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1 Battery Disposal July TI#13300 Introduction Types of Batteries Federal Hazardous Waste Requirements State Hazardous Waste Requirements Federal Hazardous Waste Determinations Battery Recycling Companies Sound Management Practices General Battery Storage Requirements Definitions References Introduction This fact sheet is intended for users of various types of batteries. It provides general information on proper handling, disposition and disposal, and Environmental Protection Agency (EPA) regulations regarding battery hazardous waste determinations and recycling. Types of Batteries Batteries come in different configurations, sizes, and voltages. The specific constituents of each battery type influence the requirements for final disposition. The following descriptions provide an overview of the major battery types. Alkaline Batteries Alkaline batteries are primary or non-rechargeable batteries. The positive pole (anode) of the battery contains zinc, while the negative pole (cathode) contains manganese dioxide. The electrolyte used in alkaline batteries is either potassium hydroxide or sodium hydroxide. Both are strong alkalis. If alkaline batteries are damaged or mishandled, the alkali electrolyte may leak out of the battery cell. Severe chemical burns can result if the electrolyte comes into contact with the skin or eyes. Carbon-Zinc (LeClanche) Batteries Carbon zinc batteries are also primary or non-rechargeable batteries. The anode contains zinc and the cathode contains manganese. The electrolyte is an aqueous solution of ammonium chloride and zinc chloride. Ammonium chloride is a severe eye irritant and zinc chloride is a corrosive material. Depleted batteries may continue to vent hydrogen gas after use or if stored above 130 degrees Fahrenheit. Lead-Acid Batteries Lead-acid batteries have a lead anode, a lead dioxide cathode, and an aqueous sulfuric acid electrolyte. The battery cell contains 60 to 75 percent lead and lead oxide, by weight, and the electrolyte contains between 28 and 51 percent sulfuric acid, by weight. The electrolyte is a strong oxidizing agent and can cause severe skin burns or irritation upon contact. If acid contacts eyes, it can cause severe damage and/or blindness. Contact lenses and smoking should be prohibited in areas where lead-acid batteries are stored or handled. 1 of 6 6/3/99 2:58 PM

2 Lithium Batteries Lithium battery types include lithium-manganese dioxide, lithium-sulfur dioxide, and lithium-thionyl chloride. The anode is composed of lithium and the cathode is composed of manganese dioxide (or sulfur dioxide, or thionyl chloride). The electrolyte of the lithium-manganese dioxide battery is composed of an organic solvent (propylene carbonate and 1,2 dimethoxyethane) solution of lithium perchlorate. In the case of lithium-sulfur dioxide, the electrolyte is also an organic solvent (acetonitrile) solution with lithium bromide. Lithium-thionyl chloride batteries have a non-aqueous thionyl chloride solution containing lithium aluminum chloride. Lithium-sulfur dioxide batteries contain pressurized sulfur dioxide gas and lithium-thionyl chloride batteries contain liquid thionyl chloride which vaporizes upon exposure to air, both of which are highly toxic. Magnesium Batteries Magnesium batteries have a magnesium anode, manganese dioxide cathode, and an electrolyte of an aqueous solution of magnesium bromide or magnesium perchlorate. These chemicals can emit highly toxic fumes when heated. If batteries show signs of leakage, proper eye and skin protection is recommended during handling. Mercury Batteries Mercury batteries have a zinc anode, mercuric oxide cathode, and an electrolyte of an aqueous solution of potassium hydroxide or sodium hydroxide. The cell has a solid cathode of mercuric oxide and contains 20 to 50 percent mercury or mercuric oxide, by weight. The battery cell contains a caustic electrolyte and can have the same adverse health effects as alkaline batteries. Nickel-Cadmium Batteries Nickel-cadmium (ni-cad) batteries have a cadmium anode, nickel oxyhydroxide cathode, and an electrolyte of an aqueous solution of potassium hydroxide. The battery cells typically contain percent cadmium and percent nickel, by weight. The electrolyte is a caustic solution and is capable of causing the same health effects as alkaline batteries addressed above. Silver Batteries Silver batteries have a zinc anode, silver chloride cathode, and an electrolyte of an aqueous solution of lithium chloride or zinc chloride and zinc sulfate. The electrolyte is a mild acid (20 to 30 percent by weight) and can cause serious chemical burns to the skin and/or eyes. Thermal Batteries Thermal batteries have a calcium