Liability Management

Considerations for Battery Energy Storage Assets

battery close up

Battery Liability Throughout the Life Cycle

Management of industrial batteries is not a trivial matter. As the volume of advanced, large-form factor batteries grows in the energy and transportation industries, the financial, environmental, and reputational liability exposure increases. Batteries are potentially dangerous products that must be managed safely and responsibly throughout their life cycle. More importantly, at the end-of-life, batteries are considered hazardous waste, and that requires even more careful handling.

Renewance is the one-stop solution for cradle-to-grave management of industrial batteries. We unburden asset owners from attempting to meet challenging regulatory obligations by ensuring effective liability management. This approach safeguards company and personal reputations, especially as batteries reach their end-of-life and need to be recycled or repurposed.

Liability Issues for End-of-Life Batteries

End-of-life management is complex and time-consuming. The process includes:

  1. Battery Removal. Spent batteries are moved from their enclosure or container to an on-site warehouse for shipment preparation. If they are moved off-site, additional regulations apply.
  2. Interim Storage. Several rules govern this step, including notification of universal waste management to the U.S. Environmental Protection Agency (EPA), type of container, labeling of containers, and the length of time in storage.
  3. Packaging for Waste Transport. The U.S. Department of Transportation (DOT) has promulgated rules regarding outer packaging strength and how the batteries or assemblies are secured.
  4. Transportation. Adherence to transportation safety regulations and HAZMAT training for employees who load, unload, and handle hazardous materials is required.
  5. Recycling. During recycling, the materials within a battery cell must be meticulously separated; a process made more challenging by the presence of epoxy coatings, which complicate deconstruction.
  6. Record Retention. Comprehensive records must be kept for each shipment of universal waste sent from the handler to other facilities.

Each step incurs significant labor and financial cost liabilities. In addition, certain obligations apply when batteries are removed from service, and if these are not met, stiff penalties may be imposed.

Renewance’s mission is to support industrial battery manufacturers, battery energy storage system integrators, and operators of battery energy storage systems by providing responsible stewardship solutions for industrial batteries. We have the expertise and experience to navigate the complexities associated with the logistics and recycling or reuse of end-of-life industrial batteries.

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