Battery Safety and Environmental Concerns

Transcript

Slide 1
Welcome to the Data Center UniversityTM course on Battery Safety and Environmental Concerns.

Slide 2
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normal play of the course. Click the Notes tab to read a transcript of the narration.

Slide 3
At the completion of this course, you will be able to:
Differentiate between various battery types
o Flooded (unsealed) batteries (also referred to as “wet cell” or “vented”)
o Valve Regulated Lead Acid (VRLA) batteries
o Modular Battery Cartridges (MBC)
Recognize the standards and codes that apply to battery systems and rooms
o Federal Code of Regulations
o Fire codes
o Environmental Protection Agency (EPA) considerations
o Occupational Safety and Health Agency (OSHA) considerations
Describe how safety regulations apply to different battery technologies

Slide 4: Introduction
Battery systems and battery rooms are regulated by a number of fire safety and environmental standards
and codes. Proper interpretation of these codes is essential in the design and implementation of data
centers and network rooms.

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It is important for data center designers to have a clear understanding of the fire safety and environmental
regulations as they apply to UPS battery installations. For example, in some cases, fire codes do not clearly
recognize improvements in battery safety resulting from changing battery technology. Valve Regulated Lead
Acid (VRLA) batteries are frequently deployed within data centers and network rooms without the need for
the elaborate safety systems that are required for flooded lead acid batteries. We’ll explore this further a
little later in the course.

Slide 5: Introduction
While most commercial battery back-up systems fall below government-required reporting levels, very large
UPS and DC plant batteries may have to comply. Failure to comply can result in costly penalties.

Environmental compliance focuses on the amount of sulfuric acid and lead at a particular location. Power
ratings for VRLA batteries and modular battery cartridges (MBC) are much higher than for flooded batteries
at the same reporting threshold. This course offers a high level summary of the regulations and provides
guidance for locating sources of regulatory information.

Let’s begin with an illustration of the common concern involved with batteries and compliance.

Slide 6: Introduction
The following scenario illustrates the common concern about batteries and compliance:

An IT manager will be installing (or maybe already has installed) a large, lead-acid battery system to back
up critical data center operations. He is nervous about all the batteries stored in his facility and now he is
informed 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.

Compliance is an important issue that all data center managers need to address. Let’s explore the issue of
compliance a little further.

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Slide 7: Code of Federal Regulations
Flooded batteries are required to comply with the Occupational Safety and Health Administration (OSHA)
Regulation 29 CFR 1926.441, Battery Rooms and Battery Charging. This regulation applies to batteries of
the unsealed type installed in new construction. Unsealed in this case means flooded batteries. Under this
regulation, ventilation, worker protection, acid flushing and neutralization are required. If using flooded
batteries please see the OSHA web site www.osha.gov for specific details on how to comply. VRLA
batteries are of the “sealed” type, so OSHA regulation 29 CFR does not apply.

Slide 8: Code of Federal Regulations

The Environmental Protection Agency (EPA) Emergency Planning and Community Right-To-Know Act
(EPCRA) requires owners to inform local authorities when their facilities have large volumes (actually
reported in weight) of hazardous materials such as sulfuric acid (present in lead-acid battery electrolyte).
These laws are spelled out in 42 U.S.C. 9601, also known as Title III of SARA, and 42 U.S.C. 1101. These
requirements will be discussed later in this course.

Let’s move on to the important topic of fire codes.

Slide 9: Fire Codes

At the local level, the standards and codes that matter most are the Fire Codes. Initially, fire codes for
stationary lead acid batteries were written for large systems utilizing flooded lead acid batteries that
supported data centers and network rooms. These systems are typically located in rooms separate from the
equipment they support. These batteries continuously vent hydrogen gas and contain electrolyte in liquid
form. Consequently, special ventilation and spill containment systems must be employed.

Smaller and distributed back-up power systems are typically located much closer to the equipment they
protect. They generally use Valve Regulated Lead Acid (VRLA) batteries. VRLA batteries are designed to
recombine hydrogen and oxygen and emit only extremely small amounts of hydrogen under normal
operating conditions. Normal room ventilation is sufficient to remove any hydrogen, so special ventilation is
not required.

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The electrolyte in a VRLA battery is not in liquid form but is immobilized. The most common technology,
termed Absorbed Glass Mat (AGM), uses a highly porous, absorbent micro fiberglass mats that immobilize
the electrolyte and prevent it from spilling. A crack or hole in the casing of a VRLA battery using AGM
technology will not result in a measurable electrolyte spill. Spill containment with VRLA batteries is therefore
not meaningful or appropriate.

