TECHNICAL COMMITTEE ON Energy Storage …...Mostafa Kashe Principal Los Angeles County 900 South...

TECHNICAL COMMITTEE ON

Energy Storage Systems

Agenda

First Draft Meeting for NFPA 855

November 27th - 30th, 2017

1. Call to Order

2. Introduction of Committee Members (Attachment A)

3. Approval of Meeting Minutes from October 23 – 25, 2017 (Attachment B)

4. Chairs Remarks

5. Staff Presentation

6. Review Public Inputs (Attachment C)

7. Old Business

8. New Business

9. Schedule Next Meeting

10. Adjournment

NFPA 855 First Draft Technical Committee Meeting Agenda November 27 - 30, 2017 - Rosemont, IL

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Attachment A: Technical Committee Roster


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Address List No PhoneEnergy Storage Systems ESS-AAA

Brian J. O’Connor11/14/2017

ESS-AAA

James B. Biggins

ChairTUV SUD America Inc./Global Risk Consultants Corporation15732 West Barr RoadManhattan, IL 60442-9012

SE 08/03/2016ESS-AAA

Zekarias Bekele

PrincipalCSA Group8501 East Pleasant Vally RoadCleveland, OH 44131

RT 08/03/2016

ESS-AAA

Andrew Blum

PrincipalFisher Engineering, Inc.10475 Medlock Bridge Road, Suite 520Johns Creek, GA 30097


Troy Chatwin

PrincipalGE Energy Storage1 River RoadBuilding 66, MS 214-21Schenectady, NY 12345-6000

M 08/03/2016

ESS-AAA

David Richard Conover

PrincipalPacific Northwest National Laboratory (PNNL)11100 Streamview CourtGreat Falls, VA 22066


Timothy Crnko

PrincipalEaton’s Bussmann Business114 Old State RoadSt. Louis, MO 63021

M 08/03/2016

ESS-AAA

Robert J. Davidson

PrincipalDavidson Code Concepts, LLC311 Camperdown CourtEasley, SC 29642-7734


James T. Dollard, Jr.

PrincipalIBEW Local Union 981701 Spring Garden StreetPhiladelphia, PA 19130

L 04/04/2017

ESS-AAA

Laurie B. Florence

PrincipalUL LLC333 Pfingsten RoadNorthbrook, IL 60062-2096Alternate: Howard Hopper

RT 08/03/2016ESS-AAA

Kevin Fok

PrincipalLG Chem Power, Inc.1857 Technology DriveTroy, MI 48083

M 08/03/2016

ESS-AAA

Ryan Gamboa

PrincipalFiretrace USA3752 West Megan StreetChandler, AZ 85226-5933Alternate: Angela Krcmar

M 08/03/2016ESS-AAA

Walter Groden

PrincipalAIG Global Technical OfficeGlobal Technical Office-Energy & Engineered Risk64 Seely PlaceScarsdale, NY 10583-2627

I 08/03/2016

ESS-AAA

Nicholas Guzman

PrincipalEGPNA1755 East Plumb Lane, Suite 166Reno, NV 89501

U 08/03/2016ESS-AAA

John A. Hillaert

PrincipalMPR Associates Inc.320 King StreetAlexandria, VA 22314

SE 11/30/2016

1NFPA 855 First Draft Technical Committee Meeting Agenda November 27 - 30, 2017 - Rosemont, IL

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ESS-AAA

Jonathan G. Ingram

PrincipalUTC/Kidde-Fenwal, Inc.400 Main StreetAshland, MA 01721

M 08/17/2017ESS-AAA

Mostafa Kashe

PrincipalLos Angeles County900 South Fremont AvenueBuilding Safety DivisionAlhambra, CA 91803

E 11/30/2016

ESS-AAA

Brad Kell

PrincipalUnienergy Technologies4333 Harbour Pointe BoulevardMukilteo, WA 98275

M 08/03/2016ESS-AAA

Chad Kennedy

PrincipalSchneider Electric8821 Garners Ferry RoadHopkins, SC 29061-8626National Electrical Manufacturers AssociationAlternate: James (Jim) Allen

M 08/17/2017

ESS-AAA

Paul Kozak

PrincipalConsultant15383 Columbia AvenueWhite Rock, BC V4B 1K1 Canada


Roger Lin

PrincipalNEC Energy Solutions155 Flanders RoadWestborough, MA 01581Alternate: Chris Quaranta

M 08/17/2017

ESS-AAA

Clinton Marshall

PrincipalFM Global1151 Boston Providence TurnpikeNorwood, MA 02062Alternate: Benjamin Ditch

I 04/04/2017ESS-AAA

Terrance L. McKinch

PrincipalMortenson Construction3278 South Duffield RoadLennon, MI 48449-9407Alternate: Jason Knedlhans

IM 08/03/2016

ESS-AAA

Celina Mikolajczak

PrincipalTesla Motors3500 Deer Creek RoadPalo Alto, CA 94304Alternate: Jason Haer

M 08/03/2016ESS-AAA

Mark Christopher Mirek

PrincipalBeecher Carlson LLC6215 Martel AvenueDallas, TX 75214

I 08/03/2016

ESS-AAA

Cliff Orvedal

PrincipalAES Energy Storage4300 Wilson BoulevardArlington, VA 22203

M 08/17/2017ESS-AAA

Matthew Paiss

PrincipalSan Jose Fire Department1661 Senter Road, 3rd FloorSan Jose, CA 95112-2522International Association of Fire FightersAlternate: Richard Karl Schlueck

L 08/03/2016

ESS-AAA

Scot Pruett

PrincipalBlack & Veatch Corporation11401 Lamar AvenueOverland Park, KS 66211-1508


Paul E. Rivers

Principal3M Company3M Center, Building 236-1B-07St. Paul, MN 55144-1000Alternate: Nick Johnson

M 04/04/2017


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ESS-AAA

Paul G. Rogers

PrincipalFire Department City of New York36 Plymouth Drive SouthGlen Head, NY 11545Fire Department City of New YorkAlternate: Leo Subbarao

E 08/03/2016ESS-AAA

David Rosewater

PrincipalSandia National Laboratories1515 Eubank, MS 1140Albuquerque, NM 87123

RT 08/03/2016

ESS-AAA

George Andrew Ruetenik

PrincipalHartford Steam Boiler1913 Remsing DriveLansing, MI 48911

I 08/03/2016ESS-AAA

Randy H. Schubert

PrincipalEricsson444 Hoes LanePiscataway, NJ 08854-4104Alliance for Telecommunications Industry SolutionsAlternate: Richard G. Kluge

U 08/17/2017

ESS-AAA

Andrzej Skoskiewicz

PrincipalStem, Inc.100 Rollins RoadMillbrae, CA 94030

M 08/03/2016ESS-AAA

Alex Spataru

PrincipalThe Adept Group, Inc.1273 Westwood Boulevard, Suite 200Los Angeles, CA 90024

SE 08/03/2016

ESS-AAA

Chris Towski

PrincipalCambridge Fire Department491 BroadwayCambridge, MA 02138

E 08/03/2016ESS-AAA

Nick Warner

PrincipalDNV GL1960 Quarry Crest DriveColumbus, OH 43204

RT 08/03/2016

ESS-AAA

Ronald W. Woodfin

PrincipalTetraTek, Inc./AES CorporationPO Box 1094Brighton, CO 80601Edison Electric Institute

U 11/30/2016ESS-AAA

James (Jim) Allen

AlternatePanasonic Industrial Sales Devices Company of America(PIDSA)3461 Plano ParkwayThe Colony, TX 75056National Electrical Manufacturers AssociationPrincipal: Chad Kennedy

M 04/04/2017

ESS-AAA

Benjamin Ditch

AlternateFM Global1151 Boston-Providence TurnpikeNorwood, MA 02062FM GlobalPrincipal: Clinton Marshall

I 08/03/2016ESS-AAA

Jason Haer

AlternateTesla Motors3500 Deer Creek RdPalo Alto, CA 94304Principal: Celina Mikolajczak

M 04/04/2017


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ESS-AAA

Howard Hopper

AlternateUL LLC47173 Benicia StreetFremont, CA 94538-7366Principal: Laurie B. Florence

RT 08/03/2016ESS-AAA

Nick Johnson

Alternate3M Company3M Center, 236-01-07Maplewood, MN 55144Principal: Paul E. Rivers

