Designing battery and e-waste recycling facilities: Three challenges you can’t ignore

Article summary: Designing battery and e‑waste recycling facilities involves navigating complex and interconnected environmental challenges. Air emissions, wastewater, and waste classification can significantly influence permitting, project timelines, and long-term performance if not addressed early. As battery technologies and recycling methods continue to evolve, these considerations are becoming more difficult—and more critical—to manage. In this article, we highlight common challenges and share practical insights to help teams reduce risk and improve project outcomes.

Designing new facilities or updating processes at battery and e‑waste recycling facilities isn’t just an engineering exercise. It requires integrating evolving technologies, planning for variable feedstocks, and navigating some of the EPA’s most complex environmental regulations—all at the same time.

As demand for lithium-ion batteries accelerates—driven by electric vehicle adoption and broader electrification trends, including battery energy storage—the scale and pace of battery manufacturing and recycling are increasing rapidly. Global battery production is projected to surpass 4 TWh by 2030, significantly expanding the volume of materials that must be managed, processed, and ultimately recycled. At the same time, lead-acid batteries remain a critical part of automotive and industrial applications, with a well-established and active recycling market. In fact, lead-acid batteries continue to be one of the most recycled products in the world, even as lithium-ion systems continue to grow and reshape the market.

As complexity grows, so does project risk

As more of these battery and e‑waste recycling facilities are developed—often on accelerated timelines—the complexity doesn’t go away; instead, it becomes more difficult to manage. Where projects often run into trouble is not in the complexity itself but in how that complexity is handled. When key environmental considerations are underestimated or addressed too late in the design process, the impacts show up quickly in the form of higher construction costs, permitting delays, and operational constraints.

Three environmental areas consistently have the greatest influence on project outcomes: air emissions, wastewater treatment, and waste classification.

Whether processing lithium‑ion batteries, lead‑acid batteries, electronic scrap, or mixed-material streams, recyclers often face tightly interconnected environmental regulatory programs. A single process change can trigger multiple requirements for air emissions, wastewater discharges, waste management, fire protection, and more—yet those connections aren’t always obvious early in design. And when these requirements are handled sequentially rather than as part of a coordinated strategy, risk compounds.

In our experience working on battery and e-waste recycling projects, three environmental areas consistently have the greatest influence on project outcomes: air emissions, wastewater treatment, and waste classification. Addressing them early, in an integrated way, can make the difference between a smooth path forward and a project that requires course correction midstream.

Managing air emissions from shredding and thermal processes

In battery and e-waste recycling facilities, an incomplete or inaccurate understanding of air emissions can result in permitting risks with direct impacts on agency/public credibility, construction timelines, and overall project cost. When emissions are not well understood early in design, projects can encounter increased regulatory scrutiny, delays in permitting, and downstream impacts such as redesigns, schedule disruptions, and higher capital costs. Those risks often emerge when a facility’s actual air emissions differ from early design assumptions or when proposed emission-control strategies are not aligned with feedstock chemistry and operating conditions.

Understanding emission sources and variability

Battery and e‑waste recycling processes can generate particulate matter, metal‑bearing dust, volatile organic compounds (VOCs), acid gases, and other regulated pollutants. Shredding, crushing, drying, thermal processing, material transfer, and dust collection systems can each introduce distinct emission profiles depending on the feedstock and process design.

Lithium‑ion battery processing presents a distinct set of challenges. Depending on the state of charge, preprocessing approach, and operating conditions, facilities may need to address thermal runaway risks, shorting or fire potential; electrolyte off‑gassing; the formation of hydrofluoric acid; and particulates containing metals such as nickel, cobalt, and manganese. In these systems, those metals are typically present as oxides rather than elemental metals—unlike conventional metal dust hazards, where finely divided metals can be combustible or explosive due to high surface area. This distinction can influence emission behavior and control strategies.

Lead‑acid battery recycling brings its own considerations, including lead-bearing particulates, acid mist, and fugitive dust. E‑waste feedstocks add another layer of variability, with compositions that can differ significantly depending on the source material.

