ATON BATTERIES: REPORTABLE QUANTITIES UNDER CERCLA 103(a)
1.
OBJECTIVE
This report provides guidance for calculating reportable quantities (RQ) of a release of Aids to
Navigation (ATON) batteries, which must be reported to the National Response Center (NRC)
under Section 103(a) of the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA). Discarded ATON batteries are considered to be hazardous waste, and in certain
numbers constitute RQ to be reported to the NRC and other appropriate Federal, State and local
environmental regulatory agencies. This report also provides information on battery constituents,
and the types of batteries that were historically used to provide power on ATON structures. The
information presented is the best available at the time of completion of this report. Other batteries
may be discovered that have not been evaluated in this report. When discoveries of this kind are
made, the information should be passed to Commandant (G-ECV-1A).
2.
THE POLICY ON ATON BATTERY RELEASE REPORTING
Effective immediately, Coast Guard units, upon discovering a release of ATON batteries in any
quantity, by Coast Guard personnel or outside sources, must notify their cognizant District
Commander by message. District Commanders should determine whether or not the release is an
RQ. If the release is an RQ, District Commanders must report the release to NRC under CERCLA
Section 103(a), and to appropriate State and local environmental regulatory agencies. District
Commanders should inform the cognizant CEU of the reported releases, and request an
Environmental Compliance & Restoration (EC&R) project for site remediation, where necessary.
District Commanders must keep all the records regarding discovering and reporting of the battery
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