The presentation covers the Requirements and Standard Operating Procedure for the Import of Lead Scrap/Used Lead Acid Batteries in India in compliance to the provisions of the Basel Convention as well as the Hazardous and Other Waste Management Rules notifiable by the Govt. of India in 2016.
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Import of Lead Scrap/Used Lead Acid Batteries - Requirements and Standard Operating Procedure
1. 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
2. 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)
3. 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)
4. 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
5. 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
6. 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
7. 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).
8. 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 )
9. 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
10. 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
11. 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
12. 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
13. 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
14. 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
15. 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 MoEFCC
confirming 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.