How confident are you with EPCRA Tier II reporting for lead-acid batteries?
During our last virtual event, Mastering Compliance Reporting for Lead-Acid Batteries, regulatory compliance experts discussed the most critical lead-acid battery compliance issues confronting EHS managers today before answering questions from the audience.
Jennifer Collins, former Pollution Prevention and Compliance Assistance Manager, IDEM
Eugene Simonds, Compliance Program Manager, Encamp
Watch the full webinar on-demand to learn tried-and-tested, compliance expert-approved strategies to bring your facility into compliance with Tier II requirements.
To get you started, here are our top three takeaways:
A lead acid battery is a rechargeable battery that produces electricity by creating a controlled chemical reaction from submerging lead plates in sulfuric acid.
When we think of Tier II reporting, the first thing that pops into our heads are the most hazardous chemicals we have in the largest volumes. However, even though sulfuric acid is designated an Extremely Hazardous Substance (EHS) by the EPA, lead-acid batteries often get overlooked due to their low chemical volume and prevalence within the industry.
Before bringing new batteries on site, it’s important to remember that because of sulfuric acid’s EHS designation, Tier II reporting thresholds for lead-acid batteries typically are lower. As soon as your facility meets the Threshold Planning Quantity (TPQ) of 1,000 pounds, you must submit a 302 report to the SERC and LEPC and will be required to fulfill additional emergency planning requirements.
Reporting deadlines for facilities that bring lead acid batteries that meet threshold requirements depends on the facility’s jurisdiction, and local requirements may be much shorter than the 60-day federal requirement. For example, facilities meeting reporting thresholds in Pennsylvania have just five days to submit this notification.
With lead-acid batteries being so prevalent and containing a relatively low volume, calculating the total amount of sulfuric acid each facility has is challenging. The first step is to find the amount of acid in each battery.
To do that, you must know the battery weight and what percentage of sulfuric acid it contains. You can find this information on the battery’s spec sheet, which provides battery weight and its safety data sheet (SDS), which will have the percentage of sulfuric acid. Now, multiply those two numbers together, and you have an approximate amount of acid inside the battery.
It’s important to know that if you have a damaged battery, a release of 1,000 pounds triggers notification requirements to the SERC, LEPC, and National Response Center. How you report will vary depending on the location of your facility, and there may also be additional reporting requirements.
However, these reporting requirements only apply to sulfuric acid that leaves your facility. Therefore, if you spill 1,000 pounds of sulfuric acid but capture, clean, and dispose of it properly, there are no EPCRA notification requirements.
Download our Lead-Acid Batteries Guide: The Ultimate Reporting Kit to learn more about reporting lead-acid batteries as a mixture or component, as well as other expert-approved strategies shared by our experts.
If you’re like many EHS managers who struggle with how to report lead-acid batteries for Tier II, don’t worry. If you address these three critical mistakes, you will be well on your way towards EPCRA Tier II compliance.
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Angelica is the Content Marketing Manager at Encamp. She has a love/love relationship with creative marketing, technology, and true crime shows.