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Air Emissions (RCRA)
Batteries
	09/12/2011	EXPORT OF USED OR SPENT LEAD ACID BATTERIES FOR RECYCLING	Memo
	Description: Spent lead acid batteries (SLABs) are prohibited from exportunderthe Resource Conservation and Recovery Act (RCRA) unless the exporter has submitted a notice to EPA requesting approval to export, obtained written consent from the receiving country via EPA, complied with the appropriate export requirements in either 40 Code of Federal Regulations (CFR) Part 262 Subpart E or 40 CFR Part 262 Subpart H, and ensured that the shipments comply with the terms of the receiving country's written consent. All export notices must include details about the proposed shipments, such as the specific recycling facility in the country of import, the maximum amount of batteries they propose to export, and the port of entry to be used in the country of import. EPA utilized alerts to note the proper Harmonized Tariff System (HTS) Classification Commodity Code for spent lead acid batteries, informed U.S. Customs and Border Protection (CBP) about the required paperwork for SLAB export shipments, and participated in the development of non-binding guidance on the environmentally sound management of SLABs under both the Basel Convention and the Commission for Environmental Cooperation.
	04/01/2010	Attention Auto Battery Recyclers and Brokers	Publication
	Description: This flyer discusses EPA regulations that become effective on July 7, 2010, in all states, regulating the export of spent lead acid batteries(SLABs). The new requirements will apply to all auto battery recyclers and brokers in the United States that export SLABs. Exporters of SLABs must submit a written notification to EPA and obtain the receiving country’s consent.
	06/08/2006	GUIDANCE FOR GENERATORS DISPOSING OF FULLY-DISCHARGED LITHIUM SULFUR DIOXIDE BATTERIES	Memo
	Description: A fully discharged lithium sulfur dioxide battery would have zero volts and would be unlikely to exhibit the reactivity characteristic. Lithium sulfur dioxide batteries that have been discharged using a Complete Discharge Device (CDD) to a voltage of one volt per cell or less are unlikely to be reactive. Discharge of batteries to remove the electric charge is an acceptable waste management practice under the universal waste rule. Batteries are considered hazardous waste at the time of removal from service. Generators, transporters, and consolidation points managing universal waste are required to comply with the land disposal restrictions (LDR). If lithium sulfur dioxide batteries are reasonably expected to contain underlying hazardous constituents (UHCs) above its universal treatment standard (UTS) level, the UHC must be treated to the UTS level before land disposal. Once batteries have been discharged and are no longer characteristic hazardous waste, it is not necessary to treat UHCs at a RCRA-permitted facility. Decharacterized universal waste meeting LDR requirements, including applicable UTS for UHCs, can be managed as nonhazardous waste and may be sent to a municipal solid waste landfill (MSWLF).
	09/03/1999	WASTE FROM ELECTRONIC AND ELECTRICAL EQUIPMENT DIRECTIVE (WEEE) AND THE BATTERIES AND ACCUMULATORS DIRECTIVE	Memo
	Description: OSW has provided comments to the U.S. Trade Representatives Office concerning the proposals from the European Union entitled the Waste from Electronic and Electrical Equipment Directive (WEEE) and the Batteries and Accumulators Directive.
	09/04/1998	NOTICE OF CERTIFICATION OF ALTERNATIVE BATTERY LABEL	Memo
	Description: EPA approved new label for nickel-cadmium (Ni-Cd) rechargeable batteries in accordance with Mercury-Containing and Rechargeable Battery Management Act of 1996. The new label depicts battery surrounded by three chasing arrows with word “RECYCLE” above it (SEE ALSO: 63 FR 50569; 9/22/98).
	11/01/1997	Implementation of the Mercury-Containing and Rechargeable Battery Management Act	Publication
	Description: This document explains the Mercury-Containing and Rechargeable Battery Management Act of 1996; provides information on successful recycling programs for rechargeable batteries; contains a summary of the Battery Act's requirements, as well as a summary of state and federal requirements affecting battery recycling prior to passage of the Battery Act; specifies why proper disposal or recycling is necessary for nickel and cadmium (Ni-Cd) and small sealed lead acid (SSLA) batteries; and defines roles that state and local governments, retailers, businesses, and public agencies can play in establishing recycling programs. The document also includes sources of additional information and a list of references.
	10/31/1997	IMPLEMENTATION OF THE MERCURY CONTAINING AND RECHARGEABLE BATTERY MANAGEMENT ACT	Memo
	Description: Section 104(a) of the Mercury Containing and Rechargeable Battery Management Act implements the federal Universal Waste (UW) rule as the management standard for batteries, regardless of state laws. Section 104(b) of the Act requires states wishing to regulate batteries to adopt provisions identical to those of the UW rule. Electrolyte removal is an activity specifically allowed of UW handlers, therefore regulation of electrolyte removal by any state is preempted by the Act.
