42 days: Batteries again…EPA’s “Rules of thumb”
SARA 312 Tier 2: 42 Days until deadline & counting down
How many pounds of batteries make my facility reportable?
(Exerpted from Michigan Environment, Great Lakes and Energy EGLE 2nd Tier2 webinar, see link at bottomo)
Sulfuric Acid is an Extremely Hazardous Substance reportable at 500 Pounds. Here’s the criteria EPA uses if you don’t have a manufacturer-specific Safety Data Sheet:
Lead: 2/3 of the weight of the battery
Battery acid: 1/3 of the weight of the battery
Sulfuric acid: 1/3 of the weight of the battery acid, or 1/9th of the weight of the battery, or about 11%
So how many pounds of batteries make my facility reportable for Sulfuric Acid: 5556 Pounds
Lead for those 5556 pounds of batteries that trigger thresholds = 3704 pounds of lead, so not “Reportable by Amount” (greater than 10,000 pounds) for Hazardous Substances (require a Safety Data Sheet)
So how many pounds of batteries get us to 10,000 pounds of lead in the batteries? 10,000 / .67 (2/3) = 14,925 pounds, or since we already had 5556 pounds of batteries, an additional: 14925-5556
= 9369 additional pounds of batteries to be reportable for Lead
If these are car batteries such as in Uninterruptible Power Source UPS systems, car batteries weigh about 60 pounds each, so that’s 157 batteries (rounding up since we can’t have a fraction of a battery).
Car batteries at 60 pounds each = 157 batteries in addition to the original 5556 pounds of batteies
to have 9369 pounds of batteries (not unusual for large UPS systems).
Of course, for large forklifts, you will need to get the weight of the battery from the Manufacturer or faceplate. Really easy to exceed your reporting thresholds for both Sulfuric Acid and for Lead in that case.
Note that if you have actual Safety Data Sheets for batteries the amount of Sulfuric Acid may be a percent or 3 lower than the EPA guidelines. Your call whether it’s worth the extra work to track that information down if you don’t already have it.
Some forklifts are now using lithium batteries, which can be even more reactive if damaged.. Currently, unless your local regulatory agency has mandated differently, he threshold for Lithium Ion batteries is still 10,000 pounds (Hazardous substance, one that requires a Safety Data Sheet, we call those “Reportable by Amount” (compared to “Reportable by EHS” for items reportable because they have exceeded their Extremely Hazardous Substance threshold (500 pounds or the TPQ, whichever is lower).
Call to Action: Share your method of collecting your battery inventory. Whose is the least burdensome?
More tomorrow, here’s to March 2nd!
Michigan EGLE links from first and second webinars of 2022 SARA 312 virtual training courses:
I’m keeping these links for awhile because they are so useful. I’ll post the session 3 recording info when it becomes available. You can sign on and listen even if you didn’t sign up for the webinar series.
RECORDING LINK FOR SESSION 2: Wed Jan 19, 2022.
Really good example on batteries. This is the “in the weeds” how to conduct your threshold determinations episode: https://attendee.gotowebinar.com/recording/4027906237723673347
I talked to Mike Young, one of the presenters, right after the first webinar. He said that it’s not unusual for them to take phone calls from people from other states (with the warning to confirm that your state doesn’t have differences in their requirements compared to Michigan).
RECORDING LINK FOR SESSION 1:
https://attendee.gotowebinar.com/recording/7957790593170499843
PRESENTATION: (I wasn’t able to attach a copy of the presentation, email the link below and they will send it to you)
SARA TITLE III – TIER II REPORTING WEBSITE: http://www.michigan.gov/sara
MICHIGAN FACILITIES’ GUIDE TO SARA TITLE III: https://www.michigan.gov/documents/deq/deq-oea-saraguidebook_509720_7.pdf
CONTACT INFORMATION:
Mike Young and Adam Pohl
517-284-7272
