Replies to Draft Office Memorandum dated 15.04.

2019
On Lime Mud re-burning:
The agro-residue based pulp manufacturing process especially if the raw material is sugar cane
bagasse; has a major handicap of presence of silica in the raw material. This silica creates
obstacles at several steps for example treatment of bagasse wash water.

Lime Mud in which Silica is not present, responds well to high temperature and is converted in
good quality CaO. The CaO then can be used in conversion of green liquor to white liquor.
However, presence of silica in Lime Mud becomes the most significant hurdle when attempts are
made to disintegrate it in a kiln at high temperature. Silica reacts with CaO and the product
becomes ‘clinker’ and not CaO. The clinker has a tendency of building ‘Hot Rings’ which severely
affects life of heat resistant material lining inside the kiln.

We believe that it will not be practical for Sugar Cane Bagasse based pulp mills to operate Lime
Mud Re-burning kiln.

On Zero Liquid Discharge / use of reverse osmosis:

Complete treatment of effluent including the final treatment by reverse osmosis is the most
comprehensive effluent treatment available at this moment of time. However, two aspects need
to be considered which reduce the benefits substantially.

The treatment by membranes creates two streams; an accept and a reject. Higher the dissolved
solids in the feed higher is the quantity of reject stream. The presence of dissolved solids in the
reject stream can be very high. It makes its further treatment very difficult and expensive.

The electrical energy demand for reverse osmosis treatment is significantly high. It should be
recognised that generation and transmission of electricity also creates effluent / pollution.
Treatment by reverse osmosis would reduce requirement of water but it would increase pollution
somewhere else.

Secondly the High capital cost and operating cost of plant and equipment to achieve zero liquid
discharge / use of reverse osmosis is beyond the means of manufacturers of writing / printing,
packaging papers from agricultural residues. It is very much possible that survival of such paper
mills will become difficult.

We believe that use of reverse osmosis and achieving zero liquid discharge is beyond the means
of Sugar Cane Bagasse based pulp mills.