	05/30/1997	TRANSPORTATION OF LEAD-ACID BATTERY COMPONENTS THAT ARE SHIPPED OFF-SITE FOR RECLAMATION	Memo
	Description: A facility shipping lead-acid battery plates would not be exempt from preparing a manifest under Part 266, Subpart G. Only the management of intact spent batteries prior to reclamation is exempt. Unmanifested waste reports (UWR) are not intended to be routinely submitted as an alternative to compliance with the manifest system. UWRs are designed to detect suspicious patterns of unusually high incidences of unmanifested wastes.
	05/16/1997	COLLECTION AND RECYCLING OF HOUSEHOLD BATTERIES	Memo
	Description: EPA does not have the authority to require battery manufacturers to take back their products for recycling once they are used. EPA may not require states or local communities to collect and recycle used batteries. This memo summarizes the Mercury-Containing and Rechargeable Battery Management Act. The Act removed obstacles to a voluntary industry take-back system. EPA is aware of a voluntary industry take-back system for the nationwide collection and recycling of Ni-Cd (Ni-Cad) batteries.
	05/13/1997	LABELING REQUIREMENTS FOR UNIVERSAL WASTE BATTERIES	Memo
	Description: Handlers of universal waste may place labels as prescribed in Section 273.34(a) on shrink-wrapped pallets of batteries rather than on each individual battery. A shrink-wrapped unit is a portable device (i.e., a container) for the purposes of Section 273.34(a). If the batteries show evidence of leakage or spillage after they have been shrink-wrapped, the shrink-wrapped unit must be placed in a container which can prevent release to the environment and the new container must be relabeled. Shrink-wrapped units may not meet DOT packaging specifications.
	04/03/1997	ATON BATTERIES AS DEBRIS	Memo
	Description: Intact containers are not debris. Mercury batteries that serve as aid to navigation (ATON) meet the definition of debris if they are deteriorated and ruptured, because they do not meet the definition of intact container. Batteries meeting the definition of debris can be treated in accordance with the alternative debris treatment standards. Non-debris mercury waste requires treatment by roasting or retorting (RMERC) or compliance with a TCLP standard.
	02/13/1997	UNIVERSAL WASTE QUESTIONS AND ANSWERS DOCUMENT	Memo
	Description: Presents a Universal Waste Questions and Answers Document. Addresses state authorization. Discusses the addition of wastes to the federal and state universal waste (UW) programs, fluorescent lamps (SEE ALSO: 64 FR 36466; 7/6/99), land disposal restrictions (LDR) recordkeeping requirements, the Mercury-Containing and Rechargeable Battery Management Act, batteries, pesticide collection programs, liability and enforcement, storage limits, mixtures of UW and hazardous waste, and manifesting.
	11/25/1996	MERCURY-CONTAINING AND RECHARGEABLE BATTERY MANAGEMENT ACT	Memo
	Description: The Mercury-Containing and Rechargeable Battery Management Act is effective nationwide on May 13, 1996. Two goals are to limit mercury (Hg) content in consumer batteries, and to promote recycling and proper disposal of used rechargeable nickel cadmium (NiCad) batteries, sealed small lead-acid batteries, and other widely used rechargeable batteries. Law limits Hg content of batteries and prohibits the sale of some Hg-containing batteries. Law requires uniform labeling and requires that collection, storage, and transportation be in accordance with the Universal Waste (UW) standards of Part 273. Law prohibits states from imposing standards not identical to UW standards. Law is not an amendment to RCRA. EPA is investigating implications on RCRA state authorization and is developing a codification rule.
	06/19/1996	REGULATORY STATUS OF SPENT LEAD-ACID BATTERIES SHIPPED TO A SECONDARY LEAD SMELTER FOR RECLAMATION	Memo
	Description: Lead-acid batteries (battery) that are held at a smelter in a transport truck for less than 24 hours, transported off-site for storage, and then shipped back to the smelter for reclamation remain exempt.
	06/14/1996	STATUS OF SLAGS FROM THE PROCESSING OF LEAD ACID BATTERIES	Memo
	Description: Slag or matte from recovery of lead from lead acid batteries is a new treatability group under the land disposal restriction (LDR). The status of residuals as prohibited or nonprohibited is determined at point of generation (SEE ALSO: 55 FR 22568; 6/1/90).
	05/01/1996	FREQUENTLY ASKED QUESTIONS ON THE UNIVERSAL WASTE REGULATIONS	Question & Answer
	Description: The universal waste (UW) regulations cover hazardous waste batteries (battery), pesticides, and mercury-containing thermostats (SEE ALSO: 70 FR 45508; 8/5/05). Wastes (e.g., fluorescent mercury lamps) may be added to the UW system (SEE ALSO: 64 FR 36466; 7/6/99). Spent lead-acid batteries may be handled under Part 266, Subpart G, or under Part 273. There are no specific provisions for satellite accumulation of UW. Only large quantity handlers of universal waste (LQHUW) must submit a one-time written notification and obtain an EPA identification number. Handlers may accumulate universal waste at or near point of generation for up to 1 year.
