ECAR Fact Sheet for Rhode Island
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.

The Rhode Island Department of Environmental Management (DEM) has prepared a guidance document to help auto recyclers lead-acid batteries. Much of the information is included in the fact sheet below. You can access the DEM's Universal Waste Rule fact sheet under “Other Relevant Resources.”

This fact sheet will give you a list of components to watch out for, as well as specific instructions on what to do with them.

Regulations

In the State of Rhode Island, any battery which is considered a hazardous waste must be managed as a universal waste. This is a special EPA designation that the DEM has adopted. These universal waste regulations are designed to encourage recycling of certain specific wastes. These rules are less demanding than the hazardous waste rules. What this means is if a waste has at least one hazardous waste characteristic, it must be managed as a universal waste if it is not managed as a hazardous waste.

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.

Lead-Acid Battery Management: You must manage lead-acid batteries in a

way that prevents releases to the environment. You must contain any waste battery that shows evidence of leakage, spillage or damage. However, you may conduct the following activities as long as the casing of each individual battery cell is not breached and remains intact and closed (except that cells may be opened to remove electrolyte but must be immediately closed after removal):

• Sorting batteries by type;
• Mixing battery types in one container;
• Discharging batteries so as to remove the electric charge;
• Regenerating used batteries;
• Disassembling batteries or battery packs into individual batteries or cells;
• Removing batteries from consumer products; or
• Removing electrolyte from batteries. Note that if the electrolyte is removed, the handler must determine whether or not it exhibits a characteristic of hazardous waste and must manage it as such if it does.

There are two groups of universal waste 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. A SQHUW is not required to notify DEM and EPA of its universal waste handling activities, and is not required to keep records of shipments of universal waste.
• 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. A LQHUW must submit written notification of universal waste management to DEM and obtain an EPA identification number prior to accumulating these amounts. Note that if the entity already has an EPA identification number, this notification is not required. A LQHUW must also keep a record of each shipment of universal waste to and from the facility

Prohibitions. You must notdispose of lead-acid batteries in the regular solid waste stream, dilute or treat it, or intentionally break it or crush it.

Accumulation Time Periods. Do not accumulate lead-acid batteries for no longer than one year from the date the waste is generated or received from others. But, you may accumulate lead-acid batteries for longer periods of time, provided that such storage is solely for the purpose of accumulation to facilitate proper recovery, treatment or disposal, and you can prove this purpose. If you accumulate waste, you must demonstrate accumulation time by:

• Placing the batteries in a container and marking or labeling the container with the earliest date that any battery in the container became a waste or was received;
• Marking or labeling the individual battery with the date it became a waste or was received;
• Maintaining an inventory system on-site that identifies the date the batteries being accumulated became a waste or was received;
• Maintaining an inventory system on-site that identifies the earliest date that any battery in a group of universal waste items or a group of containers of universal waste became a waste or was received;
• Placing the battery in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or
• Any other method which clearly demonstrates the length of time that the battery has been accumulated from the date it becomes a waste or is received.

Labeling and Marking. Small and large quantity handlers of universal waste must label each universal waste item or each container of universal waste items with the words “Universal Waste” and the identity of the waste, e.g. "Universal Waste -- Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)."

You must also satisfy US DOT packaging, labeling, marking, placarding, and shipping paper requirements for any universal waste that is a US DOT hazardous material prior to offsite shipment,

Response to Releases. Should your lead-acid batteries leak or spill, or if there is unintentional breakage of significant numbers of batteries, you must manage the released material as hazardous waste if it has hazardous waste characteristics.

Transportation.You are allowed to self transport lead-acid batteries, but there are specific requirements for transporters. If you use a transporter, they must be properly licensed to remove your waste.

Employee Training. You must train employees on proper waste handling and emergency procedures.

Links to the Regulations. Use the following links to view the regulations pertaining to mercury.

Rhode Island's Universal Waste Management Requirements

Federal EPA 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 mercury management program.

1. Are you properly managing your lead-acid batteries? You must manage your wastes in way that prevents releases of any waste or component of universal waste to the environment. You must also contain any universal waste item that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container.
2. Are you properly disposing of your lead-acid batteries? Do not dispose of a batteries in the regular solid waste stream, dilute or treat it, or intentionally break or crush it.
3. Are you complying with required accumulation times for lead-acid batteries? Do not accumulate batteries for more than one year from the date the universal waste is generated or received from others, unless you can prove that such storage is solely for the purpose of accumulation to facilitate proper recovery, treatment or disposal.
4. Are you properly labeling your lead-acid batteries? You must label each universal waste item or each container of universal waste items with the words “Universal Waste” and the identity of the waste, e.g. "Universal Waste -- Battery(ies)," or "Waste Battery(ies)," or "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.

• Use an authorized recycler.
• Indoor storage is recommended for lead-acid batteries.
• Store batteries on an acid resistant rack or tub.
• 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.

Contacts

1. For more information, contact the Rhode Island
2. To report a spill or leak, immediately call the DEM at 401-222-1360 or, if after hours, call the
   24-hour emergency number at 401-222-3070.
3. To report an environmental incident or complaint, contact the DEM Offices.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Rhode Island Universal Waste Fact Sheet
2. Rhode Island - Permitted Hazardous Waste Transporter List
3. Rhode Island Mercury Recyclers
4. Rhode Island's Hazardous Waste Compliance Workbook for Generators

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