anode, calcium chromate cathode, and a solid lithium chloride and potassium chloride electrolyte which are strong oxidizers or caustics capable of causing skin irritation. These batteries may also contain asbestos. If batteries show signs of leakage, proper eye and skin protection is recommended during handling. The battery manufacturer's Material Safety Data Sheet should always be reviewed for specific environmental and health hazards for the actual battery being used. Federal Hazardous Waste Requirements As a generator of a solid waste, the generator is required to make a determination as to whether the solid waste is a hazardous waste. This may be accomplished by applying user knowledge or testing the waste. Typically, hazardous waste classification is based upon the Resource Conservation and Recovery Act (RCRA) Characteristics of Hazardous Waste. Title 40 Code of Federal Regulations (CFR) Part 261, "Identification and Listing of Hazardous Waste," addresses the four hazardous waste characteristics: ignitability; corrosivity; reactivity; and toxicity. A waste is considered a hazardous waste if it exhibits any one or more of these characteristics. The following criteria are used to make these determinations: Ignitability A solid waste exhibits the characteristic of ignitability (Environmental Protection Agency (EPA) Hazardous Waste Number D001) if a representative sample of the waste has any of the following properties: 2 of 6 6/3/99 2:58 PM

3 It is a liquid and has a flash point of less than 140 degrees Fahrenheit; It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture, or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard; It is an ignitable compressed gas (as defined in Title 40 CFR ); or It is an oxidizer (as defined in Title 49 CFR ). Corrosivity A solid waste exhibits the characteristic of corrosivity (EPA Hazardous Waste Number D002) if a representative sample of the waste is aqueous and has a ph less than or equal to 2 or greater than or equal to 12.5 Reactivity A solid waste exhibits the characteristic of reactivity (EPA Hazardous Waste Number D003) if a representative sample of the waste has any of the following properties: It is normally unstable and readily undergoes violent changes without detonating; It reacts violently with water; It forms potentially explosive mixtures with water; When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment; It is a cyanide or sulfide bearing waste which, when exposed to ph conditions between 2 and 12.5, can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment; or It is capable of detonation or explosive decomposition or reaction at standard temperature and pressure. Toxicity A solid waste exhibits the characteristic of toxicity if, using the Toxicity Characteristic Leaching Procedure (TCLP), the extract from a representative sample of the waste contains any of the contaminants equal to or greater than the concentrations listed below: Contaminant Concentration (milligrams per liter) EPA Hazardous Waste Number Cadmium 1.0 mg/l D006 Chromium 5.0 mg/l D007 Lead 5.0 mg/l D008 Mercury 0.2 mg/l D009 Silver 5.0 mg/l D011 Note: Only the contaminants of interest in batteries are listed in the above table. State Hazardous Waste Requirements All but four states (Alaska, Hawaii, Iowa, and Wyoming) are authorized by the EPA to administer their own hazardous waste programs. As a result, these states have promulgated hazardous waste regulations that may be more stringent than the Federal regulations. For example, California regulates zinc, a component of alkaline batteries, under the Toxicity characteristic. Both Washington and California hazardous waste regulations include bioassay characterization criteria. Bioassay characterization is a method of determining the potential toxicity of a material by observing its effect on the growth of a suitable animal, plant, or microorganism under controlled conditions. Under this waste criteria, alkaline and carbon-zinc batteries may be considered a state-regulated hazardous waste. Therefore, the generator must ensure he applies the most stringent regulations when considering hazardous waste disposal. Federal Hazardous Waste Determinations Batteries (except lead-acid batteries) are not specifically regulated under Federal RCRA regulations. However, many batteries may exhibit one or more of the characteristics of a hazardous waste and require management as 3 of 6 6/3/99 2:58 PM

