CONFIDENTIAL

ILMC Visit Report – May 2013

Pondy Oxides and Chemicals Ltd

G17 to G19 and G30 to G32Sipcot Industrial ParkMampakkamSriperumbudurKancheepuram DistrictTamil Nadu StateIndia

Introduction

In May last year through the intervention of the ILZDA and then at the request of the Tamil Nadu Pollution Control Board (TNPCB), the ILMC and the Blacksmith Institute set up a “real time” workshop to demonstrate how the “Benchmarking Assessment Tool” (BAT) could be used to resolve Lead exposure issues, raise environmental performance and reduce occupational exposure at ULAB recycling plants through a constructive dialogue facilitated by the use of BAT.

Subsequently, the Director of the TNPCB, Mr. R Kumar, decided that the Board would like to consider the use and application of the BAT and asked the Blacksmith Institute to set up a workshop for his staff, with the support of the ILZDA and one of its member companies and the ILMC.

Benchmarking Assessment Tool Workshops – Chennai, May 2013

There were twenty four delegates, comprising of environmental technicians and engineers from the TNPCB offices throughout the state.

The workshop contained two distinct sections with the first comprising of two presentations. The first presentation explained the use and application of the Benchmarking Assessment Tool, including how to analyse observations and prepare a list of recommendations, and the second presentation, an explanation of how to fill in and complete the BAT Form in a manner that is easy to collate and analyse.

However, unlike the workshop in Bangalore where the delegates could only watch a video of a recycling plant, the ILZDA had made arrangements for the Chennai delegates to visit the Pondy Oxides and Chemicals ULAB Recycling plant at the Sipcot Industrial Park in the Kancheepuram District of Tamil Nadu to undertake their BAT field exercise.

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The arrangements made by the ILZDA, and agreed with Mr. K Chandrasekaran, the General Manager of the plant, were extremely helpful and presented the delegates with a working, and live plant to use and apply the BAT.

At the beginning of the plant tour and inspection, the ILMC thanked Mr. Chandrasekaran for allowing the Workshop delegates to visit the plant and undertake their field exercise. Mr. Chandrasekaran was also assured that if anything untoward was found during the inspection, it would not be used against the company as this was a training exercise and not an official visit. Nevertheless, the ILMC also undertook to send a confidential report to Pondy metals for their consideration after the BAT was completed. It was also agreed that photographs could only be taken by the ILMC and that they would not be published in the public domain. Mr. Chandrasekaran declined an invitation to join the workshop the following day for the feedback sessions due to prior commitments.

Introduction to plant operations

The Pondy Oxides plant produces about 40,000 tons of refined Lead and Lead alloys per annum using two 10 ton Rotary furnaces.

The plant does not have a mechanical battery breaker and consequently normally purchases soft lead scrap from underground and undersea cables and battery plates, either domestically or imported.

Soft Lead scrap

The battery plates are stored in the smelting area where they are inspected and sorted by hand prior to transfer to the furnace charging screw conveyor. The bags containing the plates had the word Nigeria printed on them, but the source of the plates is unknown. Nearly all the bags were in a poor condition and torn exposing grids and paste to the atmosphere. The plates were dry and there was certainly a potential exposure risk from the dry Lead oxides and sulfates, especially as so much dry paste was spilled onto the floor area and over the bags piled in the heap.

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However, irrespective of the source of the bagged used battery grids, the fact that the bags were torn and oxide paste was spilled onto other bags and all over the floor renders the packaging and transportion unsatisfactory. In addition, the other question to ask is, “What has been done with the Battery Electrolyte?” Unfortunately, the most likely fact is that the electrolyte has been dumped into the environment or the nearest river and it is most unlikely that the electrolyte has been drained from the ULAB, contained and treated prior to disposal.

The used battery plates arrive in woven plastic bags and are then hand sorted

Furthermore, the operators take the grids from the bags and manually remove the paste by banging the plates on a solid object or with hitting the grids with a small hammer. The grids are put to one side to be recycled separately from the paste in a crucible. The risks of occupational lead exposure from this practice are very high, despite the respirators that were supplied by the company and worn by the operators. Such a practice would not be permitted in Europe, the USA, or Australia and is in contravention of the Basel Technical Guidelines.

Indeed, this is the same practice that was employed by the “informal” sector in Senegal and condemned by the WHO, the Dakar University Medical School and the Government of Senegal because it was proven to be one of the main reasons for the death of eighteen infants and babies. Pondy metals need to seriously consider their raw material source and move towards purchasing whole ULAB and installing either an OSHA approved “Battery Saw” or an automated “Battery breaker”. The fabrication and installation of a Battery Saw is not expensive and it can undoubtedly be made locally. It would mean that the company’s purchasing options improve and they can buy whole ULAB instead of being restricted to soft Lead and used battery plates.

Charge material for the furnace is transferred to the various charge buckets that fit into the screw conveyor charger.

The charge buckets are then lifted into the screw conveyor by overhead crane as required and as each one is emptied, so it is removed and the next one is then lifted into position.

Without knowing how the charge buckets are filled, it is difficult to estimate the Lead exposure risks, but there is no ventilation assigned to this task. The company does have an ISO 9001 Certificate, which means that risk assessments have been carried out for each job, but the emphasis is always towards safety and not hygiene.

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The screw conveyor charge buckets with the Lead paste, fluxes and reagents

The front protrusion of the conveyor goes directly into the furnace through the open door and the screw then delivers the charge directly into the drum.

The Furnace Screw Conveyor Charger

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The two Rotary Furnaces are side by side

There is effective combustion gas containment with ventilated flues, incorporating drop out chambers, cyclones, spark arrestors and baghouses located outside the furnace area.

