Waste batteries: appropriate measures for permitted facilities

5. Waste treatment appropriate measures

The appropriate measures for waste treatment at regulated facilities with an environmental permit for the treatment of waste batteries.

5.1 Preparing batteries for reuse or further treatment (including sorting, testing, charging, discharging and dismantling)

1. The sorting of mixed batteries into their different types or chemistries must take place in a dedicated area of a building. You must have written procedures for the sorting and repackaging of waste batteries.

Sorting may be undertaken manually or using automated mechanical systems (for example, using infrared, X-ray, laser or optical devices). Where sorting is done manually, site operatives must be given appropriate personal protective equipment and receive regular training on the identification of relevant battery types and chemistries and what to do if any non-conforming batteries or other wastes are identified in a load. If batteries are sorted mechanically then you must have measures in place to monitor and assess the performance and reliability of the sorting process.

The sorting process, including associated loading, unloading and repackaging activities, must be designed and operated in a way that ensures the batteries are handled and treated safely, preventing damage and associated risks, including, for example, short-circuiting, fire or leakage or loss of materials.

Once sorted, the batteries must be repackaged in appropriate containers that are clearly labelled to identify their contents and date of sorting and stored and handled in accordance with the relevant Waste storage and handling appropriate measures.

2. Staff involved in testing, charging and discharging batteries must be appropriately trained in how to do it safely and the equipment used must be tested and inspected regularly by a qualified electrician. Activities involving high voltage equipment and batteries (for example, the testing, charging, discharging or dismantling of EV batteries or similar) must be undertaken by appropriately trained and qualified technicians, for example, holding an Institute of the Motor Industry (IMI) Level 4 certificate for diagnosis, testing and repair of electric or hybrid vehicles and components, or equivalent qualification.

3. Activities involving the testing, charging, discharging and dismantling of batteries must be undertaken in dedicated and marked, well-ventilated areas of a building, away from waste storage areas and flammable or combustible materials. Areas where such activities are carried out on large Li-ion battery packs or modules should be provided with thermal imaging equipment to monitor and identify increases in battery temperature. You must have procedures and measures in place for the safe management of damaged or self-heating batteries identified during these activities, for example, involving their safe removal and insolation.

4. To minimise potential risks such as electric shock, short circuiting and thermal runaway, large battery packs and modules (for example, from electric vehicle (EV) or battery energy storage systems (BESS)) should be tested and, where necessary, safely discharged to an appropriate level before being subject to further treatment (including dismantling, where possible).

5. Large Li-ion battery packs, for example, from EVs or BESS, may contain liquid coolants, including ethylene glycol water solutions. Where relevant, these liquids must be fully drained from the batteries prior to mechanical treatment (for example, shredding). Liquids removed from batteries must be collected and stored in appropriate sealed containers in an appropriately contained or bunded storage area and sent for appropriate recovery or disposal. Other components that should be removed from large Li-ion battery packs where possible, prior to mechanical treatment, include insulation materials (for example, components containing ceramic refractory fibres) and other electronic components such as external electric cables, battery management systems and central processing units and printed circuit boards.

6. The selection and design of the battery discharging process must consider and have measures in place to mitigate and minimise relevant hazards, including, for example, electrical hazards, gas formation, battery corrosion, electrolyte leakage and temperature rise. Where possible, and practicable to do so, you should consider options to recover energy from battery discharging activities.

7. Where solutions and liquids are used to discharge batteries (for example, through immersion), they must be contained in an appropriate tank or container resistant to the chemicals and processes involved and provided with appropriate secondary containment. The liquid used must be subject to regular sampling and testing to inform its reuse or safe disposal, including the need for any treatment.

8. You should give priority to testing and preparing waste batteries where they could be reused. If they cannot be reused, you must make sure they are recycled or recovered at a suitable permitted facility.

9. You should identify and segregate all waste batteries that could be reused as soon as possible to prevent damage to them and to maximise the opportunities for reuse.

10. You must store batteries designated for reuse in appropriate containers and packaging, in a building and separate from other waste batteries.

11. Waste batteries that are subject to the Persistent Organic Pollutants (POPs) Regulations are not eligible for reuse. Where relevant, you should follow our guidance on how to identify and destroy waste that contains POPs and the management of waste lead acid batteries containing POPs.

12. Any batteries that are being prepared for reuse must be fully functional and electrically safe, in accordance with all relevant product safety standards and regulations.

13. If you are preparing batteries for reuse you must take precautions to make sure there is no pollution of the environment. The standards specified elsewhere in this guidance for storage of components, liquids and other materials apply equally when batteries are being tested and prepared for reuse.