M 04/04/2017

ESS-AAA

Richard G. Kluge

AlternateEricsson1 Ericsson DrivePiscataway, NJ 08854Alliance for Telecommunications Industry SolutionsPrincipal: Randy H. Schubert

U 08/17/2017ESS-AAA

Jason Knedlhans

AlternateMortenson Construction700 Meadow Lane N.Minneapolis, MN 55433Principal: Terrance L. McKinch

IM 04/04/2017

ESS-AAA

Angela Krcmar

AlternateFiretrace International8435 N. 90th Street, Suite 2Scottsdale, AZ 85258Principal: Ryan Gamboa

M 08/03/2016ESS-AAA

Chris Quaranta

AlternateNEC Energy Solutions78 Sprague StreetNorthbridge, MA 01534Principal: Roger Lin

M 08/03/2016

ESS-AAA

Richard Karl Schlueck

AlternateFire Department City Of New York895 Bryant AvenueNew Hyde Park, NY 11040International Association of Fire FightersPrincipal: Matthew Paiss

L 04/04/2017ESS-AAA

Leo Subbarao

AlternateFire Department City of New York258-15, 83rd AvenueGlen Oaks, NY 11004Principal: Paul G. Rogers

E 08/03/2016

ESS-AAA

Brian J. O’Connor

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

5/26/2016


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Attachment B: Previous Meeting Minutes


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TECHNICAL COMMITTEE ON Energy Storage Systems

Minutes First Draft Meeting for NFPA 855

October 23rd- 25th, 2017

1. The Chair, Jim Biggins, called the meeting to order 8:00am

2. The committee members and guests went around the room and stated their name and employer.

3. The Chair, Jim Biggins, gave remarks about the goals of the meeting and how the meeting will run.

4. NFPA Staff Liaison, Brian O’Connor, gave a presentation outlining the NFPA standards development process, legal matters and housekeeping announcements.

5. Howard Hopper of UL gave a brief presentation regarding UL 9540A

6. Paul Hayes gave a brief presentation regarding the coordination of NFPA 850 & 855

7. The Technical Committee reviewed 220 Public Inputs over 3 days

8. Assignment of task groups to review a number of public inputs

9. Next Meeting Scheduled for the end of November 2017 in Chicago.

10. Meeting was adjourned at 3:00pm on Wednesday, October 25th


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Attendance

James Biggins, Chair, Global Risk Consulting

Brian O’Connor, Staff Liaison, NFPA

Principal members:

Andrew Blum, Fisher Engineering

Troy Chatwin, GE Energy Storage (on phone)

David Conover, PNNL

Timothy Crnko, Eaton’s Bussmann Business

Robert Davison, Davidson Code Concepts, LLC

Laurie Florence, UL LLC

Kevin Fok, LG Chem Power

Ryan Gamboa, Firetrace USA

Nicholas Guzman, EGPNA

John Hillaert, MPR Associates Inc.

Jonathan Ingram, Kidde-Fenwal, Inc.

Brad Kell, Unienergy Technologies

Chad Kennedy, National Electrical Manufacturers

Roger Lin, NEC Energy Solutions

Clinton Marshal, FM Global (on phone)

Celina Mikolajczak, Tesla Motors

Mark Mirek, Beecher Carlson

Cliff Orvedal, AES Energy Storage

Matthew Paiss, IAFF

Paul Rivers, 3M Company

Paul Rogers, FDNY (on phone)

George Ruetenik, Hartford Steam Boiler (on phone)

Andrzej Skoskiewicz, Stem, Inc

Chris Towski, Cambridge Fire Department

Nick Warner, DNV GL


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Ronald Woodfin, Edison Electric Institute

Alternates:

Jason Haer, Tesla Motors

Howard Hopper, UL LLC

Richard Kluge, Alliance for Telecommunications Industry

Jason Knedlhans, Mortenson Construction

Richard Schlueck, IAFF (on phone)

Leo Subbarao, FDNY

Guests:

Chuck Foster, Energy Storage Association

Paul Hayes, American Fire Technologies

Jan Gromadzki, Tesla Motors

Justin Perry, Dominion Energy

Jeffery Betz, AT&T

Kevin DiGenova, Lockheed Martin Advanced Energy Storage

David Ginder, Saft America

Steven Ruth, Nexceris LLC

Steve Cummings, Nexceris LLC


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Attachment C: Public Input Report


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Public Input No. 213-NFPA 855-2017 [ Global Input ]

There is a general lack of consistency with regard to the references to sodium batteries. The following are some of theterms used:

Sodium – all

Sodium – ion

Sodium beta

Sodium aqueous

Sodium high temperature

Sodium sulfur

Sodium nickel chloride and others

Some distinction needs to be made, but maybe only two distinctions are needed: Sodium-ion, and Sodium-beta. All can be lumped under these categories and perhaps other terms deleted.

Statement of Problem and Substantiation for Public Input

Consistency of terms.

Submitter Information Verification

Submitter Full Name: Richard Kluge

Organization: Ericsson

Street Address:

City:

State:

Zip:

Submittal Date: Sun Oct 01 20:08:56 EDT 2017

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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There is a high degree of similarity between the installation needs of Pb-Acid and Flooded Nickel-Cadmium batterytypes. Flooded Pb-acid have as much in common with Nickel-Cadmium as they do with VRLA. For ease of use, itmight be worth lumping Pb-acid and flooded Nickel-Cadium as these are common telecom batteries with a long andwell understood safety record in telecom and UPS applications.


Simplify the document by combining batteries with comparable installation characteristics.




Affilliation: ATIS

Street Address:

City:

State:

Zip:



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When the text: "Telecommunications facilities ...with battery storage less than 50-V ac, 60-V dc" is used, considerdropping the 50-V ac term. Telecommunications facilities don't have batteries that store ac voltage, so this term isconfusing. It is also unclear as to if you need to meet one or the other or both.


50V ac is confusing when referencing telecom applications as we don't have batteries that store ac voltage. It is also unclear if both ac and dc limits or either ac or dc limits apply when determining the exception.




Affilliation: ATIS

Street Address:

City:

State:

Zip:



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Numerous areas in Chapter B reference NFPA 70E and a 50V limit. This should be clarified as either ac or dc voltage orboth.


The reference to a 50V limit per NFPA 70E is not consistent with other references in the standard that distinguish between ac and dc. 50V dc is not a hazard to trained workers from a telecom perspective.




Affilliation: ATIS

Street Address:

City:

State:

Zip:

Submittal Date: Mon Oct 02 20:55:56 EDT 2017


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Where ever "Large Scale Testing and Fault Conditions" is referred to, the following statement should be added.

Where a standard for large scale testing is not available, extrapolated small scale testing may be evaluated to assessthe potenial for fire sread to adjacent energy storage system inits, surrounding equipement, or though an adjacent fireresistance barrier.


No standard for large scale testing of ESS systems is currently available. Though UL 9540A will include this in the future, it is not been revised as of yet. My suggestion would be to include an alternate form of evaluation in the light of a the lack of an existing standard.


Submitter Full Name: andrew miraldi

Organization: Miraldi Engineering

Affilliation: FZSonick Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 04 09:11:35 EDT 2017


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Recommendation: reserving Chapter 18 for "RecycledEnergy Storage System Technologies". Reason: As theapplication of this technology gathers pace, and ecologicalconsiderations come into view, some physical batteries fororiginal use may be recommissioned for ?a secondary use. This document should at least set the broad contours of astandard of care for extending the life cycle of these systemsthrough multiple applications.


As the application of this technology gathers pace, and ecological considerations come into view, some physical batteries for original use may be recommissioned for a secondary use. This document should at least set the broad contours of a standard of care for extending the life cycle of these systems through multiple applications.


Submitter Full Name: William Cantor

Organization: TPI Corporation

Street Address:

City:

State:

Zip:



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Public Input No. 565-NFPA 855-2017 [ New Section after 1.1 ]

TITLE OF NEW CONTENT

Type your content here ...

Chapter 1 Administration

1.1 Scope

1.1.1 This Standard does not cover Energy Storage Systems (ESS) for communications equipment (facility) under the exclusivecontrol of communications utilities located outdoors or in building spaces used exclusively for such installations. Communication equipment facilities shall comply with the requirements of NFPA 76 Standard for the Fire Protection ofTelecommunications Facilities.


