ECAR Fact Sheet for Vermont
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.

You may choose to manage your spent lead-acid batteries under the "Universal Waste" rule, which is a special EPA designation. 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.

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

Vermont's Universal Waste Regulations

Federal EPA Standards for Universal Waste Management

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. 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.
2. If the facility is a LQHUW, they are required to have an EPA Identification Number. Verify that the facility has an EPA Identification Number.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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.
• 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.
• Place cracked or leaking batteries in a closed, watertight, acid resistant storage container.

Contacts

1. For more information, contact the Vermont Department of Environmental Conservation, Waste Management Division at 802-241-3888.
2. To report a spill or leak, call the Vermont Division of Waste Management at 802-241-3888 (weekdays), the 24-hour spill reporting hotline at 800-641-5005, or the National Response Center at 800-424-8802.
3. To report an environmental incident or complaint, call 802-241-3820, or contact the nearest regional enforcement officer.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Vermont - Environmental Assistance Division Lead-Acid Battery Guidance

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