Once the lead-acid batteries are on site, and you have made the appropriate notification to the SERC and LEPC to satisfy 302 requirements, the next step is to determine whether or not you have to report lead-acid batteries (or their components) under Sections 311 and 312, or the Hazardous Chemical Inventory Reporting Requirements.
Section 311 and 312 requires any facility with chemicals in quantities that equal or exceed the following thresholds must report:
- For EHSs, the TPQ listed in Appendix A and B or 500 pounds, whichever is lower.
- For other hazardous chemicals (that require a SDS), the threshold is 10,000 pounds.
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 the below excerpt:
The main components are lead and/or lead oxide and the electrolyte (sulfuric acid and water). The 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 here. 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 will 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, you will 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 though because you’re using them to power forklifts on site and you always have batteries on the charging station. In that 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 required to report the sulfuric acid as an EHS.