The telecommunications industry is a utility that is typically designated or recognized by governmental law or regulation by public service/utility commissions that install, operate and maintain communications systems (such as telephone, CATV, Internet, satellite. or data services). This utility may be subject to compliance with codes and standards covering their regulated activities as adopted under governmental law or regulation such as state regulatory commissions and the Federal Communications Commission. The industry currently has a matured standard regulating telecommunications operations (NFPA 76) and the topic (ESS) should be the responsibility of the Technical Committee on Telecommunications, that is best focused on network reliability of public telecommunications and the fire protection challenges of this industry.


Submitter Full Name: Jeffrey Betz

Organization: AT&T Corporation

Street Address:

City:

State:

Zip:



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Public Input No. 33-NFPA 855-2017 [ Section No. 1.1 ]

1.1 Scope.

This standard establishes criteria for minimizing the hazards associated with Stationary and certain Mobile and Portableenergy storage systems (ESS).


This proposal adds clarity by confirming that the scope is applicable to Stationary ESS and certain Mobile and Portable ESS.


Submitter Full Name: chuck foster

Organization: Foster Associates

Affilliation: Energy Storage Association

Street Address:

City:

State:

Zip:

Submittal Date: Sun Sep 24 12:34:46 EDT 2017


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1.1 Scope.

This standard establishes criteria for minimizing the hazards associated with energy storage systems (ESS).

Installations of ESS for telecommunications equipment under the exclusive control of utilities located outdoors or in buildingsused exclusively for such installations are outside the scope of this standard. Please refer to NFPA 76 for fire protectionguidelines for these applications.


The scope is revised to recognize the exemption for telecommunications equipment installations contained in NFPA 70. The text is based on the current NFPA 70 language. Including such wording at the start of NFPA 855 will greatly reduce the need for numerous buried exceptions in the body of the document. The document will be more usable, without impacting the ESS use by telecommunications carriers which have unique installation features best addressed in NFPA 76 which is an occupancy specific standard.

Telecom installations are outside the scope of NFPA 70, are low voltage and safe to touch, do not use disconnects, are not listed systems, have their own fire resistance criteria, do not require sprinklers, do not have Battery Management Systems or Energy Storage Management Systems, have unique spatial and installation location rules, and are float charged and rarely discharged. They are a unique application, with an excellent safety record, outside the primary area of concern of the ESS technical committee and should excluded from the scope.




Affilliation: ATIS

Street Address:

City:

State:

Zip:



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1.1 Scope.

This standard establishes criteria for minimizing the hazards associated with energy storage systems (ESS).

Telecommunications facilities with lead-acid and nickel-cadmium battery storage less than 50-V ac, 60-V dc and in compliancewith NFPA 76 are outside the scope of this standard.


The scope is revised to recognize that telecommunications equipment installations of low voltage lead-acid and nickel-cadmium batteries complying with NFPA 76 are low risk. The text is based on exemption language currently used elsewhere in the NFPA 855. Including such wording at the start of NFPA 855 will greatly reduce the need for numerous buried exceptions in the body of the document. The document will be more usable, without impacting the ESS use by telecommunications carriers which have unique installation features best addressed in NFPA 76 which is an occupancy specific standard.

Telecom installations are outside the scope of NFPA 70, are low voltage and safe to touch, do not use disconnects, are not listed systems, have their own fire resistance criteria, do not require sprinklers, do not have Battery Management Systems or Energy Storage Management Systems, have unique spatial and installation location rules, and are float charged and rarely discharged. They are a unique application, with an excellent safety record, outside the primary area of concern of the ESS technical committee and should excluded from the scope.




Affilliation: ATIS

Street Address:

City:

State:

Zip:



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Public Input No. 236-NFPA 855-2017 [ Sections 1.1, 1.2 ]

Sections 1.1, 1.2

1.1 Scope.

This standard establishes criteria for minimizing the hazards associated with energy applies to the design, construction,installation, commssioning, operation, maintenance, and decommissioning of stationary, mobile and portable energy storagesystems (ESS).

1.2 Purpose.

This standard provides the minimum requirements for the fire prevention, fire protection, design, construction, installation,commissioning, operation, maintenance, and decommissioning of stationary, mobile, and portable ESS minimizing the hazardsassoiated wth ESS .


The scope and purpose statements in the draft standard seem reversed and the proposed change will ensure the scope and purpose are appropriate. The scope should cover what the standard applies to and the purpose should cover the issues or concerns the standard is intended to address. The scope is clearly stationary, mobile and portable ESS from the design through to decommissioning. The purpose is clearly to minimize hazards associated with the ESS that are covered in the scope.e

Also a more general comment about the scope of the standard and the criteria (in general) contained in the standard I feel is appropriate, but do not have any suggested revisions to address this comment (as I believe they could be significant). The scope indicates that the standard applies to stationary, mobile and portable energy storage systems. In Chapter 4, Section 4.1 clearly indicates an application to stationary ESS and I believe in Chapters 4 and 5 there is never any use of the term 'mobile' or 'portable'. As such it is unclear if ALL the provisions in the standard apply to all three types OR if they only apply to stationary ESS. In the latter case if only intended to apply to stationary ESS then the scope in Chapter 1 might be considered misleading and users may be expecting some provisions for mobile and/or portable ESS. In the former case then given the scope one could conclude ALL the provisions in the standard apply to mobile and portable ESS as well, unless the criterion is specifically indicated as applying to stationary ESS. A review of the provisions of Chapters 4 and 5 suggests that some of the provisions would not necessarily be appropriate for mobile and/or portable ESS and could be challenging to apply to those ESS.


Submitter Full Name: David Conover

Organization: Pacific Northwest National Lab

Street Address:

City:

State:

Zip:



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1.3.1 This standard shall not apply to ESS which are an integral part of a generating plant or substation.


- These sites are not open to the public, and first responders are trained not to enter these properties without escort from the utility company.- NFPA 850 currently has methodology within Chapters 4 through 8, particularly Chapter 4, which can and should be applied to ESS installations located at a generating plant or substation. - The language "generating plant or substation" was paraphrased from NFPA 70 Section 90.2 (A) (4). In this referenced section, NFPA 70 exempts such electric utility facilities.


Submitter Full Name: Dennis M Kovach

Organization: American Electric Power Service Corp.

Affilliation: Edison Electric Institute (comment being submitted on behalf of EEI)

Street Address:

City:

State:

Zip:



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1.3* Application.

This standard applies to the following:

(1) Stationary ESS having capacities exceeding the values shown in Table 1.3

(2) Mobile ESS used in stationary applications

(3) Portable ESS interconnected to provide a stationary source of power

Installations which are less than threshold quantities shall follow guidelines set by the authorities having jurisdiction.

Table 1.3 Stationary ESS Threshold Quantities

ESS Technology Aggregate Capacitya

kWh MJ

Battery ESS

Lead acid, all types 70 252

Nickel-cadmium (Ni-Cd) 70 252

Lithium-ion, all types 20 72

Sodium, all types 20c 72c

Flow batteriesb 20 72

Other battery technologies 10 36

Batteries in residential occupancies 1 3.6

Capacitor ESS

Capacitors, all types 3 10.8

Other ESS

All other ESS 70 252

aFor ESS units rated in amp-hrs, kWh equals rated voltage times amp-hr rating divided by 1000.

bIncludes vanadium, zinc-bromine, polysulfide-bromide, and other flowing electrolyte-type technologies.

cValues for sodium-ion technologies are 70 kWh (252 MJ).


Installations that fall below the threshold quantities do not require filing for review as per applicable codes, but should still follow certain guidelines.


Submitter Full Name: Tamara Saakian

Organization: Director of Technology Management, New York City Fire Department

Street Address:

City:

State:

Zip:



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1.3 * Application.






ESS Technology Aggregate Capacity a

kWh MJ

Battery ESS




Sodium, all types 20 c 72 c

Flow batteries b 20 72



Capacitor ESS


Other ESS




cValues for sodium-ion and Sodium Nickel Chloride technologies are 70 kWh (252 MJ).


Chemistry with intrinsic safety and a flawless record should allow for MAQ equal to or greater than Lead Acid, Ni-Cad, and Sodium Ion technologies





Street Address:

City:

State:

Zip:

Submittal Date: Tue Oct 03 09:42:37 EDT 2017


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1.3* Application.