14. Following preparation for reuse, an end of waste assessment must be undertaken and recorded, to make sure the batteries meet all of the conditions to be considered a non-waste product, taking into account Environment Agency guidance on the definition of waste and end of waste tests.

5.2 General waste treatment

1. Where wastes cannot be prepared for re-use, they must be treated to maximise the recycling and recovery of materials whether that is at the same facility or by further downstream processing.

2. You must fully understand, monitor and optimise your waste treatment process to make sure you treat waste effectively and efficiently. You must not treat waste to deliberately dilute it or mix any hazardous outputs with any non-hazardous outputs.

3. The treated output material must meet your expectations, and you must fully classify and characterise them to ensure they are suitable for their intended disposal or recovery route.

4. You must identify and characterise emissions from treatment processes and take appropriate measures to control them at source.

5. You must have up-to-date written details of your treatment activities, and the abatement and control equipment you are using. This should include information about the characteristics of the waste you will treat, and the waste treatment processes, including:

• simplified process flowsheets that show the origin of any emissions
• details of emission control and abatement techniques for emissions to air and water, including details of their performance
• diagrams of the main plant items where they have environmental relevance – for example, storage tanks, treatment and abatement plant design
• details of physical treatment processes, for example shredding, separation, compaction, filtration, heating, cooling or washing
• details of any treatment processes (chemical, thermal or biological)
• details of any effluent treatment, including a description of any flocculants or coagulants used
• an equipment inventory, detailing plant type and design parameters – for example, time, temperature, pressure
• waste types to be subjected to the process
• the control system philosophy and how the control system incorporates environmental monitoring information
• process flow diagrams (schematics)
• venting and emergency relief provisions
• a summary of operating and maintenance procedures
• process instrumentation diagrams

6. You must have up to date written details of the measures you will take during abnormal operating conditions to make sure you continue to comply with permit conditions. Abnormal operating conditions may include:

• unexpected releases
• start up
• momentary stoppages
• shut down

7. You should use material flow analysis for relevant contaminants in the waste to help identify their flow and fate. You should use the analysis to determine the appropriate treatment for the waste either directly at the site or at any subsequent treatment site. Material flow analysis considers the contaminant quantity in the:

• waste input
• different waste treatment outputs
• waste treatment emissions

8. You should use the analysis and your knowledge of the fate of the contaminants to make sure you correctly treat and either destroy or remove them.

9. The use of material flow analysis should be risk-based considering:

• the hazardous properties of the waste
• the restricted chemicals in the waste
• the risks posed by the waste in terms of process safety
• occupational safety and environmental impact
• knowledge of the previous waste holders

10. A treatment process may destroy certain substances in the waste. It could also put substances into the air, water or the ground, or produce residues which are sent for disposal. You should minimise the weight of these outputs. The treatment process may produce residues for recovery or reuse, and you should maximise the weight of these outputs.

11. You must not proceed with the treatment if your risk assessment or material flow analysis indicates that losses from a process will cause:

• the breach of an environmental quality standard
• the breach of a benchmark
• a significant environmental impact

12. The treatment plant must be specifically designed, commissioned and operated to be fit for purpose. The designs need to consider chemical process hazards and a hazard assessment of any potential chemical reactions. They also need to consider prevention and protective measures and process management, such as:

• working instructions
• staff training
• appropriate process control measures
• monitoring systems, alarms and interlocks
• plant maintenance
• checks
• audits
• emergency procedures

13. To track and control the process of change, you must have a written procedure for proposing, considering and approving changes to technical developments, or to procedural or quality changes.

14. Where an emission is expected, all treatment plant or vessels must be enclosed and vented to the atmosphere via an appropriate scrubbing and abatement system (subject to explosion relief).

15. You must minimise the release of diffuse emissions to air from activities which may give rise to them (for example, shredding or granulating) by:

• carrying out the activity using enclosed equipment or in an enclosed building
• maintaining the enclosed equipment or buildings under an appropriate pressure
• collecting and directing the emissions to an appropriate abatement system

16. You must make sure that any substances, mixtures and components removed as part of your treatment process are subsequently recovered or disposed of at an appropriately permitted facility.

17. Treatment activities must take place under weatherproof covering such as a roofed building, in a dedicated area provided with impermeable surfacing and sealed drainage and with spillage collection facilities appropriate to the materials being handled. Associated equipment, including hoppers, conveyors, storage skips or bays, must also be provided with appropriate containment or covering to prevent emissions and exposure to rain, wind, extreme temperatures and direct sunlight.

