Encl. (4) TO COMDTINST 16478.12
First CG District ATON Battery Recovery Site Safety Plan
a)
General: The air-depolarized batteries consist of an inert plastic
or hard rubber case , potassium hydroxide liquid electrolyte, zinc-
mercury alloy anode, carbon cathode, and an insoluble residue or
lime bed. The Saft batteries will also contain a starch based
electrolyte gelling agent. The pH of the electrolyte is close to
14. The EPA Hazardous Waste Identification Number for these
batteries should be D002 (corrosivity). You may note that under
COMDTINST M 16478.1B they are also identified as waste code D009
(toxicity characteristic for mercury). Actual TCLP analysis for
mercury indicates that the D009 is not necessary, see Figure C.2. a
for TCLP analysis results. Also, if the batteries have been broken
open and the electrolyte has been diluted/neutralized by contact
with sea water or the pH otherwise cannot be measured as 12.5 or
more, the battery carcass does not meet the definition of a
hazardous waste, but should be disposed of or recycled utilizing
normal battery disposal procedures.
b)
LABELING: A battery which contains electrolyte (intact) or a broken
battery which fails the field pH test, must be handled as a
hazardous waste. Transportation of these batteries requires the
following information:* Proper Shipping Name = Waste Battery,
electric storage, wet filled with alkali
* Hazard Class = Corrosive material
* Identification Number UN2795
* Lable = CORROSIVE
* EPA Hazardous Waste Number D009
c)
PACKAGING: Intact batteries shall be double-wrapped in plastic
bags, palletized, and banded. Batteries will be placed upright with
layers separated by plywood or cardboard. The total pallet is not
to exceed 4 layers in height. On-board the recovery vessel the
batteries can be double-wrapped and placed into a drum with
absorbent material filling the voids. Any battery which is
determined to be currently leaking electrolyte must be packed into
an individual container and isolated. Upon return to the unit,
batteries will be off-loaded and handled according to the same
procedures used for spent batteries being returned from ATON
servicing. If primary batteries are not
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