1. 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

2. 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

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

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

5. Global Lead Uses (2016) (Lot of Scope for India for LAB Supply)
Source:

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

7. World Top 10 Auto Markets (2017) (India Already the 4th Largest)
Source:

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

9. Trend of Lead Acid Batteries Demand in India (Projections for Local & Export of LABs)
Source -

10. 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

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

12. India’s Lead Imports and Exports (India should Import Refined Lead or ULAB/Scrap?)
(Source:

13. 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:

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

15. Status (2017) of Lead Waste Imports by the Recyclers (1000 Tonnes)
(Source : Agenda MoEFCC Expert Committee Meetings 81st to 93rd :

16. Status(2017) of Imports by Waste Type (1000 Tonnes)
(Source : Agenda – MoEFCC Expert Committee Meetings 81st to 93rd :

17. 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 ?

18. 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

19. 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

20. 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

21. 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

22. 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

23. 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

24. 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

25. 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.

28. 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.

29. 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

30. 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

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