Regional workshop Lead Batteries´ Environmentally Sound Management Guidelines Bratislava (Slovak Republic), 18-19 March 2014 Environmentally sound management of lead batteries in the Syrian Arab Republic Dimitris Tsotsos Chemical/Environmental Engineer (MSc)

DOCUMENTATION Assessment of state of the art Proposals for policy reforms

LEAD BATTERIES: What is meant? Starter batteries for vehicles + Industrial batteries (large batteries used in the industry)

Types of Pb batteries Type of batteries Technology Typical uses Starter batteries (rechargeable) Lead - Acid Automotive/Motorcycle Starter, Lighting and Ignition (SLI) Industrial batteries (rechargeable) Lead Acid Standby Alarm systems, emergency back-up systems, e.g. rail and telecommunications applications Lead Acid Traction Motive power sources e.g. forklift trucks

Estimated quantities in Syria Type of vehicle Number Time for battery replacement (years) Weight (kg) Generated waste car batteries (tones/year) Passenger cars   1,441,173 3 15 7,206 Public transport cars 95,827 40 1,278 Tracks approx. 360,000* 4,800 Motorcycles >50 cc approx. 220,000* 1.5 440 <50 cc 140,000* 1 210 TOTAL 13,934

Assessment of state of the art Existing environmental legislation Management systems for batteries’ collection, treatment/recycling Role/responsibilities of state institutions

II. Proposals for policy reforms Proposals for policy/ institutional/ organizational arrangements necessary for the improvement of the existing situation

Assessment of state of the art Findings - Legislation “Nucleus” for waste management on which specific regulations for the management of lead batteries can be based: Framework Law 49/2004 + Environmental Law 50/2002 LBS Protocol Adoption: 7 March 1996 Entry into force: 11 May 2008 Hazardous Wastes Protocol Adoption: 1 October 1996 Entry into force: 19 January 2008

Assessment of state of the art Findings – Legislation Clear procedure is described concerning any application submitted to the authorities (Ministry for Environment Affairs, Ministry of Industry, Ministry of Local Administration) for getting/supervising a permit for treatment/ recycling of hazardous wastes recycling of Pb batteries (installations)

Assessment of state of the art Findings – Institutional organization Decentralized system (permits/control) Ministries 14 Regional Districts Environment Affairs Industry Local Administration

Assessment of state of the art Findings – Enforcement Controls/inspections are made mainly on the basis of complaints made by citizens concerning annoyance from emissions from illegal installations (conducted by the Regional Directorates) A comprehensive inspection plan of targeted visits to Pb recycling installations or for controls of illegal collectors (on the road) does not exist

Assessment of state of the art Findings – Human resources The same staff dealing with issuing the permits is also responsible for the enforcement procedures (monitoring/ inspection), in other Districts there is a separate department for the supervision/control of the installations The main “load” for inspections lies to the District of Aleppo in which the battery treatment/recycling factory is located

Assessment of state of the art Findings – Management of Pb batteries Numerous illegal small Pb foundries (total number of those illegally operating units is not known: only in Aleppo area approx. 6000 of such small “workshops” are assumed to be operational) Almost certain that these foundries do not apply any environmental protection measures

Assessment of state of the art Findings – Management of Pb batteries A state owned (by the Ministry of Industry) Pb recycling factory exists (Syrian Company for Batteries and Liquid Gases in Aleppo). It collects the waste car batteries from the approx. 100 repair centers for state vehicles It is the only existing organized system for the collection and treatment of used car batteries

Separate collection of Pb batteries – WHY? Contains sulphuric acid (64% of the electrolyte) Battery to be separately collected and INTACT No dismantling/breaking/emptying!

Assessment of state of the art Findings – Management of Pb batteries The collection, transport, storage of car batteries is entirely in the hands of the small private car repair workshops Sold to recycling units (small foundries) No licensed collectors

Assessment of state of the art Findings – Operation/capacity of the Syrian Company for Batteries and Liquid Gases (Aleppo) Today (…) : 1,700 ton/year Capacity : 18,000 ton/year (new line in operation) Can cover the total quantities of waste batteries (13,000 ton/year)

Assessment of state of the art Findings – Operation of the Syrian Company for Batteries and Liquid Gases (Aleppo) Old fashioned rotary kilns, no devices for air emission control/measurements, battery breaking made manually in the open air without any devices for the collection of liquids/solids coming out from this operation To avoid nuisance to the surrounding population the smelting process is taking place 1-2 times per week, battery breaking and the assembly of the products takes place during the remaining week days

Assessment of state of the art Findings – Producers/importers Producers/importers of batteries are registered by the Ministry of Industry/Economy & Trade Known quantities of “fresh” batteries put on the market

Proposals for policy reforms Producers/importers Collect Form a “collective” their own scheme/company “brand name” (to cover whole/part of the country)

Proposals for policy reforms Conditions to be fulfilled (permit): The foreseen quantities of used lead batteries to be collected and recycled according to the average market share of each producer/importer must be documented The technical infra-structure (i.e. collection bins in vehicle repair/maintenance workshops, tracks/lorries for the transport of the used batteries, storage places)

Proposals for policy reforms Conditions to be fulfilled (permit): The financial means to execute the required work The names and economical contribution of each of its stakeholders for the system’s operation (producers/importers) according to each one’s market share Responsibility to the scheme/company and not to each producer/importer

Proposals for policy reforms Collectors/transporters A license from the respective Regional Inspectorate in order to be allowed to collect lead batteries from vehicle repair/maintenance workshops A letter of intent with a single producer/importer or collective system which he will cooperate with The means to undertake the work (i.e. vehicles, packaging materials, personnel)

Proposals for policy reforms Recyclers EIA Permit Technologies Monitoring Only intact batteries to be accepted

Proposals for policy reforms Car repair/maintenance shops Have to prove the storage of used batteries or their submission to a licensed collector/ transporter on a 1:1 basis (1 new battery for 1 used battery) Batteries circulation book Withdrawal of license

Proposals for policy reforms Authorities Maintain, operate and update a register of batteries producers/importers Issue a permit for each single or collective system applying for it Issue a license for collectors/transporters Issue an environmental permit for recyclers supervise/monitor/control

Proposals for policy reforms Legislation Update, modify existing laws/regulations accordingly

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