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Submission to NSW Dept of Infrastructure, Planning and Natural Resources (DIPNR) RE: Wagga Wagga lead battery recycling facility proposed by Renewed Metal Technologies Pty Ltd in DA05/0517

----- Original Message -----
From: The LEAD Group
To: [email protected]
Sent: Tuesday, July 19, 2005 4:43 PM
Subject: 05/0517

Dear DIPNR,

Thanks for the opportunity to submit comments on the Wagga lead acid battery recycling plant proposed by Renewed Metal Technologies.

I have made the following estimate of the annual tonnage of lead acid batteries which are not currently being recycled in Australia.

Unofficial figures from our federal environment agency estimate perhaps 1500 tonnes of lead acid batteries have been shipped to Asia in contravention of the Basel Convention, because a couple of shipments were intercepted when destined for China in the last 6 mths, but that some 95,000 tonnes of lead acid batteries arises per yr by their estimate and the two plants that recycle the majority of our batteries (Australian Refined Alloys in Melbourne and in Sydney) only process 60,000 tonnes per annum between them (though they each have a capacity to process 35,000 tonnes per annum). When I rang Exide Technologies (in Melbourne), the only company licensed by the federal government to ship batteries for recycling overseas (they are shipped to Exide's secondary smelter in Wellington, New Zealand) to ask for the annual tonnage shipped, they phoned back to say their licence allows up to 12,000 tonnes annually and this year they'll come very close to the mark. By my reckoning this leaves some 20,000 tonnes per annum either still in vehicles or dumped or buried or "recycled" in whole car body recycling (see below) and dumped as flock overseas.

Even if the Hydromet plant approved for Wollongong is built and takes the approved 12,000 tonnes per annum from second quarter 2006 as planned, this still leaves 8,000 per annum for the proposed new plant to recycle plus the backlog from all the dumped batteries in years gone by, plus potentially, batteries imported from poorer countries within our region who do not have safe facilities for battery recycling. Dr Peter Hurley of Blake International Limited in the UK has written:

"Of the 4.6 million tonnes used to make batteries every year world-wide only 3.5 MT gets recycled. My problem is I don't know where the other 1.1 million tonnes goes."

With good business management, RMT could also potentially take some of the capacity currently recycled by ARA or Exide, thus, by Engitec's claim, leading to safer working conditions and reduced emissions and waste for the recycling of Australian batteries.

I am concerned that the proponent has not explained exactly how they will increase battery recycling rates in Australia and that they have neither proposed to change from the existing palette transport system nor the dependence on road freight. There are in my view, major environmental impacts from vehicle emissions and the occasional accident during transport and storage while awaiting collection, which have therefore not been commented upon in the EIS.

I personally regularly see lead acid batteries dumped on the street in suburban Sydney despite the fact that theoretically whenever you buy a replacement battery, the dealer is supposed to accept your old battery for recycling. When I was speaking to the lab-workers at the Western Australia sugar mill I asked why they didn't dispose of the leaded lab waste by adding them to the load with their lead acid batteries whenever they are picked up, I was told that lead acid batteries are not picked up in such remote areas due to the complete lack of licensed hazardous waste transporters and the batteries are simply dumped at the local tip.

What will RMT be doing to decrease such dumping, which has a long history in Australian culture? What will they be doing to improve the storage and transport technology?

 A local waste collector/processor in New South Wales commented to me in May last year that "battery recycling companies are folding and people are putting batteries in their rubbish bins and skips".

Thinking outside the square, in March of 2004 he had said:

"I have worked on a collection regime for lead acid batteries which could be extended to tyres and related wastes, because they occur together and so can be picked up as a combination of bulky wastes and dense batteries.

"NSW EPA is very proud of their tyre burying policy but you can mine coal for less than the cost of digging up the EPA's shredded tyre landfill, and this situation isn’t likely to change for a very long time into the future. I've developed a method providing for one collection path of all the automotive and other wastes and the companies it has been tested on love it. I would give them an 8'X8'X8' cage for any size tyre which would be loaded/ unloaded mechanically and the tyres would be processed as required. Batteries would be placed into leakproof tubs and transported at the same time. You could take out brand new tyres and batteries on the return trip. It would be auditable by the government. Other wastes are transported in the same tubs or cages, and processed in the same licenced facility with the resulting products distributed as appropriate to end users. Individual waste collection and handling costs are reduced due to the fewer levels of individual handling, and co-location of processing to one central facility.  

"The appliance industry has been put on notice to come up with some solutions and I see an opportunity to work with the tyre and battery industry to share a waste collection path. You have to have a licence to deal with tyres and batteries with lead in them, but you would also have to have a licence to deal with TVs and monitors as they have lead in them.

"Industrial rents are high and you need lots of space for the large thru-puts because you don't get much income per tonne, and presently it's cheaper to bury these wastes because the users aren't asked to pay ongoing fees for landfill maintenance.

"There could be a $200 tariff on new cars to properly dispose of every old car to enable ensuring that the tyres, batteries and oils don't get into the shredder flocks. The rubber/plastics could be burned in a cement kiln to offset coal production and would attract a credit from the Greenhouse Office. Its more cost effective / energy efficient to burn tyres than to shred them.
"A large battery manufacturer had considered implementing my national pick-up scheme for batteries and related wastes, and have realised it would require an education campaign as well which may be able to involve The LEAD Group.
"Extended Producer Responsibility is all well and good for ensuring redesigning of products so they are less toxic and more recyclable but consumers can end up paying for recycling instead of the solely the producers, ensuring we have the money to deal with the waste that's already out there."

My sense is that an Engitec plant in Australia can only improve lead acid battery recycling as long as concomitant improvements are undertaken in the transport of the batteries. It is good to note that there is a rail siding some 700 m from the proposed Bomen site and if DIPNR were to insist on the proponent building a rail spur (if not straight away, then at least as thru-flow increases), this could change the face of battery transport in Australia.

 Other issues relating to the EIS are that the stack emissions need increased velocity to ensure the system of "pollution by dilution" (spreading the load over a wider area) - not by any means a sustainable practice - is maximised. The air and waste emissions are an ongoing concern to the community and a requirement to reduce annual emissions by at least 1% per annum is a policy that would give the community some peace of mind.

If the proponent (and the government) were to grapple with these problems, we could end up with safer lead acid battery recycling than we've ever had in Australia and the region, but it is wise to note that there is no such thing as an environmentally sustainable smelter as zero emission smelters have not yet been developed.

 Yours Sincerely
Elizabeth O'Brien, Manager, Global Lead Advice & Support Service (GLASS) - incorporating the Lead Advisory Service Australia (LASA), run by The LEAD Group Inc.
PO Box 161 Summer Hill NSW 2130 Australia
Ph +612 9716 0132, Freecall within Australia 1800 626 086
Fax +612 9716 9005
Web: www.lead.org.au
Email: The LEAD Group

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