1. Environmental Issues in Secondary Lead Smelting Sector Ruby Sinha & Q.Q.Hassan Environmental Engineer West Bengal Pollution Control Board Paribesh Bhawan, Sec.-III, Bidhan Nagar, Kolkata- 700098 Website : www.wbpcb.gov.in

2. Environment Protection Agencies in India West Bengal Pollution Control Board, a statutory body, was constituted in 1974 as per the provisions of the Water (Prevention and Control of Pollution) Act Ministry of Environment & Forests, GoI Department of Environment GoWB Central Pollution Control Board West Bengal Pollution Control Board

3. Environmental Legislations in India Water (Prevention and Control of Pollution) Act, 1974 Water (Prevention and Control of Pollution) Cess Act, 1977 Air (Prevention and Control of Pollution) Act, 1981 (amended in 1987) Environment (Protection) Act, 1986 (amended in 1991) Public Liability Insurance Act, 1991 (amended 1992)

4. Environmental Legislations in India Hazardous Wastes (Management, Handling and Transboundary Movement ) Rules, 2008 (amended in 2010) Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989 (amended in 2000) Biomedical Wastes (Management and Handling) Rules, 1998 (amended in 2000 ) Plastic Wastes (Management and Handling) Amendment Rules, 2011 Municipal Solid Wastes (Management and Handling) Rules, 2000 Noise Pollution (Regulation and Control) Rules, 2000 (as amended ) Ozone Depleting Substances (Regulation and Control) Rules, 2000 Batteries (Management and Handling) Rules, 2001 E-Waste (Management & Handling) Rules,2011

5. Implementation of Environmental Legislation by WBPCB Issuance of Permit Surveillance Creating Awareness

6. Categorisation of industries Depending upon the pollution potential, WBPCB classified the industries into three different categories: “ RED ” category: i) Special Red & ii) Ordinary Red “ ORANGE ” category “ GREEN ” category A few activities with no pollution potential are classified as “ Exempted “ Category.

7. Industrial Siting policy in West Bengal To combat the industrial pollution in West Bengal, Board has formulated Industrial Siting Policy in Dec,1997 which has been amended time to time looking at the trend of environment scenario in the State. Salient Feature of Industrial Siting policy : Industries under “RED” category are not permitted to set up in Municipal Areas falling under KMA.‏ These units cam be permitted in Panchayet areas with adequate pollution abatement systems.

8. Salient Feature of Industrial Siting policy Industries under “ORANGE” category can be permitted in Municipal area except KMC & HMC areas or within industrial estates in case of KMC and HMC area with adequate pollution control measures subject to the condition that the site clearance should be obtained from municipal authorities. Industries under Green Category can be permitted in any area in the state subject to site clearance by the local body. Exempted category – need not apply for CFE and CFO

9. Regulatory Compliances to be achieved for Setting up and Operating an Industry Permits Required: (i) Environment Clearance from MoEF, GoI and SEIAA,GoWB (as applicable for some specific categories of industries ) As per the EIA Notification 2006 few projects and activities requires prior EC from the competent authority for new, expansion or modernization projects. Those activities are broadly categorised under two categories – Cat. A and Cat. B, based on their potential environmental impacts. Clearance for Cat. A projects is accorded by MoEF, GoI and for Cat. B projects by SEIAA,GoWB. (iii) Consent to Operate from WBPCB for operating any industrial unit (to be renewed periodically)

10. Regulatory Compliances to be achieved for Setting up and Operating an Industry (ii) Consent to Establish from WBPCB before establishment of any new industry before expansion or modification of an existing industry (iii) Consent to Operate from WBPCB for operating any industrial unit (to be renewed periodically)

11. Regulatory Compliances to be achieved for Setting up and Operating an Industry Permits Required: (iv) Authorisation under HWM Rules from WBPCB (applicable for Hazardous waste generating/storage/ handling/ collection/ transportation units and common HW treatment, storage & disposal facility) (v) Registration for Recycling/Reprocessing of Hazardous Wastes (as enlisted under Schedule IV of HWM Rules) from WBPCB

