Storing Batteries Prior to Reclamation

Facilities that store lead-acid batteries prior to reclamation, and that do not use the method of regeneration to reclaim the batteries, must follow slightly different requirements than those for facilities that do not store batteries in their facilities. These requirements vary, depending on whether the facility that is storing the batteries is an interim status facility or a permitted facility.

Interim status facilities are treatment, storage, and disposal facilities (TSDFs) that were handling hazardous waste materials prior to the time that the RCRA standards came into effect in 1980, as you may recall from our discussion in Unit 5 of this course in which we covered the permitting of TSDFs. These facilities were issued "interim status permits" to provide them with time to upgrade their facilities and procedures to comply with RCRA regulations.

A permitted facility, on the other hand, is a facility for which its owner or operator applied for and obtained an operating permit from the EPA, or from a state agency, after the establishment of the RCRA regulations. The operating permit allows the TSDF to treat, store, and dispose of hazardous waste.

Both types of facilities must follow the same notification requirements under section 3010 of the RCRA. The RCRA regulations then outline specific guidelines for each type of facility (refer to 40 CFR 266.80).

To learn more about RCRA visit our RCRA Hazardous Waste Safety Online Training web page.