(2) Stand-alone Utility Scale Installations greater than 1 MWh (in aggregate) located in stand-alone enclosures or Normally-Unoccupied ESS buildings shall comply with Chapter XX.





kWh MJ

Battery ESS








Capacitor ESS


Other ESS






AES appreciates that the scope of the 855 Committee is very broad – from a 1kWh home UPS to the largest utility-scale systems (currently AES Escondido at 120,000 kWh, which much larger systems coming soon). The challenges and risks associated with installing systems in regularly occupied residential and commercial structures are quite different from those experienced in stand-alone utility-scale energy storage installations which are autonomous and occupied only occasionally for maintenance. We feel that the committee has done a good job of crafting a standard to protect against the risks associated with the anticipated rapid deployment of residential and commercial storage products, however we feel that some of the requirements contained within the draft standard are unnecessary for larger-scale applications and could have a significant detrimental impact on this industry. As such, we urge the committee to consider an additional chapter to consider the fundamentally-different nature of these large-scale stand-alone systems.


Submitter Full Name: Cliff Orvedal

Organization: AES Energy Storage

Street Address:

City:

State:

Zip:



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1.3* Application.







kWh MJ

Battery ESS ESSd








Capacitor ESS


Other ESS





d The aggregate energy values for batteries are at 100% State of Charge.

Additional Proposed Changes

File Name Description Approved

NFPA_855_Change_Proposal_Table_1.3_Section_3.3_Table_4.5_State_of_Charge_SStookey_Austin_FD_10032017.docx

Code change proposal for Table 1.3, add a new definition for State of Charge to Section 3.3, and revise Table 4.5 concerning State of Charge


See the attached proposal to address State of Charge


Submitter Full Name: Carl Wren


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Organization: Scott Stookey, City of Austin (TX) Fire Department

Street Address:

City:

State:

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PART1:RevisetherowtitledBatteryESSinTable1.3byaddinganewreferencenote“d”toreadasfollows:

BatteryESSd

d.Theaggregateenergyvalueforbatteriesareat100%StateofCharge

PART2:ReviseSection3.3byaddinganewdefinitionforStateofChargethatreadsasfollows:

STATEOFCHARGE(SOC):Theavailablecapacityinabatteryexpressedasapercentageofratedcapacity.Itisthedegreetowhichabatteryhasbeenchargedrelativetoareferencepoint(100%iffullychargedor0%whenfullydischarged)indicatingthetotalelectricalchargethancanbestoredbythebattery.SOCismeasuredinpercent(%).

PART3:RevisethecolumntitledMaximumRatedEnergy*(kWh)inTable4.5toreadasfollows:

MaximumRatedEnergy*(kWh)at100%SOC

BASIS FOR CHANGE PROPOSAL: State of Charge is an important consideration of certain battery systems. In the case of Lithium Ion (LI) batteries, SOC can influence the thermal stability of the battery because it will influence its operating temperature. An important consideration in the proper use of LI batteries is maintaining the Solid Electrolyte Interphase. At typical cell voltages, mixtures of lithiated carbon (or Li metal) and organic electrolyte are not thermodynamically stable and a reaction between the two materials will occur. The result of this reaction is the formation of a passivation layer on the carbon surface, referred to a Solid Electrolyte Interphase. It is an ion conducting and electronically insulating layer. Mikoljak1 reports that for most commercial LI chemistries the SEI layer will itself breakdown when cell temperature reaches the range of 75 to 90°C. The exact temperature depends on cell chemistry and the SOC.

It's Austin FDs experience that SOC is also used as a basis for rating the energy capacity of LI and certain Ni-Cd batteries. For lead acid batteries, this is commonly represented as the specific gravity of the electrolyte solution. While Austin FD has no experience with this, it’s understood that SOC can also be established by measuring the battery current and integrating it in time.

SOC provides useful information in evaluating the state of health data being measured by the Energy Storage or Battery Management systems. Increasing certain types of battery > 100% SOC can accelerate the cell or battery’s service life because it effect the remaining number of charging cycles.

Austin (TX) FD thanks the NFPA 855 TC for considering this proposal.

PROPONENT:ScottStookey,GraduateEngineerA‐HazardousMaterials,Austin(TX)FireDepartment.V:512‐974‐0157,E:[email protected]

1 Mikolajcak, C., Kahn, M., White, K., Thomas Long, R., Lithium‐Ion Batteries Hazard and Use Assessment, National Fire Protection Research Foundation, July 2011, pg. 14


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1.3* Application.







kWh MJ

Battery ESS




Sodium and zinc , all types 20c 72c




Capacitor ESS


Other ESS




cValues for sodium-ion technologies are 70 kWh (252 MJ). Zinc-based battery chemistries exclusive of flow-basedsystems such as zinc-bromine.

Note to the reviewers: Most zinc-based chemistries are less hazardous than flow battery systems (zinc-manganesedioxide Duracell batteries, and zinc-air chemistries used in hearing aids). It seems unreasonable to have zinc-basedbattery systems lumped into the 10kWh threshold when they have inherently safer features than flow (such as zinc-bromine). Most zinc based chemistries use the same alkaline electrolyte (potassium hydroxide, KOH) as in Nickel-cadmium.


Zinc-based battery systems such as zinc-air and zinc manganese dioxide used in hearing aids and Duracell batteries (respectively) are lumped into the "other battery" section despite being much more inherently save than many of the other categories (e.g. zinc-based flow). It is nonsensical that zinc-based flow has a 20kWh and other zinc-based chemistries have a 10kWh threshold.


Submitter Full Name: Constantine Spanos

Organization: Consolidated Edison Company of NY

Affilliation: None

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1.3* Application.







kWh MJ

Battery ESS




Sodium, all types 20 70 c 72 252 c




Capacitor ESS


Other ESS




c Values for sodium-ion technologies are 70 kWh (252 MJ).


thanks to a large diffusion and years of application Sodium Nickel Chloride has already demostrate intrinsically safety.


Submitter Full Name: Nicola Zanon

Organization: FZSONICK SA

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1.3 * Application.






ESS Technology Aggregate Capacity a

kWh MJ

Battery ESS




Sodium, all types

20

70 c 252 72 c

Flow batteries b 20 72



Capacitor ESS


Other ESS






Thanks to a large diffusion and years of experience in large applicaiton Sodium Nickel Chloride is for sure as safe as Sodium ion


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1.3* Application.







kWh MJ

Battery ESS



Lithium-ion, all types 20 Equivalent to Flow Batteries? See attached 72


Flow batteriesb20 20 Equivalent to Li-ion Batteries? See attached 72



Capacitor ESS


Other ESS







NFPA_855_Comments_from_Primus_Power.pdf Comments from Primus Power on relative hazards


Revise values in Table 1.3 Stationary ESS Threshold Quantities and Table 4.5 Maximum Rated Energy forBattery ESS to accurately reflect inherently less hazardous nature of flow batteries.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 503-NFPA 855-2017 [Section No. 4.5 [Excluding any Sub-Sections]]


Submitter Full Name: Mark Collins

Organization: Primus Power

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1.3* Application.




Portable ESS

(3) Charging, storage and deployment of mobile ESS


Table 1.3 Stationary and Mobile ESS Threshold Quantities


kWh MJ

Battery ESS








Capacitor ESS


Other ESS






Correlates mobile ESS requirements with proposal Chapter 4 requirements. Note that there are no real requirements in the standard regulating portable ESS, these need to be considered.


Submitter Full Name: Howard Hopper

Organization: UL LLC

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Submittal Date: Tue Sep 26 19:01:22 EDT 2017


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1.4 Retroactivity.

The provisions of this standard reflect a consensus of what is necessary to provide an acceptable degree of protection fromthe hazards addressed in this standard at the time the standard was issued.

1.4.1

Unless otherwise specified, the provisions of this standard shall not apply to ESS installations that existed or were approved forconstruction or installation prior to the effective date of this standard.

1.4.2

Where specified, the provisions of this standard shall be retroactive.

1.4.3

In those cases where the authority having jurisdiction determines that an existing situation presents an unacceptable degree ofrisk, the authority having jurisdiction shall be permitted to apply retroactively any portions of this standard deemed appropriate.

1.4.4

The retroactive provisions of this standard shall be permitted to be modified if, in the judgment of the authority havingjurisdiction, their application clearly would have an impact and only where it is clearly evident that a reasonable degree ofsafety is provided.

