Lead-acid batteries are commonly used to power equipment like electric vehicles, forklifts, and industrial machinery, and also as backup power sources for things such as a building’s lighting and fire protection systems. These batteries are feasible because of their low upfront costs, as well as their ability to be recharged and limit costs long-term. But even just bringing them on site to a facility subjects a business to regulations under the EPA’s Emergency Planning and Community Right-to-Know Act (EPCRA).
EPCRA reporting is required
Generally, lead-acid batteries consist of lead-based plates that sit in a bath of sulfuric acid and water, or electrolyte. In the eyes of EPA, this qualifies them as a hazardous chemical. And whether in use or hooked up at a recharging station, a lead-acid battery on site at any facility requires EPCRA reporting.
Lead-acid batteries on site
When a facility brings any new chemical on site, various regulations can apply to that chemical. EPCRA is one such regulation. The purpose of EPCRA is to encourage both a Local Emergency Planning Committee (LEPC) and State Emergency Response Commission (SERC) to plan for emergencies caused by potential chemical hazards present in their communities. Facilities must therefore report certain chemicals above a threshold to these entities, including the sulfuric acid in lead-acid batteries.
Of particular concern are Extremely Hazardous Substances (EHSs). An EHS is any chemical that “could cause serious irreversible health effects from accidental releases,” as defined by EPA. EHSs are published in Appendix A and B of the Code of Federal Regulations, and sulfuric acid is included on the list with a Threshold Planning Quantity (TPQ) of 1,000 pounds. The TPQ is the threshold for which a facility must determine if they need to report an EHS to their SERC and LEPC.
Because lead-acid batteries are generally considered a mixture, the amount of sulfuric acid must be aggregated across all batteries and other sources of sulfuric acid within a facility. Per EPA regulations, once the 1,000-pounds threshold is met, federal EPCRA rules are that the notification to the SERC and LEPC must be made within 60 days after a shipment is received or produced on site.
Federal regulations further state the following information must be submitted to the SERC and/or LEPC:
- Emergency Planning Notification – this notice says your facility is subject to the emergency planning requirements of EPCRA Section 302.
- Facility Emergency Coordinator Designation – designates a facility representative who will participate in the local emergency planning process as a facility emergency response coordinator.
- Changes Relevant to Emergency Planning (LEPC only) – a notice regarding any changes occurring at your facility that may be relevant to emergency planning. This notification must happen within 30 days after the changes have occurred.
- Requested Information (LEPC only) – the LEPC can request additional information to help develop or implement their local emergency plan.
The format to submit this information is not specified by the EPA. Rather, the format varies based on what SERC and LEPC your facility must coordinate with.
See our eBook, Lead-Acid Batteries – A Detailed and Interactive Guide
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