ECAR
Fact Sheet for Connecticut
Batteries
 
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The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
If
handled improperly, lead-acid batteries removed from vehicles pose
certain hazards. Battery components are toxic and corrosive, and
can also be a fire and explosion hazard. Lead and sulfuric acid
can contaminate the air, soil and water. Direct contact with sulfuric
acid can burn the skin and eyes. Exposure to lead in the environment
can pose a serious health hazard to children. Lead is also very
toxic to aquatic life.
Because
batteries contain lead and sulfuric acid, lead-acid battery disposal
is fully regulated as a hazardous waste management activity. When intact
lead-acid batteries are recycled, the handling requirements
are relaxed, but the batteries are still subject to limited hazardous
waste regulations. This fact sheet will tell you:
- How to determine whether spent batteries should
be considered a hazardous waste.
- What you need to do to handle batteries in compliance
with the rules that apply to you.
The
Connecticut Department of Environmental Protection (CT-DEP) has
prepared a guidance document to help auto recyclers manage lead-acid
batteries. Much of that information is included in the fact sheet
below. You can access the link to CT-DEP’s Auto Recycling Guide
under Other Relevant Resources.
Regulations
In Connecticut, spent lead-acid batteries
must be recycled, and cannot be disposed of with other solid wastes. The basic rule of thumb is that the batteries must be either
reclaimed either through regeneration or another means. If the batteries
are not reclaimed, you must follow the hazardous waste regulations.
Your first option is to manage spent lead-acid batteries under
the lead-acid battery recycling rules. If you choose to manage your lead-acid
batteries under these rules, you must:
- Segregate batteries from paper, rags, garbage,
flammables, scrap metal or hazardous chemicals by means of a dike,
berm, wall or other physical barrier.
- Store spent lead-acid batteries on an impervious
surface and inspect the batteries weekly for leaks and deterioration.
- Open, handle or store spent lead-acid batteries
so that the battery case does not rupture, leak, or produce short
circuits.
Your
second option is to manage your lead-acid batteries under the Universal
Waste Rule. EPA developed universal waste regulations to encourage
recycling of certain specific wastes. These rules are less demanding
than the hazardous waste rules.
The universal waste rules are applicable to auto recycling companies
who receive and store batteries for recycling, but are not applicable
to companies that reclaim batteries (covered under separate rules).
Auto
recyclers who receive, store, and send batteries off-site for recycle
are "universal waste handlers." There are two groups of
handlers, based on the amount of universal waste accumulated on-site
at any one time:
- Small Quantity Handler of Universal Wastes (SQHUW)
– accumulates less than 11,000 lbs. (5,000 kg) of universal waste
at any time during a calendar year.
- Large Quantity Handler of Universal Wastes (LQHUW)
– accumulates 11,000 lbs. or more (5,000 kg) of universal waste
at any time during the calendar year, which would
require the site to have an EPA Identification Number.
Once
you trigger the LQHUW status you remain a LQHUW for the rest of
the calendar year. However, you re-evaluate your classification
at the start of each calendar year.
Battery Storage. Always store lead-acid batteries in a secured, covered location,
that is designed to contain leaks and temperature extremes. Keep
batteries away from open flames or other ignitable sources. Do not
stack lead-acid batteries since they may crack and leak acid and
other hazardous components, thereby incurring a potential expensive
cleanup. Keep batteries off the ground to prevent them from coming
in contact with water, which may result in contaminated runoff into
creeks and streams. Do not store batteries around inside floor drains
or outside storm drains.
Improper storage practices can result
in potential violations to the Federal Clean Water Act, as well
as violations of state and local water quality laws.
Labeling
and Marking. Waste batteries (i.e., each battery),
or a container or tank in which the batteries are contained, must
be labeled or marked clearly with any one of the following phrases:
"Universal Waste -- Battery(ies)," or "Waste Battery(ies),"
or "Used Battery(ies)."
Response
to Releases.
Should your batteries leak onto the ground, you must immediately
contain all releases and determine whether any material resulting
from the release is hazardous waste. If so, you must manage the hazardous
waste in compliance with all applicable laws.
Regardless
of which set of rules lead-acid batteries are managed under, a hazardous
waste determination must be conducted on spilled acid and broken
lead-acid batteries, and on any materials used to clean a spill,
to establish whether or not their disposal is subject to hazardous waste regulations.
Links
to the Regulations. Use
the following links to view the regulations pertaining to battery
management.
Connecticut
Universal Waste Regulations (Section 22-a-449(c)-113)
Connecticut Lead-Acid Battery
Recycling Rules (RCSA 22a-449(c)-106(c)
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things he
or she checks to see if you are in compliance with environmental
regulations. It makes good sense for you to perform a "self-audit"
and catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with self-audits
(see Audit Policy Page).