However, there is no hygiene hooding over the centre tapping areas or any hooding around the rotary doors.

Time did not permit observation of the charging and tapping procedures, but in every instance when centre tapping rotary furnaces are tapped for slag and metal, large quantities of dust and fume are discharged uncontrollably into the work areas.

Centre tapping Rotary furnaces are widely used in India, but the design is out of date and has been displaced by “front tapping” and “titling” Rotary Furnaces. The design of these types of furnace means that the charging and tapping ventilation can be in one place, that is, at the front end of the furnace and fume and dust emissions are much easier to contain and ventilate at the front of the furnace.

Nevertheless, despite all the shortcomings highlighted in this report, the TNPCB are very pleased with the company’s flue gas system and regard it as a “model” for other plants. However, none of the drop out pipes were sealed and so dust discharged from the baghouses through the non-return rotary valves could easily be dispersed in the wind or breeze. It would appear that the TNPBC staff do not fully understand what the hygiene requirements for the Rotary Furnace should be and they certainly have not seen such a furnace tapped, otherwise they might not be so pleased.

A major safety hazard is that there is no guarding around the base of the furnace and the rollers with their “pinch points” are exposed and a clear safety hazard. All mechanical “pinch points” must be guarded or rendered inaccessible.

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The dust storage silos with the collection drums in place, but not covered

Dust collection drum below the Cyclone, the drop out nozzle goes into the drum, but there is no seal around the drum

The refinery presented a number of safety and hygiene concerns.

Three operators were seen to be wearing their own “Bandanas” instead of the company issue dust masks, thereby exposing themselves unnecessarily to a higher level of occupational exposure.

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Three operators were wearing their own bandanas instead of dust masks

The refining crucibles were very low to the floor level (~ 35 cm) and with an untidy working area there is a distinct possibility that a person could fall into the molten metal. The standard in most countries is that the top lip of such a crucible must be at least I metre above floor level to reduce the risk of workers falling into the crucible.

Low crucibles and guards missing from the mixer drive pulley

Three of the mixers did not have any guards covering the drive belts and pulleys, but they remained fully operational.

There was one section of the safety handrail missing from the elevated working platform and anyone falling through the gap would fall 4 metres onto a concrete floor. The guard rail is removed to permit reagents required for the refining process to the delivered to the refinery floor, but it must be replaced when the delivery is completed.

Part of the guard rail had not been replaced on the raised refinery floor

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Safety guards were missing from some of the mixer belt drives and three operators were wearing personal “bandanas” instead of respirators

One outstanding feature of the Pondy Oxides operation is the Effluent Treatment Plant that collects all process and surface water for treatment and does not discharge any liquid to the environment, but recirculates it back into the plant with any surplus being evaporated using solar energy.

The Effluent Treatment Plant showing the solar evaporation bed for surplus treated effluent

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Pondy Oxides employ a road sweeper to tour the plant all day and every day collected any dust and Leaded material that has fallen into the roadways. All the roadways in and around the plant are clean and the site looks tidy. Sweeping collected by the road sweeper are charged to the furnaces and any lead contained in the dust is recovered.

Pondy oxides agreed to make their plant open for inspection as part of the training workshop on the understanding that any shortcomings identified during the BAT exercise would not be held against them.

Indeed, as for the company’s openness and hospitality, the delegates were shown every part of the process and allowed to ask as many questions as they wished. As for the workshop, although serious shortcomings in “good practice” were identified at the plant by the delegates, some issues of concern raised in this report were outside the scope of the BAT training course, such as ULAB import controls and furnace design and these matters were not raised by the delegates.

Conclusion

It is absolutely vital that delegates attending a BAT training session have first-hand experience of conducting an “on-site” inspection because the classroom shields them from the realities of understanding what is going on in the real world. In this respect it is so important for ILZDA members to open their doors and welcome BAT delegates. Equally, it is important for the respective State Pollution Control Boards to recognise the value of engaging with the smelter managers and developing environmentally sound ULAB recovery and recycling procedures and processes.

Feedback from the delegates was positive with regard to the use and application of the BAT because it gave the delegates a clear framework to Benchmark the procedures adopted for ULAB recovery and recycling. Interestingly there was no criticism of the plant operation, despite most of the shortcomings being identified by the delegates.

Nevertheless the introduction of BAT into the Pollution Control Boards’ inspection policy was designed to encourage the Inspectors to work with the industry to improve performance and not impose sanctions as has been the practice in other industries.

How the BAT process moves forward now is a very delicate matter because with a better understanding of the Benchmarks necessary to achieve the ESM of ULAB recycling there is every reason to believe that Pollution Board inspectors will be more discerning when considering license applications from poor performing or “informal” sector recyclers. If this is so, then the members of the ILZDA will benefit, but only if they also comply with the “Good Practices” associated with the ESM of ULAB.

It is therefore important at this stage and before this report is sent to Pondy Oxides that the views and opinions of the ILZDA are made know, considered and discussed. The potential benefits to the better performing members of the ILZDA are clear and BAT offers an opportunity to not only reduce the adverse environmental and health effects of poor recycling operations through the licensing process, but also to move the “informal” operators towards ULAB collection and suppliers to the formal sector.

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Such a move would mean that more ULAB would be available to the formal sector and the ILZDA membership, and there is plenty of scope for this type of operation because India is a big country and ULAB have to be collected across huge distances. However, there has to be an agreed way forward with the ILZDA fully committed to the project and this should be a priority for discussion with the ILA and the ILMC before further BAT training proceeds in October.

Brian WilsonILMC June 2013

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