Photovoltaic - Solar Modules Proposed As California Universal Waste

California Department of Toxic Substance Control has proposed regulations to add photovoltaic - solar modules as a category under the Universal Waste regulations. Solar modules are a form of photovoltaic technology where a semiconductor material, such as silicon, cadmium telluride or copper indium selenium, is encapsulated between two sheets of tempered glass. Solar modules are relatively simple, being comprised predominantly of a silicon or semiconductor substrate, which for thin–film modules is a thin layer of two or more metal– based semiconductors applied to the surface of glass. Solar modules are likely to exhibit the characteristic of toxicity due to heavy metals (such as cadmium, copper, lead, and selenium) and thus would be classified as hazardous waste, if disposed.

Currently, the volume of waste solar modules in California is very small with the exact number unknown. However, with the increase in deployment of solar modules throughout the state to meet its increasing energy needs, as well as meet the renewable energy goals established by the Governor, that volume of waste solar modules is anticipated to increase at a steady rate over the next 20 years.

The broad objectives of the DTSC regulations are to:

• Establish a conditional exemption in section 66261.6 (recyclable materials) for non–RCRA hazardous waste solar modules that are collected, transported and recycled by being reclaimed as part of a reclamation program administered by a solar module vendor (as defined in the proposed regulations).
• Designate hazardous waste solar modules, that are either RCRA hazardous waste or non–RCRA hazardous waste, as universal waste provided that the solar modules are recycled, not disposed, and are managed in accordance with the existing requirements of chapter 23 (Standards for Universal Waste Management).
• Maintain the existing hazardous waste requirement for recycling activities, including reclamation activities and other forms of hazardous waste treatment activities, which require a hazardous waste facility permit or other grant of authorization from DTSC.

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