	12/01/1995	LEAD-ACID BATTERIES AND UNIVERSAL WASTE	Question & Answer
	Description: Lead-acid batteries (battery) that are managed under Part 266, Subpart G, are not subject to the universal waste management standards under Part 273.
	09/14/1995	STATUS OF UNUSED OFF-SPECIFICATION LEAD PLATES USED IN LEAD-ACID BATTERY PRODUCTION	Memo
	Description: Unused off-specification lead plates from lead-acid battery (batteries) production (i.e., nonlisted CCP) are not solid wastes when reclaimed. Used plates are spent materials and solid waste when reclaimed.
	06/01/1995	SPENT LEAD-ACID BATTERIES AND COUNTING REQUIREMENTS	Question & Answer
	Description: Spent lead-acid batteries (battery) that will be reclaimed are not subject to the generator’s monthly counting requirements. Wastes are counted only if they are subject to substantive regulation. Substantive regulations are those regulations which directly relate to storage, treatment, or disposal (SEE ALSO: Part 273).
	01/12/1995	WOULD REGENERATION EXEMPTION APPLY TO VARIOUS TYPES OF LOCATIONS AT WHICH LEAD-ACID BATTERIES ARE REGENERATED?	Memo
	Description: The battery regeneration exemption applies to batteries regenerated at any type of facility. The exemption only covers batteries sent for regeneration. Other types of recycling are subject to Subtitle C regulation. Lead-acid batteries recycled in all ways are covered under Part 266, Subpart G (SUPERSEDED: 261.6(a)(3)(ii) removed, See Part 273 and 60 FR 25535; 5/11/95).
	12/13/1994	LE VALT MERCURY-CADMIUM BATTERIES	Memo
	Description: Unused batteries sent for reclamation are CCPs being reclaimed, and are not solid wastes. Mercury-cadmium batteries must be treated by thermal recovery. EPA recognizes that most battery recycling technologies in the U.S. are not designed to treat these wastes (SEE ALSO: Part 273).
	11/01/1994	REGENERATION VERSUS RECLAMATION FOR SPENT LEAD-ACID BATTERIES	Question & Answer
	Description: Spent lead-acid batteries returned to a battery manufacturer for regeneration are not subject to Subpart G of Part 266, nor to any other Subtitle C regulations. Battery regeneration is similar to recycling of a commercial chemical product (CCP). (SUPERSEDED: Section 261.6(a)(3)(ii) removed, See Part 273 and 60 FR 25535; 5/11/95)
	04/15/1994	Analysis of Potential Cost Savings and the Potential for Reduced Environmental Benefits of the Proposed Universal Waste Rule	Publication
	Description: This document addresses proposed changes to the management of universal wastes (e.g., nickel-cadmium and mercuric oxide batteries, mercury-containing thermostats) under RCRA. It discusses characteristics of universal wastes, cost analysis, and potential for reduction in environmental benefits, and the appendix lists sources for unit cost estimates.
	03/31/1994	INTERPRETATION ON REGULATORY STATUS OF MERCURY RELAYS AND SWITCHES WHEN RECLAIMED	Memo
	Description: Clarification of when a secondary material is a spent material and the definition of contamination are discussed. Materials such as used lead-acid batteries (battery), solvents, and mercury thermostats and switches are spent materials when sent for reclamation, even if they can still be used for their original purpose. Characteristic sludges and by-products are not solid wastes when reclaimed. Commercial chemical products (CCPs), whether listed or characteristic, are not solid wastes when reclaimed.
	03/24/1994	CLARIFICATION OF WHEN A SECONDARY MATERIAL MEETS THE DEFINITION OF ""SPENT MATERIAL""	Memo
	Description: Clarification of when a secondary material is a spent material and the definition of contamination are discussed. Materials such as used lead-acid batteries (battery), solvents, and mercury thermostats and switches are spent materials when sent for reclamation, even if they can still be used for their original purpose (See Also: RO 14814). Characteristic sludges and by-products are not solid wastes when reclaimed. Commercial chemical products (CCPs), whether listed or characteristic, are not solid wastes when reclaimed.
	02/04/1994	REGULATORY STATUS OF MERCURY BATTERIES	Memo
	Description: Containers as debris. Mercury battery (batteries) carcasses containing hazardous waste liquid or sludge may be hazardous debris based on a case-by-case determination.
	12/23/1993	MANAGEMENT OF LEAD-ACID BATTERIES THAT ARE RECYCLED	Memo
	Description: Section 266.80(a) applies to locations where lead-acid batteries are stored, but not reclaimed, regardless of the battery management activities that the owner or operator may conduct at other locations. Section 266.80(b) applies to locations where lead-acid batteries are both stored and reclaimed (SEE ALSO: Part 273).
