Battery storage can present serious environmental problems and safety concerns. How you deal with them has a direct impact on your company's bottom line.
You just read another memo about an Environmental Protection Agency (EPA) fine for lead-acid battery problems. This follows on the heels of that burn accident that occurred last month. What can you do to prevent such occurrences? You need to become familiar with the laws, codes, ordinances, and requirements that pertain to the storage, handling, spill, containment, and disposal of stationary lead-acid battery systems (SLABS).
During normal operations, SLABS have their own Pandora's box of environmental compliance, enforcement, and liability concerns. Batteries (whether sealed or flooded) present a potentially large remediation and liability expense in terms of sulfuric acid and lead. Since sulfuric acid and lead are extremely hazardous, the potential of a hazardous material spill exists anywhere you have SLABS.
Such a spill may result from the improper handling of hazardous material discharge or a slow and undetected corrosive breach of a SLABS' containment over time. Both scenarios create a chain of events, which may include opportunities for hazardous exposure to employees, workers, or tenants of the property. If a discharge becomes a spill, then the issue shifts to containment and cleanup.
If you're responsible for the proper handling and periodic monitoring of SLABS, then you should make yourself familiar with the Uniform and National Building and Fire Codes. These codes provide detailed guidelines to simplify your task of making SLABS safe for people and the environment.
The Occupational Safety and Health Administration (OSHA), EPA, and other regulatory agencies operating under such guidelines, want to see more stringent standards for the storage, handling, spill containment, and disposal of hazardous materials. This becomes obvious when you read the recent amendments to Sec. 64 of the Uniform Fire Code (UFC) (formerly known as "Art. 64").
Sec. 64 deals specifically with SLABS' spill containment. This adoption of the new amendment increases the scope of enforcement by including all battery types and reducing the minimum liquid capacity thresholds for the article to apply. Here's an excerpt:
"This change clarifies that the scope of the article applies to all battery types, including gel cell batteries. The definition of lead-acid battery includes all electrochemical cells interconnected to supply a nominal voltage of DC power."
The revision broadens the scope of the article to regulate battery systems with more than 50 gal aggregate capacity rather than 100 gal. The writers of the revision wanted to ensure Art. 64 - rather than Art. 50 - applies to these systems. This brings Art. 64 and Art. 50 in line with the original intent of the standards developers. The electrolyte in most batteries is sulfuric acid, which we classify as a toxic substance (except when the amount is 50 gal in concentrations over 12.5%, according to IFCI's Hazardous Materials Classification Guide).
Art. 80 applies to battery systems with an electrolyte capacity between 50 gal (in unsprinklered occupancies) and 100 gal, and Art. 64 applies to systems over 100 gal. The revision itself says, "More restrictive provisions for a less hazardous commodity do not make sense."
There's another twist to applying Art. 80 across the board, according to this revision. Here's an excerpt:
"The revision also deletes the requirement to apply Art. 80 to battery systems with individual battery capacities in excess of 20 gallons (75.7 L). The provisions of Art. 64 adequately and more specifically cover the hazards related to battery systems."
Additionally, the National Fire Protection Association Sec. 111 (NFPA 111) committee is reviewing the spill containment regulation. They may adopt the restrictions imposed by the new Sec. 64 of the Uniform Fire Code, with one variation: the elimination of any minimum liquid capacity threshold. This is a clear signal toward more stringent regulation of hazardous materials and a fundamental shift in the enforcement of spill containment and storage of hazardous materials in SLABS throughout the nation.
The audit. To prevent being blindsided, you need to conduct a full environmental audit of your storage systems. The audit should address these key factors: hazardous discharge, spill containment, ventilation, personal protection systems, fire/life/safety systems (including body and/or eye wash stations), and administrative procedures.
The audit is obviously necessary if you are going to fix any problems, because you must know what they are before you can fix them. But, the audit has the further advantage of providing a proactive and defensible posture in the case of an event and liability.
Post audit. Once you have conducted the audit, you'll need to resolve the problems you found. To make your audit worthwhile, here is what you need to do:
Prioritize. Rank each problem (based on severity and potential severity) on a scale of 1 to 5, with 1 being the most critical. If they all seem most critical, then assign a "1" to the first 20% on the list. Once you have ranked these, do only the "1" items. Review your list each week and reprioritize.
Analyze. You can do this step while some of the other repairs take place. Don't fall into the trap of thinking you need a solid master plan before you can start any work. The first step is to look over your data, and plot a Pareto chart or use some other device to build a graph that may show you possible trends and relationships between events. Do you see a trend? Do you see an underlying cause you can fix once to knock out several problems?
Report. Your management team should know the actions you are taking. So, draft a short letter that lists some of the items you are addressing. The purpose of this letter is to show progress. Write it as a document your company can show the EPA or an insurance company, not as a memo that could hang your company out to dry. You are documenting the company's good intentions, not its deficiencies.
Network. Talk with others in the industry to see how they deal with these problems . Talk with vendors, and see what certified, lab tested, and code compliant solutions they have. Something as simple as a containment system could pay for itself an hour after you install it.
Follow-up. Re-audit those items you have addressed, to ensure they are curing the problems you identified. Familiarize yourself with spill containment regulations, codes, requirements for SLABS. Remember to pay particular attention to Uniform Fire Codes by conducting annual reviews of regulations. This will help to ensure compliance of amendments or additional requirements for spill containment to keep EPA fines and accidents away from your battery room.
Sidebar: Thinking Ahead
Government agencies, environmental groups, popular media, and private citizens have a position of intolerance to any degradation or damage to the environment. Thus, forward-thinking action to curb possible hazardous environmental events is risk management responsive, as well as legally and politically correct - all of which ultimately protect people and property.