South Africa Battery Recycling

1. South Africa Battery Recycling February 2019

2. Words and Intent Matter • The next three slides show language from the regulation that we feel are important to discuss. • Preamble of the National Environmental Management Amendment Act 62 of 2008 • The definition of ‘best practicable environmental option’ • Part 3 of the NEM Waste Act 59 of 2008

3. National Environmental Management Amendment Act 62 of 2008 • From preamble (page 2): (emphasis added) • sustainable development requires the integration of social, economic and environmental factors in the planning, implementation and evaluation of decisions to ensure that development serves present and future generations • everyone has the right to have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that - • prevent pollution and ecological degradation; • promote conservation; and • secure ecologically sustainable development and use of natural resourceswhile promoting justifiable economic and social development

4. Definitions • “best practicable environmental option” means the option that provides the most • benefit or causes the least damage to the environment as a whole, at a cost acceptable to society, in the long term as well as in the short term • Page 13 – Chapter 1- Principles (4)(b) • Environmental management must be integrated, acknowledging that all elements • of the environment are linked and interrelated, and it must take into account the • effects of decisions on all aspects of the environment and all people in the • environment by pursuing the selection of the best practicable environmental • option.

5. From NEM Waste Act 59 of 2008 • Part 3 • Reduction, re-use, recycling and recovery of waste • 17. (1) Unless otherwise provided for in this Act, any person who undertakes an activity involving the reduction, re-use, recycling or recovery of waste must, before undertaking that activity, ensure that the reduction, re-use, recycling or recovery of the waste— • (a) uses less natural resources than disposal of such waste; and • (b) to the extent that it is possible, is less harmful to the environment than the disposal of such waste. The battery industry feels this agrees with our position that an LCA must be conducted to prove environmental benefit

6. Overall • Batteries do not represent a significant risk to the environment when landfilled or incinerated. • Batteries represent less than 0.1% of landfill weight and even less by volume. • Collection and Recycling of batteries is more harmful to the environment than landfilling and at a high cost to consumers. • The predominant use of spent battery materials is fertilizer. This means batteries can either be placed in the ground or we can spend a lot of time/money/resources with more harm to the environment to put the battery materials on the ground.

7. A Note on Fertilizer • Recent work being finalized out the US is showing only 1-3% of fertilizer is ever up-taken by plants • Most fertilizer is either in the soil permanently or, washes into surface water.

8. A Note on Landfill Content • Batteries represent less than 0.1% by weight (less by volume) • Why focus on 0.1% when far more volume is there? • Should NEA do a study on landfill content?

9. Sustainability and Battery Recycling • At least 11 independent studies since 1987 have shown: • Primary battery recycling: • Energy intensive • Overall net-negative for the environment • Adds more greenhouse gasses to the environment than landfill or incineration • Landfill disposal of spent batteries is a proper and sound management method

10. Various Studies • Fukuoka University Landfill Study – 1987 to present • Waterloo Risk Assessment Study – 1992 • University of Liege Faculty of Medicine, Belgium – 1994 • UK Department of Trade and Industry – 2000 • Solid Waste Association of North American (SWANA) – 2003 • French Environment Ministry Principal Research Agency – Efficiency of Battery and Accumulator Procedures (2006) • UK Department of Environmental Study – 2006 • NEMA Literature Review • Cal Recovery Lysimeter Study - 2010 • NEMA LCA (from MIT) – 2011 • NEMA LCA (From MIT) refresh - 2018

11. 2011 Life Cycle Assessment • North America based recycling • Recycling is more of a burden to the environment than landfill disposal MIT LCA

12. 2018 Life Cycle Assessment Refresh • Recycling is still a burden to the environment compared to landfill

13. Recommendations • Do a review of landfill content for South African waste • Perform a battery recycling Life Cycle Assessment based on the South African market.

