| File Note: |
Gone through the SOPs 2024 issued by CPCB and verified by RO and found that:
1. As per Sr.no.1.1.1 (vii), Annexure1 of SOP,detail of Air Pollution Control system installed in the unit along with the diagram and their specification is to be provided. However, same is not found attached.
2. As per Sr.no.1.1.1 (viii),Annexure1 of SOP,detail of ETP with for treatment of acidic waste water and discharge from scrubber. The industry has claimed that there will be no trade effluent as dry batteries are to be used. However, as per SOP requirement ETP is still required for scrubbing effluent. But as per RO report no ETP provided.
3. As per Sr.no.2.1.1, Annexure1 of SOP, furnace connected with expansion chamber, Cooling tubes,ducts, cyclone/Multi cyclone, bag filter with pulse jet/ mechanical shaker arrangements, alkali scrubber with alkali dosing, connected with ETP is required. However, as per RO report, only wet scrubber is provided.
4.As per Sr.no.4.1.3, Annexure1 of SOP, Arrangement for washing of plastic components before being sent for recycling and acidic water neutralization facility. No report in this respect received from RO.
5. As per Sr.no.4.1.3, Annexure1 of SOP, floors in the loading area should be kept wet through sprinkling to reduce the chances for lead particles/dust getting airborne. The reply of RO is not satisfactory
6. As per Sr.no 4.1.4 Annexure1 of SOP, any water used for washing, rain water etc should be collected through separate pits for removing metallic lead etc and the pit should have fine screens for passage of clear water. Compliance by RO is not satisfactory.
7. As per Sr.no 4.1.5 , Annexure1 of SOP, the movement of vehicle to the administrative/working/production areas should ensure that only the trucks involved in the material handling /transportation reach the work areas, and their tyres are washed before they leave these areas.Compliance by RO is not satisfactory.
8. As per Sr.no 4.1.6, Annexure1 of SOP, the unit should have facilities for washing tyres for vehicle entering and going out of the recycling facility. Compliance by RO is not satisfactory.
9. As per Sr.no 5, Annexure1 of SOP, certain guidelines are prescribed for transportation. In case, the industry has to use its own vehicle for transportation, then it has to submit point wise compliance there to. Otherwise, industry to submit and undertaking to the effect that it will get the raw material/product transported only through the authorized transporter the concerned SPCBs as per HWM Rules.
10. Above all, CPCB has revised the SOPs for recycling of lead scrap/used lead acid batteries in year 2024, which have additional compliance to be made. RO to compare and check whether all compliance's of new SOPs 2024 is being done.
Please submit point wise compliance through return reply as application is already 14 days old and we have to take a final decision to decide the same. In case, the industry has yet to make compliance's which may take sometime, then return the application with the observation and request to resubmit the complete application.
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