4 such. The following information is provided to assist you in making the proper waste determinations: Alkaline Batteries: Alkaline batteries are not considered a RCRA-regulated hazardous waste. The electrolyte of an alkaline battery does not meet the definition of an aqueous solution or free liquid; therefore, they are not, by definition, a corrosive waste. However, aquatic bioassay analysis conducted (Martin Mariettta, 1992) to further characterize the toxicity of the battery leachates indicates alkaline batteries would be classified as hazardous waste in those states which use bioassay characterization criteria. Your state regulatory authorities should be contacted to obtain a current interpretation. Carbon-Zinc Batteries: Carbon-zinc batteries are not considered a RCRA-regulated hazardous waste. As with alkaline batteries, these batteries may be subject to state-regulation as a result of bioassay characterization criteria. Lead-Acid Batteries: Lead-acid batteries destined for disposal are considered a RCRA-regulated hazardous waste due to their lead content (EPA Hazardous Waste Number D008). Lithium Batteries: Lithium batteries are subdivided into the following categories: Lithium-manganese dioxide batteries are non-hazardous solid wastes; Lithium-sulfur dioxide batteries (single-cell) are non-hazardous solid wastes; Lithium-sulfur dioxide batteries (multi-cell) may be non-hazardous solid waste or characteristic hazardous wastes. If equipped with a Complete Discharge Device (CDD), the batteries are considered a non-hazardous solid waste after discharging. If not equipped with a CDD, multi-cell lithium-sulfur dioxide batteries are characteristic hazardous wastes due to ignitiability (D001) and reactivity (D003). Lithium-thionyl chloride batteries (multi-cell) are characteristic hazardous wastes. If these batteries have a CDD, after discharge, these batteries are a characteristic hazardous waste due to toxicity (chromium, D007). Batteries without a CDD are considered a characteristic hazardous waste due to toxicity (chromium D007), ignitability (D001), and reactivity (D003). Magnesium Batteries: Batteries with 50 percent or greater remaining charge are considered a RCRA-regulated hazardous waste due to the characteristic of toxicity (chromium, EPA Hazardous Waste Number D007). Batteries with less remaining charge are not considered RCRA-regulated hazardous waste. In some cases, the charge may be determined using a Battery Test Set. In those cases where the charge cannot be determined, the batteries should be disposed of as a characteristic hazardous waste. Mercury Batteries: Mercury batteries are considered a RCRA-regulated hazardous waste due to the characteristic of toxicity (mercury, EPA Hazardous Waste Number D009). Ni-Cad Batteries: Ni-cad batteries are considered a RCRA-regulated hazardous waste due to the characteristic of toxicity (cadmium, EPA Hazardous Waste Number D006). Silver Batteries: Silver batteries are considered a RCRA-regulated hazardous waste due to the characteristic of toxicity (silver, EPA Hazardous Waste Number D011, and mercury, EPA Hazardous Waste Number D009). Thermal Batteries: Thermal batteries are considered a RCRA-regulated hazardous waste due to the characteristic of toxicity (chromium, EPA Hazardous Waste Number D007). Regulatory Exemptions RCRA either reduces the regulatory requirements or exempts certain spent solid wastes from regulation if the materials are recycled by use, reuse, or reclamation. In regards to batteries, the following batteries or recycling methods are exempt: Spent lead-acid batteries that are being reclaimed; Batteries from which precious metals are reclaimed (silver, under the Precious Metals Program); batteries returned to the manufacturer for regeneration; or Batteries managed as universal waste. The EPA has promulgated universal waste rules designed to reduce the regulatory burden and encourage recycling of certain common wastes. These regulations are codified in Title 40 Code of Federal Regulations Part 273, 4 of 6 6/3/99 2:58 PM

5 "Standards for Universal Waste Management" and are applicable in only four states (Alaska, Hawaii, Iowa, and Wyoming). Currently, this regulation applies to all types of batteries, except lead-acid batteries. Lead-acid batteries are typically managed under Title 40 Code of Federal regulations Part 266, Subpart G, "Spent Lead-Acid Batteries Being Reclaimed." Further, under EPA Universal Waste regulations, each state can develop its own listing (and associated regulations) for the management of universal wastes. Coordination with your state regulatory agency is recommended to determine specific disposition and disposal requirements. Additional in formation on the Universal Waste Rule is contained in the PRO-ACT Fact Sheet, "Universal Waste Rule," August Additional regulatory relief may also result from a recent Public Law (PL ), "Mercury-Containing and Rechargeable Battery Management Act," 13 May The purpose of this law is to: Phase out the use of mercury-containing batteries; Provide for the