1.4.5

Unless otherwise specified in this standard, the provisions of this standard shall apply to new ESS and their component partsand to ESS or component parts that are made in whole or in part with previously used materials.


Existing systems should be grandfathered in, especially since many systems have been in commercial operation for several years.


Submitter Full Name: Kevin Fok

Organization: LG Chem

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Submittal Date: Sat Sep 30 09:45:20 EDT 2017


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1.4 Retroactivity.

The provisions of this standard reflect a consensus of what is necessary to provide an acceptable degree of protection fromthe hazards addressed in this standard at the time the standard was issued.

1.4.1


1.4.2


1.4.3


1.4.4


1.4.5

Unless otherwise specified in this standard, the provisions of this standard shall apply to new ESS and their component partsand to ESS or component parts that are made in whole or in part with previously used materials.


Retroactivity is an administrative matter that is solely the province of political jurisdictions. If anything, a statement like this should go into the forward of the standard.




Affilliation: the Energy Storage Association

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Public Input No. 361-NFPA 855-2017 [ Sections 1.4.1, 1.4.2, 1.4.3, 1.4.4 ]

Sections 1.4.1, 1.4.2, 1.4.3, 1.4.4

1.4.1


1.4.2


1.4.3


1.4.4



Very large installation bases of existing technology ESS products, installed well before this code was proposed could be affected. The products installed under previous versions of fire and building codes should be grandfathered in.





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Sections 1.4.1, 1.4.2, 1.4.3, 1.4.4

1.4.1


1.4.2


1.4.3


1.4.4



Very large installation done in the past years would be affected by retroactivity. The products installed under previous versions of fire and building codes should be grandfathered in.




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Sections 1.4.1, 1.4.2, 1.4.3, 1.4.4

1.4.1


1.4.2


1.4.3


1.4.4



No exception to rectroactivity shall be permitted. What is installed since many years is compliant with the previous fire code



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Public Input No. 215-NFPA 855-2017 [ Section No. 1.4.4 ]

1.4.4

The non- retroactive provisions of this standard shall be permitted to be modified if, in the judgment of the authority havingjurisdiction, their application clearly would have an impact and only where it is clearly evident that a reasonable degree of safetyis provided.


This section seems to allow changes to non-retroactive provisions to make them retroactive – not changes to the retroactive provisions. I scanned the document and none of the requirements seemed to be retroactive.




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1.5.1

Where the provisions of this standard are not satisfied, a failure modes and effects analysis meeting the provisions of Section4.15 or other comparable set of data and analysis that documents equivalency with the intent of this standard shall beprepared and submitted to the authority having jurisdiction.


Section 4.15 provides the details associated with the conduct of a HMA. The reference to this section in Section 1.5.1 provides a needed 'connector' up front in the standard to those provisions.




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1.5.1

Where the provisions of this standard are not satisfied, a failure modes and effects analysis or other comparable set of dataand analysis that documents equivalency with the intent of this standard shall be prepared and submitted to the authorityhaving jurisdiction.


Lockheed Martin Advanced Energy Storage intends to deploy large scale electrochemical energy storage systems of both a Li-Ion technology and a proprietary flow battery chemistry. These deployments are generally outdoors, and often on the utility side of the meter. With this standard as written, we would rely heavily on the equivalency clause to gain approval from AHJ’s. A high degree of safety for these systems can be achieved with these three elements:

Compliance with UL 9540, including appropriate subsystem listings to UL 1973 for the battery system and UL 1741 for the power conversion system; A thorough, well-documented safety analysis, including an FMEA and a 3rd party fire risk assessment; Appropriate fire testing of the system, conducted or witnessed by a 3rd party.

Those three elements, appropriately applied and approved by the AHJ, should obviate the need to apply more prescriptive elements of the NFPA 855 standard as written, including size and separation limitations, constantly attended monitoring, and automatic fire suppression.



Public Input No. 568-NFPA 855-2017 [Section No. 4.6.2]

Public Input No. 569-NFPA 855-2017 [Section No. 4.8.2 [Excluding any Sub-Sections]]



Submitter Full Name: Kevin DiGenova

Organization: Lockheed Martin Advanced Energy Storage

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2.1 General.

The documents or portions thereof listed in this chapter are referenced within this standard and shall and should beconsidered part of the requirements of this document.


"shall" being an absolute requirement is in contrast with the listed documents that are certainty not aligned... competing code bodies have contributed to a disharmonized collection of reference material, ... recommended comment would be to change to "should"





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2.1 General.

The documents or portions thereof listed in this chapter are referenced within this standard and shall should be consideredpart of the requirements of this document.


shall" being an absolute requirement is in contrast with the listed documents that are certainty not aligned... competing code bodies have contributed to a disharmonized collection of reference material, ... recommended comment would be to change to "should




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2.2 NFPA Publications.

National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 1, Fire Code, 2018 edition .

NFPA 2, Hydrogen Technologies Code, 2016 edition .

NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2015 edition .

NFPA 13, Standard for the Installation of Sprinkler Systems, 2016 edition .

NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2017 edition .

NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, 2016 edition .

NFPA 30, Flammable and Combustible Liquids Code, 2018 edition .

NFPA 52, Vehicular Natural Gas Fuel Systems Code, 2016 edition .

NFPA 54, National Fuel Gas Code, 2018 edition .

NFPA 58, Liquefied Petroleum Gas Code, 2017 edition .

NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2018 edition .

NFPA 69, Standard on Explosion Prevention Systems, 2014 edition .

NFPA 70®, National Electrical Code®, 2017 edition .

NFPA 70E®, Standard for Electrical Safety in the Workplace®, 2018 edition .

NFPA 72®, National Fire Alarm and Signaling Code®, 2016 edition .

NFPA 76, Standard for the Fire Protection of Telecommunications Facilities, 2016 edition.

NFPA 101®, Life Safety Code®, 2018 edition.

NFPA 111, Standard on Stored Electrical Energy Emergency and Standby Power Systems, 2016 edition .

NFPA 750, Standard on Water Mist Fire Protection Systems, 2015 edition .

NFPA 853, Standard for the Installation of Stationary Fuel Cell Power Systems, 2015 edition .

NFPA 1142, Standard on Water Supplies for Suburban and Rural Fire Fighting, 2017 edition .

NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2018 edition .

NFPA 2010, Standard for Fixed Aerosol Fire-Extinguishing Systems, 2015 edition .


It is difficult to keep copies of old standards available. It is easier for users of standards to simply be able to reference the latest revision of the referenced standards.



Public Input No. 479-NFPA 855-2017 [Sections 2.3.1, 2.3.2, 2.3.3, 2.3.4, 2.3.5, 2.3.6, 2.3.7, 2...]




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Public Input No. 479-NFPA 855-2017 [ Sections 2.3.1, 2.3.2, 2.3.3, 2.3.4, 2.3.5, 2.3.6, 2.3.7, 2... ]

Sections 2.3.1, 2.3.2, 2.3.3, 2.3.4, 2.3.5, 2.3.6, 2.3.7, 2.3.8

2.3.1 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.

ANSI Z535.1, American National Standard for Safety Colors, 2011 .

ANSI Z535.2, American National Standard for Environmental and Facility Safety Signs, 2011 .

ANSI Z535.3, American National Standard for Criteria for Safety Symbols, 2011 .

ANSI Z535.4, American National Standard for Product Safety Signs and Labels, 2011 .

ANSI Z535.5, American National Standard for Safety Tags and Barricade Tapes, 2011 .

ANSI Z535.6, American National Standard for Product Safety Information in Product Manuals, Instructions and Other CollateralMaterials, 2011 .

2.3.2 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM E108, Standard Test Methods for Fire Tests of Roof Coverings, 2017 .

2.3.3 IAPMO Publications.

International Association of Plumbing and Mechanical Officials, 4755 E. Philadelphia Street, Ontario, CA 91761.

Uniform Plumbing Code, 2015 .

2.3.4 ICC Publications.

International Code Council, 500 New Jersey Avenue, NW, 6th Floor, Washington, DC 20001.

International Plumbing Code, 2015 .

2.3.5 IEEE Publications.

IEEE, 3 Park Avenue, 17th Floor, New York, NY 10016-5997.

IEEE C2, National Electrical Safety Code, 2017 .

2.3.6 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

UL 790, Standard Test Methods for Fire Tests of Roof Coverings, 2014 .

UL 1564, Standard for Industrial Battery Chargers, 2013 .