	11/10/1993	REGULATORY STATUS OF BATTERY CARCASSES	Memo
	Description: Intact containers are not debris. Because batteries are a type of container, battery carcasses are not debris and are not eligible for the alternate debris treatment standards.
	10/22/1993	REGULATORY STATUS OF USED NICKEL-CADMIUM BATTERIES	Memo
	Description: Used nickel-cadmium batteries (battery) that can no longer be used for the purpose for which they were produced are spent materials and are solid wastes when reclaimed. The nickel-cadmium repair process (replacing damaged separator material and electrolytes) may be a regeneration activity that qualifies for the 261.6(a)(3) exemption for batteries returned to the manufacturer for regeneration because the activity is similar to recycling CCPs (SUPERSEDED: 261.6(a)(3)(ii) removed; See Also Part 273 and 60 FR 25535; 5/11/95).
	09/14/1993	REGULATORY STATUS OF LITHIUM SULFUR DIOXIDE BATTERIES	Memo
	Description: The regulatory determination made in the letter, Williams to Berger (RPC# 3/18/87-01), regarding the potential reactivity of lithium sulfur dioxide (LiSO2) batteries (battery) is still in effect.
	08/04/1993	REGULATORY STATUS OF PLASTIC CHIPS FROM RECLAMATION OF LEAD-ACID BATTERIES	Memo
	Description: Plastic chips from spent lead-acid batteries (battery) are spent materials. EPA has viewed the by-product category as a catch-all that includes most materials that are not spent materials or sludges. The category may include materials that are not generated from production processes.
	05/06/1993	WASTE MANAGEMENT OPTIONS FOR ZINC-CARBON BATTERIES	Memo
	Description: Zinc-carbon batteries that contain cadmium are subject to land disposal restrictions (LDR) only if they fail the TCLP and extraction procedure (EP) (SUPERSEDED: see 63 FR 28556; May 26, 1998). Zinc-carbon batteries are not subject to the cadmium battery recycling standard. The applicable D006 treatment standard is based on stabilization (SEE ALSO: Part 273).
	02/23/1993	CLARIFICATION OF THE SATELLITE ACCUMULATION PROVISION FOR HAZARDOUS WASTE GENERATORS	Memo
	Description: Provides clarification of the phrases "at or near point of generation" and "under control of operator. . ." for wastes that are generated at many individual locations (e.g. calculator batteries (battery)) and accumulated in satellite areas.
	02/23/1993	STATUS OF UNLISTED COMMERCIAL CHEMICAL PRODUCTS WHEN RECYCLED	Memo
	Description: For purposes of 261.2, EPA interprets nonlisted CCPs to include all types of unused commercial products that exhibit hazardous waste characteristics, even if these products are not commonly considered chemicals (e.g., circuit boards, batteries (battery), etc.). Unlisted CCPs that are sent for reclamation are not solid waste. Reclamation of CCPs that recovers only a minimal amount of material that is of questionable value may be more similar to waste management than legitimate recycling. Persons claiming that a nonlisted CCP being reclaimed is not a solid waste retain the burden of proving that the recycling is legitimate.
	01/28/1993	MOVEMENT OF NICKEL CADMIUM BATTERIES FROM MEXICO TO JAPAN VIA THE UNITED STATES	Memo
	Description: Hazardous waste is subject to RCRA within U.S. borders. Hazardous waste imported to the U.S. from Mexico for subsequent shipment to Japan is subject to RCRA requirements the moment that it enters the U.S., including import provisions and export provisions. Used batteries that are sent to a battery manufacturer for regeneration are not subject to the Part 262 export requirements (SUPERSEDED: 261.6(a)(3)(ii) removed, See Part 273 and 60 FR 25535; 5/11/95).
	12/15/1992	Used Dry Cell Batteries: Is a Collection Program Right for Your Community?	Publication
	Description: This document helps communities determine whether establishing a program to collect used dry cell batteries is right for them, focusing on household battery collection. It also reviews ten key issues related to setting up and running a collection program, from determining the types and amounts of dry cell batteries being discarded to estimating the likely costs of a program.
	07/15/1992	Environmental Fact Sheet: Mercury in the Municipal Solid Waste (MSW) Stream	Publication
	Description: This fact sheet describes EPA's examination of the major sources of mercury in the MSW stream, such as batteries and paint residues. EPA predicts a dramatic decrease in mercury discards in the next several years due to source reduction and recycling efforts.
	08/01/1991	REGULATORY STATUS OF OFF-SPECIFICATION CIRCUIT PRINTING BOARDS	Question & Answer
	Description: An unused circuit board is a commercial chemical product (CCP) and is not a solid waste when reclaimed. For purposes of Section 261.2 (SEE ALSO: 261.4(a)(14) exclusion for shredded circuit boards), EPA interprets a CCP to include all types of unused CCPs that exhibit characteristics (e.g., circuit boards, batteries (battery)) (SEE ALSO: 45 FR 78541; November 11 1980 for Section 261.33; RPC# 2/23/93-02). Section 261.2(f) documentation may be required.
