There are two ways of reporting lead-acid batteries for Tier II reporting, according to the EPA. Some states have published guidance on how they expect lead-acid batteries to be reported. Here are couple state sources:
- Texas: https://www.tceq.texas.gov/assets/public/permitting/tier2/Lead acid battery guidance.pdf
- California: https://calepa.ca.gov/wp-content/uploads/sites/6/2016/10/CUPA-Bulletins-2011yr-April28.pdf
- Oregon: https://cr2khelp.zendesk.com/hc/en-us/articles/360020742552-Reporting-Lead-Acid-Batteries-in-CHS-Manager
EPA’s recommended approach states that a facility should be consistent in reporting between 311 (SDS Reporting) and 312 (Chemical Inventory Reporting). EPA also states that the submission of the Tier II form can be used for 311 purposes for hazardous chemicals brought on site between October 1 and December 31, but confirm with your SERC and LEPC. For 311, when a new chemical is brought or produced on site and it exceeds its threshold, facilities must submit the SDS of the chemical to their SERC, LEPC, and local fire department within 3 months. For lead-acid batteries, the SDSs generally combine all components of the battery into one SDS. This may differ if you manufacture, refill, recycle, or provide maintenance on lead-acid batteries at your facility. If that’s the case, you may have the bulk ingredients on site and therefore have different SDSs per ingredient. For the general use case, facilities will submit SDSs for the entire lead-acid battery to comply with 311. And based on EPA’s guidance mentioned above, reporting between 311 and 312 should be consistent and therefore reporting on the battery, not the components. However, if lead-acid batteries are not the only source of sulfuric acid at your facility, it may make sense to report sulfuric acid aggregated across all forms.
When reporting lead-acid batteries as a mixture, be sure to include physical and health hazards associated with every mixture component listed on the SDS. Depending on what state your facility is in and what reporting system they have chosen to use, you may have to report the overall mixture as an EHS or the mixture component (sulfuric acid, in this case) as an EHS.
If you’re required to use EPA’s Tier2 Submit software to file your Tier II report, here is what your lead-acid battery will look like reported as a mixture.
EHS is marked as Yes because they require the overall chemical to be marked as an EHS if one of the mixture components is an EHS.
If your SERC uses E-plan for submissions, the system will require the overall chemical to be marked as an EHS, just like Tier2 Submit. Below is an excerpt from their instructions.
Tier II Manager
If your SERC (or LEPC) uses Tier II Manager as their portal, you will have the option of indicating that the lead-acid batteries contain an EHS and that is exceeds the TPQ. Below is a screenshot from a PDF report out of Tier II Manager.
If you decide to report the sulfuric acid separately, the reporting is a little more straightforward. Since sulfuric acid is an EHS, you will simply check the EHS box on whichever system your SERC uses.