12. Regulatory Compliances to be achieved for Setting up and Operating an Industry Permits Required: (vi) Import Clearance for Hazardous Waste from MoEF, Govt. of India Import Clearance for Schedule III (Part D) Hazardous Wastes from WBPCB Import Clearance for Hazardous Chemicals from WBPCB (vii) Registration for Battery dealers/Reprocessors from WBPCB (under Batteries (Management and Handling) Rules, 2001 )

13. Permits Required for Setting up and Operating a Secondary Lead Smelting Industry (i) Consent to Establish from WBPCB before establishment of any new industry before expansion or modification of an existing industry The Recycling industrial units registered under the HWM Rules are exempted from obtaining EC as per the Amended EIA Notification,2009 (ii) Consent to Operate from WBPCB for operating any industrial unit (to be renewed periodically) (iii) Authorisation under HWM Rules (to be renewed periodically) (iv) Registration for Recycling/Reprocessing of Hazardous Wastes

14. Permits Required for Setting up and Operating a Secondary Lead Smelting Industry (iii) Authorisation under HWM Rules (to be renewed periodically) (iv) Registration for Recycling/Reprocessing of Hazardous Wastes

15. Procedure for obtaining Consent to Establish from WBPCB Submission of Application in prescribed form alongwith requisite fee. Application Form and Challan for depositing fee are available in WBPCB’s website www.wbpcb.gov.in

16. Procedure for obtaining Consent to Establish from WBPCB Important documents to accompany the Application Form : (a)Site clearance/ Trade Licence from local body ( Corporation / Municipality / Panchayet) (b) Land documents like Land deed/porcha/ Rent agreement or lease document ( for rented premises) (c) Project Report (to include brief process details, environment management plan) (d) Site Plan, Route Map (e) Documents in support of Fixed Capital Investment

17. Procedure for obtaining Consent to Operate from WBPCB Submission of Application in prescribed form alongwith requisite fee. Application Form and Challan for depositing fee are available in WBPCB’s website www.wbpcb.gov.in Important documents to accompany the Application Form : a)Consent to Establish(NOC) of WBPCB b)Trade Licence from local body ( Corporation / Municipality / Panchayet)

18. Procedure for obtaining Consent to Operate from WBPCB (c) Land documents like Land deed/porcha etc., Rent agreement or lease document ( for rented premises) (d) Brief process details, details of Pollution Control Devices (e) Site Plan, Route Map (f) Documents in support of Fixed Capital Investment (g) Other statutory licences ( e.g. Factory licence, fire licence etc)

19. Procedure for obtaining Hazardous Waste Authorisation from WBPCB Submission of Application in prescribed form alongwith requisite fee. Application Form and Challan for depositing fee are available in WBPCB’s website www.wbpcb.gov.in Important documents to accompany the Application Form : a)Consent to Establish(NOC) and Consent to Operate of WBPCB b) Photograph of Environmental Information display Board in English and Bengali language e) Photocopy of Hazardous Waste Stock Register d) Status of Water Cess Payment

20. Procedure for obtaining Registration from WBPCB Submission of Application in prescribed form Form-5 Application Form and Challan for depositing fee are available in WBPCB’s website www.wbpcb.gov.inwww.wbpcb.gov.in Important documents to accompany the Application Form a)Consent to Establish(NOC) of WBPCB b) Process Flow Chart along with Material Balance (highlighting waste generation) Registration issued by SPCB in the form of a Pass-book mentioning HW type and quantity permitted for purchase

21. CFE/CFO Issuance Authority Office Consent to Establish Consent to Operate District Industries Centre Green (small) Orange (small) Green (small) WBPCB Green Orange Ordinary Red Special Red Green Orange Ordinary Red Special Red

22. Validity Periods of Consent to Establish & Consent to Operate

23. Secondary Lead Smelting Units in West Bengal In West Bengal, the secondary lead smelting units are mostly unorganized sector. A number of such units are operating in Kankurgachi and Picnic Garden areas in Kolkata, Sankrail and Domjur in Howrah. Few smelting units have also come up in the North 24 Pgs, Hooghly and Medinipur (E).

