&EPA
United States
Environmental Protection
Agency
OHice of
Solid Waste ana
Emergency Response
DIRECTIVE NUMBER: 9443.01(84)
TITLE: Lithium-Sulfur Dioxide Battery, RIL
APPROVAL DATE: 3-84
EFFECTIVE DATE: 3-84
ORIGINATING OFFICE: office of Solid waste
B FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OS WER OS WER OS WER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.01(84)
Key Words:
Regulations
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Batteries
40 CFR 261.23, 264.312, 265.312
Lithium-Sulfur Dioxide Battery, RIL
Regional Branch Chiefs, Regions I-X
Transmitted to Defense Logisties Agency, DOD
Eileen Claussen, Director, Characterization and Asessment
Division
#9443.01(84)
3/ 7/84 RIL
3/22/84 Transmittal Memo to Regions
Spent or discarded lithium-sulfur dioxide batteries exhibit the charac-
teristic of reactivity as defined in 40 CFR §261.23. Therefore, users of such
batteries may no longer send regulated quantities of the batteries to either
sanitary landfills or Subtitle C land disposal facilities unless they have been
rendered non-reactive (§264.312, 265.312).
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tub tit Is C land disposal facilitiss (UssT 264.312 sad 245.312)
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.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
Mr. Dick Bruner
Executive Director
Technical and Logistics Services (DLA-S)
Defense Logistics Agency
Cameron Station
Alexandria, Virginia 22314
Dear Mr . Bruner :
This letter is in response to a number of requests made
by the Department of Defense ( DOD) for guidance from the
Environmental Protection Agency (EPA) on the regulatory status
of spent and/or discarded lithium-sulfur dioxide (Li/SO2)
batteries.
EPA recognizes that the Department of Defense has done
extensive work in assessing the hazards posed by lithium
batteries.!/ and in developing procedures for managing spent or
discarded Li/SC>2 cells. In fact, DOD currently considers
these .batteries to be hazardous wastes for management purposes.
Consequently, the purpose of this letter is simply to render
an Agency opinion as to whether lithium batteries are hazardous
wastes under the rules promulgated pursuant to the Resource
Conservation and Recovery Act of 1976 (RCRA), and to clarify
the application of those rules to the management (i .e . , disposal)
of lithium batteries.
The term 'lithium batteries' as used in this letter applies
only to those batteries or cells commonly referred to as lithium-
sulfur dioxide batteries. At: this time, EPA does not have
sufficient information to make a blanket determination as to
whether lithium batteries using other cathode materials (i .e.,
thionyl chloride (SOC12), polycarbon monofluoride ((CF)X),
manganese dioxide (Mn02), iodine (I), silver oxide (Ag20),
silver chromate (Ag2Cr04), vanadium pentoxide ^205) , iron
sulfide (FeS), copper oxide (CuO) , and lead bismuthate (Bi2Pb2C>5))
exhibit the characteristic of reactivity. Consequently, handlers
of these lithium batteries must evaluate them against the reactivity
characteristic identified in §261.23 as well as the other hazardous
waste characteristics to determine if the batteries should be
handled as hazardous wastes.
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Based on a careful review of the available data and
information, EPA has concluded that lithium-sulfur dioxide
batteries clearly exhibit the characteristic of reactivity as
defined in 40 CFR 261.23. Handlers of these wastes must,
therefore/ comply with all applicable standards under 40 CFR
Parts 262 to 266, and 124, 270, and 271. Under these standards,
the land disposal of reactive waste is prohibited unless the
waste is treated or otherwise rendered non-reactive. (See
SS264.312 and 265.312).
Under 40 CFR 261.23, a solid waste is considered to
be reactive if a representative sample of the waste has
of the following properties:
(1) It is normally unstable and readily undergoes violent
change without detonating.
(2) It reacts violently with water.
(3) It forms potentially explosive mixtures with water.
(4) 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.
(5) 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.
(6) It is capable of detonation or explosive reaction if it
is subjected to a strong initiating source or if heated under
confinement.
(7) It is readily capable of detonation or explosive
decomposition or reaction at standard temperature and pressure.
(8) It is a forbidden explosive as defined in 49 CFR 173.53
or a Class 3 explosive as defined in 49 CFR 173.88.
The lithium in Li/S02 cells will form potentially explosive
hydrogen gas when mixed with water (§261.23(a)(3)), and Li/S02
cells are capable of violent rupture or reaction if subjected to
a strong initiating source or if heated under confinement
(§261.23(a) ( 6).) . However, of primary concern is the potential,
under existing management practices, for components of the batteries
to generate toxic gases, vapors, or fumes in a quantity sufficient
to present a danger to human health or the environment when those
components are mixed with water or exposed to certain pH conditions
(S261.23(a)(4) and (a)(5)).
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A review of the existing literature clearly indicates that
Li/S02 batteries are capable of violent reaction if mishandled
by being exposed to a strong initiating source or heated under
confinement. Incidents of violent cell ruptures, particularly
of cells of the unbalanced design, have been documented in
laboratory abuse tests and under actual field conditions.
Although newer designs of Li/S02 batteries incorporate a number
of safety features that reduce their explosive potential in most
circumstances, forced discharge below zero volts, penetration,
or heating in a confined area may still cause vented batteries
to violently rupture.
