Technical Advancement of Battery Manufacturing in India Import of Used Lead Acid Batteries (ULAB) and Other Lead Wastes in India - Need and Procedure Technical Advancement of Battery Manufacturing in India Dr R S Mahwar, Environmental Consultant Former Director (Addl.), Central Pollution Control Board, Delhi CONFERENCE JANUARY 17, 2019, NOIDA, UP By

My sincere thanks for this Privilege to the Federation of Indian Small Scale Battery Association (FISSBA) Ghaziabad Lead and Battery Association Battery Directory and Year Book Shivam Information

Top 10 Countries Share (%) in Global Lead Reserves (India’s share only 2.5 %)

Global Lead Market (1000 Tonnes) (India can become a Global Lead Aid Battery Manufacturing Hub)

Global Lead Uses (2016) (Lot of Scope for India for LAB Supply) Source: https://www.tridge.com/stories/strong-demand-and-supply-concerns-where-to-source-for-lead

Global Automobile Production (Further Supports Safe LAB Business Plans) Source: International Organization of Motor Vehicle Manufacturers

World Top 10 Auto Markets (2017) (India Already the 4th Largest) Source: http://ilamindia.in/automobile-industry.php

Domestic End Use Pattern of Refined Lead in India (Lot of LAB Use Already in Place) Source: Ministry of Mines, Govt of India

Trend of Lead Acid Batteries Demand in India (Projections for Local & Export of LABs) Source - https://www.mordorintelligence.com/industry-reports/india-lead-acid-battery-market

Lead Material Flow Cycle (LMFC) in India (Lead Inventory?) Primary Lead Other Materials Export Lead Import Lead Other Uses Lead Export LAB Automobiles LAB Export Other Uses LAB Import ULAB Automobiles Export Lead Wastes Import Recycling Uses Other Materials Import Environment

Production* of Primary and Secondary Lead in India (1000 tonnes) Primary Lead Installed Capacity (HZL) : 1,85,000 MTA Production (2017-18): 1,68,000 Tonnes Secondary Lead Installed Capacity : 1.25 + Million MTA** Production (2017-18 ): 2,93,000 Tonnes (*Source: Ministry of Mines; **Registered Recycling Capacity : 2.1 Million MTA )

India’s Lead Imports and Exports (India should Import Refined Lead or ULAB/Scrap?) (Source: http://ficci.in/spdocument/22947/Non-Metal-Report.pdf)

Apparent* Lead Consumption in India (1000 tonnes) (*Mathematical sum of the production plus imports minus exports ) (Industry estimates indicate consumption as 1.0 million tonnes but is that really a consumption or use ?) (Source: http://ficci.in/spdocument/22947/Non-Metal-Report.pdf)

Lead Recycling Capacity (1000 Tonnes) in India : 2100 (Maximum Lead 60 - 65 % of the Recycling Capacity) Source: Central Pollution Control Board

Status (2017) of Lead Waste Imports by the Recyclers (1000 Tonnes) (Source : Agenda MoEFCC Expert Committee Meetings 81st to 93rd : http://envfor.nic.in/division/importexport

Status(2017) of Imports by Waste Type (1000 Tonnes) (Source : Agenda – MoEFCC Expert Committee Meetings 81st to 93rd : http://envfor.nic.in/division/importexport

Facts Relevant to Decision Making for Involvement into LMFC Lead is a naturally occurring and “to exist for ever” material. Lead is not a consumable material - Only its form or bonding changes. Loss (or consumption?)- Only what gets released into the environment. Fate of the primary lead produced in India from start till date ? Lead Quantity that is Traceable to the India’s Primary production ? How much lead is in the “Lead Material Flow Cycle (LMFC) ” in India. How long the Indian Lead reserves of 2.2 million tonnes will last even with an average production of 1,50,000 tonnes refined lead per year ? Is the primary lead production adequate for the LMFC (inventory not Known)?. What could be best possible option for meeting the need of the growing LMFC ?

