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1 Joint Commission for Environmental Cooperation and U.S./Mexico Border 2012 Collection and Storage of SLABs December 4, 2007 Slide 2 2 RSR Corporation Primary Business Reclamation of Lead Acid Batteries Responsible for secondary lead smelter operations in three states Primary Products Lead Plastic Sodium Sulfate Slide 3 3 RSR Corporation Spent Batteries Supplied from Battery Manufacturers Purchased from Scrap Dealers Slide 4 4 RSR Corporation Slide 5 5 Slide 6 6 Slide 7 7 Battery Reclamation Process Slide 8 8 Responsibilities U.S Regulatory Background If you generate Spent Lead Acid Batteries (SLABs) and send those batteries for disposal, the hazardous waste rules apply for the storage, transportation and disposal of the SLABs If you generate, collect and/or transport SLABs for reclamation (but you do not reclaim the SLABs) you are exempt from the hazardous waste regulations; If you reclaim SLABs but dont store SLABs before you reclaim them, you are exempt from the hazardous waste regulations; but If you reclaim SLABs and store the batteries before you reclaim them you are classified as a Hazardous Waste Treatment Storage or Disposal (TSD) facility. Slide 9 9 U.S Regulatory Background Secondary lead smelters are regulated by the same rules and requirements as US hazardous waste disposal operations RCRA Waste Permits are required; Operating requirements for the storage areas are in place (secondary containment, aisle space, labeling,) Procedures for inspecting incoming loads are required Procedures for unloading SLABs for storage are required; Procedures for addressing broken batteries and spills are required. Procedures for handling non-conforming waste are required Inspection procedures for storage of SLABs are required; Documented inspections of both the SLABs and the storage area are required. So what does this mean? Slide 10 10 Rigorous oversight and inspections by Regulatory Agencies; Customer audits and due diligence; SREA U.S Regulatory Background In addition there are Slide 11 11 Good Management Practices Slide 12 12 Good Management Practices Slide 13 13 Good Management Practices Slide 14 14 Good Management Practices Slide 15 15 Good Management Practices Slide 16 16 Good Management Practices Slide 17 17 Good Management Practices Slide 18 18 Good Management Practices Incoming material basics Prior to transferring received material (SLABs and containers) check for : Leakage Labeling Batteries that are broken, cracked, leaking, or not stacked upright Sampling can be and may be required Slide 19 19 Good Management Practices Unloading Batteries Handle batteries in a manner that prevents the spilling of battery liquid Clean up any spillage immediately Banding should be placed in the appropriate disposal container Contaminated pallets should be washed before reuse or disposal Slide 20 20 Good Management Practices Slide 21 21 Good Management Practices Storage of material Batteries are to be palletized and stacked upright All containers and pallets of batteries must be stacked in a safe manner (shifting potential addressed) and there must be adequate aisle space (to accommodate inspections and emergency response) All containers must remain closed and labeled Material is to be properly labeled Slide 22 22 Good Management Practices Slide 23 23 Good Management Practices Slide 24 24 Good Management Practices Slide 25 25 Good Management Practices Slide 26 26 Good Management Practices Slide 27 27 Good Management Practices Slide 28 28 Good Management Practices Slide 29 29 Container Storage Area Not in a 100 year flood plain Materials of construction must be compatible with the material to be stored. The base must be free of cracks and gaps and sufficiently impervious to contain leaks, spills and rain Ability to remove liquids within a short timeframe Secondary containment must be capable of handling 10% of the maximum liquid capacity in storage Prevent or manage run-on Prevent containers or waste from coming in contact with standing water Inspections Slide 30 30 Truck Management Slide 31 31 Truck Management Slide 32 32 Inspections Types of Inspection Inspections of incoming material Inspections of material in storage area (weekly) Inspections of storage area (weekly) Slide 33 33 Inspections Slide 34 34 Inspections Battery Storage Area: Drums, Boxes and Containers Are all containers closed and capped? Are all containers in good condition? (No severe dents, cracks, splits or corrosion?) Are all containers intact (no leaks or spills)? Are all containers labeled with hazardous waste labels (including accumulation dates)? Slide 35 35 Inspections Storage: Are all containers in an upright position? Are all containers stacked in a manner which allows adequate aisle space for inspection around and through the area? Are containers stacked in a manner to ensure safety and stability? Slide 36 36 Inspections Area: Is the surface free of cracks? Is the surface clean (free of debris)? Is the surface free of standing water? Is the surface free of spills or leaks? Is the surface coating intact (no signs of wear)? Are the warning signs posted? Slide 37 37 Inspections Secondary Containment System: Is the run-off/spill containment system intact? (No signs of wear or cracks?) Is the containment system clean and clear? Slide 38 38 Inspections One last word on inspections If you are going to document your MISTAKES make sure you document your CORRECTIVE ACTIONS Slide 39 39 Summary Battery Recycling is a success story Battery Recycling is the right thing to do In the US, the battery reclamation process at Secondary Lead Smelters is a highly regulated and controlled process to protect the environment. Slide 40 40 The supreme reality of our time is the vulnerability of our planet. President John F. Kennedy speech June 28,1963 Slide 41 41