	05/30/1991	HOUSEHOLD WASTE EXCLUSION SCOPE	Memo
	Description: Hazardous waste nickel-cadmium batteries (battery) generated by consumers in their homes are within the household hazardous waste exclusion. Batteries removed by service centers are not within the exemption (SEE ALSO: Part 273).
	05/30/1991	NICKEL-CADMIUM BATTERIES RECYCLING	Memo
	Description: Provides a general discussion of the regulation of nickel-cadmium (NiCad, NiCd) batteries and state legislation requiring manufacturers to take back spent batteries (take-back programs) (SEE ALSO: Part 273).
	03/04/1991	USED BATTERIES RETURNED FOR REGENERATION EXEMPTION	Memo
	Description: EPA draws a clear distinction between regeneration (processing to remove contaminants to restore product) and material recovery (processing to recover material as an end product). Batteries sent for smelting are not exempt under 261.6(a)(3) (smelting is not regeneration) (SUPERSEDED: 261.6(a)(3)(ii) removed, See Part 273 and 60 FR 25535; 5/11/95). Discuses the rationale for the spent lead-acid battery rule.
	02/13/1991	HAZARDOUS WASTE DETERMINATIONS FOR NICKEL-CADMIUM BATTERIES	Memo
	Description: Unused batteries are CCPs and are not solid waste when destined for reclamation. Used batteries are spent materials and are solid waste when destined for reclamation. Used batteries that are partially reclaimed but need further reclamation are generally solid waste. A variance may be used to show that partially reclaimed used batteries are not solid waste (SEE ALSO: Part 273).
	06/27/1990	ACCIDENTAL OMISSION OF 40 CFR 266.80(B)(3) AND (B)(4)	Memo
	Description: Section 266.80(b)(3) and (b)(4) were accidentally omitted from the CFR. The regulations read correctly as of 7/1/92 CFR.
	05/23/1990	NICKLE/CADMIUM BATTERIES, REGULATORY STATUS	Memo
	Description: There is an exemption for a battery (batteries) returned for regeneration, not spent nickel-cadmium battery export for reclamation (SUPERSEDED: see 60 FR 25535; 5/11/95). Draining is not regeneration. A battery does not have to be contaminated to be a spent material. If it is unknown if a battery reusable, generator may consider spent. Generator determines if spent. Must document claims per 261.2(f) (SEE ALSO: Part 273).
	05/01/1990	REGULATION OF NICKEL/CADMIUM BATTERIES AS SCRAP METAL WHEN RECLAIMED	Question & Answer
	Description: A used nickel/cadmium battery (batteries) is a spent material. Once separated out, metal plates may be exempt scrap metal if recycled. If metal plates are removed and mixed with non-scrap metal, the plates lose their scrap metal designation (SEE ALSO: Part 273).
	11/17/1989	RECYCLING OF LEAD-ACID BATTERIES	Memo
	Description: Restricted wastes, like lead-acid batteries, may be stored on the land in tanks or containers (i.e., land disposed) without meeting treatment standards if done solely to accumulate as necessary to facilitate proper recovery, treatment, or disposal. Storage must comply with all storage standards, such as secondary containment. the Battery shell (casing/housing) is the container (SEE ALSO: Part 273).
	10/19/1989	SPENT LEAD-ACID BATTERIES MANAGEMENT	Memo
	Description: Speculative accumulation is not applicable to lead-acid batteries (battery) that are reclaimed or any other material already defined as solid waste. Persons who store but do not reclaim batteries are not subject to regulation (SEE ALSO: Part 273).
	11/28/1988	APPLICABILITY OF PERMITTING TO SPENT LEAD-ACID BATTERY RECYCLING	Memo
	Description: Pieces of lead metal from batteries can be scrap metal. The exemption no longer applies if metal pieces are mixed with other wastes that are regulated. Wastes derived from spent materials are spent materials. Some lead-acid battery components are not solid wastes when reclaimed. Discussion of the regulatory status of reclaimed battery components. Discussion of the EPA analysis of the regulatory status of 16 materials from spent lead-acid battery recycling, including battery acid, plastic chips, metal battery pieces, and lead sulfates. Spent lead-acid battery components used to produce fertilizer are used in a manner constituting disposal. Fertilizer produced for the general public's use that meets land disposal restrictions (LDR) treatment standards is no longer subject to regulation (SEE ALSO: Part 273).
	08/26/1988	SECONDARY LEAD SMELTER VARIANCES	Memo
	Description: Lead plates removed from lead-acid batteries at smelter and awaiting further reclamation in smelter are solid waste. Partially-reclaimed lead at a smelter is typically eligible for a variance from the solid waste definition. Discussion of common lead-acid battery cracking practices at lead smelting facilities (SEE ALSO: Part 273).
