A ‘√’ next to a response in the guide indicates that is the preferred response in terms of environmental compliance. If you select a response without a ‘√’, you may still be in compliance; however, you should verify that you are in compliance by contacting the appropriate federal or state regulatory agency and discussing your activity with them.

USED BATTERY STORAGE AND DISPOSAL

Has the facility determined whether its batteries are regulated as universal waste or hazardous waste?

There are many types of used batteries with different disposal requirements. Some of these batteries may be classified as hazardous waste.

Under the Universal Waste Rule, batteries that do not exhibit hazardous waste characteristics may be regulated as universal wastes and subject to less stringent requirements than other hazardous wastes. For example, many small sealed lead acid batteries (used for electronic equipment and mobile telephones) and nickelcadmium batteries are under universal wastes rules. Most alkaline batteries are not hazardous waste under RCRA and can be disposed of as general trash. Check with your local waste authority to see if there is a battery collection program.

Yes–Facility has completed the waste determination process to determine whether its batteries should be regulated as universal or hazardous waste.  √

No–Facility has not determined whether its batteries should be regulated as universal or hazardous waste.

N/A–Facility does not generate used batteries.

Does the facility protect used batteries from storm water contact?

When placed out-of-service, the facility should transport batteries to an accumulation area specifically designed for storage prior to removal from the site. The storage accumulation area should protect the batteries from weather and storms. It should be designed (1) with secondary containment to prevent any spillage or leakage from contaminating the soil or surface waters; and (2) without floor drains that could receive spills and deliver them to the storm sewer, sanitary sewer, streams, rivers or other surface water, or into the ground by an injection well. One may store batteries inside or outside under a tarp or roof. Store batteries in a pan or other device so that any leakage cannot enter floor drains or spill onto the ground. Improper storage results in batteries being considered “abandoned.”

Yes–Facility protects used batteries from storm water contact.  √

No–Facility does not protect used batteries from storm water contact.

N/A–Facility does not store used batteries.

How does the facility manage/dispose of used batteries?

Return to supplier–Facility returns used batteries to supplier.  √

Recycle–Facility sends batteries to a recycling facility.  √

Service–Facility pays service company to pick up used batteries.  √

Hazardous waste landfill–Facility sends used batteries to a hazardous waste landfill. Facility has records of where and how many batteries were sent.  √

Other–Method of disposal is not listed here.

N/A–Facility does not generate used batteries.