4 The record articles

Are You in Compliance? Top 5 Overlooked Environmental Requirements for Data Centers

Posted: February 24th, 2021

Authors: Heather B. 

Your company spent millions building the next generation data center. Money was spent to acquire land, establish infrastructure, construct the building, and purchase and install high-tech cloud, cooling, and critical back-up power supply equipment. On the environmental side, stormwater permits/plans were obtained, your air permit is in hand and you’re logging generator run times, and you know about the annual hazardous materials reporting due March 1. The site is now operating but are there gaps in your environmental compliance program? Do you know what you may not know?

  1. Refrigerants and the Clean Air Act. Thousands of server racks and large uninterruptible power supplies (UPS) operating 24/7 need to be kept cool or they run the risk of overheating and your reliability takes a nosedive. Chillers and air handlers with evaporator coils are often found in data centers to cool such equipment. These closed-loop systems contain and cycle a refrigerant that is likely regulated under the Clean Air Act and may have a high global warming potential. Inspections, maintenance, leak tracking, and use of certified technicians and equipment are some of the requirements for facilities using cooling units, particularly those with greater than 50 pounds of refrigerant.

What to do:
If your cooling system maintenance is not done in-house, ensure your contractor is well versed in 40 CFR 82 Subpart F, performs leak tests and verifications, tracks leak rate calculations, maintains excellent maintenance and equipment inventory records for your sites, and can show proof of technician and equipment certifications. If your team handles refrigerant internally, all of this applies and more. Note the recent revisions to the rule and further, more stringent revisions under the new administration. Developing a Refrigerant Management Plan is a great solution and should be a best management practice, otherwise you may be dealing with a violation of the Clean Air Act.

  1. Wastewater, FIFRA Approved Chemicals, and Pretreatment Standards. Water-cooling systems are often injected with chemicals (e.g., Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) approved biocides/fungicides to prevent growth of bacteria, and/or other chemicals for corrosion control) that may adversely impact the municipal treatment plant or publicly owned treatment works (POTW) to which the water-cooling system blowdown is discharged. Under the National Pollution Discharge Elimination System (NPDES), POTW’s must remain in compliance with their water discharge limits. If water received from industrial users, such as data centers, contains chemicals that will compromise the POTW process or water quality, the industrial user can be held accountable. Depending on your jurisdiction, there may be notification requirements prior to discharging chemically-treated water to the POTW. There may also be a requirement to ensure your water treatment chemicals are pre-approved prior to use.

What to do:
Contact your local water authority to learn the specifics of your jurisdiction and what chemicals you can and cannot use in your system before they contact your facility to ask questions.

Bonus tip: If your water-cooling system discharges to stormwater drains instead of sanitary drains, ensure you have the proper NPDES permits (or your state’s equivalent) if applicable. Notifications, sampling, reporting, and more may be required depending upon your location, discharge flow rate and contents, and chemical use.

  1. Spill Prevention, Control, and Countermeasure (SPCC). If your data center stores at least 1,320 gallons of oil products aboveground, is your SPCC plan in place prior to starting operations? Are spill response materials in place? Are monthly inspections occurring, documented, and signed? Have you increased oil storage capacity by more than 55 gallons since the original SPCC plan was developed? (Think data center expansions, oil drum storage, or transformer replacements.) If so, you have 180 days from the time the additional material arrived to revise your plan and each time thereafter. Tick Tock…

What to do:
Keep abreast of equipment and product deliveries which could trigger the SPCC revision timeline, particularly in the data center environment where processes can change very rapidly.  And don’t forget that annual training requirement and associated records!

  1. Speaking of petroleum products and hazardous materials… Aside from the required Emergency Planning and Community Right-to-know Act (EPCRA) notifications to the various agencies and the annual reporting mentioned earlier, do your local jurisdictions have additional hazardous material storage requirements? These can include above ground tank registrations, initial or annual regulatory inspections, and/or permit requirements.

What to do:
Localities differ in what they require, so check with the local fire marshal’s office or other emergency planning entity to ensure you have not missed these important requirements.

  1. Lithium Ion (Li-ion) Batteries storage and disposal considerations. Battery storage has both safety and environmental considerations. As Li-ion batteries begin overtaking their competitor, lead acid batteries (LABs), in data center UPS systems, data centers need to be ready when the batteries’ lifespans cease. Fortunately, these batteries can be recycled, but not without risk. There are a number of inherent issues with Li-ion batteries that must be understood when considering their end-of-life journey. While their lifespan is longer than LABs, the chemistry of Li-ion batteries varies and plays an important role in how they should be handled.


Lithium is highly reactive and difficult to control. Influences such as high temperatures, using a higher than recommended charging voltage, a short circuit, or even excess strain on the battery can cause an exothermic reaction. If a Li-ion battery is crushed or punctured, a thermal event can result. The larger the battery, the stronger the thermal reaction and the higher the likelihood of igniting adjacent flammable materials, creating a safety and environmental nightmare.

What to do:  From a safety perspective, ensure Li-ion batteries are not exposed to high temperature or prolonged sunlight. Only allow trained personnel to remove them from hardware, ensuring they are not damaged in the process. Handle and package them carefully so casings are not damaged, cores do not come into direct contact with each other, and make sure batteries are professionally discharged before sending out for recycling. Never mix damaged and undamaged batteries. Do not store discarded Li-ion batteries inside of a building since there is a high risk of short-circuiting and catching fire. When sending batteries off-site, always use permitted treatment facilities, which have specialized tools, processes, and controls for dismantling the batteries. To comply with environment requirements, ensure Li-ion batteries are included in the EPCRA hazardous materials planning and reporting and do not discard them in an unauthorized manner.

Was there something on this list new to you?  Do you need a gap analysis performed on your compliance program and associated permits and plans?  Are you expanding soon and need support?  Do you want to hear more on environmental, health, and safety considerations for data centers?  Please contact me at hbrinkerhoff@all4inc.com if you have questions, feedback, or need help with a project.


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