Encl. (4) TO COMDTINST 16478.12
First CG District ATON Battery Recovery Site Safety Plan
lead is a secondary issue. Unlike the primary batteries the pH of the
lead acid batteries is more difficult to characterize and will be found
to cover a wide range of values. Any leaking lead acid battery which
field pH test at a value of 2 or less is a hazardous waste.
f)
Leaking lead acid batteries and primary batteries which fail the
field pH test are a hazardous waste. They must be individually
packaged, labeled, and stored separately. As hazardous waste they
will have to be disposed of under a Hazardous Waste Manifest, using
the unit's EPA ID Number or a temporary ID Number will need to be
assigned by the state. Batteries and battery pieces which are
determined not to be hazardous waste may be shipped under a bill of
lading.
C.3
ENVIRONMENTAL MONITORING
a.
Environmental monitoring serves three main functions: a) It provides
the documentation necessary to show that the site has been cleared of
spent batteries. b) Soil samples taken can be used to assess potential
environmental impact of batteries in the environment, and to determine
if there is a need for additional site remediation. c) Monitoring can
be use to show that potential environmental impacts from the cleanup
actions have been minimized, and that a Quality Assurance Plan (QAP)
has been followed, resulting in valid documentation/sample collection.
b.
On the site plan, identify the aid name, acid number, number of
batteries, location of batteries, battery type(s) and condition. The
center or datum of the Site Plan is the largest concentration of
batteries. Indicate a fixed or surveyed object on the Site Plan for
reference. Indicate the direction of North and insert the appropriate
scale. Normally, a 40 foot radius is used. The entire terrestrial
area within the 40 foot radius will be searched for batteries. If
batteries are found outside the 40 foot radius adjust the scale to fit
the site.
The distance from the aid to the last battery found will be considered one
(1) SITE RADIUS. The search for batteries should be extended outward for
one additional SITE RADIUS. For
PAGE 9
Previous Page