18. Where wastes are shredded, a range of separation technologies may be employed to further segregate and purify the fractions produced. For example, eddy-current separators, electrostatic separators, and density separation. Such treatment processes must be contained, extracted and abated to prevent and control emissions (including, for example, dust, metals, volatile organic compounds (VOCs) and other relevant gases, such as hydrogen fluoride (HF) and hydrogen chloride (HCl)).

19. You must fully characterise and classify fractions produced by your waste treatment processes, including process solutions and effluents, before determining suitable disposal or recovery options. Characterisation must consider all relevant substances, including, for example, those identified in section 5.3 ‘Additional measures for the treatment of waste batteries’ (on this page) and section 7 ‘Emissions monitoring and limits appropriate measures’ of this guidance.

20. You must make sure that any required sample is representative of the waste and has been taken by someone technically competent to do so. A representative sample is one that takes account of the full variation and any partitioning of the material.

21. Wherever possible, you should sample waste fractions and residues in line with relevant guidance, for example:

• WM3 Waste classification – Guidance on the classification and assessment of waste – Appendix D
• EN 14899 Characterization of waste – Sampling of waste materials – Framework for the preparation and application of a Sampling Plan
• CEN/TR 15310 1 Characterization of waste – Waste Collection – Part 1: Guide on the selection and application of criteria for sampling under various conditions
• CEN/TR 15310 2 Characterization of waste – Waste Collection – Part 2: Guide on sampling techniques
• CEN/TR 15310 3 Characterization of waste – Waste Collection – Part 3: Guide on procedures for sub sampling in the field
• CEN/TR 15310 4 Characterization of waste – Waste Collection – Part 4: Guide to the packaging procedures for storage, conservation, transportation and delivery of samples
• CEN/TR 15310 5 Characterization of waste – Sampling of waste – Part 5: Guide on the process of developing a sampling plan.

23. Chemical analysis carried out on waste fractions and residues produced by your treatment process (for example, for process monitoring or waste characterisation and classification) must be carried out by laboratories:

• that have robust quality assurance procedures
• accredited by the United Kingdom Accreditation Service (UKAS) (or equivalent) to BS EN ISO/IEC17025, where possible
• using recognised accredited methods, where they are available

24. You must only use waste codes for single material outputs, for example plastic or metal, where the treatment involved is aimed at producing a pure material fraction. Contamination by other materials must be negligible.

5.3 Additional measures for the treatment of waste batteries

1. Your treatment process must be specifically designed, built, operated and maintained for the type and chemistry of waste batteries that it will treat. For example, taking into account the materials and chemicals contained in the waste, the effect of any residual charge they may contain, and the potential emissions and other risks associated with their treatment, such as chemical reactions, corrosion, fire and explosion and electrical hazards.

2. Other than initial sorting and dismantling activities (see section 5.1 ‘Preparing batteries for reuse or further treatment’ on this page), batteries should not be treated manually by hand, for example, using manual hand tools.

3. Mechanical treatment of waste batteries must take place in dedicated, enclosed treatment plant that makes sure:

• all substances released during treatment are collected and contained
• emissions are prevented and minimised through the provision of appropriate extraction and abatement systems, including gases (for example, steam, other vapours, mists and fumes), dusts and particulates

4. You must have and maintain an emissions inventory that includes information on the potential emissions to air and water from the battery treatment processes undertaken, including their source, nature, composition and fate. The emissions released from a treatment process will vary, depending upon the type and chemistry of the batteries treated and the nature of the treatment processes undertaken. Examples of potentially polluting substances, which should be considered where relevant (based upon the chemistry of the batteries being treated), may include dusts and particulates, metals (for example, lead (Pb), nickel (Ni), cobalt (Co), copper (Cu), cadmium (Cd), manganese (Mn), lithium (Li), mercury (Hg), zinc (Zn)) and VOCs, as well as other substances such as sulphuric acid, ammonium chloride, ammonia, HF, HCl, potassium hydroxide, sulphur dioxide and per-and poly fluoroalkyl substances (PFAS). See Emissions Monitoring and Limits appropriate measures for more information.

5. Where possible, the battery treatment process and associated plant and equipment should be designed and operated to minimise manual handling of waste (for example, using enclosed conveyors and hoppers, forklift trucks).

6. Any liquids released from the treatment process, including wash waters, must be collected and contained in appropriate chemically resistant and bunded containers or tanks. Containers or tanks containing potentially volatile liquids, or liquids that may produce fugitive emissions (including odour, fumes or mists), must be held in fully enclosed containers or tanks. Tank vents must be provided with appropriate abatement where necessary to prevent emissions of volatile substances.

7. Solid waste materials and residues generated and collected from waste battery treatment processes must be collected and held in appropriate containers that are chemically resistant to the materials contained and designed to prevent or contain potential emissions (for example, including emissions of dust, volatile gases or fumes, mists, odour, liquids).

