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Update on Batteries

Update on Batteries. Bill Pollock; Alameda County HHW program bill.pollock@acgov.org. A few Flaming UPS trucks pique DOT’s Interest in battery recycling. DOT Rule Change. Special Provision 130 Published in the Federal Register (Jan 14 th HM215J & HM 224D)

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Update on Batteries

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  1. Update on Batteries Bill Pollock; Alameda County HHW program bill.pollock@acgov.org

  2. A few Flaming UPS trucks pique DOT’s Interest in battery recycling

  3. DOT Rule Change • Special Provision 130 Published in the Federal Register (Jan 14th HM215J & HM 224D) • Requires insulating all batteries to prevent short circuit • Makes no distinction between spent batteries and new batteries–does not exclude alkalines • Uniquely it regulates batteries when shipped as Universal waste

  4. DOT April 3rd 2009 letter focuses specifically on spent batteries and details DOT’s concerns about spent battery recycling and transportation. • The new rules do allow common household batteries including rechargeable NIMH and NICAD to be comingled and shipped on a bill of lading as long as SP130 is followed – (taping- or otherwise protected from short circuit

  5. DOT Enforcement • DOT visited Kinsbursky in LA, a destination facility for the BIG Green Box • DOT found numerous compliance issues with the way batteries are shipped in the Big Green Box • Northern California HHW program was issued written warning letter by the DOT

  6. Programs respond by Taping batteries Carefully stacking Eco Solutions has a clear acrylic pour in substance that will coat batteries and be acceptable to recyclers. Latex paint can be used for batteries destined for Haz Waste Landfill * Other chemicals may change hazard class for transport and disposal

  7. Various entities request relief from SP 130 for specific batteries through a DOT Interpretation letter Unlike Exemptions and Special Packing authorizations Interpretation immediately apply to anyone shipping these materials

  8. DOT Interpretation letters On DOT Website http://www.phmsa.dot.gov/hazmat/regs/interps • Interpretation # • 09-90 April 16th from Paul Johnson @ Kinsbursky • Spent 1.5 volt alkaline batteries of any form factor are not considered a hazard and are not subject to SP 130 insulating requirements • 09-150 August 13th From George Kerchner • Spent 6 volt C/ZN and 9 volt Alkaline batteries are not considered a hazard and are not subject to SP 130 insulating requirements. • 09-135 from Florida HHW program • 09-169 from Pennsylvania HHW transporter: • Reaffirms Kinsbursky letter with respect to 1.5 volt Alkalines

  9. DOT Interpretation letters continued • 09-112 June 23rd George Kerchner letter. • Government agencies transporting spent batteries from a collection site to a Government facility in a Government owned vehicle using a Government employee as driver is not considered “In Commerce “and not subject to the entire HMR including SP130. The collection site does not have to be Government facility – can be a store or commercial entity. *NOTE Using a Contractor to transport or contract personnel to drive a government vehicle puts the activity “In Commerce” HMR requirements and SP 130 will apply.

  10. T&D Vendor Requirements Destination Facility requirements

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