Presentation Details
| Scaling PV End‑of‑Life Decisions: Generator Knowledge, Regulatory Perspectives, and Leach Testing Data Taylor Curtis1, Cara Libby2, Mitch Rencheck2. 1National Laboratory of the Rockies, Golden, CO, USA.2Electric Power Research Institute, Palo Alto, CA, USA.3Electric Power Research Institute, Palo Alto, CA, USA |
Abstract
With approximately 35 GWdc of PV capacity (25–32 million modules) expected to be decommissioned in the United States by 2035, rising to nearly 80 GWdc (126–157 million modules) by 2045 and approximately 130 GWdc (269–336 million modules) by 2050, clear and scalable hazardous waste determinations will be essential for regulatory compliance, operational planning, and domestic resource recovery. Under U.S. hazardous waste law, this determination is often a prerequisite to lawful management of a PV module prior to recycling or landfilling and governs downstream handling, transport, storage, and end-of-life options. Although Method 1311 Toxicity Characteristic Leaching Procedure (TCLP) is the primary compliance pathway to assess the toxicity characteristic, application at scale is complicated by: (1) lack of sampling guidance for PV modules; (2) cost and logistics that constrain high‑volume testing; and (3) documented TCLP result variability. These challenges heighten compliance risk and impede scalable end-of-life management as retirements accelerate. Within the National Science Foundation (NSF) Convergence Accelerator “Securing critical material supply chains by enabling phOtovoltaic circuLARity (SOLAR)” project led by Battelle Memorial Institute, National Laboratory of the Rockies (NLR) and Electric Power Research Institute (EPRI) are evaluating how generator knowledge––often referred to as acceptable knowledge (AK)––can be applied at scale under existing regulations as an alternative to TCLP testing for PV module hazardous‑waste determinations. This work includes a foundational study, consensus building among federal and state regulators and industry on AK for PV modules, and new data on module leaching behavior and composition.
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