RCRA Options for Recycling Waste Lead-acid Batteries
Although lead-acid batteries generally exhibit the hazardous waste characteristic of toxicity for lead (D008) and would be subject to significant restrictions when discarded, the EPA encourages their recycling by providing two alternative management standards. Lead-acid batteries may be managed as “universal waste” under 40 CFR Part 273 or under the specific alternative standards of 40 CFR 266, Subpart G.
Managing Lead Batteries as Universal Waste
A universal waste handler is prohibited from disposing or diluting lead-acid batteries, and must manage them in a way that prevents releases of any of their components to the environment. If a battery is damaged and could leak, it must be kept in a closed, structurally sound container that is compatible with the contents of the battery. In general, treating lead-acid batteries is also prohibited, except when specific management standards are met.
Under the Universal Waste Regulations, 40 CFR 273, there are permissible treatment activities. The generator may remove the lead-acid batteries from the devices they are powering; discharge them so as to remove the electric charge; remove the electrolytes as long as the batteries are reclosed immediately after removal; or regenerate them. (The electrolyte itself must be managed as a hazardous waste under 40 CFR 260-272, if it exhibits a characteristic)
Each individual battery or container in which the batteries are stored must be marked with the words “Universal Waste—Battery(ies),” or “Waste Battery(ies),” or “Used Battery(ies).” Generally, the generator must be able to demonstrate that the batteries have not been stored on site for more than one year. This can be accomplished in many different ways, including indicating an accumulation start date on the battery or container or maintaining an inventory system, log, or computer record.
Training and Emergency Response
Employees must be trained in how to properly handle lead-acid batteries and in emergency procedures in the event of fire, explosions, and releases. If the battery is compromised, any resultant releases must be contained immediately.
Reclaiming Spent Lead-acid Batteries
If a generator is storing lead-acid batteries destined for reclamation by regeneration (i.e., replacing the electrolytes) or by any other method other than regeneration, then he or she is exempt from most of the standard RCRA regulations (40 CFR Part 262-270).
What this means, in essence, is that there are no specific RCRA management standards—including time limits—and no requirements for marking, training, or manifesting, as long as you follow the minimum requirements in 40 CFR 266, Subpart G.
If the lead-acid battery will be reclaimed by a method other than regeneration, the generator will be subject to applicable land disposal restriction requirements found in 40 CFR Part 268. In particular, since the generator is managing a prohibited waste that is excluded from regulation subsequent to the point of generation, he must place a one-time notice describing the exemption and disposition of the waste in the facility’s on-site files (40 CFR 268.7(a)(7)).
Off-site Shipments of Lead-acid Batteries
Take into consideration any DOT hazardous materials transportation regulations under 49 CFR 171-180 applicable to shipping lead-acid batteries off site. The generator is not required to use the uniform hazardous waste manifest to ship universal waste lead-acid batteries to a universal waste handler. However, large quantity handlers of universal waste (anyone who accumulates more than 5,000 kilograms total of all universal wastes—batteries, pesticides, mercury-containing equipment, or lamps—on site at any one time) must keep a record of each shipment. This record can take the form of a log, invoice, manifest, bill of lading, or any other shipping document.
What other difficulties do you find managing batteries? Share comments below.
Tags: RCRA, recycling, universal waste
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