ECAR
Fact Sheet for Texas
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
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. Because exposure to lead in the environment can pose a serious
health hazard, used lead-acid batteries are hazardous and they have
to be handled according to special rules. However, since they
are very common items, and because they can be handled as self-contained
units, they have been given a special designation, called "universal
wastes. " By properly recycling your used lead-acid batteries,
you can get something of a break from the otherwise very demanding
rules that apply to most hazardous wastes. 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
Regulations
Some hazardous wastes are so common,
they're practically universal. They're what state and federal environmental
rules call "universal waste." The good news is that most of these
wastes are easily recycled. And by managing an otherwise hazardous
waste as a universal waste, businesses can streamline their hazardous
waste reporting and manifesting requirements. 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 that categorize these
used lead-acid batteries as "universal wastes" can avoid several
regulatory hurdles and expenses:
- You don't need to register with
the TCEQ if you generate or handle only universal waste.
- You don't need to include universal
waste when you figure your hazardous waste generator status.
- You don't have to identify universal
waste on your facility's Notice of Registration (NOR).
- You don't have to report universal
waste on your Annual Waste Summary.
- You can accumulate universal waste
for up to one year before sending it for disposal.
- You don't need a manifest when
shipping your universal waste in Texas.
- You don't need to use a registered
waste hauler to transport your universal waste.
- You don't need to pay a hazardous
waste generation fee.
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 stormdrains.
Remember: universal waste is still hazardous waste and may not
be disposed of in the garbage.
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.
Transportation. A transporter
of universal waste is not required to get an identification number
or required to obtain a hazardous waste transporter permit. 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. A transporter of
universal waste is required to deliver the shipment to a universal
waste handler, destination facility, or foreign destination.
Links to the Regulations. Use
the following links to view the regulations pertaining to battery
management.
Texas
Administrative Code (TAC) Universal Waste Rule
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.
- 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.
- 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).
- Verify where your waste batteries
are being shipped. A transporter of universal waste is required
to deliver the shipment to a universal waste handler, destination
facility, or foreign destination.
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
- For more information on Universal
Waste management, contact TCEQ's Waste Permits Division at 512-239-6412.
- For general questions, contact the
TCEQ Regional
Office nearest you.
- To report a spill/release or other
pollution emergencies, contact the Emergency 24-hour Hotline at
1-800-832-8224.
- To report an environmental incident
or complaint, contact 1-888-777-3186.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
None.
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