f Key waste requirements, including proper container management and labeling and onsite accumulation time limits f Training requirements f Recordkeeping, including hazardous waste manifests and bills of lading Other Regulatory Considerations for Generator of Waste Batteries While this article focuses on regulatory requirements and best practices associated with managing end-of-life batteries under RCRA, facilities that use and dispose of batteries are subject to additional hazardous material management requirements as well. Emergency Planning and Community Right-to-Know Act In-use and waste batteries may also be subject to reporting under several sections of the Emergency Planning and Community Right-to- Know Act (EPCRA). Most notably, even a few large lead-acid batteries can trigger reporting under Section 302 Emergency Planning Notification and Sections 311 and 312 Chemical Inventory Reporting, due to sulfuric acid’s status as an Extremely Hazardous Substance (EHS). For a comprehensive catalog of chemicals subject to EPCRA reporting programs, see EPA’s List of Lists. Department of Transportation Generators of end-of-life batteries transported within the US are subject to the US Hazardous Material Regulations, including 49 CFR 173.185 for lithium batteries and 49 CFR 173.159 for lead-acid batteries. Regulatory requirements under these sections include packaging, shipping papers, labeling, and marking requirements. Waste batteries shipped internationally are also subject to International Air Transport Association (IATA) Dangerous Goods Regulations and International Maritime Dangerous Goods (IMDG) Code.
Prior to recycling, batteries are commonly shredded to separate out valuable metals and black mass. Batteries and the separated components can no longer be managed as universal waste after arriving at a TSDF or hazardous waste recycling facility and must be managed as hazardous waste. Black mass is recycled to recover metals and create new battery cathode and anode powders. Metals from black mass are recovered through pyrometallurgical (using heat) or hydrometallurgical (using solvents) recycling processes, then made into precursor cathode active materials, and then into cathode active materials for use in new lithium-ion batteries. Battery recyclers that store batteries or black mass with hazardous waste characteristics prior to recycling are required to apply for and obtain a RCRA Part B permit. Facilities subject to Part B permitting may trigger additional air emission standards in 40 CFR 264 Subparts AA and BB. Based on Trinity’s experience with permitting and supporting compliance at battery treatment and recycling facilities, the complexity of these regulations and state-specific nuances (e.g., interpretation on allowable holding times) is a key factor in strategic planning for recycling facilities, including determining how to best invest resources in new facilities, facility expansions, and new process innovations. Developing Compliant End-of-Life Battery Programs Trinity recommends developing waste management programs that outline applicable regulatory requirements and best practices. A waste management plan or written program serves as a cohesive document to define the facility’s waste management program, including how each type of waste battery generated by the facility should be managed and disposed. A written waste management plan serves several functions including identifying key regulatory requirements, supporting management of change and institutional knowledge, and improving sustainability outcomes and lowering disposal costs.
For generators of waste batteries, a waste management plan may include the following elements:
RELATED TRAINING
f Summary of applicable regulations f Sustainability goals and policies f General facility information
Introduction to Waste Management/RCRA Oct 22, 2024 Kansas City, KS Dec 10, 2024 Charlotte, NC
f Waste determination matrix documenting management method (e.g., universal waste or Subpart G) and associated requirements for each waste battery type f Hazardous waste generator and universal waste handler size determination
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