	02/25/1988	ATON BATTERIES, GENERATOR DEFINITION FOR	Memo
	Description: A generator site may include each vessel where waste is generated. If a buoy is brought onto a ship to remove an ATON battery, the ship is the generation site rather than the buoy. A ship accumulates spent batteries per 262.34. A shore facility accepting spent batteries may qualify as a transfer facility (SEE ALSO: Federal Facility Compliance Act (FFCA) section 3022 and Part 273).
	09/17/1987	EXPORT OF SPENT BATTERIES	Memo
	Description: Intact lead-acid batteries (battery) shipped to Canada are not subject to manifesting or export notification because no reclamation has taken place. (SUPERSEDED: 266.80(a)(6)-(7), 273.40, and 273.56)
	08/12/1987	WASTE CHARACTERIZATION: LITHIUM BATTERIES	Memo
	Description: Lithium sulfur dioxide batteries tend to exhibit the reactivity characteristic (D003).
	07/30/1987	AIDS TO NAVIGATION (ATON) BATTERIES AND RCRA REQUIREMENTS	Memo
	Description: Each ATON unit service area (landbased or tender vehicle) is a point of generation (ships as generators) that is subject to the applicable generator standards (SEE ALSO: Federal Facility Compliance Act (FFCA) section 3022)). Aids to navigation batteries (ATON) that are removed from service must be manifested. The location where the battery is removed from service is a waste generation site. Batteries may be held for up to 10 days at a transfer facility (SEE ALSO: Part 273). The entire aid to navigation (ATON) battery is counted in weight calculations. Each ATON unit service area (landbased or tender vehicle) is a point of generation that is subject to the applicable generator standards. The satellite accumulation area provisions do not apply to ATON service locations (SEE ALSO: Part 273).
	06/24/1987	RECYCLING V. CONTINUED-USE OF LEAD-ACID BATTERIES	Memo
	Description: Hazardous spent material (batteries) recycling is regulated. A used lead-acid battery is not a waste until it has served its intended purpose or is spent. A used battery that is not reclaimed in any way can be sold or given away for further battery use without being subject to regulation. A company must document legitimacy (SEE ALSO: Part 273).
	06/19/1987	EXPORT REQUIREMENTS FOR SPENT BATTERIES SENT TO FOREIGN COUNTRIES FOR RECYCLING	Memo
	Description: RCRA 3017 prohibits the export of hazardous waste without prior notification to EPA. Spent batteries sent to a foreign country for recycling are exempt from the export requirements if the batteries are uncracked. Notification and consent can cover a period of up to 12 months. A 60-day waiting period for approval to export applies only to the first shipment. Bilateral agreements can take priority over a written consent requirement. (SUPERSEDED: See 266.80(a)(6)-(7), 273.20, 273.40, and 273.56)
	04/17/1987	SPENT LEAD-ACID BATTERIES BEING RECLAIMED	Memo
	Description: Waste destined for recycling has the same potential for harm as waste destined for treatment or disposal. Only those persons who reclaim lead-acid batteries are subject to regulation for storage prior to recycling (SEE ALSO: Part 273).
	03/18/1987	REACTIVE CHARACTERISTICS OF DISCHARGED LI/SO2 BATTERIES	Memo
	Description: Based on the supplied data, EPA agrees that Li/SO2 (lithium-sulfur dioxide) batteries are unlikely to exhibit the reactivity characteristic when they are fully discharged to zero volts. Fully-charged and duty-cycle Li/SO2 batteries are reactive. The generator is responsible for the hazardous waste determination. The placement of ignitable (D001) or reactive (D003) waste into a landfill is prohibited unless it is treated, rendered, mixed before, or immediately after, placement in the landfill so that it is no longer characteristic (SEE ALSO: Part 268).
	02/19/1987	REPROCESSING OF BATTERIES	Memo
	Description: Waste destined for recycling has the same potential for harm as waste destined for treatment or disposal. Only persons who reclaim lead-acid batteries are subject to regulation for storage prior to recycling (SEE ALSO: Part 273). RCRA 3017 mandated export regulations unless the Administrator is notified, the receiving country has consented, a copy of the consent is attached to the manifest, and the shipment conforms to the consent.
	02/12/1987	BATTERY RECYCLING AND EXPORT	Memo
	Description: Waste destined for recycling has the same potential for harm as waste destined for treatment or disposal. Only persons who reclaim lead-acid batteries are subject to regulation for storage prior to recycling (SEE ALSO: Part 273). RCRA 3017 mandated export regulations unless the Administrator is notified, the receiving country has consented, the copy of consent is attached to the manifest, and the shipment conforms to the consent. EPA expects that exporters will not typically exceed the 90 day generator time limit.
	01/14/1987	LITHIUM BATTERIES	Memo
	Description: Generators must determine if a lithium battery (lithium thionyl chloride (SOCL2)) exhibits a characteristic.
