tinned State*
Environmental Protection
Agency
Office ol
Solid Waste and
Emergency Response
vxEPA
DIRECTIVE NUMBER: 9443.05(83)
TITLE: Hazardous Waste Identification Regulations as
They Apply to Waste Batteries and Cells
APPROVAL DATE: 7-27-83
EFFECTIVE DATE: 7-27-83
ORIGINATING OFFICE: office of Solid waste
0 FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D 8 — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
>WER OSWER OSWER
DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.05(83)
Key Words: Batteries, EP Toxlcity Test
Regulations: 40 CFR 261.24
Subject:
Hazardous Waste Identification Regulations as They Apply to
Waste Batteries and Cells
Addressee:
Leroy J. Wilder, Jr.
Wisconsin 53711
Jay-0-Vac, 630 Forward Drive, Madison,
Originator: David Friedman, Manager, Waste Analysis Program
Source Doc: //9443.05(83)
Date: 7-27-83
Summary:
Most common batteries and cells rapidly degrade when placed in a landfill.
Thus, when testing such products to determine if they exhibit the Extraction
Procedure Toxicity Characteristic (§261.24) they should be cut up into small
pieces. If, after such preparation, none of the concentration levels in Table 1
of that section are exceeded, the batteries are not hazardous wastes and may be
disposed of in a sanitary landfill. Batteries that yield extracts exceeding any
of the thresholds in Table J are hazardous and must be disposed of in a RCRA
permitted facility.
Those batteries and cells which are manufactured in such a manner as to
prevent disintegration after disposal may be tested (pending development of other
tests) by using a salt water solution. If, after submersion for one month in
such a solution, no leakage occurs, the product can be considered to be corrosion
resistent. If the package is also structurally resistent to crushing, it can be
evaluated in the EP Toxicity Test without being cut up.
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9443.05(83)
RSt NCMIA340r
Mr. Leroy j. wilder, Jr. * -
Ray-O-Vac
630 Forward Drive
Had!son, NX 53711
Dear Mr. Nilders
X an writing in response to your July 14, 1983 request for
clarification of the Resource Conservation and Recovery Act (RCRA)
hazardous waste identification regulations as they apply to waste
batteries and cells.
As we discussed in our telephone conversation on July 7, 1983,
•ost common batteries and cells rapidly degrade when placed in a
landfill. Thus, when testing such products to determine If they.
exhibit the Extraction Procedure Toxicity characteristic (40 CFR
261.24) the batteties and cells should be cut up into small pieces
(i.e., to pass 1 era sieve). If, after such preparation, none of
the concentrations listed in 40 CPR 261.24 Table 1 are exceeded
the batteries are not hazardous wastes and may be disposed of In
a sanitary landfill. Batteries that yield extracts exceeding one
or more thresholds are hazardous wastes and nust be disposed of
in a RCRA permitted facility.
Certain batteries and cells, however, are manufactured in
such a manner as to prevent disintegration after disposal. Such
products may be tested without being cut up. At this tine,
we have not developed testing thresholds for identifying such abuse
resistant products. Pending development of such tests you may
evaluate the corrosion resistance of your products using a aalt
water solution* If after submersion for 1 month in a salt water
solution no leakage occurs, the product can be considered to
be corrosion resistant. If the package is also structurally
resistant to crushing, it can be evaluated in the EP Toxicity
test without being cut up.
,. ,.- X.trust that this explanation assists you in evaluating your
wastes. I would like to also bring to your attention the fact
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that we have a toll free hotline (1-800-424-9346), if you ever
need assistance with any aspect of the RCRA regulations.
~~-- Sincerely yours.
David rriedoan
Manager
Waste Analysis Program
WH-565B/DPRIEDMAN:NA:S248:X24770:7/26/83:DISK:NA3408
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