24. Secondary Lead Smelting Process Lead Smelting is a thermal metallurgical process in which lead is separated in fused form from the non- metallic materials or or other undesired metals with which it is associated. The lead bearing wastes alongwith flux and reducing agents are smelted in furnace, molten metal is tapped and made into ingots. The slag is recycled for approx. 2-3 times for extraction of lead. Residual slag is disposed of as hazardous waste.

25. Pollution generated from Secondary Lead Smelting Units Air Pollution Flue gas containing particulate matter and lead in particulate, fugitive emission Water Pollution Waste water from the scrubber (APC Device), Unused dilute acid in battery Hazardous Waste Lead bearing slag, dust from APC Device, sludge from scrubber etc.

26. Pollution Control Measures Air Pollution Control : Cyclone Separator/ Gravity Settling Chamber, Bag filter, Scrubber Water Pollution Control : Scrubbing liquid to be reused after settling. Residual acid from battery to be collected properly and neutralized before discharge.

27. Standards to be maintained Emission Standard : ParameterConcentration Particulate Matter50 mg/Nm 3 Lead as Pb in Particulate 10 mg/Nm 3

28. Pollution Control Measures Hazardous waste : On-site storage in earmarked area with shed and impervious lining Disposal to common TSDF for Hazardous Waste

29. Hazardous Waste as defined in the Rules Any waste which by reason of any of its physical, chemical, reactive, toxic, flammable, explosive or corrosive characteristics causes danger or is likely to cause danger to health or environment, whether alone or when in contact with other wastes or substances, and shall include wastes listed in Schedules I, II & III of the Rules

30. Is a waste Hazardous or not ?? Waste is hazardous if  it is listed in Schedule I Schedule I  Or, if it falls in Schedule II (analysis required) Schedule II For the purpose of regulation of Import & Export, a waste is considered as hazardous if it is listed in Schedule-III

31. Solid wastes generated from secondary lead smelting units Solid wastes Non-hazardous Hazardous ( Not covered under HWM Rules) (covered under HWM Rules)

32. Hazardous wastes TypesSources Lead slagProcess Sludge (lead containing)Scrubber Sludge (acidic) From lead acid breaking activity ( after neutralisation) Lead dustSettling chamber, Cyclone, bag filter Damaged & discarded bags Bag filter Other wastes Damaged refractory lining/bricks. Broken asbestos roof sheet.

33. Type and Nature of HWs  Recyclable – wastes having potential for recovery of useful /valuable material e.g. Metal bearing dross, ash, used oil etc.  Incinerable – wastes having high calorific value, mainly organic wastes like solvents, tars, off-spec. Organic products etc.  Land Disposable – wastes that can neither be recycled or incinerated

34. Disposal Methodology of HWs Recyclable Wastes – to be sold to actual recyclers authorised for processing the particular hazardous waste Note : SPCB Registration required for non-ferrous metal wastes, used & waste oil, e-waste, ink waste, paint waste etc. As listed in Sch-IV Incinerable Wastes – may be incinerated onsite in captive incinerator or in common HW incinerator; Note : CPCB standard and guidelines to be followed for the operation of the incinerator. Disposable wastes – to be disposed in authorised HW disposal facility; to be stabilised before disposal, if required.

35. Types of wastes WastesType RecyclableLead dust, lead slag ( upto certain extent), damaged bag filter cloth, settling particles from settling chamber etc. IncinerableNone DisposableNon recyclable Lead slag Damaged Refractory lining, Sludge ( acidic)

36. Storage of Hazardous Waste  Till disposal for recycling/ treatment/ land filling, HWs are to be stored onsite in bags/ containers/pits in a covered area.  Storage permitted for a period not exceeding 90 days SPCB may extend the storage period, in case of i. Small generator, generating HW upto 10 TPA ii. Recyclers, reprocessors and facility operators upto 6 months of their annual capacity iii. Generators who do not have access to any TSDF in the concerned State iv. Wastes which need to be specifically stored for development of a process for its recycling, reuse.

