v>EPA
              United States
              Environmental Protection
              Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9441.07(84)

TITLE: Exclusion of Household Wastes
               APPROVAL DATE: 4-19-84

               EFFECTIVE DATE: 4-19-84

               ORIGINATING OFFICE:

               0 FINAL
                   of Solid Waste
               D DRAFT

                STATUS:
         [  ]  A- Pending OMB approval
         {  j  B- Pending AA-OSWER approval
         [  ]  C- For review &/or comment
         [  ]  D- .In development or circulating

                       headquarters
               REFERENCE (other documents):
  OSWER      OSWER      OSWER
fE    DIRECTIVE    DIRECTIVE

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 PART 261   SUBPART A - GENERAL
                                                DOC:  9441.07(84)
 Key  Words:     Household Wastes,  Exclusion,  Batteries

 Regulations:

 Subject:       Exclusion of  Household Wastes

 Addressee:     Bonnie  Stuckey, Wesselman Park Nature Center, 551 North Boeke
               Road, Evansville,  Illinois  47711

 Originator:    John H.  Skinner, Director, Office of Solid Waste

 Suorce Doc:    #9441.07(84)
Date:
Summary:
4-19-84
     Household C and D cell batteries, most of which are of the carbon-zinc
variety, are exempted from regulation under RCRA as they do not pose a signif-
icant environmental problem.  Nickel-cadmium and mercury cell batteries,  while
more hazardous than the carbon-zinc variety, are not disposed of  in  large
quantities by homeowners -and would not result in locally large concentrations
in a landfill.

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                                                             9441.07 (84)
Miss Bonnie Stuckey
Weaselnan Park Nature Center
551 North Boeke Road
Evansville, IN 47711

Dear Hiss Stuckay :

     Thank you for your letter of March 21, 1984, in which
you request information on the proper disposal of household
batteries. ...                                    .-.-..
   , .»r-  •   ,
   .  bnder the Resource Conservation, and Recovery Act (RCRA),  ,j
EPA is responsible for establishing regulations for controlling *
the generation, transportation, storage, treatment, and
disposal of hazardous waste.  In passing RCRA, Congress .
exempted household wastes from control under the hazardous
waste regulatory progran.  Neither Congress nor the Agency
believes that requiring hone owner 3 to identify which of their
wastes nay be hazardous and to comply with the significant
regulations other hazardous waste generators must follow
would prove feasible either from an economics or enforcement
point of view.

     As a result, household C and D cell batteries are exempted
from regulation under RCRA.  The Agency does not believe that
this poses a significant environmental problem since most
household batteries are of the carbon-zinc variety„  Carbon-zinc
batteries, while disposed of by siany households, contain only  •
very small quantities of hazardous constituents and are generally
dispersed throughout a landfill.  Tt is the nickel-cadmium
and mercury batteries which are. hazardous.  Bowever, since
nickel-cadmium batteries are considerably more expensive
than most household batteries and also are rechargeable, they
are seldom disposed of in significant quantities by home owner a.
Consequently, the Agency does not believe that these batteries
pose a serious environmental hazard.  Mercury colls, while
of concern if. disposed of in large quantities (e.g., by.a
manufacturer), generally are very srcall (a .g-._, hearing aid
and watch batteries) and thus contain only very small amounts
of nercury. • These would also not be expected to result in
locally large concentrations in the landfill since household-
use of these battori.es is snail.

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                           -2-
     While the Agency certainly encourages the recycling of
        s wherover possible, we are not aware of any facilities
that recycle carbon-zinc batteries,  rtor do we currently have any
poster-a or other materials that discuss the recycling or
nroner disposal of household wastes.  However, you r.ay wish
to contact the Indiana State Board of Health since that Agency
has responsibility for the hazardous waste program in Indiana.
Their address is?

                Land Pollution Control Division
                _t.^ta Board of Health
                1330 Hast Michigan Street, Pm A-304
                Indianapolis, Indiana 46206
                (317) 631-0194

     In addition, several national organizations disseminate
information on hazardous waste recycling programs.  You
nay wish to contact the Hazardous Waste Project of Environmental
Action foundation, Dupont Circle Building, Wasnington, n.C.
20036.

     I hope this information will be of uae to you.


                               Sincerely yours,
                               John H. Skinner
                                  Director
                            Office of Solid Uaste

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