How emissions assumptions and timing drive risk

Across these scenarios, risk is most often introduced when teams:

• Rely on incomplete or overly simplified emission inventories
• Select emission-control technologies that don’t align with actual process chemistry
• Delay evaluating air-dispersion modeling and regulatory thresholds until late in the design process

The common thread is timing. When air emissions are addressed early—using realistic, process-specific data—they become far more manageable for both permitting and facility design. When they’re deferred, they often force redesign and create delays that carry through the rest of the project timeline.

This is where Barr’s integrated approach to engineering design and environmental permitting starts to pay off. Evaluating emissions alongside process decisions helps teams make choices that hold up through permitting and into operations.

Designing wastewater systems for complex chemical streams

Wastewater is another area where early assumptions can quickly give way to more complicated realities.

In battery and e‑waste recycling facilities, wastewater treatment is rarely “plug and play.” Even facilities expected to be primarily “dry” operations often generate regulated wastewater streams once air pollution controls, fire protection systems, and routine operations are fully considered.

Drivers of wastewater complexity

These streams can include acids, dissolved metals, suspended solids, salts, fluorides, organics, solvents, and semi‑volatile compounds—originating from wet shredding, hydrometallurgical processing, air pollution control equipment (e.g., wet scrubbers), equipment washdown, floor drains, stormwater contact areas, battery discharge systems, neutralization steps, and spill response activities.

Additional complexity comes from intermittent events. Fire suppression, decontamination, and routine maintenance activities can introduce high‑volume wastewater flows that must be anticipated early, not retrofitted later.

Planning early for wastewater system performance

The challenge isn’t just treatment—it’s understanding the volume and type of wastewater streams and how they interact within the facility. That’s why early planning typically focuses on:

• Identifying and characterizing expected sources
• Determining whether streams should be segregated or combined
• Evaluating reuse or recycling opportunities
• Understanding discharge requirements

At the same time, treatment-system design must account for residuals such as sludge, filter cake, or spent media, which may require separate waste determinations.

Early planning for wastewater is especially important since wastewater management decisions are often closely tied to other systems.

Wastewater decisions rarely exist in isolation. Early planning for wastewater is especially important since wastewater management decisions are often closely tied to other systems. A wet scrubber used for air emissions control, for example, may transfer pollutants into wastewater and hazardous waste streams. Similarly, metals removal processes, such as precipitation systems, can generate solids that require additional handling, storage, and disposal considerations.

Even containment systems designed to capture firefighting water or fluids generated during spill response can influence wastewater volumes in ways that affect tank sizing, secondary containment, and permitting strategy.

When these factors are evaluated together, they can be managed holistically. When they’re addressed independently, they often create downstream conflicts.

Navigating waste classification and facility permitting

Waste classification is another area where early decisions have long-term implications.

In battery and e‑waste recycling, regulatory determinations are rarely static. Materials change as they move through collection, storage, and processing, and those changes can shift the way they are regulated.

How materials shift regulatory status

Lithium‑ion batteries illustrate this complexity. While EPA guidance classifies many discarded lithium‑ion and lithium primary batteries as hazardous waste due to ignitability and reactivity characteristics (D001 and D003), they may also be managed under universal waste regulations. That distinction matters, because regulatory status can change once batteries enter the recycling process.

Processing steps can move materials from one regulatory category to another—triggering new requirements.

Processing steps such as shredding, disassembly, thermal treatment, or electrolyte removal can move materials from one regulatory category to another—triggering new requirements around storage, containment, accumulation time, training, permitting, recordkeeping, and emergency planning.

Lead‑acid battery recycling follows a different but equally structured regulatory path, with spent batteries excluded from federal universal waste rules and managed under separate provisions (40 CFR Part 266, Subpart G). At the same time, processing residues, treatment sludges, and recovered materials may still require independent waste determinations.

E‑waste introduces additional variability depending on material composition, including the presence of metals such as lead, cadmium, mercury, and chromium, as well as brominated compounds. How those materials are processed and stored plays a key role in how they’re ultimately classified.

How classification decisions shape facility design

These waste classifications aren’t just regulatory—they’re design drivers.

They influence building layout, process containment design, and fire protection requirements under frameworks such as the International Fire Code (IFC), National Fire Protection Association (NFPA), and local regulations governing battery storage, hazardous material quantities, ventilation, and fire suppression systems. They also affect whether a facility is regulated as a generator or is subject to potentially lengthy permitting as a treatment unit, storage facility, or recycler under state and federal programs.