37. Transportation of Hazardous Waste  HWs to be properly packed and labelled for transport to ensure safe handling  HW Containers shall be marked as per Form-12Form-12  Information on hazardous nature of wastes and measures to be taken in case of emergency shall be provided to the transporter in Form-11Form-11  Transport to be in accordance Motor Vehicles Act, 1988 and related guidelines  Manifest System (Form-13) to be maintainedForm-13

38. Waste generator TSDF Operator Transporter Manifest in Form 13 for transportation The occupier shall prepare six copies of the manifest in Form 13 comprising of color code indicated belowForm 13 (all six copies to be signed by the transporter) SPCB White Green Yellow Orange Pink Orange BluePink Green Yellow BluePink Green Orange Blue

39. Responsibilities of Occupier (HW generator, recycler, TSDF Operator) To obtain Hazardous Waste (HW) Authorisation To obtain HW Registration ( Recycler only) To obtain CPCB permission for utilization of HW ( under rule 11) To treat/dispose their wastes on their own or through common TSDF facility To store HWs in an environmentally safe manner till disposal To maintain record of storage, sale, transfer, recycling and reprocessing of HWs in Form- 3 Contd…

40. To maintain Manifest System (Form-13) for waste transport and disposalForm-13 To submit Annual Returns (Form 4) to SPCB by 30 th June of every year for the preceding period April to March (Recyclers to submit Annual Return in Form-6)Form 4 To report accidents related to hazardous wastes (Form-14) Responsibilities of Occupier (HW generator, recycler )

41.  To grant, refuse or cancel HW Authorization  To prepare inventory of the HW generating units and quantum of HW generation  To monitor HW generating units for ensuring safe storage, treatment and disposal of wastes  To analyze the waste characteristics in order to decide its nature Contd… Responsibilities of SPCB

42. Hazardous Waste Authorisation Who needs ? All units (occupier) generating, handling, collecting, receiving, treating, transporting, packaging, storing, selling, recycling, reprocessing, recovering, reusing and disposing hazardous wastestreatingtransportingrecyclingrecoveringreusingdisposing

43. Registration of HW recycling units Who needs Registration ? All units recycling or reprocessing hazardous wastes specified in Schedule-IVSchedule-IV application in Form-5 to the SPCB needs CFE (in case of fresh application) and valid CFO and HW authorisation (in case of renewal) Registration issued by SPCB in the form of a Pass-book mentioning HW type and quantity permitted for purchase

44. Sale / Auction of HWs listed in Schedule-IV  Sale only to units having valid Registration  Can be sold to any registered unit in the country  Each sale to be endorsed in original Pass-book of purchaser issued by the SPCB  To check waste type specified in the original Pass-book  To check whether purchaser has capacity to process the quantity available for sale

45. Import and Export of HW  MoEF is the nodal agency  Schedule III to be used for regulating HW export and import.  Export & Import ban on 30 items (Schedule VI)Schedule VI  Import shall be permitted only for recycling or recovery or re-use and not for disposal.  Export may be allowed to an actual user of the waste or operator of a disposal facility with the Prior Informed consent of the importing country  Wastes listed in Part-D of Schedule III can be imported by traders registered with the SPCB on behalf of actual users

46. Responsibilities of Importer and Exporter Submit Form-7 & Form -8 to MoEF with copy to SPCB prior to import or export Obtain PIC and submit along with Form- 7 & 8 in case of Import and Export of Wastes listed in Schedule-III Part –A Ensure that movement document (Form-9) accompanies the consignment Inform SPCB and CPCB in advance regarding date & time of arrival of consignment (Importer)

47. Illegal Traffic Any import or export of hazardous waste without prior permission of the Central Govt. or through submission of false information or not tallying with movement documents (Form-9) For illegal import, importer has to re-export the waste at his cost within 90 days of arrival

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