Response to Item C-3-b, Secondary Lead Smelters 

 

Good afternoon Chuck.

On behalf of the Association of Battery Recyclers, I am submitting the attached response to EPA’s survey 

question on Sheet C-3-b regarding use of chlorinated materials (e.g., PVC) in lead-acid batteries. This response 

is made on behalf of all the survey respondents. 

<<PVC Response for ABR21JUL10.pdf>> 

Please let us know if you have any questions, and have a nice afternoon.

Russell

Russell S. Kemp, PE

Principal

ENVIRON International Corporation

1600 Parkwood Circle, Suite 310

Atlanta, Georgia 30339

(Tel) 678-388-1654

(Fax) 770-874-5011

(Cell) 404-374-7836

rkemp@environcorp.com

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From: "Russell Kemp" <rkemp@environcorp.com>

To: Danny.Greene@erg.com; French.Chuck@epamail.epa.gov

Date: 7/21/2010 1:55 PM

Subject: Response to Item C-3-b, Secondary Lead Smelters

CC: Robert.Steinwurtzel@bingham.com

Attachments: PVC Response for ABR21JUL10.pdf

Page 1 of 1
On Form C-3-b of the ICR Survey of the Secondary Lead industry, EPA asks:

It is the EPA's understanding that the potential for emissions of dioxins and furans from furnaces (particularly blast 

furnaces) is related to the presence of chlorinated materials (e.g., polyvinyl chloride (PVC) plastic) in furnace feed 

materials. Please provide any changes in the use of chlorinated materials in battery construction (e.g., decreased 

PVC content) and how these changes, if any, are expected to affect dioxin/furan emissions. 

ABR has inquired with its members and lead-acid battery manufacturers and offers the following 

response on behalf of its smelter members to the above question:

Historically, PVC was widely used as a separator material in the manufacture of all types of lead-acid 

batteries, including automotive Starting, Lighting, and Ignition (SLI) batteries. In the recycling of 

batteries that contain PVC separators, the separators would typically become part of the feed material 

to the smelting furnaces.

The use of PVC as a separator material has been phased out in the manufacture of automotive SLI leadacid batteries. It is believed that this phase-out was essentially completed more than 20 years ago. 

Given the turnover of automotive SLI batteries, it is believed that the phase out occurred long enough 

ago that the SLI batteries being recycled today should be free of PVC separators.

PVC continues to be used in the manufacture of non-automotive lead-acid batteries including reserve 

power batteries (e.g., telecommunications installation standby batteries) and motive power batteries 

(e.g., forklift batteries). Some of the PVC materials used in the manufacture of reserve power batteries 

goes into exterior case materials (including “jars,” covers, terminal rings, etc.) and some internal parts 

that may or may not make their way into the furnace feed depending upon the configuration of the 

recycling facility’s processes for handling non-automotive batteries. PVC continues to be used as a plate 

wrapping material and in other interior components of some motive power lead-acid batteries. In 

general, the PVC in those internal components would make its way into the smelting furnaces at the 

recycling facilities. 

ABR does not have any data from which to form an opinion regarding how the changes in PVC use in 

battery construction over time would have affected dioxin/furan emissions. There are a great many 

variables in addition to the chlorine content of the feed material that affect dioxin/furan emissions. The 

ABR does not have sufficient information to correlate the presence of PVC in feed material with 

dioxin/furan emissions.