	01/01/1987	SPENT LEAD-ACID BATTERIES	Question & Answer
	Description: A person who drains spent acid from battery shells is subject to the generator provisions if the acid exhibits a characteristic. Because the act of draining batteries is not part of the reclamation process, a person who drains but does not crack batteries is not subject to 266.80(b) (SEE ALSO: Part 273).
	12/31/1986	SPECIAL MATERIALS DISPOSED OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKS	Memo
	Description: Batteries and capacitors are exempt from the landfill containerized liquid requirements. They do not need to be 90% full, crushed, or shredded before disposal (SEE ALSO: Part 273).
	10/20/1986	SCRAP METAL REMOVED FROM SPENT ALKALINE BATTERIES THAT ARE RECYCLED	Memo
	Description: Zinc bar, nickel and cadmium plate, and steel scrap from batteries are scrap metal. Mixtures of scrap metal and non-scrap metal (lead oxide sludge) removed from a spent lead-acid battery are hazardous waste, not scrap metal. Scrap metal is exempt when it is recycled whether it is characteristic or not. Metal that contains only an oily film is still scrap metal (SEE ALSO: 261.4(a)(13) exclusion for processed scrap metal).
	07/28/1986	BATTERY RECONDITIONING	Memo
	Description: The regeneration and resale of used lead-acid batteries (battery) is exempt from regulation (SUPERSEDED: 261.6(a)(3)(ii) removed in 60 FR 25535; 5/11/95) (SEE ALSO: 266.80(a) and Part 273).
	07/11/1986	LEAD-ACID BATTERY IMPROPER DISPOSAL	Memo
	Description: An individual consumer may dispose of lead-acid batteries (battery) (baunder household hazardous waste (HHW) exemption). EPA regulates storage of lead-acid batteries by the reclaimer prior to the reclamation, but not the generation, storage, or transportation by other persons (SEE ALSO: Part 273).
	07/02/1986	REGENERATION OF USED BATTERIES EXEMPTED FROM REGULATION	Memo
	Description: Discusses the regulatory status of regenerated batteries (battery) under Section 261.6(a)(3)(ii) (SUPERSEDED: See Part 273, 60 FR 25535; 5/11/95, and current Section 261.6(a)(3)). Discusses the definition of regeneration.
	06/10/1986	MINING WASTE EXCLUSION FOR A FERROALLOY FACILITY	Memo
	Description: Wastes from ferroalloy facility producing ferrosilicon (silvery iron) are not excluded under the section 261.4(b)(7) Bevill exemption for mining and mineral processing wastes. Metal scrap is neither an ore nor a mineral. If predominant input is a scrap steel or old batteries (battery) then the wastes from the facility are not excluded by section 261.4(b)(7).
	05/01/1986	HAZARDOUS WASTE EXPORT RULE	Memo
	Description: Spent lead-acid batteries (battery) sent to Taiwan for reclamation are exempt from the hazardous waste exportation regulations since the generator does not reclaim batteries. Section 266.80 exempts the generator from Part 262 requirements. (SUPERSEDED: See 266.80(a)(6)-(7))
	02/06/1986	REUSE/RECYCLE REGULATIONS IMPACT ON SPENT LEAD-ACID BATTERY RECYCLING	Memo
	Description: A request that EPA reconsider a position on whether to regulate battery (batteries) components generated from breaking and separation operations. The lead-acid battery recycle/reuse rules is promulgated to ensure storage and transportation conducted in environmentally safe manner (SEE ALSO: Part 273). The insurance industry has curtailed writing new environmental insurance policies.
	01/21/1986	MERCURY, REFINING/REUSE OF SCRAP	Memo
	Description: Free-flowing, 99% pure mercury is not a solid waste (SW). Metals suitable for direct use, or that only need to be refined to be usable are products, are not wastes. Any electrical switches, instruments, scrap batteries (battery), or other spent materials from which such pure mercury will be reclaimed are SW.
	12/18/1985	BATTERIES, SCRAP METAL, AND PRECIOUS METALS	Memo
	Description: Spent lead-acid batteries (battery) are hazardous waste (HW) at generation. Generators, transporters, and persons who store (but not reclaim) batteries for reclamation not subject to regulation (SEE ALSO: Part 273). Discussion of recycled scrap metal with precious metals excluded (SEE ALSO: current 261.6(a)(3)(ii)). Precious metals reclaimed from HW and suitable for direct reuse or only need refining before reuse are products, not wastes.
	09/01/1985	BATTERY REGENERATION	Question & Answer
	Description: The Section 261.6(a)(3)(ii) exclusion applies to any facility that regenerates batteries. Spent lead-acid batteries that are regenerated qualify for the 261.6(a)(3)(ii) exclusion unless the battery is cracked for lead recovery (SUPERSEDED: 261.6(a)(3)(ii) removed, See Part 273 and 60 FR 25535; 5/11/95).
