The Lifecycle of a Lead-Acid Battery

Lead-acid batteries are a commonly used device to power cars, powered industrial trucks, i.e. forklifts or lift trucks, and serve as backup power sources to cell towers. Generally, these batteries are comprised of lead based plates that sit in a bath of sulfuric acid and water, which is called electrolyte. Lead-acid batteries are commonly used to power so many different devices and vehicles because of their ability to be recharged and their low cost. We’ll walk you through bringing a lead-acid battery on site at your facility and what reporting is involved. We’ll also walk you through handling damaged lead-acid batteries, in case of a spill or broken battery.

Bringing a Lead-Acid Battery On Site

When a new chemical is brought on site, there are several regulations to consider that can trigger additional requirements for your facility and organization. One of those regulations is the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA’s purpose is to encourage local committees and states to plan for emergencies caused by potential chemical hazards that are present in their communities. In order for the Local Emergency Planning Committee (LEPC)and the State Emergency Response Commission (SERC) to become aware of these chemical hazards, facilities are required to report certain chemicals above a threshold to these entities. Extremely Hazardous Substances (EHSs) are of particular concern. These are chemicals that “could cause serious irreversible health effects from accidental releases,” defined by the EPA. EPA publishes a list of EHSs in Appendix A & B. Sulfuric acid is listed on the list of EHSs with a Threshold Planning Quantity (TPQ) of 1,000 pounds. The TPQ is 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 needs to be aggregated across all batteries and other sources of sulfuric acid. Once the 1,000 pounds threshold is hit, federal EPCRA rules state that the notification to the SERC and LEPC must be made within 60 days after a shipment is receive or it’s produced on site. The federal regulations state that the following information must be submitted to the SERC and/or LEPC:

  • Emergency Planning Notification – this is the notice that says your facility is subject to the emergency planning requirements of section 302
  • Facility Emergency Coordinator Designation – this is the designation of 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) – this is 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 the above information is not specified by the EPA. The format varies based on what SERC and LEPC your facility must coordinate with.