobenzene
Chlorobenzene
-
Ethyl benzene
-
Xylene
-
* Time-weighted average
Not exceeding 8 hrs of operation of
the process unit
3-8
5 mg/m3 TWA*
75.0 ppm & 450.0 mg/ Nm3 TWA
50.0 ppm & 300.0 mg/ Nm3 Ceiling #
75.0 ppm & 350.0 mg/Nm3 TWA
3
100 ppm & 435.0 mg/ Nm TWA
100 ppm & 435.0 mg/ Nm3 TWA
# A Ceiling limit is one that may not be exceeded for any period of time, and is applied to
irritants and other materials that have immediate effects

Source Emission Monitoring
Source
:
Stack attached to Poly Aluminum
Chloride reactor.
Parameters
:
PM, HCl Vapor & Mist and TOC.
Duration
No. of Samples
:
:
30 Minutes
Two samples during reaction time.
The following standard may be applicable or as prescribed by SPCB, whichever is stringent:
PM
150 mg/Nm3
HCl Vapour & Mist
35 mg/Nm3
TOC
20 mg/Nm3

Analysis of process waste water
The unit claims that there is no waste water generation, which needs to be verified during
trial run. However, following sampling should be carried out incase waste water is
generated.
Samples to be collected
:
Waste water as outlet of reactor
Parameters
:
pH, TSS, COD, TDS, Chloride, AOx,
TOC, Havey Metals (Cr, Cd, Ni, Cu,
Mn, Co, Mo, Pb, Tl and Te)
No. of Samples
:
2

Analysis of Hazardous waste
As the hazardous waste i.e. Aluminum Chloride is generated by the Friedal Craft
reaction, thus analysis shall be done for the following.
i.
ii.
pH
Halogenated Aromatic compounds (4-Chloroacetophenone,
Chlorobenzene, 1, 2 Dichlorobenzene, 1, 4-Dichlorobenzene)
iii.
iv.
Halogens (Chlorine, Bromine and Iodine)
Halogenated Aliphatic Compounds (Dichloromethane, Methyl Chloride, 1,
2- Dicholoriethane, Dibromomethane, 2- Dibromo 3-Chloropropane).

Analysis of Product
The product i. e. Poly Aluminum Chloride is required to be analyzed for following
constituents:
i. Halogenated Aromatic compounds (4-Chloroacetophenone,
Chlorobenzene, 1, 2 Dichlorobenzene, 1, 4-Dichlorobenzene)
ii. Halogens (Chlorine, Bromine and Iodine)
iii. Halogenated Aliphatic Compounds (Dichloromethane, Methyl Chloride, 1,
2- Dicholoriethane, Dibromomethane, 2- Dibromo 3-Chloropropane).

Assess the capacity of plant with respect to storage handling and utilization of
Haloginated Aluminum Chloride in terms of tones per day along with details of such
facilities

Chemical Mass Balance during trial utilization of Aluminum Chloride
i.
ii.
iii.
iv.

Quantity of the product recovered.
Quantity of Halogenated Aluminum Chloride utilized alongwith the material
consumed in reaction in MT/Day or MT/hr or per batch.
Assess the total loss during the proposed procedure (Material Balance).
Water Balance.
pH of soil samples collected from the top surface and sub-surface (> 30 cm) from
atleast three locations within the premises. Including storage, handling and transfer
point of various chemicals used including Halogenated aluminum chloride.
Part-B
Information required to be collected during the trial run
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Note on hazardous waste handling, transportation, storage and feeding
mechanism.
Sources of procurement of raw material i.e. aluminum chloride alongwith the
process flow diagram of its generation.
Process flow diagram for utilization of hazardous waste i.e. Aluminum
Chloride.
Safety measures for handling, transportation and storage of hazardous waste
.i.e safety gadgets for workers, acid proof floor lining with proper slope and
collection pit, chemical handling and storage area, on site storage of Process
solid waste, manifest data.
Details of fire safety arrangements.
Layout plan.
Copy of consent order (showing prescribed standards).
Copy of the on –site emergency plan as approved from Industrial Health &
Safety department.
Sketch showing locations of ambient air quality stations (with marking of
North, South direction) along with the prevailing wind direction.
Log book copy with information on quantity of hazardous waste utilized,
product manufactured alongwith the quantity of solid waste generated during
the entire trial run operation.
Name of the industries to which the Poly Aluminum Chloride will be sold.
Copy of the TSDF membership.
Details of quantity of wastewater generated and effluent treatment facilities
provided, if any.
The trial run shall be brought to the notice of personnel involved in the
operations.