UL 1741, Standard for Inverters, Converters, Controllers and Interconnection System Equipment for Use With DistributedEnergy Resources, 2016 .

UL 9540, Safety of Energy Storage Systems and Equipment, 2016 .

2.3.7 UN Publications.

United Nations Headquarters, New York, NY 10017.

UN 38.3, Recommendations on the Transport of Dangerous Goods: Lithium Metal and Lithium Ion Batteries, 2015 .

2.3.8 Other Publications.

Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003 .


It is difficult to keep copies of old standards available. It is easier for users of standards to simply be able to reference the latest revision of the referenced standards.



Public Input No. 477-NFPA 855-2017 [Section No. 2.2] Same reasoning



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2.3.5 IEEE Publications.

IEEE, 3 Park Avenue, 17th Floor, New York, NY 10016-5997.

IEEE C2, National Electrical Safety Code, 2017.

IEEE 484, Recommended Practice for Installation Design and Installation of Vented Lead-Acid Batteries for StationaryApplications

IEEE 485, Recommended Practice for Sizing Vented Lead-Acid Storage Batteries for Stationary Applications

IEEE 1145, Recommended Practice for Installation and Maintenance of Nickel-Cadmium Batteries for Photovoltaic (PV)Systems

IEEE 1187, Recommended Practice for Installation Design, and Installation of Valve-Regulated Lead-Acid Batteries forStationary Applications

IEEE 1375, IEEE Guide for the Protection of Stationary Battery Systems

IEEE 1578, Recommended Practice for Stationary Battery Electrolyte Spill Containment and Management

IEEE 1635/ASHRAE 21, Guide for the Ventilation and Thermal Management of Batteries for Stationary Applications

IEEE 1657, IEEE Recommended Practice for Personnel Qualifications for Installation and Maintenance of Stationary Batteries


These IEEE standards are critical to energy storage systems installations.




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UL 790, Standard Test Methods for Fire Tests of Roof Coverings, 2014.

UL 1564, Standard for Industrial Battery Chargers, 2013.

UL 1741, Standard for Inverters, Converters, Controllers and Interconnection System Equipment for Use With DistributedEnergy Resources, 2016.

UL 9540, Safety of Energy Storage Systems and Equipment, 2016.

UL 1973, Standard for Batteries for Use in Light Electric rail (LER) Applications and Stationary Applications, 2016


The Standard for the batteries contained in ESS's should be included UL 1973





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UL1973 Standard for batteries for use in light electrical rail (LER) aplications and stationaryapplcation, 2016


Standard for batteries contained in ESS



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UL 1973, Standard for Batteries for Use in Light Electric rail (LER) Applications and Stationary Applications, 2016


Standard for safety for battery based on Lithium ion, sodium nickel, sodium sulfur.




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UL 1974, Standard for Evaluation for Repurposing Batteries , 2017


UL 9540A, Test Methods for Thermal Runaway Fire Propagation within Battery Energy Storage Systems, 2017.


UL publications referenced in other public inputs.



Public Input No. 65-NFPA 855-2017 [New Section after 4.4]

Public Input No. 66-NFPA 855-2017 [New Section after 4.2.5.3]




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Submittal Date: Mon Sep 25 12:32:40 EDT 2017


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2.3.7 UN Publications.

United Nations Headquarters, New York, NY 10017.

UN 38.3, Recommendations on the Transport of Dangerous Goods: Lithium Metal and Lithium Ion Batteries, 2015. currentaddition identified in the Federal Registry


I sit on the UN panel for 38.3 and we are working on the next revision. If you state the version you will then have to update the document immediately after 38.3 revision is released. By Federal Law you must test to the latest standard to ship. All previous should be grandfathered in to whatever was on the Federal Registry at time of testing


Submitter Full Name: David Ginder

Organization: Saft America

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Normally-unoccupied Facility

A facility which is operated, maintained or serviced by employees who visit the facility only periodically to check its operationand to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility.


Added new definition to distinguish between occupied buildings and those that are only occupied occasionally for maintenance.




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3.2 NFPA Official Definitions.

3.2.1* Approved.

Acceptable to the authority having jurisdiction.

3.2.2* Authority Having Jurisdiction (AHJ).

An organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approvingequipment, materials, an installation, or a procedure.

3.2.3 Labeled.

Equipment or materials to which has been attached a label, symbol, or other identifying mark of an organization that isacceptable to the authority having jurisdiction and concerned with product evaluation, that maintains periodic inspection ofproduction of labeled equipment or materials, and by whose labeling the manufacturer indicates compliance with appropriatestandards or performance in a specified manner.

3.2.4* Listed.

Equipment, materials, or services included in a list published by an organization that is acceptable to the authority havingjurisdiction and concerned with evaluation of products or services, that maintains periodic inspection of production of listedequipment or materials or periodic evaluation of services, and whose listing states that either the equipment, material, orservice meets appropriate designated standards or has been tested and found suitable for a specified purpose.

3.2.5 Shall.

Indicates a mandatory requirement.

3.2.6 Standard.

An NFPA Standard, the main text of which contains only mandatory provisions using the word “shall” to indicate requirementsand that is in a form generally suitable for mandatory reference by another standard or code or for adoption into law.Nonmandatory provisions are not to be considered a part of the requirements of a standard and shall be located in anappendix, annex, footnote, informational note, or other means as permitted in the NFPA Manuals of Style. When used in ageneric sense, such as in the phrase “standards development process” or “standards development activities,” the term“standards” includes all NFPA Standards, including Codes, Standards, Recommended Practices, and Guides.


What is the purpose of the asterisks?




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Fire Command Center

[add definition of the Fire Command Center referenced in 4.12]


Suggest adding a definition for the Fire Command Center referenced in 4.12.




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THERMAL RUNAWAY

A condition whereby a battery on charge or discharge will overheat and destroy itself through internal heat generation causesby high overcharge or overdischarging current or other abusive condition.Type your content here ...


The draft standard employs the phrase "Thermal Runaway" in 10 different sections yet the term isn't defined. The definition indicates the primary causes of thermal runaway in valve regulated lead acid and lithium ion batteries employing carbonated solvents with lithium salts. Defining this term is important because prevention of thermal runaway is critical safety consideration in the design of electrochemical stored energy systems and as a benchmark for the performance of Energy Storage Management System.

An example of an abusive condition is mechanically puncturing a cylinderical or prismatic cell Lithium Ion cell.

PROPONENT: Scott Stookey, Graduate Engineer A-Hazardous Materials, Austin (TX) Fire Department. V: 512-974-0157, E: [email protected]


Submitter FullName:

Carl Wren

Organization:Scott Stookey, City of Austin Fire Department - Fire Marshal's Office. V:512-974-0157E: [email protected]

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CHARGE CONTROL

One or more methods for effectively terminating the charging of a rechargeable battery.


Section 4.3 sets forth requirements for charge controllers but the term isn't defined. This definition was based on a review of the Handbook of Batteries - 3rd edition, by David Linden and Thomas Reddy. The definition is useful as charge control is important in the prevention of thermal runaway and monitoring the cell or battery's State of Health over its service life.




Organization: Scott Stookey, City of Austin Fire Department

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Battery Management System (BMS)

A system that monitors, controls, and optimizes performance of an individual module in an energy storage system and has theability to disconnect the module from the system in the event of abnormal or hazadous conditions.This system can becompletely independent of the ESMS.


Batteries modules with BMS's can be installed without requiring a master control or management scheme (MSMS), that could potentially add additional complexity and cost for the user.





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ENERGY STORAGE SYSTEM CABINET. A cabinet containing components of the energy storage system that is included in theUL 9540 listing for the system where personnel cannot enter the enclosure other than reaching in to access components formaintenance purposes. Type your content here ...


By defining energy storage system cabinet, container and dedicated use buildings it will assist in clarifying application of the standard.






Submitter Full Name: Robert Davidson

Organization: Davidson Code Concepts LLC

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E NERGY STORAGE SYSTEM CONTAINER . A pre-fabricated building designed and installed to contain components of anenergy storage system e your content here ...


By defining energy storage system cabinet, container and dedicated use buildings it will assist in clarifying application of the standard







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ENERGY STORAGE SYSTEM DEDICATED USE BUILDING . A building constructed on site that is only used forelectrochemical energy storage, energy generation, and other electrical grid related operations Type your content here ...


