ECAR Fact Sheet for District of Columbia
Batteries

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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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

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.

Regulations

Automotive recyclers who generate, collect, transport, store, or regenerate lead-acid batteries for reclamation purposes may be exempt from certain hazardous waste management requirements. 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.

Battery Storage. Indoor storage is preferable to outdoor storage to avoid contact with water and to avoid extreme temperatures that can cause cracking. Rain, snow, and draining water should not enter the storage area.

• Store used batteries on a non-reactive, impermeable and curbed surface. A non-reactive and impermeable surface will help insure that lead-contaminated sulfuric acid will not corrode the floor and leak through into the soil and ground water. Curbing (high edges) will prevent leaks or spills from running off the edge.
• Coat asphalt or concrete storage surfaces with an acid-resistant epoxy, fiberglass or plastic coating.
• A wooden frame lined with heavy polyethylene (20 to 40 mil thick) may also be used to store batteries. Check it regularly for cracks or tears. Another option is to use large polyethylene fish totes without drains to store the batteries.
• To avoid releases of lead contaminated acid, make sure that there are no floor drains which lead outdoors or which connect to sewer systems, storm drains, or septic tanks.

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.

Stacking and Packaging Batteries. Package lead-acid batteries in accordance with federal DOT regulations and/or get assistance from a battery specialist who is shipping spent batteries out of state for recycling.

• Stack batteries pole side out to increase stack stability.
• Stack batteries in layers no more than five high.
• Place same-size batteries on pallets and separate layers with a shock-absorbing material.
• Shrink-wrap, band and properly label.
• Generally, batteries are packaged three layers high.
• Leaking batteries must be shipped in leak-proof containers, separately from intact batteries.

Disposal. You cannot dispose of lead-acid batteries in landfills, nor incinerate them. You may only send lead-acid batteries to a lead-acid battery retailer or wholesaler, a permitted secondary lead smelter, or a collection or recycling facility authorized by the federal Environmental Protection Agency or the state.

You should transport spent batteries to battery retailers on a monthly basis. Battery handlers should arrange for shipping at least once every six months, depending on the volume accumulated.

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. Here are some tips to prevent releases:

• Avoid stockpiling spent lead-acid batteries.
• Store batteries upright to protect against acid leaks through vent holes.
• Inspect batteries weekly for cracks or leaks. Keep a log of your inspections. If batteries have been exposed to freezing temperatures, inspect them more often.
• Place cracked or leaking batteries in an acid-resistant, leak-proof container such as a sturdy plastic tote.

Links to the Regulations. Use the following links to view the regulations pertaining to battery management.

District of Columbia's Hazardous Waste Management Requirements: Copies of the DC Hazardous Waste Management Regulations are available from the Department for a small fee to cover the cost of copying. For more information, contact the Hazardous Waste Division at 202-535-2290.

Federal EPA Standards Applicable to Generators of Hazardous Waste

Self-Audit Checklist

1. All battery handlers are required to manage the batteries and other solid waste generated from battery activities according to specific parameters and procedures. If so, ensure that batteries are stored on a non-reactive, impermeable and curbed surface. Coat asphalt or concrete storage surfaces with an acid-resistant epoxy, fiberglass or plastic coating. To avoid releases of lead contaminated acid, make sure that there are no floor drains which lead outdoors or which connect to sewer systems, storm drains, or septic tanks. Keep a log of your weekly inspections when you check for leaks or cracks. Keep cracked or leaking batteries in closed containers that are acid-resistant and leak proof, away from non-leaking batteries. Contain and neutralize all spills. Ensure outdoor battery storage is designed so no weather elements can get in.

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.

• It is preferable that you store the batteries inside a well-ventilated area, on pallets and in an organized manner.
• Neutralize small spills with common baking soda, lime or cement. Wear eye protection and gloves. Contain the spill and manage it as hazardous waste.
• Use a wooden frame lined with heavy polypropylene or a small plastic swimming pool to store batteries. Check frequently for cracks or tears.
• If batteries are stored over asphalt or concrete, coat these surfaces with acid-resistant epoxy, fiberglass, plastic coating, or a polypropylene liner.
• Store leaking or cracked batteries in sealed, five-gallon plastic pails.
• Store batteries in an upright position to prevent leakage from vent holes.
• Do not stack batteries more than three high.
• When transporting lead-acid batteries, they should be loaded to prevent them from short-circuiting, becoming damaged or leaking acid.
• Accumulate as few lead-acid batteries as possible.
• Ensure that you send your lead-acid batteries to permitted recyclers, brokers or other allowable facilities.
• Before you start collecting lead-acid batteries, arrange and know where they will be ultimately sent.
• Make sure you are in compliance will all local and fire department laws, as they may have restrictions on battery storage.
• Never drain the acid from the battery.
• Ensure that your employees are trained how to handle lead-acid batteries, specifically leaking batteries.
• Always use eye protection and gloves when handling lead-acid batteries.
• Always wash your hands after handling lead-acid batteries.

Contacts

1. For more information, contact the District of Columbia Department of Health, Hazardous Waste Division at (202) 535-2270.
2. For reportable spills or leaks, call the DC Emergency Management Agency's 24-hour communications hotline at 202-727-6161, or the non-emergency number at 202-673-3331. If a spill requires contact to a federal agency, the person required to give the notice would, at the same time, be required to give telephonic notice to the DC Emergency Management Agency and the Department of Health, Hazardous Waste Division.
3. To report an environmental incident or complaint, contact the Environmental Health Administration.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

None.

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