Household Hazardous Waste Exclusion Household hazardous waste is excluded from the definition of hazardous waste under 40 CFR 261.4(b)(1). While waste, including batteries, generated by routine household activities is exempt from regulation as hazardous waste under this section, most industrial, commercial, and office facility waste does not meet this criteria. Facilities generating hazardous waste, including batteries, from areas such as bunkhouses may be able to utilize this exemption. However, in all cases EPA recommends that batteries be managed and disposed of in a manner that protects workers, prevents damage to the batteries, and minimizes the risk of fire. Lithium-Ion Battery Hot Topics More on Lithium-Ion Thermal Runaway Events Thermal runaway events occur when damage, short-circuiting, and other conditions cause a lithium-ion battery to have an uncontrollable exothermic reaction. Thermal runaway causes extreme temperatures and fires in lithium-ion batteries and are a key driver for the proposed new category of universal waste for lithium batteries. If a facility is storing many lithium-ion batteries together, there is the risk of a thermal event propagating to the other batteries and causing a very large fire event. In its May 24, 2023 memo “Lithium Battery Recycling Regulatory Status and Frequently Asked Questions”, EPA provided recommendations for safely managing end-of-life lithium batteries and preventing runaway events. Recommended practices include: f Storing lithium batteries away from flammable materials and occupied spaces and in spaces with good ventilation and climate control; f Developing emergency procedures and coordinating with local fire marshals (e.g., through Tier II reporting and fire marshal inspections); f Installing fire detection and suppression systems; and f Implementing proactive employee training and battery inspection procedures. Routine inspections of lithium-ion storage areas should include visual examination of the area for smoke, fire, and fumes (e.g., electrolyte venting). Temperature monitoring and inspection using thermal imaging can also help detect potential runaway events. If a thermal runaway event occurs, water and fire suppressant used to extinguish lithium-ion battery fires may contain solvents from the battery electrolyte and metals. Wastewater generated must be analyzed to confirm that it can be discharged under the facility’s National Pollutant Discharge Elimination System (NPDES) or pre-
treatment permit or collected as waste and assessed for hazardous waste characteristics (e.g., toxicity). If a runaway event occurs outside, a facility should consult the state and federal spill reporting requirements to determine if the water and or fire suppressant used to extinguish the runaway event should be reported. Managing Damaged Lithium-Ion Batteries Damaged, defective, or recalled (DDR) lithium-ion batteries may be managed as universal waste if the damage has not breached individual cell casings. DDR batteries with damaged individual cell casings must be managed as hazardous waste. DDR batteries are more likely to have runaway events and should be stored separately in a non-flammable material (e.g., sand). DDR batteries may not be shipped by air and must be packaged in accordance with US Department of Transportation (DOT) regulations in 40 CFR 173.185(f). While EPA and state agencies may use the term “DDR” to provide guidance and safety information to generators of waste batteries, note that “DDR” is a DOT term rather than a term found in the RCRA regulations. As alluded to in the DOT section below, RCRA hazardous waste and DOT hazardous materials regulations have independent requirements and must both be considered in managing compliance with end-of-life battery requirements. The Rise of Treatment and Recycling of Lithium-Ion Batteries Recycling of lithium-ion batteries has become increasingly important as the demand for electric cars and consumer electronic devices rise and more critical resources, such as lithium, nickel, and cobalt, are required. Batteries and devices containing batteries are often collected, sorted, and shipped by retailers, e-waste collectors, information technology vendors, and car mechanics. Universal waste handlers are facilities that generate and/or accept universal waste and accumulate it in accordance with 40 CFR 273 Subpart B or C. Universal waste handlers are classified as small or large quantity handlers depending on the maximum quantity of universal waste accumulated at any time. Universal waste handlers are not permitted to transport, dispose, or treat universal waste except as provided in Subparts B and C. Universal waste handlers may remove and sort batteries, discharge electric charge from batteries, and remove and regenerate electrolyte in batteries. Outside of these activities, universal waste handlers are not permitted to open or breach battery cells. Facilities that open or breach battery cells must be permitted treatment, storage, and disposal facilities (TSDFs) or hazardous waste recycling facilities. These facilities are subject to separate requirements under 40 CFR 264 and 40 CFR 261.6(c)(2), respectively. Facilities that open or breach battery cells include battery recyclers and shredders.
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