Bill Pollock; Alameda County HHW program

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) 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 3 rd 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 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

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 # April 16 th from Paul 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 August 13 th 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 from Florida HHW program from Pennsylvania HHW transporter: Reaffirms Kinsbursky letter with respect to 1.5 volt Alkalines DOT Interpretation letters On DOT Website

DOT Interpretation letters continued June 23 rd 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 Requirements TypeClean HarborsPhilip EnvVeolia 1.5 Volt AlkalineNo insulation 6 & 9 VoltNo insulation – Co-mingle with 1.5v ok No insulation Co-mingle with 1.5V ok Taped & packed separately Destination Facility requirements TypeKinsbursky/ Toxco AERC 1.5 Volt AlkalineNo insulation 6 & 9 Volt AlkalineNo insulation Co-mingle ok Insulated & packed separately

TypePackCo-mingleDOT REFFuture action? 1.5 Volt Alkalines No insulation09-090None 6 & 9 Volt Alkaline No insulationCo-mingle with above none Other Alkaline 12Volt InsulatePack separatelyWill Request DOT Interpretation Ni Cad/Ni MH InsulateNi-Cad & NiMH comingled Will Request DOT Interpretation Li Ion Rechargeable InsulatePack separatelynone Li primaryInsulatePack separatelynone Lead Acid /SLA InsulatePack separatelynone Button cells (not lithium) InsulatePack separatelyWill Request DOT Interpretation