8. Where the battery electrolyte is removed as part of the treatment process (for example, during the treatment of lead acid or Li-ion batteries), the process must be designed and operated to ensure that it is safely collected and contained, and emissions to the environment are prevented (including potential emissions of volatile gases, other gases or fumes, acid mists and odour). The treatment process must also be designed and operated to optimise the removal and collection of the electrolyte and prevent or minimise the contamination of other output factions and materials.

9. The materials and fractions resulting from the shredding of batteries may need to be treated further to remove electrolyte (for example, vacuum drying of shredded Li-ion battery material or washing of the shredded plastic casings of lead acid batteries). Where this is done, the treatment process must be fully enclosed and contained, with emissions directed to an appropriate abatement or collection system.

10. The breaking of lead acid batteries must be undertaken using specialised battery breaking equipment and not using manual tools or other machinery, and in a way that prevents, or where that is not possible, minimises human contact and exposure. Batteries must not be dropped from or crushed by vehicles or mobile equipment. If mechanical saws are used to open batteries, this should be done in a contained enclosure with necessary measures in place to provide sufficient ventilation, extraction and abatement of emissions, safe collection of acid, and protection measures for site operatives (example of a ventilated battery saw). Battery acid must be directly collected and contained from battery breaking operations and held in enclosed acid-resistant tanks or containers provided with appropriate secondary and tertiary containment, and not allowed to collect, drain or accumulate on open surfaces.

11. Dust and acid mist emissions from lead acid battery treatment processes must be collected and passed to an appropriate abatement system (for example, a bag filter or wet scrubber). If gas containing acid mist is sent to a bag filter, mist filters should be installed. Scrubbing water must be sent to an adequately designed waste water treatment plant to treat the pollutants contained (for example, acids and metals).

12. Lead acid battery storage and treatment areas must be provided with acid resistant surfaces and sealed drainage systems to collect any spillages, which are connected to dedicated waste acid storage tanks or an on-site effluent treatment plant. All equipment used must be acid-resistant.

13. Any mechanical treatment of lithium batteries, or other batteries or wastes containing flammable substances (for example, electrolytes or solvents), must be done using specialised processes and plant that are designed and operated to prevent and minimise the risk of fire or explosion. The shredding of such wastes must be done safely under controlled conditions (for example, using an inert gas, under vacuum, in water or other aqueous inerting solutions) to prevent explosions or ignition of the flammable electrolyte and other combustible or flammable substances or materials. Where forced ventilation is used to prevent the risk of explosions, gas concentrations should be kept below 25% of the lower explosive limit.

14. Your plant must be fitted with appropriate process monitoring and control systems, for example, to:

• detect any build-up of explosive or other hazardous gases
• detect changes in operation conditions, for example, temperature, pressure, oxygen concentration, air flow
• trigger appropriate automatic measures being taken (including, where necessary, safe plant shutdown) when relevant safe operating conditions and limits are approached or exceeded, for example, exceedance of oxygen concentration or lower explosive limit

15. You must take measures to prevent the corrosion of plant, equipment or other site infrastructure (including pipework, conveyors, vessels, flanges and fittings) that could come into contact with corrosive substances. Examples of corrosive substances include battery electrolytes (for example, sulphuric acid from lead acid batteries and potassium hydroxide from alkaline batteries) and associated substances or breakdown products (for example, hydrogen fluoride from the reaction between Li-ion battery electrolyte lithium hexafluorophosphate and water). Measures should include:

• use of corrosion resistant materials
• preventing or minimising the formation or deposit of corrosive substances
• regular inspection and maintenance

16. Shredded Li-ion battery material that contains the electrolyte and associated organic solvents should be considered flammable unless tested and demonstrated otherwise. The battery treatment process should be designed and operated as a contained and abated system whereby electrolyte is promptly removed and collected from the shredded material as an integral part of the treatment process and prior to its storage. Treatment to remove the battery electrolyte typically involves drying and evaporation (usually under vacuum) or washing of the shredded material. Treatment processes carried out on shredded battery material must be carried out in a controlled or inert atmosphere unless it has been treated to remove the electrolyte and organic solvents.

17. Any organic solvents or other flammable liquids or gases collected from battery treatment processes must be stored in appropriate vessels that are approved for the safe storage of the chemicals in question and in accordance with all other relevant guidance, for example, HSG 51 The storage of flammable liquids in containers, HSG 176 The storage of flammable liquids in tanks and HSG 140 Safe use and handling of flammable liquids.