Study all components of the Lead Material Flow Cycle (LMFC) Need of Gap Analysis Study for Justification of Lead Wastes Import in India Study all components of the Lead Material Flow Cycle (LMFC) Lead contained in the LMFC Lead Requirement to meet the increasing size of the LMFC Uniformity in misleading terms (usage, consumption, demand etc) relating to the lead requirement Comparison of the Economic, Environmental and Social implications of: Increasing primary production (lead ore reserves just 2.5% of the world) Increasing Lead Import Increasing ULAB/Scrap import and its recycling Conclusion India certainly needs to import Lead Wastes but it is not possible to justify this need on the basis of the existing information on the Lead Material Flow Cycle

Lead Waste Imports Permitted in India Waste lead acid batteries* whole or crushed (Basel No - A1160) HW Rules 2016 – Part A Permitted with Prior Informed Consent (*Drained Batteries Only) Lead Scrap - Bulk finished form such as plates (Basel No - B1020) HW Rules 2016 – Part B Permitted without Prior Informed Consent

Requirements - Facilities & Standard Operating Practices Lead Waste Receipt & Unloading Separate Approach Road Separate covered storage area Area run off to ETP Battery Breaking Battery breaking machine/Breaker Noise control measures Separate Plastic Washing Area Impervious flooring Run off to ETP

Requirements - Facilities & Standard Operating Practices Rotary or Box Furnace Air Pollution Control System (APCS) Suction hoods covering the charging points Suction hoods covering 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 DG Sets- Acoustic enclosure, stack 3 meters above the shed

Requirements - Facilities & Standard Operating Practices Storage/Disposal of Hazardous and Other Wastes Separate and covered storage for HW TSDF membership for HW disposal Separate storage for plastics wastes Disposal of Plastic wastes to authorised recyclers Storage/dispatch of Product (Ingots) Separate and covered packaging/dispatch area Movement of product dispatch vehicles independent from the raw material handling areas

Storm Water Management Complete segregation of the storm water drains All lead involving activities to be carried out under covered sheds Minimum movement from process areas to non process areas No vehicle movement during rains Slopes should not permit any water logging

Import Permission Application -Checklist of Documents Form 5 (dully filled) Justification for Import......??? Consents under Water/Air Acts/Authorization (Minimum 20 Months validity) Registration for Recycling waste intended for import (Minimum 20 Months validity) 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 APCS, Scrubber, ETP etc Battery Breaking System – Description 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 required for Waste lead acid batteries*, whole or crushed (Basel No - A1160) Acknowledgement of the receipt of copy of application from the SPCB

Application to MoEF for Import Permission - Steps Involved Letter addressed to the Joint Director (HSMD), MoEFCC with From 5 and all documents attached to it. Submit a copy of the above to the SPCB, obtain a receipt. Upload the signed Form 5 and all the required documents and the SPCB receipt on the online < iwms.nic.in > and click submit. The hard copy of the application is required to ne submitted within a week from the date of the making the online application. Prepare the status of compliance to the “ Minimum Requirement - Facilities and Operating Practices” (i.e. compliance to SOP) for ready reference. Attend the meeting as per the agenda & schedule as given on the website. Presence in the meeting is mandatory for first time applicants.

Appraisal Process 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 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.

FISSBA Questionnaire - General Awareness on Health & Environmental Aspects of Lead Acid Battery Manufacturing/Recycling Industry Awareness on the Health Aspects of Lead Adverse effects of lead on human health Limit for “lead in blood” prescribed by the Central Pollution Control Board (CPCB) for the lead industry workers Awareness on the Environmental Aspects of Lead  Rules notified by the Govt of India for the Management and Handling of Batteries in the year 2001? Rules Notified by the Govt of India in 2016 for the Management and Trans-boundary Movement of the Hazardous and Other wastes? Standards Operating Procedure prescribed by CPCB on recycling of Lead Wastes Recycling of lead wastes require obtaining of registration from the SPCBs

FISSBA Questionnaire - General Awareness on Health & Environmental Aspects of Lead Acid Battery Manufacturing/Recycling Industry Lead wastes can be imported only by the recyclers registered with the SPCBs Permission of the MoEFCC is required for import of the lead wastes in India Any feasible use of the spent sulphuric acid contained in the ULAB. Awareness of the Best Management Practices (BMPs) for Lead Acid battery Manufacturing / Recycling Industry Personal Protective Equipment (PPE) that are required to be used in Lead Battery manufacturing /recycling industry Need of a reference document on BMPs) in the Lead Battery/Recycling industry. Willingness to contribute in the preparation of the BMPs document

Thank You........ Wishing you all a very productive conference (Questionnaire survey response requested please)