ECAR Fact Sheet for Michigan
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

Battery components are toxic and corrosive. Lead and sulfuric acid can contaminate the air, soil and water. Direct contact with sulfuric acid can burn the skin and eyes. This fact sheet will tell you:

• How to determine if your operation qualifies as a "universal waste handler"
• What you need to do to handle batteries in compliance with the rules that apply to you

This fact sheet does not include requirements for companies that reclaim batteries or operate a battery recycling process.

Regulations

Lead acid batteries are banned from landfills in Michigan.

In Michigan, most facilities choose to recycle lead acid batteries under a specific hazardous waste rule for this type of battery. The other choice is to handle lead acid batteries as a "universal waste."

Batteries being recycled under the hazardous waste rule are not counted when determining the facility's hazardous waste generator status. It is not necessary to use a waste manifest when shipping the batteries to a recycler but it is necessary to have shipping papers and meet other US Department of Transportation requirements for shipping hazardous materials. In addition, there isn't a time limit how long the batteries can be stored on-site before shipping.

Auto recyclers who receive, store, and send batteries off-site for recycling may choose to become an "universal waste handlers." When lead acid batteries are handled as "universal waste," the requirements will depend on the amount of all universal waste being handled on-site. 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. LQHUW are required to obtain a Michigan Site Identification Number from the Department of Environmental Quality (DEQ), Waste and Hazardous Materials Division (WHMD).

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 or seepage into groundwater. 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 being handled as universal waste (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.

Transportation. A transporter of universal waste is not required to get an identification number or required to obtain a hazardous waste transporter permit from DEQ, WHMD. A waste manifest is not required either, but a transporter must comply with all applicable US Department of Transportation (US DOT) regulations, including having the shipment properly packaged, labeled, marked, placarded, and transported with the proper shipping papers. Contact US DOT at (517) 377-1866 for more information. Discuss permitting requirements with your DEQ, WHMD District Office staff by clicking on the highlighted text for office locations and contact information.

A transporter of universal waste is required to deliver the shipment to a universal waste handler, destination facility, or foreign destination. A transporter who stores universal waste longer than 10 days, must manage the universal waste according to the applicable handler requirements ..

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

Michigan's Natural Resources and Environmental Protection (Act 451), Part 111 regarding Hazardous Waste Management and administrative rules

40 Code of Federal Regulations, Part 273- RCRA Standards for Universal Waste Management

Identification and Listing of Hazardous Waste

Part 262 - Standards Applicable to Generators of Hazardous Waste

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.

1. Are batteries being handled under the lead acid battery rule R 299.9804 or the universal waste rule? If under the battery rule, has the facility characterized the waste? Keep characterization records for at least 3 years from date of shipment. If batteries will be reclaimed by another method than regeneration (electrolyte replacement), then small quantity and large quantity generators of hazardous waste must meet the federal land disposal restrictions requirements and keep copies of the "land ban" for at least 3 years from date of shipment. Continue with audit if being managed as universal waste.
2. What is the facility's universal waste handler category (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.
3. If the facility is a LQHUW, have you obtained a Michigan Site Identification Number. Verify that the facility has a Michigan Site Identification Number.
4. 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.
5. 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.
6. 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.
7. 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.
8. 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.

• 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 closed, watertight, acid resistant storage container.
• Store batteries upright, on wooden pallets, in a secure, covered location, on a bermed impermeable surface or in watertight, acid resistant containers.
• Do not pile batteries higher than four batteries high.
• Remove other known sources of lead from vehicles when practical.
• Store lead parts in a covered container that is strong enough to hold the weight of the lead.
• Recycle lead parts with a metals or battery recycler.

Contacts

1. For more information, contact DEQ's Environmental Assistance Center at 1-800-662-9278.
2. Contact your DEQ, WHMD District Office.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Michigan Universal Waste Guidance Document
2. Recycled Materials Market Directory Miscellaneous Category for list of battery recyclers

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