Import of Lead Scrap/Used Lead Acid Batteries -Requirements and Standard Operating Procedure

By

Dr R S Mahwar, Environmental Adviser, ILZDA

Former Additional Director, Central Pollution Control Board

(Ministry of Environment, Forest & Climate Change), Govt. of India

National Conference on Lead Batteries – New Opportunities & Challenges

27 & 28 November 2017, Bangalore

Lead Waste Imports Permitted in India – HW Rules 2016

Waste lead acid batteries*, whole or crushed (Basel No - A1160)

HW Rules 2016 – Part A

Import permitted with Prior Informed Consent (PIC)

(*Drained batteries only as per the policy of the MoEFCC)

Lead Scrap - Bulk finished form such as plates, etc (Basel No - B1020)

HW Rules 2016 – Part B

Import permitted without Prior Informed Consent (PIC)

Lead Wastes Imports Permitted in India – HW Rules 2016

Importer

Registered Recycler

Registration production should include the material to be imported

Recyclable Materials Listed in Schedule VI of the HW Rules 2016

• Used Lead acid battery including grid plates and other lead scrap

• Lead battery plates (ISRI Code –Rails)

• Battery lugs (ISRI Code-Rakes)

• Scrap drained/dry Lead batteries (ISRI Code –Rains)

Requirements - Facilities & Standard Operating Practices

Lead Waste Unloading

Separate and covered storage area

Impervious flooring

Sprinklers for dust control

Area run off to ETP (Physico-Chemical Process Based ETP)

Material Trucks Tyre washings before their return

Washings to ETP

Battery Breaking

Top cutting machine (or Breaker for whole battery crushing)

ECS & Noise control measures

Separate Plastic Washing/Segregation Area (PWSA)

Impervious flooring for PWSA

PWSA connection to ETP

Requirements - Facilities & Standard Operating Practices

Rotary or Box Furnace

Emission Control System (ECS)

• Suction hoods covering the charging & the molten lead tapping points

• Expansion/Cooling Chamber

• Cyclone Separator

• Bag Filter (Pulse jet/mechanical shaker)

• Alkaline scrubber (Closed loop with spent liquid going to ETP)

• ID fan

• Stack

Height – 30 meters (minimum)

Port Hole, platform and access ladder for stack Monitoring

Requirements - Facilities & Standard Operating Practices

Storage/Disposal of Hazardous and Other Wastes

Separate and covered storage for HW (Process and ETP sludge)

Separate and covered storage for plastics wastes

TSDF membership for HW disposal

Disposal of Plastic wastes to authorised recyclers

Storage/dispatch of Product (Ingots)

Separate and covered packaging/dispatch area

Movement of product dispatch vehicles/trucks independent from the raw material handling areas

Standards for Lead Levels

Work Area : 0.05 mg/m3 (Time Weighted Average of 8 hours)

Stack : 10.0 mg/Nm3

Treated effluent : 0.1 mg/l

Ambient Air near boundary wall : 1.0 µg/m3 (24 hrs avg)

Blood (whole) Lead in Workers/Persons

10 µg/dL

Persons with blood lead levels greater than 42 µg/dL

• To be shifted non-lead activity areas

• Given special medical treatment till the lead levels come back to acceptable level (10- micrograms /dl).

Regulatory Requirements

Valid Registration

Minimum Facilities & Standard Operating Practices (SOP)

Valid Consents & Authorization (Water & Air Acts and HW Rules 2016)

Analysis Report for Lead

Stack Emissions

Waste Water (Treated effluent)

Ambient air

Work Zone Environment

Soil

Ground water

Workers Blood

Prior Informed Consent (For ULAB Import )

Import Permission Application -Checklist of Documents

Form 5 (dully filled)

Justification for Import

Valid Consents under Water/Air Acts/Authorization under the HW Rules

Valid Registration for Recycling of the waste intended for import

Reports of the analysis of lead in soil, work zone air, ambient air, ground water, treated effluent, stack emissions and blood of the workers.

Process Flow Diagram (PFD) indicating ECS, Scrubber, ETP etc

Battery Breaking System

Photographs and video CD of the running plant

Document depicting the status of employment generation, number of people benefited etc

Prior Informed Consent (PIC) in case of permission rehired for Waste lead acid batteries*, whole or crushed (Basel No - A1160)

Acknowledgement of the receipt of copy of application from the SPCB

Form 5 - HW Rules 2016

S. No. Description Details

(1) (2) (3)

1. Importer (name and address) in India

Contact person

Tel, fax and e-mail

Facility location/address

Reason for import

2. Exporter (name and address) outside of India

3. Details of waste to be imported

(a) Quantity

(b) Basel No.

(c) Single/multiple movement

(d) Chemical composition of waste (attach details)

(e) Physical characteristics

(f) Special handling requirements, if applicable

Form 5 - HW Rules 2016 (Contd.)

(1) (2) (3)

4. For Schedule III A hazardous waste whether Prior Informed Consent has been obtained

5. For importer

(a) Process details along with environmental safeguard measures (attach separate sheet)

(b) Capacity of recycling or co-processing or recovery or utilization

Enclose a copy each of valid authorisation and valid consent to operate from SPCB

6. Details of import against the Ministry of Environment, Forest and Climate Change permission in the previous three years

7. Port of entry

Application to MoEF for Import Permission - Steps Involved

Take Photos and Video (Max 10 minutes) of the Running Plant

Prepare the PFD

Description of the Battery Breaking & associated ECS/Noise control System

Write the justification of import

Make copies of copy all the documents required to be attached and sign

Scan the signed copies of all the documents (SSCDs) including the PFD

Fill up form 5

MS Word (Say File A*)

Put most of the details in Annexures, as the online application format does not permit putting all details in the form itself

Application to MoEF for Import Permission - Steps Involved

Online Application

Log on to the website iwms.nic.in

Click to the icon of the industry and register as new user.

The system will provide a user ID and Password which can ne changed by the industry

Click on HW tab on the Import/Export and fill up From 5 on line

Take a print of the Form 5 filled online (should be same as File A prepared in MS Word) and put signatures & date and scan it

Click Save draft

Application to MoEF for Import Permission - Steps Involved

Make a covering letter addressed to the Joint Director (HSMD), MoEFCC, Sign it and attach From 5 and all documents

Submit a copy to the SPCB, obtain a receipt on a copy of the covering letter and scan it.

Upload the signed Form 5 , annexures, SSCDs and SPCB receipt on the online and click submit.

Send a hard copy* of the application to MoEFCC by Post or

Submit in person to the Central Registry Section. (* Along with the PIC-Request to MoEFCC for signatures on the PIC i.e Movement Document is also to be made in the covering letter in case the exporter requires so)

Prepare a presentation on compliance to the “ Minimum Requirement -Facilities and Operating Practices” (i.e. compliance to SOP)

Attend the meeting as per the agenda & schedule given on the website.

Presence at the meeting is mandatory for first time permission

Appraisal Process

The application is forwarded to CPCB for inspection of the unit and submitting of the report to MoEFCC

MoEFCC will write to the industry in case any improvements are required

(The industry can take action on the basis of the minutes given on the website without waiting for the letter to save time)

Complete action on the improvements and send a letter to MoEFCCconfirming the action with evidence (Photos, CD etc)

Keep a track of the application status

Be present at the meeting venue as per the schedule on the website (not mandatory unless asked).

MoEFCC issues the permission letter after the minutes are approved and put on the website.

The Permission is issued for a quantity which is about 1/3rd of the recycling capacity with a validity of 18 months.

Thank you