*
Lithium-sulfur dioxide batteries typically contain strips
of lithium metal as the anode as well as a non-aqueous electrolyte
consisting primarily of sulfur dioxide (SC>2) and smaller concen-
trations of acetonitrile (CH3CN) and a lithium salt, typically
lithium bromide (LiBr). Lithium is known to react with water to
produce potentially explosive hydrogen gas. Although lithium
battery cells are constructed such that their reactive components
do not ordinarily come into contact with water under normal
operating conditions, if placed in a landfill/ or otherwise
improperly managed, these batteries will eventually corrode and
allow their reactive constituents to come into contact with water.
The reactive nature of lithium is of particular concern since
substantial quantities of partially discharged cells or cells of
the unbalanced, or excess lithium type, are often disposed of
together. The Agency believes that under existing management
practices, (i.e., storage in drums or disposal of batteries in
drums), potentially explosive concentrations of hydrogen gas
might reasonably be expected to occur (261.23(a)(2)).
The Agency also believes that the practice of accumulating
large quantities of Li/S02 batteries could result in concentrations
of toxic gases, vapors", or- fumes in sufficient concentration to
present a danger to human health or the environment." As mentioned
previously, newer lithium battery.cells are designed to automati-
cally vent 862 and other components to the air to minimize the
possibility of explosion due to pressure when the cells are
exposed to external heat or short.circuiting. During operations
such as collection, processing, and disposal, the batteries may
be exposed to mechanical shock, short circuiting, immersion in
water or penetration. These operations are likely to cause
cells to rupture and/or vent their reactive materials in potentially
dangerous concentrations if venting or rupture occurs in a confined
area or if significant numbers of cells are involved. Sulfur
dioxide is a strong irritant and is capable of causing incapacitation
at concentrations above 50 ppm and has proven to be life-threatening
at concentrations of 400-500 ppm. In addition, acetonitrile (CH3CN)
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will decompose to form toxic cyanide fumes when heated. Lithium
also reacts with acetonitrile to produce lithium cyanide (LiCN),
which in turn can react with weak acids to produce toxic hydrocyanic
gas. Potentially dangerous concentrations of these, as well as
other toxic fumes and vapors, may, therefore, be expected to
result if the reactive components of these batteries are exposed
to water or acidic conditions during collection, processing, or
disposal operations.
The inherently reactive nature of lithium-sulfur dioxide
batteries was, in fact, demonstrated by a fire at the Croton
Point Landfill in Westchester County, New York on April 20, 1981.
In that incident, a number of drums of lithium-sulfur dioxide
batteries, which were improperly handled, caught fire due either
to short circuiting or contact with moisture. The fire resulted
in a number of violent ruptures as well as the generation of
toxic gases and fumes which posed a hazard to personnel combating
the fire .
The Agency recognizes that the degree of hazard' posed
by lithium battery cells depends upon a large number of
variables including:
0 the quantity of cells accumulated in one location and
the condition of the cells (e.g., whether they have
vented, are partially depleted, fully discharged, of the
balanced or unbalanced type, etc.)
0 the procedures used in storing, transporting, disposing,
or otherwise handling spent or discarded batteries.
• the proximity of workers or the general public to the
batteries.
to the variable nature of the hazards posed by lithium
batteries under different conditions, the Agency had considered
whether it was feasible to establish accumulation levels below
which quantities of lithium batteries would not be considered
reactive and, therefore, not subject to the hazardous waste
regulations. However, the Agency does not believe that there
is sufficient information available at this time to reasonably
establish such exemption levels specifically for lithium batteries
The Agency's conclusion that lithium-sulfur dioxide
batteries exhibit the characteristic of reactivity does not
affect the applicability of other provisions of the hazardous
waste regulations. Of specific interest to DOD may be §261.5,
which conditionally exempts from hazardous waste regulation all
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-5-
hazardous wastes from generators that do not generate more than
1000 kg. per month of hazardous waste or accumulate more than
1000 kg. of such waste at any time.2/ However/ you should be
aware that when calculating the quantity of waste generated for
purposes of assessing small quantity generator status, all hazardous
wastes from all sources that are generated at a particular site!/
in a one-month period or which are accumulated over any period
of time must be counted. You should also be aware that Congress
is currently considering amendments to RCRA that would lower the
small quantity generator exemption level to 100 kg.
As mentioned previously, the practical effect of the
Agency's conclusion that lithium batteries are reactive wastes
is that regulated quantities of these batteries may not be
disposed of at most hazardous waste land disposal facilities.
Sections 264.312 and 265.312 prohibit landfilling of reactive
wastes unless they are treated, rendered, or mixed such that
they no longer exhibit the characteristic of reactivity and
unless the general requirements for reactive wastes contained
in §§264.17(b) and 265.17(b) have been met.
If you have any questions about the information contained
in this letter, please do not hesitate to contact either
Francine Jacoff or Robert Axelrad, of my staff at (202) 382-4761.
Sincerely yours,
/s/ Jaci W. McCraT
Lee M. Thomas
Assistant Administrator
.2/1 Acute hazardous1 wastes are subject to a 1 kg. exemption
lovel for quantities generated in a one-month period or accumu-
lated over any period of time. As a characteristic hazardous
waste, lithium batteries are subject to the 1000 kg. exemption
le ve 1.
2,/See §260.10 definitions for 'individual generation site1 and
•on-site ' .
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