efficient and cost-effective collection and recycling of batteries (lead and cadmium-containing batteries); and Implement a national, uniform system for labeling batteries. According to the RCRA Hotline, the EPA has not codified any regulations pertaining to the above law, nor is there any estimated date as to when they will. The typical approach is for the EPA to publish a proposed rule regarding implementing regulations and allow for a comment period. At the conclusion of the comment period, the EPA will review the comments received and publish a final rule promulgating the implementing regulations. Battery Recycling Companies Many batteries can be recycled rather than disposed of as either a solid or hazardous waste. The following is a partial listing of battery recycling companies: Mercury Refining Company (MERCO), (800) They accept mercury, silver, and carbon-zinc batteries for recycling. They also have agreements with battery recyclers who can process ni-cad and lithium batteries. Rechargeable Battery Recycling Corporation (RBRC), (540) They have a contract with the International Metals Reclamation Company Incorporated to recycle ni-cad batteries. Battery Conservation Technologies, Incorporated, (915) They will recycle alkaline, carbon-zinc, mercury, silver, ni-cad, and lead-acid batteries. Sound Management Practices PRO-ACT suggests coordinating with the following installation organizations prior to disposing or recycling used batteries: The installation Environmental Management Office to ensure conformance with environmental regulations; The installation Transportation Office to ensure conformance with transportation regulations; The servicing DRMO to ensure conformance with DoD polices; and, The base Safety and Bioenvironmental Engineering offices to ensure proper personal protective equipment is available for safe handling. General Battery Storage Requirements Batteries require some care to ensure proper and safe storage. The following suggestions are offered: Batteries require cool, well ventilated, dry storage areas. Temperatures should not exceed 130 degrees Fahrenheit. Protect batteries against being damaged, crushed, punctured, or short-circuited. Do not smoke or eat in battery storage areas. Store batteries separately from other hazardous material. 5 of 6 6/3/99 2:58 PM

6 Definitions The following definitions will assist you in understanding battery terminology and making proper waste determinations: Anode: The terminal of a battery or cell that releases electrons during the production of any external current; the negative terminal of a primary cell or battery. Battery: Technically, a combination of two or more cells electrically connected to transform chemical energy into electrical energy. In everyday usage, a single cell such as the one found in a flashlight is also referred to as a battery. Cathode: The terminal of a battery or cell that accepts electrons during the production of an electric current; the positive terminal of a primary cell or battery. Cell: A device, which generates electricity, consisting of two different substances placed in an electrolyte. Dry Cell: A cell, in which the electrolyte exists in a paste and is absorbed in a porous medium, or is otherwise restrained from flowing. Electrolyte: The conducting medium for the flow of current in a cell. Non-Rechargeable: A characteristic of a primary battery that can convert chemical energy into electrical energy irreversibly. Primary Battery: One that can convert chemical energy into electrical energy irreversibly. Rechargeable: A characteristic of a storage battery that can convert chemical energy into electrical energy and vice versa. Secondary battery: One that can convert chemical energy into electrical energy and vice versa. Serviceable Battery: One that can be used for its originally intended purpose. Storage battery: Same as secondary battery. Unserviceable Battery: One that is in such a condition or state that it cannot be used for its originally intended purpose. Wet Cell: A cell whose electrolyte is in liquid form and free to flow. References 1. "Battery Disposition and Disposal," Headquarters, Department of the Army, Technical Bulletin TB , 1 October "Environmental Compliance for the DRMS Hazardous Property Program," Chapter 21, "Batteries," Defense Reutilization and Marketing Service, DRMS-M 6050, October "Environmental Compliance for the DRMS Hazardous Property Program," Chapter 32, "Universal Waste Management Standards," Defense Reutilization and Marketing Service, DRMS-M 6050, October "Mercury-Containing and Rechargeable Battery Management Act," Public Law , 13 May PRO-ACT PRO-ACT Home CrossTalk Fact Sheets Technical Inquiries Research Services Search PRO-ACT 6 of 6 6/3/99 2:58 PM