	08/13/1985	REGULATORY STATUS OF SOLDER DROSS WHEN SMELTED FOR LEAD RECOVERY	Memo
	Description: Solder dross is a by-product. An unlisted (characteristic) by-product is not a solid waste when it is reclaimed. Discussion of spent material versus by-product. Spent materials include spent solvents, acids, pickle liquor, catalysts, and lead-acid batteries (battery). By-products include distillation residues, slags, dross, and tank bottoms (SEE ALSO: RPC# 8/28/92-01).
	08/09/1985	REGULATORY STATUS OF STEEL INDUSTRIAL BATTERY CASES SENT OFFSITE FOR RECLAMATION	Memo
	Description: Industrial steel battery (batteries) cases and lead plates with acid and lead removed are scrap metal. Mixtures of scrap metal (battery cases) and other regulated recyclable materials (lead oxides) must be managed as hazardous waste when sent for reclamation (SEE ALSO: Part 273).
	04/19/1984	HOUSEHOLD WASTES - DISPOSAL OF CARBON-ZINC BATTERIES	Memo
	Description: Batteries (battery) from households are exempt as household hazardous waste. Carbon-zinc batteries pose little threat to the environment. Batteries which are hazardous (nickel-cadmium, mercury) are generally not disposed of in large numbers by households.
	03/07/1984	REGULATORY STATUS OF SPENT/DISCARDED LITHIUM-SULFUR DIOXIDE BATTERIES	Memo
	Description: Lithium-sulfur dioxide batteries (battery) clearly exhibit the characteristic of reactivity (D003) because of their potential to generate toxic gas. There is insufficient information to make a blanket determination for all lithium batteries. There is no determination whether lithium batteries with other cathode materials (e.g., thionyl chloride, polycarbon monofluoride, manganese dioxide, iodine, silver oxide, silver chromate, vanadium pentoxide, iron sulfide, copper oxide, and lead bismuthate) are reactive.
	06/24/1981	REGULATORY STATUS OF SAFT GELLED ELECTROLYTE PRIMARY BATTERIES	Memo
	Description: Typical SAFT Gelled Electrolyte Primary batteries (battery) do not exhibit any characteristics and are not listed hazardous waste.
Best Demonstrated Available Technology (BDAT)
Bevill Amendment
Boilers
Burning
Buy Recycled
Characteristic Wastes
Chemicals (RCRA)
Cleanup
Cleanup (RCRA)
Closure (Hazardous Waste)
Combustion
Combustion of Hazardous Waste
Compliance
Composting
Conditionally Exempt Small Quantity Generators (CESQG)
Construction and Demolition Waste
Construction and Demolition Wastes
Containers
Containment Buildings
Corrective Action (RCRA)
Corrosive Wastes
Crude Oil
Definition of Solid Waste
Delisting Petitions
Disposal
Drip Pads
Educational Materials
Enforcement (RCRA)
EPA Forms
Exclusions (RCRA)
Exports
F-wastes
Financial Assurance (hazardous waste)
Financial Assurance (nonhazardous waste)
Gas
Generators
Grants (hazardous Waste)
Grants (municipal solid waste)
Groundwater Monitoring
Hazardous Waste
Hazardous waste data
Hazardous Waste Identification
Hazardous Waste Recycling
Household Hazardous Waste
Identification of Hazardous Waste
Imports
Incineration
Incinerators
Industrial Furnaces
Industrial Wastes
Jobs Through Recycling Program
K-wastes
Land Disposal Restrictions
Land Disposal Units
Land Treatment Units
Landfills
Large Quantity Generators (LQG)
Legislation (hazardous waste)
Liability (Hazardous Waste)
Listing Hazardous Waste
Manifest
Medical Waste
Mercury Wastes
Military Munitions
Mining Waste
Miscellaneous Units
Mixed Waste (radioactive waste)
Municipal Solid Waste
Native American - Tribes
Native Americans - Tribes
Natural Gas
Nonhazardous Waste
Oil
Oil Filters
P-wastes
PCBs
Permits and Permitting
Petitions
Petroleum Refining Wastes
Polychorinated Biphenyls (PCBs)
Post-closure (hazardous waste)
Procurement
Public Participation
Radioactive Mixed Waste
Reactive Wastes
Recycling
Reducing Waste
Siting (waste facilities)
Small Quantity Generators (SQG)
Solid Waste
Solvents
Source Reduction
Special Wastes
State Programs (RCRA)
Storage
Surface Impoundments
Tanks
Test Methods
Toxicity Characteristic
Transporters
Treatment
TSDFs
U-wastes
Underground Storage Tanks (UST)
Universal Waste
Used Oil
Variances
Waste Determinations for Combusted Non-Hazardous Secondary Materials
Waste Minimization
Waste Piles
Waste Reduction
Wood Preserving Wastes
(Not Categorized)

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