When these decisions are aligned early with facility design and permitting strategy, projects move forward more predictably. When they’re not, they tend to surface later as design revisions or permitting challenges and delays.

Integrated thinking minimizes risk and improves outcomes

Across battery and e-waste recycling facilities, one theme shows up consistently: environmental systems and project design are interconnected.

One theme shows up consistently: environmental systems and project design are interconnected.

A change in shredding configuration can alter air emissions. An air pollution control decision can shift pollutants into wastewater. A wastewater treatment system can generate hazardous residuals. Storage or accumulation decisions can affect fire code requirements, building design, and permitting pathways.

Individually, each decision may seem manageable. Together, they can either support a well-coordinated design—or introduce compounding risk.

When these elements are addressed independently or too late in the design process, projects are more likely to encounter permitting delays, redesigns, and operational limitations. When they are addressed together, early in the design process, the outcome is very different.

Why integrated planning leads to better outcomes

Facilities that take an integrated approach are better positioned to:

• Navigate permitting more efficiently
• Avoid late-stage redesigns
• Build systems that operate reliably and safely
• Maintain flexibility as operations evolve

This is where combining engineering design and environmental expertise becomes a strategic advantage. Aligning regulatory requirements with process and facility design from the outset helps reduce risk and create a clearer path from concept through operation.

Aligning regulatory requirements with process and facility design from the outset helps reduce risk and create a clearer path from concept through operation.

Barr partners with battery and e‑waste recycling operators to support that alignment—helping integrate environmental considerations into design, permitting, construction, startup, and ongoing compliance.

In a regulatory landscape that continues to evolve alongside battery technologies and recycling methods, integrated environmental planning isn’t just about compliance—it’s a core part of how successful facilities are designed.

If you’re navigating these challenges in your own facility, contact our team to explore how an integrated approach can support your project from design through operation.

About the authors

Anne Weaver, senior mechanical engineer, has 18 years of experience, including nearly nine years with mining group RTK, supporting clients across a range of industries. Her work includes managing project teams, developing budgets and schedules, navigating highly regulated manufacturing environments, and collaborating with government organizations. She has led a variety of initiatives, including multiple R&D efforts, and has experience scaling technologies from benchtop to pilot plant and full-scale production facilities. Her background spans direct air capture (DAC), mineral processing, and manufacturing applications, and she has conducted third-party gap reviews to help clients identify risks and strengthen project outcomes.

Kim Alfonsi, vice president and senior environmental consultant, has more than 30 years of experience supporting air permitting and compliance efforts across industrial sectors. She serves as a principal and senior technical resource on projects involving New Source Review, Title V, and minor sources, with experience spanning the power, pharmaceutical, manufacturing, and battery recycling industries. Her work includes developing and managing compliance programs for air, chemical reporting, and water, as well as working directly with regulatory agencies to support permitting strategy and negotiations.

Grace Ricker, senior chemical engineer, has a decade of experience helping industrial clients address air regulatory requirements. She supports air permitting and compliance projects through regulatory evaluations, permitting analysis, enforcement actions, and routine reporting, and serves as a project manager across the manufacturing, power, and fuel sectors. Her experience also includes work on lead and lithium battery recycling projects, bringing a practical understanding of the air compliance challenges associated with these facilities.

Greg Patten, senior environmental scientist, has more than 40 years of experience supporting clients through complex environmental compliance challenges. His work includes merger and acquisition support, pre-purchase asset analysis, and the development of environmental permitting and compliance strategies. He has led multimedia compliance audits, prepared permitting and compliance plans, and developed environmental management systems. Greg also helps clients navigate regulatory requirements when siting, constructing, and modifying new and existing facilities.

Paul Schiller, vice president and senior structural engineer, has more than 30 years of experience and specializes in the execution of large, multidisciplinary projects for heavy industry. In recent years, he has led project teams as a project manager or principal engineer for industrial mining and manufacturing facilities across the full project lifecycle—from concept studies through permitting, design, construction, and startup. His experience includes project planning, conceptual design and economic analysis, structural design and detailing, plan and specification preparation, on-site inspections, and construction support. Paul has also led multidiscipline teams on over 100 battery recycling projects, including ongoing work at secondary lead smelters in Minnesota, Missouri, and Florida.