EPA considers lead-acid batteries a hazardous chemical and, depending on quantities and thresholds, they can come under the agency’s requirements for chemical inventory reporting. When batteries are on site, and you’ve made the appropriate notification to the SERC and LEPC to satisfy EPCRA Section 302 requirements, the next step is to determine whether you have to report lead-acid batteries (or their components) under EPCRA Sections 311-312 for Hazardous Chemical Inventory Reporting Requirements.
Sections 311-312 require any facility with chemicals in quantities that equal or exceed the following thresholds to report lead-acid batteries in these instances:
Before we dive into how to report the batteries, let’s take a look at a typical SDS for a lead-acid battery. Most SDSs will break out the components like this:
The main components of lead-acid batteries are lead and/or lead oxide and the electrolyte (sulfuric acid and water). Other components should be reviewed as well; however, neither antimony or polypropylene are listed in Appendix A and B, so the general threshold of 10,000 pounds would apply to them if you’re reporting by component (unless your state has specific thresholds).
Lead and/or lead oxide is not listed as an EHS in Appendix A or B either, and therefore does not need to be aggregated across different sources of lead per EPA’s guidance document. Primarily, sulfuric acid will be the chemical used to determine if you must report because of the TPQ. For sulfuric acid, the TPQ listed in Appendix A/B is 1,000 pounds. Therefore, the lower threshold of 500 pounds should be used.
To calculate whether or not the battery(s) you have on site exceed the TPQ or 500 pounds (whichever is lower), you’ll need the total weight of the battery. For this calculation, let’s assume the battery weighs 60 pounds. To calculate the total amount of sulfuric acid in the battery, multiply the weight (60 pounds) by the percentage of sulfuric acid (44%). The result is 26.4 pounds of sulfuric acid.
60 lbs x .44 = **26.4 pounds**
Generally, one battery will not push you over the threshold unless it’s very large. Let’s say you have 20 of these batteries because you’re using them to power forklifts on site and batteries are routinely on the charging station. In this situation, you would take the 26.4 pounds of sulfuric acid and multiply it by the number of batteries you have on site, which is 20.
26.4 pounds of sulfuric acid x 20 batteries = **528 pounds of sulfuric acid**
In this situation, the amount of batteries you have on site have exceeded the threshold, and you are indeed required to report the sulfuric acid as an EHS.
Are you also in charge of meeting the Waste compliance for your organization? Download our new guide Hazardous Waste Documentation Retention: What Do You Need to Keep, and for How Long to ensure you’re meeting the EPA’s Waste (RCRA) records requirements.
See our eBook, Lead-Acid Batteries – A Detailed and Interactive Guide
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Megan is Encamp’s VP of Compliance & Customer Success and formerly a Senior Environmental Scientist. But she’s also a Certified Environmental and Safety Compliance Officer® (CESCO), an EHSMS Internal Auditor, a Certified Hazardous Materials Manager, eRailSafe certified, a HAZWOPER 40 Hour - Emergency Response Technician, and skilled in RCRA, DOT, and ISO 14001. Obviously, she knows “compliance.”