ECAR Fact Sheet for Wisconsin
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

In the state of Wisconsin, lead-acid batteries are not regulated as hazardous waste as long as they are sent to a recycler and are not leaking. They are considered a "salvageable material," which is considered useful as a reprocessing material or from which replacement or spare parts can be utilized.

Automotive recyclers (generators) can accept, accumulate and ship out lead-acid batteries for recycling without having to report them to the Wisconsin Department of Natural Resources (WDNR) or to manifest the shipments. However, if you dispose of them, then you must follow the hazardous waste regulations.

Storage Requirements.

• Store lead-acid batteries on a pallet over a non-reactive, curbed, and sealed surface such as coated concrete or asphalt. A non-reactive, impermeable surface will help insure that acid and lead will not corrode or pass through the pallet and leak into the soil or groundwater. Curbing will prevent leaks and spills from running off the edge.
• Store batteries in an area with no floor drain.
• Inspect batteries weekly for cracks and leaks. Keep a log of your inspection (if batteries have been exposed to freezing temperatures, inspect them more often).
• Place cracked or leaking batteries in an acid-resistant, leak-proof, closed container, separate from non-leaking batteries. Contain and neutralize spilled acid.
• If constructing outdoor storage, design so rain, snow and draining water cannot enter.

Transporters who store lead-acid batteries must follow the same storage requirements as generators.

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.

Transporting Requirements. You may self-transport non-leaking waste lead-acid batteries, or hire a licensed solid or hazardous waste transporter. Transporters are exempt from hazardous waste licensing requirements if the lead-acid batteries are ultimately destined for recycling, transported in good condition (no cracks or leaks), and not transported with any other hazardous waste. If they are not destined for recycling, you must use a hazardous waste transporter. In addition, if you transport non-leaking lead-acid batteries to a permitted recycler, you do not require a solid waste transportation license.

Lead-acid battery transporters must have motor carrier authorization. The batteries must be transported in compliance with all state and federal Department of Transportation requirements.

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.

Wisconsin Hazardous Waste Regulations (NR 590.01-690.81)

Wisconsin Recycling Regulations - Waste lead-acid batteries destined for recycling (NR 625.12)

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. 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 over a non-reactive, curbed and sealed surface where there is no floor drain. 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 five high.
• When transporting lead-acid batteries, they should 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 Wisconsin's DNR Auto Salvage Sector Resource Specialist at 715-831-3263, or contact the WDNR Regional Office in your area. For northern Wisconsin, call 715-635-2101 or 715-365-8900; West Central Wisconsin, call 715-839-3700; Northeast Wisconsin, call 920-492-5800; Southeast Wisconsin, call 414-263-8500; and, for South Central Wisconsin, call 608-275-3266.
2. All spills should be immediately reported using Wisconsin's 24-hour toll free hotline at 800-943-0003. If you discover a discharge through analysis of soil or water, use the Hazardous Substance Release Fax Notification Form.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Wisconsin's Auto and Scrap Recycling Website
2. Wisconsin - Battery Reclaiming Facilities

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