Slide 10: Two Main fire Codes

The two main fire codes in the United States relating to battery systems are the Uniform Fire Code (UFC)
and the International Fire Code (IFC).

Originally published by the Western Fire Chiefs Association, the UFC is now published by the National Fire
Protection Association (NFPA - 1) as of 2003.

The International Code Council (ICC) writes the IFC. The ICC was created in 1994 when the Southern
Building Code Congress International (SBCCI), the International Conference of Building Officials (ICBO),
and the Building Officials and Code Administrators International (BOCA) united to create a set of
harmonized standards.

Slide 11: Two Main Fire Codes

Model codes are written by organizations and published every few years. A locality, town, county, or state
can choose which code (and which version of the code) to adopt and enforce. For example, the entire State
of Alaska adopted the IFC, while only certain towns in Arizona may have adopted it. Many jurisdictions still
use the 1994 or 1997 UFC. Checking with the local safety inspector is the best method to determine which
code applies to a specific installation. Keep in mind that local authorities can also modify the codes. Under
the codes, battery systems are subject to special installation requirements, depending upon amount of
electrolyte and the nature of the battery technology.

Codes change with each rewrite and jurisdictions use differing versions of codes. This course can only
generalize about codes. Checking with local authorities is essential in order to determine which code they
enforce.

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Slide 12: Application of the Codes to Battery Technologies
Before applying the codes, one must understand how the codes will apply to a specific installation. There
are four questions that must be answered:
1. What is a battery system?
2. How many gallons of electrolyte are in this battery system?
3. Is the electrolyte free-flowing liquid or is it immobilized?
4. At what electrolyte volume does the code apply?

Let’s explore each of these questions.

Slide 13: Application of the Codes to Battery Technologies

What is a Battery System?

Under the UFC definition, a battery system consists of three interconnected subsystems:
1. A lead-acid battery
2. A battery charger
3. A collection of rectifiers, inverters, converters and associated electrical equipment as required for a
particular application

From this definition each individual UPS or DC Plant constitutes one battery system. Smaller, separately
installed UPSs are independent and do not have an additive effect on the electrolyte capacity. A fault in one
system will not propagate to the others, as they are independent of each other. The threshold triggers are
defined per battery system and not by facility. The code specifically does not instruct the summation of
independent battery systems.

Slide 14: Application of the Codes to Battery Technologies

How many gallons of electrolyte are in a battery system?

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Gallons are a liquid measure and the fire codes seek to determine the amount of liquid electrolyte in the
battery system. In a flooded battery system 100% of the electrolyte is in liquid form. In a VRLA battery
solution, about 3% of the electrolyte is in liquid form. These values are provided by the battery manufacturer.
The liquid electrolyte values in each battery within the battery system are added together to arrive at the
total for a system.

Slide 15: Application of the Codes to Battery Technologies

Is the electrolyte free-flowing liquid or is it immobilized?
The International Fire Code was modified in 2001 to create different rules for VRLA batteries. It recognized
that VRLA batteries have different properties when compared to flooded batteries. IFC (Section 609) applies
to VRLA battery systems having an electrolyte capacity more than 50 gallons. The IFC specifically states for
VRLA batteries, “The battery systems are permitted to be in the same room with the equipment they
support.” The IFC also has requirements for thermal runaway, neutralization, and ventilation.

The 2003 Uniform Fire Code has also changed. Certain requirements, such as spill containment, apply only
to battery systems having free-flowing electrolyte in excess of 1000 gallons. The intent was to exempt
batteries with immobilized electrolyte, like VRLA batteries, from such rules.

Slide 16: Application of the Codes to Battery Technologies

At what electrolyte volume does the code apply?

For a flooded battery system the IFC (Section 608 and 609) and UFC (Article 64 in the old code and Article
52 in the updated code) use 50 gallons of electrolyte capacity criteria for when compliance is required.
Below 50 gallons the code is not applied. For a room with sprinklers the UFC threshold increases to 100
gallons. In data centers or network rooms using an alternative method of fire protection (for example, Halon
or FM200), the 50-gallon level applies.

One should assume that any UPS application using a flooded battery must comply with the fire codes. Both
codes specify requirements for occupancy separation, spill control, neutralization, and ventilation. In the
2000 and earlier editions of the UFC, Article 64 required VRLA battery systems exceeding the liquid

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electrolyte volume threshold values to meet special protection requirements. In 2003 the code was revised
to apply spill containment requirement only to flooded battery systems (ie., batteries with free-flowing
electrolyte) with a minimum of 1,000 gallons. The purpose of the change was to hold batteries to no higher
standard than applies for hazardous material covered elsewhere in the code. Requirements other than spill
control still apply at the 50 and 100 gallon limits.