14. Appendix • Study summaries to follow if needed.

15. Disposal ResearchFukuoka University (Japan) Landfill Study - 1987 • Evaluated degradation of primary batteries in landfills • Initiation of study predated mercury elimination - focused on mercury release from buried batteries • Batteries not significantly eroded after 20 years • Mercury in leachate was below Japan’s environmental standard • Manganese and zinc levels barely detectable

16. Disposal ResearchWaterloo University (Canada) Risk Assessment - 1992 • Evaluated disposal options / Predated mercury elimination • Dry cell batteries do not represent a concentrated source of heavy metals in municipal solid waste • No evidence that landfilling these batteries presents environmental or health problems • Recycling presents significant risks - health-related problems with separate collection, storage and disposal

17. Disposal ResearchUniversity of Liege (Belgium) - 1994 • Focused on effects of zinc from batteries on aquatic life • Risks to the environment from landfill / incineration not likely to be significant • Contribution of zinc from household batteries to the environment is small, due to: • Relatively small quantities in relation to soil background, • Other sources of elemental zinc • Reduced solubility and mobility in soil • Household batteries can be safely disposed of in landfills • Recycling of primary batteries is not necessary, and may cause safety problems

18. Battery CollectionUK Department of Trade and Industry - 2000 • Environmental Conclusions • Detrimental environmental impacts of collecting and transporting batteries outweigh environmental benefits of recycling • Little evidence to support negative environmental impacts from batteries in the waste stream • As recycling rates increase, more metals are diverted, but at the cost of increasing detrimental environmental impacts • Financial Conclusions • The costs of collecting and recycling consumer batteries are significant, with collection / transport / administration costs dominating recycling costs • Collection and recycling costs would exceed €1100 / ton, even in the most favorable circumstances

19. Disposal ResearchSolid Waste Association of North America - 2003 • Report focused on metals arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver. • Concentration of metals in leachate database for non hazardous waste landfills are ten or more times lower than regulatory levels. “MSW landfills can provide for the safe, efficient and long-term management of disposed products containing RCRA heavy metals without exceeding limits that have been established to protect public health and the environment. MSW landfills should contain the releases of RCRA heavy metal pollutants at levels that protect public health and the environment for extremely long periods of time if not forever.” Solid Waste Association of North American (SWANA) "The Effectiveness of Municipal Solid Waste Landfills in Controlling Releases of Heavy Metals to the Environment.“ - 2003 MSW = Municipal Solid Waste RCRA = Resource Conservation and Recovery Act

20. Disposal ResearchFrench Environment Ministry Study - 2006 • Recycling programs in place since the mid 1990s • Costly and economically inefficient means of managing environmental risks linked to used batteries. • "It appears that selective collection and recycling are no longer desirable for the majority of batteries and accumulators,“ • "The environmental impacts linked to their management alongside household waste does not justify the high costs of recycling." • Strict mercury content limits have radically reduced potential environmental impacts of the most common batteries. • Incineration or landfilling • Cost-effective alternatives to recycling • Little or no increased risk for the environment BNA - International Environment ReporterWednesday, May 3, 2006, Page 313 ISSN 1522-4090

21. Recycling beneficial, but at high cost $400 million for recycling $60 million for landfill Greenhouse gas reduction benefit is 6000 tons per year (small), but: Costs $2550/ton Greenhouse gas trading price today around $9/ton. It is better to collect and recycle batteries containing mercury, cadmium and lead Likelihood of batteries such as alkaline that do not contain hazardous materials to pollute the environment through disposal in landfill sites is very small Note: Energizer challenged ERM on majority of processing as hydrometallurgical recycling in Europe (it is 0%). This would eliminate any recycling benefit. Battery CollectionUK Department of Environmental Study - 2006 6000 x $2550 = $15,300,000/year vs 6000 x $9 = $54,000/year 283 X

22. Literature Review Critical Review of the Literature Regarding Disposal of Household Batteries; Completed Dec 2007 (186 pgs) CalRecovery, Inc. in association with Den Boer Waste Consulting, GER; Fukuoka University, JAP; IMAGE, University of Padova, IT; Univ of Central Florida Covered English, German (incl. German, Austrian, and Swiss), Dutch (including Holland and Belgium), Polish, Italian, Japanese, Korean, Spanish Few studies in most languages – Those that exist do notsuggest household batteries are hazardous

23. Cal Recover Lysimeter Study • August 2007 – November 2008 • Batteries under simulated (laboratory) landfill conditions • Re-circulated leachate (worst case scenario) • Waste content typical of waste in municipal streams • Ten reactors (two control – no batteries, and two each for battery content of typical (0.15% and batteries quartered), intensified (0.15% with 1/5th pieces) and worst case(0.75% and 1/5th pieces) • Levels of battery materials below values for MSW landfills and orders of magnitude below any level considered harmful.