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4 Environmental Analysis 4.17 Utilities and Service Systems Generation of solid waste during the construction phase would be properly disposed of in accordance with applicable statutes and regulations. Similarly, any waste generated during future decommissioning of the Project would be required to be properly managed and disposed of in a licensed off-site landfill or recycling facility. Therefore, the proposed Project would not exceed state or local standards or exceed the capacity of the receiving landfills, and impacts related to solid waste generation would be less than significant. Battery Disposal The proposed energy storage system will likely use lithium-ion batteries. Used lithium-ion batteries are not considered hazardous waste by the U.S. Environmental Protection Agency (USEPA); at present there are optional USEPA guidelines (USEPA's Universal Waste Regulations)that address the responsible disposal and recycling of these batteries. Some lithium- ion batteries may be considered hazardous waste under the Resource Conservation and Recovery Act (RCRA) if they exhibit a characteristic of hazardous waste such as ignitability, reactivity, or toxicity when they are disposed. Commercial establishments are responsible for determining whether any waste they produce is hazardous waste, including lithium-ion batteries at their end of life (USEPA 2023). Since some lithium-ion batteries may have more hazardous properties than others, it can be difficult for a waste generator to identify which of its waste lithium-ion batteries are defined as hazardous waste when disposed of. Therefore, where there is uncertainty, USEPA recommends that businesses consider managing lithium-ion batteries under the federal "universal waste" regulations in Title 40 of the Code of Federal Regulations (CFR) part 273 (USEPA 2023). The universal waste regulations provide a streamlined set of requirements for generators of specific types of common hazardous wastes (e.g., fluorescent lamps containing mercury, batteries) from a wide variety of commercial settings. Requirements differ depending on whether waste generators accumulate less or more than 5,000 kilograms of total universal wastes onsite at one time, but they include instructions on how to manage the waste, how to label containers, how long the waste can be accumulated on site, and where the waste can be sent, among others. Universal waste regulations do not require shipment using a hazardous waste manifest but do require that the waste be sent to a permitted hazardous waste disposal facility or a recycler (USEPA 2023). During Project operation, battery cells may occasionally be replaced due to defects or loss of efficiencies. More significantly, all batteries will be removed from the Project site during Project decommissioning. The battery modules included in the BESS will be recycled or disposed of in accordance with the federal and California nonhazardous and hazardous waste requirements applicable at the end of their useful life. Many battery manufacturers offer to reclaim batteries as many of the component parts can be recycled from spent batteries and used in new products. In addition to re-use in new battery cells, the recycled materials extracted can be used in a wide variety of consumer products such as lithium grease, concrete additives, and some glass products. Ultimately, many options exist to manage used lithium-ion batteries, and batteries will not be disposed of in a municipal landfill. Impacts related to battery disposal will be less than significant. Griffith Energy Storage Project 4.17-12 Tetra Tech/SCH 2022120675 Draft Environmental Impact Report August 2023