Both the UFC and the IFC require an approved method to prevent thermal runaway in VRLA battery
systems.

Slide 18: Environmental Regulations

Codes are supposed to provide clear direction of when and how they should be enforced. However,
interpretation is often up to the local inspector. This can present substantial variance in application of a code.
A common misinterpretation of the older UFC has sometimes been to sum the quantity of electrolyte in
different battery systems. Such an interpretation, if enforced, could lead to the absurd situation where there
is a need to identify every item in a facility that contains a VRLA battery and to provide for separate spill
containment and occupancy separation for each device. The UFC provides clear guidance in this area by
providing a definition of a battery system.

Note: This distinction should not be confused with EPCRA reporting requirements. EPCRA requires a
building owner to declare when the aggregate amount of sulfuric acid in batteries throughout the facility
exceeds 500 pounds. Because electrolyte is approximately 2/3 water and 1/3 acid, some inspectors have
recently taken a broader, and incorrect, interpretation by requiring owners to report when the total amount of
electrolyte exceeds 500 pounds.

Slide 19: Environmental Regulations

Some common questions to consider when installing a UPS battery system are:
Will I have to report my batteries as hazardous material (hazmat)?
Where do I find the rules?
What are EPCRA, SARA, SERC, CERCLA, and LEPC?

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 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 frustrating and arduous task.

Slide 19: EPA and OSHA

It is important for the data center designer to understand the influence of the Environmental Protection
Agency (EPA) and The Occupational Safety and Health Agency (OSHA), with EPA being the main driver.
Government agencies are interested in the quantities of substances at a given site that could be dangerous
to employees or neighbors. A site with a few hundred battery containers full of lead and sulfuric acid is a
likely candidate for inspection. The Internet is a good resource for gathering information regarding these
battery safety issues. Those who have experience dealing with government agencies in the past know that
no single resource has all the answers. However, the best starting point to learn about the subject of battery
safety and related environmental regulations is www.epa.gov.

Slide 21: Important Technology

Data center personnel should become familiar with the following terminology:
“Pro-active” compliance: reporting the hazardous materials present in the batteries at your site
“Re-active” compliance: reporting accidents (i.e., spills or releases)
These key categories can be broken down into four, more specific sub-categories:
1. Emergency planning and emergency response plans
2. Hazardous chemical storage reporting
3. Toxic chemical release inventory
4. Emergency release notification

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Slide 22: Hazardous Substances-MSDS
Hazardous substances commonly listed on a lead-acid battery material safety data sheet (MSDS) are:
• Electrolyte
Electrolyte in a lead-acid battery is about 1/3 sulfuric acid (CASRN # 7664-93-9) and 2/3
water. Sulfuric acid is considered an “Extremely Hazardous Substance” (EHS).
It is also important to know if the electrolyte is in a liquid state (used in vented or flooded
batteries), or if it is immobilized (as in a Valve Regulated Lead Acid battery).

• Lead (Pb) – CASRN # 7439-92-1

Battery plates and posts contain solid lead, most of which is encased inside the container.
Minute amounts of lead could be suspended in the liquid electrolyte.

• Lead Dioxide (PbO2) – CASRN # 1309-60-0

Lead Dioxide is pasted onto the positive plates encased inside the battery.
It can only be exposed if the container is ruptured.

• Lead Sulfate (PbSO4) – CASRN # 7446-14-2

Lead sulfate is formed at both the positive and negative plates during discharge.
It normally is present only in insignificant amounts.

Slide 23: Location of the Rules

Where are the rules?

The laws that affect data centers got their start in 1980 with the EPA “Superfund.” The law was called the
“Comprehensive Environmental Response, Compensation, and Liability Act,” or CERCLA. In 1986,
CERCLA was amended by yet another Act of Congress called the “Superfund Amendments and
Reauthorization Act,” (SARA). Embedded in Title III of SARA was the creation of the “Emergency Planning
and Community Right-to-Know Act” (EPCRA).

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Laws say what must be done, and can be found in the U.S. Code.
• SARA is codified in 42 U.S.C 9601 et seq.
• EPCRA is codified in 42 U.S.C. 1101 et seq.

Slide 24: Location of the Rules

Regulations give the procedures of how to do it and can be found in the Code of Federal Regulations
(CFRs).

Both the US Code and the CFRs are generally referenced, so it is important to understand both. Take care
when reviewing these; they both have similar requirements, and they both have a similar numbering system.
The same chemical will have different reporting requirements and quantities from one section to the next.