By defining energy storage system cabinet, container and dedicated use buildings it will assist in clarifying application of the standard







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Public Input No. 536-NFPA 855-2017 [ Section No. 3.3.1 [Excluding any Sub-Sections] ]

A single cell or a group of One or more cells connected together electrically in series , in or parallel, or a combination ofboth both, to provide the required operating voltage and current levels .


Change to be consistent with the IEEE definition (ref: IEEE 1881)




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Public Input No. 240-NFPA 855-2017 [ Section No. 3.3.1.1 ]

3.3.1.1 Flow Battery.

A type of storage battery that includes chemical components dissolved in two different liquids. Ion exchange, which providesthe flow of electrical current, occurs through the membrane through a membrane which separats the two liquids while bothliquids circulate in their own respective space.


Editorial enhancement to make it clear the membrane is separating the two liquids.




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A type of storage battery that includes chemical components dissolved in two different liquids. Ion Energy storage is achievedvia a) ion exchange, which provides the flow of electrical current, occurs through the a membrane while both liquids circulatein their own respective space or b) plating of a metal on electrodes .



Conventional_Flow_Compare.pdf Comparison to Conventional Flow Batteries


Revise language to more accurately define flow batteries to include other commercially available types.



Public Input No. 512-NFPA 855-2017 [Section No. B.5.1 [Excluding any Sub-Sections]]




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A type of storage battery that includes chemical components dissolved in two different liquids. Ion exchange, which providesthe flow of electrical current, occurs through the membrane while both liquids circulate in their own respectivespace rechargeable battery in which energy is stored in liquid electrolytes that flow through an electrode stack, forming positiveand negative half cells that exchange ions during charge or discharge, typically through a membrane separator .


Change to be consistent with the IEEE definition (ref: IEEE 1881)




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3.3.2 Cell.The basic electrochemical

unit

building block of a battery , characterized by

an anode and

a

cathode, used to receive, store, and deliver electrical energy. [ 70 :706.2]

positive electrode, a negative electrode, and electrolyte.


hange to be consistent with the IEEE definition (ref: IEEE 1881)




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One or more devices, assembled together, capable of storing energy in order to supply electrical energy at a future time. Theenergy storage systems equipment (constructed either as one unitary complete system or as matched assemblies that whenconnected are the system) may include equipment for charging, discharging, control, protection, power conversion andcommunication.


Adding this language should help clarify what equipment may be considered part of an ESS, and keeps is consistent with language used in the UL9540 standard.


Submitter Full Name: Tommy Jacoby

Organization: Greensmith Energy

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3.3.4.1 Capacitor Energy Storage System.

A stationary, rechargeable energy storage system consisting of capacitors, chargers, controls, and associated electricalequipment designed to provide electrical power to a building (does this then exclude capacitors staged with batterydevices that are not designed to provide power to buildings or the electrical system directly, but rather to absorbcurrent transients to increase battery storage response time???) . The system is typically used to provide standby oremergency power, an uninterruptable power supply, load shedding, load sharing, or similar capabilities.


Language unclear




Affilliation: None

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3.3.4.1

CapacitorElectrochemical Energy Storage System

.A stationary, rechargeable energy storage system consisting of capacitors, chargers, controls, and associated electricalequipment designed to provide electrical power to a building. The system is typically used to provide standby or emergencypower, an uninterruptable power supply, load shedding, load sharing, or similar capabilities.(EESS). An energy storage system that utilizes electrochemical storage devices such as batteries as the means for energystorage.


The term electrochemical energy storage is being utilized in the document to identify battery energy storage and similar technologies. This term should be defined. In addition, the capacitor energy storage system, is being proposed to fall under the overall category of "electrochemical" energy storage for this standard as well as the fire codes, so a specific definition for capacitor energy storage system does not need to be included.


Submitter Full Name: Laurie Florence


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Public Input No. 102-NFPA 855-2017 [ Sections 3.3.4.1, 3.3.4.2 ]

Sections 3.3.4.1, 3.3.4.2

3.3.4.1 Capacitor Energy Storage System.

A stationary, rechargeable energy storage system consisting of capacitors, chargers, controls, and associated electricalequipment designed to provide electrical power to a building. The system is typically used to provide standby or emergencypower, an uninterruptable power supply, load shedding, load sharing, or similar capabilities. controls and equipment.

3.3.4.2 Mobile Energy Storage System.

An energy storage system capable of being moved and utilized as a stationary ESS and not installed as fixed or permanentlyinstalled electrical equipment temporary source of power .


Capacitor ESS can be mobile or stationary. They may also be used for applications other than building power.

The mobile definition was modified to better reflect the new Chapter 4 requirements. The "stationary ESS" reference had to be removed since by definition it is a fixed installation.




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An energy storage system capable of being moved and utilized as a stationary Stationary ESS and but not installed as fixedor permanently installed electrical equipment.


Attempts to clarify Mobile ESS.




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An energy storage system capable of being moved and utilized as a stationary Stationary ESS and not installed as fixed orpermanently installed electrical equipment.


Stationary ESS is a defined term and should be capitalized.





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3.3.4.4* Pre-Engineered Energy Storage System.

An energy storage system that is not a prepackaged system but instead is pre-engineered and field-assembled using separatecomponents supplied as a system by a singular entity that is matched and intended to be assembled as an energy storagesystem at the system installation site.


Removes the reference to pre-packaged ESS listed to UL 9540 (See A.4.2.1) as that product does not exist.





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Sections 3.3.4.4, 3.3.4.5

3.3.4.4* Pre-Engineered Energy Storage System.

An energy storage system that is not a prepackaged system but instead is

, Pre-Engineered

Energy storage systems that are not self-contained systems but instead are pre-engineered and field-assembled usingseparate separate components supplied as a system by a singular entity that is are matched and intended to be assembledas an energy storage storage system at the system installation site.

3.3.4.5* Prepackaged Energy Storage System.

An energy storage system

, Self-Contained

Energy storage systems where the components such as cells, batteries, or modules and and any necessary controls,ventilation, illumination, fire suppression, or alarm systems are assembled, installed, and packaged packaged into asingular energy storage container or unit.


These changes copy over the definition text from NFPA 70;706.2. Since 855 and 70 will be used together it would seem to be a good idea if they define ESS the same way.



Public Input No. 253-NFPA 855-2017 [Section No. 4.2.3.2]




Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

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Public Input No. 250-NFPA 855-2017 [ New Section after 3.3.4.5 ]

Energy Storage System, Other.

Energy storage systems that are not self-contained or pre-engineered systems but instead are composed of individualcomponents assembled as a system.


There needs to be a catch all category for ESS that does not fall into pre-engineered or self-contained. This covers ESS that someone who is not a manufacturer might integrate from off the shelf ESS components.This category is in NFPA 70;706.2




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3.3.4.5 * Prepackaged Energy Storage System.

An energy storage system where the components such as cells, batteries, or modules and any necessary controls, ventilation,illumination, fire suppression, or alarm systems are assembled, installed, and packaged into a singular energy storagecontainer or unit.


The ESS industry does not manufacture commercial sized Pre-Packaged listed or labeled ESS (exception TESLA Powerwall). It does supply pre-engineered systems where individual components are subject to various UL standards including 9540, 1973 and 1741.





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Public Input No. 165-NFPA 855-2017 [ New Section after 3.3.7 ]

Fault Condition Testing

If equipment not listed per UL9540, testing of an energy storage system unit where single fault conditions are individuallyintroduced to ensure the fault does not create unsafe conditions. Each fault condition is removed and the equipment repared orreplaced if necessary prior to the applicaion of the next fault condition. Fault conditions to be applied shall be based on asystem analysis to identify fault that may result in such unsafe conditons.


Fault Condition Testing is in the title of section 3.3.7, but the section does not address it. This proposed section provides the needed details.


Submitter Full Name: Kleber Facchini

Organization: SC Electric

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Submittal Date: Fri Sep 29 17:32:52 EDT 2017


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3.3.7 Large Representative -Scale Fire and Fault Condition Testing.

Testing of an energy storage system unit that induces a fire into single thermal event into a cell contained within the unit undertest, and evaluates whether the resultant fire will spread to adjacent energy storage system units, surrounding equipment, orthrough an adjacent fire resistance rated barrier.

