NYMPP: Section 1 - Mechanical Activities
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New York Sea Grant's
Marina Pollution Prevention Web Site

Section 1:
Mechanical Activities
- Battery Replacement

Potential Environmental Impacts

If not handled properly, lead acid batteries pose certain hazards. Battery components are toxic and corrosive, and can also be a fire and explosion hazard. Lead and sulfuric acid can contaminate the air, soil and water. Direct contact with sulfuric acid can burn the skin and eyes. Exposure to lead in the environment can pose a serious health hazard to children. Lead, which is also very toxic to aquatic life, can be carried into the marina basin by storm water runoff when spent lead acid batteries are not managed properly. Lead released in the basin can contaminate the sediment making dredging and disposal of the material very difficult and costly.

Best Management Practices

  • Avoid long-term storage of lead acid batteries by sending accumulated batteries to an authorized recycler within six months of receipt. Limit accumulation of large quantities of spent batteries. If necessary, ship more frequently.

  • Store spent lead acid batteries upright in a secure location, protected from the elements, preferably indoors in a space with an impermeable floor. Batteries stored outside should be stored on an impermeable surface with secondary containment and covered to prevent contact with rain or snow.

  • Never stack batteries directly on top of each other. Layer with wood.

  • Never drain batteries or crack the casings.

  • Place cracked or leaking batteries in a sturdy, acid-resistant, leak-proof, sealed container (e.g., a sealable 5-gallon plastic pail). The container should be kept closed within the battery storage area.

  • Strap batteries to pallets or wrap batteries and pallet in plastic during transport.

  • Keep written records of weekly inspections of spent lead acid batteries.

Regulatory Issues

  • Spent lead acid batteries must be recycled, and may not be disposed of with other solid wastes.

  • If you sell lead acid batteries at your facility, you must accept a used lead acid battery for each new battery that is sold to a customer. Consumers that are not returning a used battery with the purchase of a new battery must pay a five-dollar return incentive payment. Retailers must post written notice informing consumers of these requirements.

  • There are two options for managing spent lead acid batteries prior to sending them for off-site reclamation. Batteries can be managed according to the Universal Waste Rules (for Federal regulations [40 CFR 273] click here; for New York regulations [6 NYCRR Subpart 374-3] click here or, alternatively, under special lead-acid battery recycling rules click here in New York.)

  • Universal Waste Rule requirements. Marinas that store less than 5,000 kilograms (11,000 pounds) of spent lead-acid batteries would be classified as "Small Quantity Handlers" under these rules. Such handlers are required to do the following [40 CFR 273 Subpart B] click here and [6 NYCRR Subpart 374-3] click here.

    • Mark all batteries (or containers holding such batteries) with the words "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries."

    • Store batteries for no more than one year before sending them off-site for recycling.

    • Place any battery that shows signs of leakage, spillage, or damage in a container that is kept closed, is structurally sound, and is compatible with the contents of the battery.

    • Immediately contain any releases of batteries or electrolyte.

    • Before shipping batteries off-site, ensure that they are packaged, marked, labeled, and placarded in accordance with U.S. DOT rules for hazardous materials.

    • Ship the batteries to another Universal Waste handler, or to an authorized destination facility for recycling. Prior to shipment, ensure that the receiving facility agrees to receive the shipment. Any shipments which are rejected must be taken back, or directed to another handler or destination facility. In addition, if you transport batteries from one site to another, you must comply with Universal Waste transporter requirements [40 CFR 273 Subpart D] click here.

  • Lead acid battery recycling rules. Persons managing their lead acid batteries under this set of rules must do the following:

    • Segregate batteries from paper, rags, garbage, flammables, scrap metal or hazardous chemicals by means of a berm, wall or other physical barrier.

    • Store spent lead acid batteries on an impervious surface (such as concrete sealed to protect the surface from degradation), and inspect spent lead acid batteries weekly for leaks and deterioration.

    • Open, handle or store spent lead acid batteries so that the battery case does not rupture, leak, or produce short circuits.

    • Although the lead-acid battery recycling rules do not specifically require it, before shipping batteries off-site, ensure that they are packaged, marked, labeled, and placarded in accordance with U.S. DOT rules for hazardous materials.

  • Regardless of which set of rules lead-acid batteries are managed under, a hazardous waste determination must be conducted on spilled acid and broken lead acid batteries, and any materials used to clean a spill, to establish whether or not their disposal is subject to hazardous waste regulations [40 CFR 262.11 click here]. For more information on New York hazardous waste testing requirements, click here.

  • If over 500 pounds of batteries are stored onsite at your facility you must report the chemicals in lead acid batteries (sulfuric acid and lead) as part of your hazardous and toxic chemical inventory and notifications required under the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) [40 CFR 355]. Click here for more information on EPCRA requirements .