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Does
Your LEPC Know Where The Rooms of Batteries Are In YourJurisdiction?
BACKGROUND
Sulfuric acid is
an EHS under Section 302 of EPCRA. All facilities with the presence of
1000 lbs. of sulfuric acid are required to notify SERCs and LEPCs of their
EHSs over the TPQ. In addition, under sections 311 and 312 of EPCRA, 500
lbs. is the reporting threshold for sulfuric acid. Sulfuric acid in lead
acid batteries is reportable under 311 and 312 if a MSDS is required by
OSHA. [Note: Section 302 does NOT involve the issue of whether or not an
MSDS is required by OSHA.
THE
ISSUE
Sulfuric acid is
present in a lot of lead acid batteries and lead acid batteries are being
used for providing uninterrupted power in UPSs. UPSs are being used by a
variety of businesses, such as telecommunications, computer/data
processing, electric utilities, emergency operation centers and a variety
of mission/safety/critical activities which require uninterrupted power.
The fact is that there are decent size rooms full of sulfuric acid
containing batteries in both traditional and non-traditional locations
(i.e., office buildings, high rises, etc.).
At least one
LEPC is looking into this issue. It appears that facilities with UPSs,
particularly in office buildings, have not been real good at reporting
their chemicals as required under EPCRA to the LEPCs and SERCs. Also, from
talking with a local HazMat team member, it may also be that LEPCs may not
have realized that sulfuric acid in lead acid batteries is an EHS.
Thus, the
question is, are other LEPCs aware of this issue and have they addressed
it? What appears to complicate this issue, at least for 311/312, is the
use of wet cell and gel cell batteries and whether OSHA requires an MSDS
for the gel cell batteries.
FYI
In late 1994,
new requirements for stationary battery systems [Article 64] were included
in the Uniform Fire Code (used in the western half of the US). These are
systems having a liquid capacity of more than 100 gallons and are used for
standby, emergency or ups, but where none of the individual lead acid
batteries exceed 20 gallons.
[Notes: Under
Article 64, if the individual batteries exceed 20 gallons each, one must
comply with the existing Article 80 [and the Uniform Building Code]. The
Uniform Building Code contains height restrictions which are determined by
Use Group Occupancy and type and amounts of chemicals. For example, the
"...Uniform Building Code Table 9-B requires a sprinkler battery room with
more than 1,000 gallons of 30-34% sulfuric acid battery electrolyte be
located not higher than the third floor of a building. This is because the
Uniform Building Code would classify such a use as a Group H-Division 7
occupancy."]
Article 64
requires a fire department permit to install or operate a battery system
with more than 100 gallons of corrosive electrolyte. Article 64 fire/spill
provisions cover/include: occupancy separation, spill control,
neutralization material required in the battery room, ventilation, signs,
and smoke detection.
[Source: "An
Analysis of Uniform Fire Code Requirements for Stationary Lead-Acid
Battery Systems" (Sept. 1994) Scott Stookey, Austin Fire Department, TX]
Send: Comments,
LEPC Information, Questions, and Feedback to:
Ruth Ellen
Schelhaus at:
Internet:
rschel@annap.infi.net
Phone day: 202-646-5671; evening: 410-757-1723
Fax day: 202-646-2300, evening: 410-757-3195
Postal: 507 Greenblades Court, Arnold, MD 21012
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