Encl. (4) TO COMDTINST 16478.12
Proper Shipping Name = Waste battery, Electric Storage, wet, filled
with acid
Hazard Class = Corrosive material
Identification Number UN2794
Label = CORROSIVE
EPA HAzardous Waste Numbers D002 and D008
(4)
PACKAGING: Batteries shall be double-wrapped in plastic bags,
palletized, and
banded. Batteries will be placed upright with layers separated by a plywood or
cardboard. Onboard the recovery vessel the batteries can be placed in a drum.
Leaking batteries must be packed into individual containers with absorbent
material and isolated.
(5)
The primary concern when handling the lead acid batteries is the
sulfuric acid electrolyte, the
lead and the toxicity of the 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.
(6)
Leaking lead acid batteries and primary batteries which fail the field
pH test are both 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.
D.
ENVIRONMENTAL MONITORING
D.1 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
clean-up actions have been minimized, and that a Quality Assurance Plan
(QAP) has been followed resulting in valid documentation/sample collection.
D.2 On the site plan, identify the aid name, aid number, number of
batteries, location of batteries, battery type(s) and condition. A standard 50
foot radius scale is provided on the site plan form. Generally, the entire
terrestrial area within the 50 foot radius will be searched for batteries. If
batteries
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