Bill Pollock; Alameda County HHW program bill.pollock@acgov.org

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

DOT Rule ChangeSpecial 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

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

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

Programs respond byTaping 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

 

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

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

DOT Interpretation letters On DOT Website

http://www.phmsa.dot.gov/hazmat/regs/interps

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.

T&D Vendor RequirementsType Clean Harbors Philip Env Veolia

1.5 Volt Alkaline

No insulation No insulation No insulation

6 & 9 Volt No insulation – Co-mingle with 1.5v ok

No insulation Co-mingle with 1.5V ok

Taped & packed separately

Destination Facility requirementsType Kinsbursky/

ToxcoAERC

1.5 Volt Alkaline

No insulation No insulation

6 & 9 Volt Alkaline

No insulationCo-mingle ok

Insulated & packed separately

Type Pack Co-mingle DOT REF

Future action?

1.5 Volt Alkalines

No insulation

09-090 None

6 & 9 Volt Alkaline

No insulation

Co-mingle with above

09-150 none

Other Alkaline 12Volt

Insulate Pack separately

Will Request DOT Interpretation

Ni Cad/Ni MH

Insulate Ni-Cad & NiMH comingled

Will Request DOT Interpretation

Li Ion Rechargeable

Insulate Pack separately

none

Li primary Insulate Pack separately

none

Lead Acid /SLA

Insulate Pack separately

none

Button cells (not lithium)

Insulate Pack separately

Will Request DOT Interpretation