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Battery Safety and Environmental Concerns
Transcript
Slide 1
Welcome to the Data Center UniversityTM course on Battery Safety and Environmental Concerns
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The screen controls
allow you to navigate through the eLearning experience
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Click the Notes tab to read a transcript of the narration
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Proper interpretation of these codes is essential in the design and implementation of data
centers and network rooms
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All rights reserved
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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
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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
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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
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Environmental compliance focuses on the amount of sulfuric acid and lead at a particular location
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This course offers a high level summary of the regulations and provides
guidance for locating sources of regulatory information
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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
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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
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Let’s explore the issue of
compliance a little further
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All rights reserved
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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
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This regulation applies to batteries of
the unsealed type installed in new construction
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Under this
regulation, ventilation, worker protection, acid flushing and neutralization are required
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osha
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VRLA
batteries are of the “sealed” type, so OSHA regulation 29 CFR does not apply
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These laws are spelled out in 42 U
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C
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S
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1101
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Let’s move on to the important topic of fire codes
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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
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These batteries continuously vent hydrogen gas and contain electrolyte in liquid
form
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Smaller and distributed back-up power systems are typically located much closer to the equipment they
protect
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VRLA batteries are designed to
recombine hydrogen and oxygen and emit only extremely small amounts of hydrogen under normal
operating conditions
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Battery Safety and Environmental Concerns

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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners
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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
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Spill containment with VRLA batteries is therefore
not meaningful or appropriate
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Originally published by the Western Fire Chiefs Association, the UFC is now published by the National Fire
Protection Association (NFPA - 1) as of 2003
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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
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A locality, town, county, or state
can choose which code (and which version of the code) to adopt and enforce
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Many jurisdictions still
use the 1994 or 1997 UFC
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Keep in mind that local authorities can also modify the codes
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Codes change with each rewrite and jurisdictions use differing versions of codes
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Checking with local authorities is essential in order to determine which code they
enforce
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All rights reserved
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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
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What is a battery system?
2
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Is the electrolyte free-flowing liquid or is it immobilized?
4
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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
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A battery charger
3
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Smaller, separately
installed UPSs are independent and do not have an additive effect on the electrolyte capacity
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The threshold triggers are
defined per battery system and not by facility
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Slide 14: Application of the Codes to Battery Technologies
How many gallons of electrolyte are in a battery system?

Battery Safety and Environmental Concerns

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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners
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In a flooded battery system 100% of the electrolyte is in liquid form
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These values are provided by the battery manufacturer
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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
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IFC (Section 609) applies
to VRLA battery systems having an electrolyte capacity more than 50 gallons
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” The IFC also has requirements for thermal runaway, neutralization, and ventilation
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Certain requirements, such as spill containment, apply only
to battery systems having free-flowing electrolyte in excess of 1000 gallons
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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
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For a room with sprinklers the UFC threshold increases to 100
gallons
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One should assume that any UPS application using a flooded battery must comply with the fire codes
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In the
2000 and earlier editions of the UFC, Article 64 required VRLA battery systems exceeding the liquid
Battery Safety and Environmental Concerns

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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners
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In 2003 the code was revised
to apply spill containment requirement only to flooded battery systems (ie
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The purpose of the change was to hold batteries to no higher
standard than applies for hazardous material covered elsewhere in the code
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Both the UFC and the IFC require an approved method to prevent thermal runaway in VRLA battery
systems
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However,
interpretation is often up to the local inspector
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A common misinterpretation of the older UFC has sometimes been to sum the quantity of electrolyte in
different battery systems
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The UFC provides clear guidance in this area by
providing a definition of a battery system
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EPCRA requires a
building owner to declare when the aggregate amount of sulfuric acid in batteries throughout the facility
exceeds 500 pounds
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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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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners
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Failure to comply can result in costly penalties
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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
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A site with a few hundred battery containers full of lead and sulfuric acid is a
likely candidate for inspection
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Those who have experience dealing with government agencies in the past know that
no single resource has all the answers
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epa
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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
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, spills or releases)
These key categories can be broken down into four, more specific sub-categories:
1
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Hazardous chemical storage reporting
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Emergency release notification

Battery Safety and Environmental Concerns

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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners
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Sulfuric acid is considered an “Extremely Hazardous Substance” (EHS)
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• Lead (Pb) – CASRN # 7439-92-1
Battery plates and posts contain solid lead, most of which is encased inside the container
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• Lead Dioxide (PbO2) – CASRN # 1309-60-0
Lead Dioxide is pasted onto the positive plates encased inside the battery
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• Lead Sulfate (PbSO4) – CASRN # 7446-14-2
Lead sulfate is formed at both the positive and negative plates during discharge
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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
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In 1986,
CERCLA was amended by yet another Act of Congress called the “Superfund Amendments and
Reauthorization Act,” (SARA)
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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners
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S
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SARA is codified in 42 U
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C 9601 et seq
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S
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1101 et seq
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Both the US Code and the CFRs are generally referenced, so it is important to understand both
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The same chemical will have different reporting requirements and quantities from one section to the next
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They are shown in the
chart you see here
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All rights reserved
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The Code of Federal Regulations is divided into 50 titles
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Subchapter J covers Superfund, Emergency Planning, and Community
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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
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State Emergency Response Commission
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The governor of each state designates a State Emergency Response Commission that is
responsible for implementing EPCRA provisions within the state
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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
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Slide 27: Other Considerations
Battery manufacturers must provide Material Safety Data Sheets (MSDS) upon request
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VRLA batteries utilize
starved electrolyte technology, thereby allowing them to use significantly less electrolyte than a comparably
rated flooded battery
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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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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners
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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
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Facilities still operating are covered by RCRA
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Regulations for packaging and transport of
batteries are addressed in 49 CFR 173
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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
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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
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VRLA batteries have miniscule amounts of liquid
electrolyte and generate much lower amounts of hydrogen than do flooded batteries
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However, older codes might still be in use in
many jurisdictions
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Most practical installations of VRLA batteries do not
trigger the spill containment and occupancy separation requirements due to their low liquid electrolyte
volume
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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners
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Flooded batteries are more likely than VRLA batteries to require reporting, whether for
reporting inventory or for the release of hazardous materials
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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
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It is important for data center designers to have a clear understanding of the fire safety and
environmental regulations concerning their UPS battery installations
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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
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The “Superfund Amendments and Reauthorization Act,” (SARA) and “Emergency Planning and
Community Right-to-Know Act” (EPCRA) provide the regulations
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© 2013 Schneider Electric
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All trademarks provided are the property of their respective owners

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