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
 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)
 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)
 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
 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
 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
 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).
 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 )
 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
 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
 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
 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
 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
 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
 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 1/3 rd of the recycling
capacity with a validity of 18 months.
Thank
you