18. Certain wastes (for example, Li-ion batteries and associated waste liquids, fractions and residues) may contain substances (for example, organic solvents) that have the potential to form explosive atmospheres. Areas of the site where flammable or explosive atmospheres may occur (for example, waste storage, handling and processing areas) should be assessed and, where appropriate, classified into hazardous zones, in accordance with the requirements of the Dangerous Substances and Explosive Atmospheres Regulations (DSEAR). Further guidance on DSEAR and hazardous area classification can be found on the Health and Safety Executive (HSE) website and in the Approved Code of Practice and guidance (L138).

19. Output fractions from lithium battery treatment processes may pose a fire risk, for example, if they contain substances such as residual electrolyte, organic solvents, or lithium and aluminium metal, or have self-heating properties. Some fractions may also contain reactive chemicals that can generate harmful compounds if they come into contact with water (for example, thionyl chloride can react to produce hydrogen chloride and sulphur dioxide; lithium hexafluorophosphate can react to produce hydrogen fluoride). Such materials, including black mass, must be held in appropriate sealed containers, for example, UN-approved drums, and stored under cover in a dry, well-ventilated location and away from potential sources of heat or ignition (including direct sunlight) and other flammable or combustible wastes. Where necessary, the containers should be designed to allow the safe venting of gases that may be released from the material.

20. Treatment processes must be designed and operated to maximise the recovery of output fractions and materials. Recovered materials include battery electrolytes, which can be recovered for re-use, for example, in the manufacture of new batteries or, in the case of sulphuric acid, used to produce gypsum. The metals used in battery electrodes, for example, the lead plate in lead acid batteries and the copper and aluminium foils in Li-ion batteries, can be recycled. The black mass recovered from the mechanical battery treatment processes can be treated further to recover metals (for example, cobalt, nickel, lithium, manganese and zinc) and graphite, typically involving the use of thermal or hydrometallurgical processes. Battery casing materials (for example, polypropylene from lead battery casings and metal casings from other types of batteries) should also be separated and recycled where possible.

21. Washing and rinsing processes (for example, for cleaning plastics or other recovered fractions or residues) must be undertaken in dedicated and contained plant and equipment, designed, monitored and maintained to provide effective washing to suitable a specification, and enclosed to contain potential fugitive emissions (for example, including VOCs, fumes, mists, spray and steam). Emissions must be collected and directed to appropriate abatement. Where possible, wash water should be reused and treated on-site using an appropriately designed waste water treatment plant or sent for further treatment at an appropriately permitted facility.

5.4 Treatment of waste containing brominated flame retardants (BFRs) and other POPs

1. You must identify, separate and remove any plastic containing BFRs for further treatment. Some BFRs are POPs.

2. You must not mix batteries containing POPs with other batteries during treatment. They must be treated separately. You may only treat batteries containing POPs if the treatment process separates the components or materials containing POPs for further treatment. Lead acid batteries with cases made of polymers other than polypropylene, particularly acrylonitrile butadiene styrene (ABS), are likely to contain brominated flame retardants including POPs. Further information is available on the management of waste lead acid batteries containing POPs.

3. You must make sure that any components or materials derived from the treatment of waste batteries that are POPs waste (as defined by Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on persistent organic pollutants) are treated as required by that regulation. This means the treatment must make sure the POP content is destroyed or irreversibly transformed. The only known cost effective way of doing this is by incineration or similar thermal treatment. You must not recycle these materials containing POPs.

4. The treatment of batteries that are not POPs waste, but which may contain POPs in some components or materials, may result in fractions where the POPs threshold is exceeded. You must assess such fractions to establish whether the threshold is exceeded and, where it is, manage those fractions as POPs waste.

5. You may treat materials (for example, plastic) that is POPs waste to separate the POPs containing fractions from the non-POPs containing fractions. For example, density separation can be used to separate plastic containing POPs from that which does not. The non-POPs fraction may then be recycled. You must demonstrate that your process reliably achieves a satisfactory separation.

6. You must fully characterise and classify (including for POPs) process solutions and washings from treatment processes, for example, density separation, before determining suitable disposal options. Where these originate from the treatment of POPs waste, any POPs must be destroyed.

7. If you separate POPs containing fractions (for example, containing BFRs) from non-POPs containing fractions, you must monitor at least once every 3 months how much POPs material is present in any fraction destined for recycling.

8. Other hazardous chemicals may be used as flame retardants. For example, antimony trioxide has been widely used as a synergist with a range of BFRs, not just those that are POPs. It is present in some plastics at concentrations exceeding the hazardous waste threshold. You must consider antimony trioxide when you are classifying plastic containing fractions from the treatment of waste batteries.

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