Approximately 90% of stationary batteries deployed in US data centers are of the lead-acid type. Lead and electrolyte must be reported in different ways to regulatory agencies depending upon the jurisdictional circumstances. This paper attempts to cut through the maze of regulations and focuses specifically on lead-acid battery requirements in terms that most data center professionals can understand. In general, the rules apply only to very large battery installations, and generally concern planning (reporting the presence of batteries at a site) and accidents (reporting spills or “releases”).
Environmental regulatory compliance is focused on the amount of electrolyte / sulfuric acid and lead in a particular location. Of the three popular technologies, vented (flooded or wet cells), valve regulated (VRLA or sealed) and modular battery cartridges (MBC), flooded batteries contain the highest levels of electrolyte / sulfuric acid and lead. The smaller amounts of electrolyte / sulfuric acid and lead in VRLA and MBC batteries allow for larger battery systems to be installed without the regulatory compliance required of comparable vented batteries.
Common questions that need to be addressed when installing a UPS battery system include the following:
- Will I have to report my batteries as hazardous material (hazmat)?
- Where do I find the rules?
- What are EPCRA,SARA, SERC, CERCLA, LEPC, etc. and why do I care?
- What do I have to declare?
- When do I have to declare it?
- To whom do I have to declare it?
- What forms do I have to use?
- What if I don’t do it?
Most commercial battery back-up systems fall below government-required reporting levels, but large UPS and DC plant batteries may have to comply. Failure to comply can result in costly penalties. Wading through the Code of Federal Regulations can be a complex and time-consuming task.
The following scenario illustrates the common concern about batteries and compliance: An IT manager is responsible for a building into which he will be installing (or maybe already has installed) a large, lead-acid battery system to back up critical operations. He is nervous enough about all these batteries and stored electricity under his roof, and now somebody says that he may have a compliance issue. He’s already been down the road with the electrical inspectors and fire marshals, and now he hears that the Federal Government may have a disturbing interest in his facility as well. Who are these people and what do they want?
Some lead-acid batteries located in data centers are subject to government environmental compliance regulations. While most commercial battery back-up systems fall below required reporting levels, very large UPS and DC plant batteries may have to comply. Failure to comply can result in costly penalties. Environmental compliance regulations focus on the amount of sulfuric acid and lead in a given location. This paper offers a high level summary of the regulations and provides a list of environmental compliance information resources.
- Getting started
- What are the rules
- Emergency planning and response plans
- Summary of inventory reporting steps
Most commercial applications of stationary lead-acid batteries will fall well below the reporting quantities required by the EPA. Flooded batteries are more likely than VRLA batteries to require reporting, whether for reporting inventory or for the release of hazardous materials. Large battery systems can add significantly to a company’s compliance work. Although spills or releases of hazardous material (hazmat) for batteries at the reporting threshold are quite rare, one must nevertheless report the presence of battery inventories in the building to local and state authorities, and one must have an emergency preparedness plan in place.
White Paper Written By:
Stephen McCluer is a Senior Manager for external codes and standards at Schneider Electric. He has 30 years of experience in the power protection industry, and is a member of NFPA, ICC, IAEI, ASHRAE, The Green Grid, BICSI, and the IEEE Standards Council. He serves on a number of committees within those organizations, is a frequent speaker at industry conferences, and authors technical papers and articles on power quality topics. He served on a task group to rewrite the requirements for information technology equipment in the 2011 National Electrical Code.
Universal Networking Services’s partnership with Universal Power Group, Inc. has enabled us to build a strong distribution network of battery and related power components that meet consumer needs for accessibility, portability, security and mobility, coupled with value added offerings such as battery pack assembly and battery replacement/recycling programs.
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