Use the following list to audit your battery storage and
management procedures.
- Has the facility made a size determination (SQHUW
vs. LQHUW)? Review records and current inventory to verify the size determination
was correct. A large quantity handler of universal wastes (LQHUW)
is a facility that accumulates 11,000 lbs. or more of all universal
wastes at any time during the calendar year.
- If the facility is a LQHUW, they are required
to have an EPA Identification Number. Verify that the facility has an EPA Identification
Number.
- All handlers of universal waste are required
to meet specific accumulation time limits. Verify that the facility has
a system in place to determine accumulation times and that no
used batteries have been on-site for more that one year.
- All handlers of universal waste are required
to manage the batteries and other solid waste generated from battery
activities according to specific parameters and procedures. Verify that universal waste
batteries are managed in a way that prevents releases of any batteries
or battery components to the environment. Verify that batteries
that show evidence of leakage, spillage, or damage that could
cause leakage under reasonably foreseeable condition are stored
in a container. Verify that containers are closed, structurally
sound, compatible with the contents of the battery, and lack evidence
of leakage, spillage, or damage that could cause leakage.
- All handlers of universal waste are required
to manage releases according to specific procedures. Verify that all releases of
waste battery residues are immediately contained. Verify that
the handler determines if the material resulting from the release
is a hazardous waste. Verify that if the material is hazardous
waste, it is handled appropriately in accordance with all applicable
RCRA requirements.
- All employees who handle or have responsibility
for managing universal wastes are required to be trained. Verify that all employees have
been trained in the proper handling and emergency response procedures
relative to their responsibilities during normal facility operations
and emergencies.
- Universal waste batteries are required to be
labeled. Verify
that universal waste batteries (each battery), or a container
in which the batteries are contained, are labeled or marked clearly
with any one of the following phrases:
- UNIVERSAL WASTE BATTERY(IES)
- WASTE BATTERY(IES)
- USED BATTERY(IES).
Best
Management Practices (BMPs)
Most
regulations tell you what you have to do to be in compliance, but
they don’t explain how to do it. That’s where "best management
practices" come into play. BMPs are proven methods that
help you to get into compliance and stay there. The following BMPs
are recommended for battery storage areas and management procedures.
- Use an
authorized recycler.
- Avoid
long-term storage of lead-acid batteries by sending accumulated
batteries to a reclaimer within six months of receipt. Limit
accumulation of large quantities of spent batteries. If necessary,
ship more frequently.
- Indoor
storage is recommended for lead-acid batteries.
- Store
batteries on an acid resistant rack or tub. Store spent lead-acid
batteries upright in a secure location, protected from the elements.
Never stack batteries directly on top of each other. Store on
acid-resistant racks or shelving, or layer with wood. Never
drain batteries or crack the casings.
- Batteries
stored outside should be stored on impermeable surfaces such
as concrete and should have secondary containment. Also, it
is recommended that batteries be covered to prevent acid run
off.
- Keep
a neutralizing agent, such as baking soda, nearby in case of
leaks or spills. If a spill does occur, the waste must be treated
as a hazardous waste.
- When
stacking batteries, make sure they are stored so that any fluid
from leaking batteries will not be released into the environment.
- Electrolyte
fluid in spent batteries contains enough lead to qualify it
as a hazardous waste. This fluid, if discharged onto the ground,
will likely make the soil which absorbs it a hazardous waste.
Remove batteries before crushing any vehicles.
- Test
batteries to determine usability or resale quality.
- If
lead-acid batteries are recharged for resale, remove lead cable
ends from batteries, store lead parts in a covered container
that is strong enough to hold the weight of the lead and recycle
the lead with a reputable recycler.
- If
spent lead-acid batteries are going to be recycled as scrap
batteries, leave lead battery cable ends attached to the scrap
batteries.
- Check
batteries for leaks, cracks, etc. prior to storing.
- Place
cracked or leaking batteries in a sturdy, acid-resistant, leak-proof,
sealed container (e.g., a sealable 5-gallon plastic pail). The
container should be kept closed within the battery storage area.
- Strap
batteries to pallets or wrap batteries and pallet in plastic
during transport.
- Keep
written records of weekly inspections of spent lead-acid batteries.
Contacts
- For more information, contact the Connecticut
Bureau of Waste Management at 860-424-3021.
- To report a spill or leak, immediately call
the Connecticut Department of Environmental Protection,
Oil and Chemical Response Division at 860-424-3338, 24 hours/day.
Should this number become unavailable for any reason, call 860-424-3333.
Within 24 hours of the spill you are required to complete a written Report of Petroleum
or Chemical Product Discharge.
- To report an environmental incident or complaint,
contact the nearest regional
office.
Related
ECAR Fact Sheets
- Hazardous Waste
Other
Relevant Resources
- Connecticut
Auto Recycling Guide
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