Slide 25: Location of the Rules

SARA Title III has four major reporting requirements with specific statutory citations. They are shown in the
chart you see here.

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The Code of Federal Regulations is divided into 50 titles. OSHA is covered under Title 29, whereas EPA
rules fall under Title 40, Chapter I. Subchapter J covers Superfund, Emergency Planning, and Community.
Now that we have discussed where the rules can be found, let’s move on our next topic: planning for an
emergency.

Slide 26: Planning for an Emergency

Every community in the United States must be part of a comprehensive plan to prepare for and respond to
emergencies involving hazardous substances. The plan involves three key subjects.

State Emergency Response Commission

o The governor of each state designates a State Emergency Response Commission that is
responsible for implementing EPCRA provisions within the state.
Local Emergency Planning Commission
o Under the supervision of the SERCs are some 3,500 emergency planning districts, and
within each of those is a Local Emergency Planning Commission. The LEPC members
usually include representatives of local fire department, police, civil defense, public health,
transportation and environmental agencies, as well as representatives of affected large
facilities, community groups and media.
Emergency Response Plan
o The LEPC must develop an emergency plan, review it annually, and provide information
about chemicals that are present in the community to its citizens.

Slide 27: Other Considerations

Battery manufacturers must provide Material Safety Data Sheets (MSDS) upon request. They can also
provide precise information about the volume and weight of electrolyte in a battery. VRLA batteries utilize
starved electrolyte technology, thereby allowing them to use significantly less electrolyte than a comparably
rated flooded battery. Consequently, the power ratings of systems using VRLA batteries can usually be
much larger before they hit reporting thresholds. For example, in one instance where two battery systems of
approximately equal ampere-hour batteries were compared, it took only 147 cells of the flooded battery to

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reach the 500 pound reporting threshold, whereas it took 746 cells of VRLA batteries to reach the same
threshold.

Slide 28: Other Considerations

Although disposal of lead-acid batteries could be the topic of a course all on its own, it should be mentioned
that disposal of batteries must be carefully controlled. Battery recycling is required by the Solid Waste
Disposal Act, Public Law 89-272, 79 Stat 997, as amended by the Resource Conservation and Recovery
Act (RCRA), Public Law 94-580, 90 Stat 2795 (1976). Facilities still operating are covered by RCRA. Sites
no longer in operation yet still requiring cleanup are covered by the Comprehensive Environmental
Response, Compensation and Liabilities Act (CERCLA). Regulations for packaging and transport of
batteries are addressed in 49 CFR 173.159. Some battery manufacturers will pick up expired batteries free
of charge just so they can recycle the lead and plastics for use in new batteries. It is important to obtain and
save complete documentation certifying that the batteries have been properly recycled. Even if someone
has a good-faith document showing that the batteries were picked up and properly disposed of, they are still
designated as a Potentially Responsible Party (PRP) and may be liable for substantial clean-up fees even if
the batteries later turn up, without their knowledge, in a toxic waste site.

Slide 29: Conclusions

Flooded batteries require special containment and ventilation due to the risks posed by their liquid
electrolyte and their continual hydrogen generation. VRLA batteries have miniscule amounts of liquid
electrolyte and generate much lower amounts of hydrogen than do flooded batteries. The latest codes
specifically recognize the technology differences between flooded and VRLA batteries and exempt VRLA
batteries from spill containment and occupational separation. However, older codes might still be in use in
many jurisdictions.

The older codes are not clear in making the distinction between flooded and VRLA batteries, and an
inspector might take a very narrow interpretation. Most practical installations of VRLA batteries do not
trigger the spill containment and occupancy separation requirements due to their low liquid electrolyte
volume. Battery systems based on VRLA batteries can be deployed, and are routinely deployed, within data
centers, network rooms and work environments in compliance with fire codes.

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Slide 30: Conclusions
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.

Slide 31: Summary

To summarize, let’s review some of the information we have covered throughout this course.
It is important for data center designers to have a clear understanding of the fire safety and
environmental regulations concerning their UPS battery installations.
The two main codes in the United States relating to battery systems are the Uniform Fire Code
(UFC) and the International Fire Code (IFC).
A battery system consists of three interconnected subsystems:
A lead-acid battery
A battery charger
A collection of rectifiers, inverters, converters and associated electrical equipment as required for a
particular application.
Every community in the United States must be part of a comprehensive plan to prepare for and
respond to emergencies involving hazardous substances.
The “Superfund Amendments and Reauthorization Act,” (SARA) and “Emergency Planning and
Community Right-to-Know Act” (EPCRA) provide the regulations.

Slide 32: Thank You!

Thank you for participating in this Data Center University™ course.

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