The representative-scale shall be sufficiently large so as to provide equipment installed in accordance with the manufacturer'sinstallation instruction directly adjacent to and on all sides of the unit under test, also considering equipment that may beplaced to the rear or, or across an aisle from, the unit under test.


“Representative-scale” testing should replace “Large-scale” testing to allow for tests appropriately sized, while reducing the total costs of performing such tests. The definition in 3.3.7 Large-Scale Fire and Fault Condition Testing does not allow for a smaller, representative test to proxy for a complete system. It is not feasible to damage a multi-million dollar system when a smaller, much less expensive test could provide the same results. This clause will block many suppliers from entering the large-scale ESS market, reducing competition, increasing customer costs, and ultimately reducing safety.Fault Condition Testing is not defined or discussed in this clause. A separate PI will be submitted to recommend adding as a new section.


Submitter Full Name: Vince Baclawski

Organization: Nema

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Submittal Date: Thu Sep 28 10:38:38 EDT 2017


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3.3.7 Large Representative -Scale Fire and Fault Condition Testing.

Testing of an energy storage system unit that induces a fire into single thermal runaway event into a cell contained into the unitunder test, and evaluates whether the resultant fire will spread to adjacent energy storage system units, surroundingequipment, or through an adjacent fire resistance rated barrier. The representative-scale test shall be sufficiently large so as toprovide equipment installed in accordance with the manufacturer's installation instruction directly adjacent to and on all sidesoft the unit under test, also considering equipment that may be placed to the rear of, or across an aisle from, the unit undertest.


“Representative-scale” testing should replace “Large-scale” testing to allow for tests appropriately sized, while reducing the total costs of performing such tests. The definition in 3.3.7 Large-Scale Fire and Fault Condition Testing does not allow for a smaller, representative test to proxy for a complete system. It is not feasible to damage a multi-million dollar system when a smaller, much less expensive test could provide the same results. This clause will block many suppliers from entering the large-scale ESS market, reducing competition, increasing customer costs, and ultimately reducing safety.Fault Condition Testing is not defined or discussed in this clause.




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3.3.7 Large-Scale Fire and Fault Condition Testing.

Testing of an assembled energy storage system unit that induces a fire into the unit under test, and evaluates whether the firewill spread to adjacent energy storage system units, surrounding equipment, or through an adjacent fire resistance ratedbarrier.


Eletrochemical ESS are an assembly composed of structural frame, individual cells or cells assembled into modules, a battery or energy managment system, and possibly an enclosure. The term "unit" raises more questions as to what is being defined. For eletrochemical ESS the proposal better clarifies what will be tested.




Organization: Scott Stookey, City of Austin Fire Department

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3.3.7 7 Large-Scale Representative Scale Fire and Fault Condition Testing.

Testing of an a typical battery unit within the energy storage system unit that induces a fire into the unit under test, andevaluates whether the fire will spread to adjacent energy storage system units, surrounding equipment, or through anadjacent fire resistance rated barrier .


A representative set up showing fire induced into one battery unit within the ESS would be adequate to demonstrate fire does not propagate to adjacent units. There is no value in destroying a multi-million dollar system to fulfill this requirement and this would be cost prohibitive for some manufacturers.


Submitter Full Name: Thameem Ismail

Organization: General Electric Distributed Grid Systems - North America Energy Storage

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Testing of an energy storage system unit that induces a significant fire into the unit under test, and evaluates whether the firewill spread to adjacent energy storage system units, surrounding equipment, or through an adjacent fire resistance ratedbarrier.


My notes show this language was agreed upon at the last drafting meeting. This correlates with the fire induced in the UL 9540A test criteria.



Public Input No. 65-NFPA 855-2017 [New Section after 4.4] companion change




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Public Input No. 139-NFPA 855-2017 [ Sections 3.3.7, 3.3.8 ]

Sections 3.3.7, 3.3.8


Testing of an energy storage system unit that induces a fire into the unit under test, and evaluates whether the fire will spread toadjacent energy storage system units, surrounding equipment, or through an adjacent fire resistance rated barrier.

New section between 3.3. 7 and 3.3. 8

x.x.x Fault Condition Testing

Testing of an energy storage system unit where single fault conditions are individually introduced to ensure the fault does notcreate unsafe conditions. Each fault condition is removed and the equipment repaired or replaced if necessary prior toapplication of the next fault condition. Fault conditions to be applied shall be based on a system analysis to identify faults thatmay result in such unsafe conditions.

Informational Note: Listed equipment will have already undergone such testing. System integration, connection points andinteractions should be considered when identifying fault conditions to be applied.

3.3.8 Maximum Rated Energy (MRE).

The quantity of energy storage permitted in a fire area prior to the area being considered a high hazard occupancy.


Fault Condition Testing is in the title of section 3.3.7, but the section does not address it. This proposed section provides the needed details.



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3.3.8 Maximum Rated Energy (MRE) or Maximum Allowable Quantity (MAQ) .



Maximum Allowable Quantity (MAQ) is used in referenced standards and is commonly known to AHJ's




Affilliation: FZSonick Inc

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3.3.8 Maximum Rated Energy (MRE) or Maximum Allowable Quantity (MAQ) .



MRE and MAQ are used with the same means in the document. i.e. chapter 4.5.4 refer to maximum allowable quantity




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3.3.8 Maximum Rated Energy (MRE) . or Maximum Allowable Quantity (MAQ)



MRE is used as alternative term for MAQ (like 4.5.4)



Organization: RnD

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3.3.9 * Normally Unoccupied Building Service Equipment Support Area.

A building service equipment support area in which people are not expected to be present on a regular basis. [ 101 , 2018]


This term appears only in the definition section and the associated annex. It is not in the body of the standard. It should be removed or made applicable. Perhaps we missed a related point in the body of the standard. Annex material can be removed as well.




Affilliation: ATIS

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3.3.10 Open Parking Garage.

A street-level or higher structure or portion of a structure with the openings on two or more sides that is used for the parking orstorage of private motor vehicles.


An underground parking structure with two vehicle access openings could be confused with the current wording as an open parking garage while it is clearly not. Just a clarification of above ground parking structure.


Submitter Full Name: Matthew Paiss

Organization: San Jose Fire Department

Affilliation: International Association of Fire fighters

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3.3.11 Registered Design Professional (RDP). Professional Engineer

An individual who is registered or licensed to practice his/her respective design profession Professional Engineering asdefined by the statutory requirements of the professional registration laws of the state or jurisdiction in which the project is to beconstructed . [ 5000 , 2018] and qualified in the area of engineering required for the specific task.


In the real world you want a professional engineer licensed by the state and with experience in the area required to perform the investigations called out in 855. There is no direct reference I can find that connects a "registered design professional" to a licensed professional engineer. States license and register a long list of professions and those relating to construction, engineering, and architecture are a very small slice of those professions. We can hope an AHJ requires the correct kind of "registered design professional" to do the work or 855 can be more specific. Change this throughout 855 to indicate that a professional engineer licensed in the state should be performing these tasks.







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3.3.12 Utility Interactive.

An energy storage system intended for use in parallel with connected to an electric utility to supply common loads that candeliver power to the utility that is capable of charging from the grid and/or discharging to the grid .


The current definition is quite confusing, and I can't understand what it is intending to say. I think the proposed definition is clear, concise, and broad enough to capture the various scenarios that could apply.




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Public Input No. 243-NFPA 855-2017 [ Section No. 4.1 [Excluding any Sub-Sections] ]

The design and , construction and installation of stationary ESS and related equipment shall comply with Chapter 4, exceptas provided in in addition to the provisions in Chapter 5 through Chapter 12.


For consistency within the standard as the standard does apply to the construction of ESS as stated in Chapter 1. The manner in which Chapters 5 to 12 are referenced suggests that Chapter 4 does not apply when something is excepted via Chapters 5 to 12. It seems more appropriate to 'tee up' the reference to those chapters as being in addition to Chapter 4 as opposed to possibly taking away or omitting provisions in Chapter 4.




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The design and installation of stationary Stationary ESS and related equipment shall comply with Chapter 4, except asprovided in Chapter 5 through Chapter 12.


"Stationary" is a defined term and should be capitalized.





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The design and installation of stationary ESS and related equipment shall comply with Chapter 4, except as provided inChapter 5 through 9 through Chapter 12 17 .


The reference should be to technology specific sections, which don't include Chapters 5-8. Also 'stationary' should be removed. The committee may also wish to reexamine how this section fits in with the technology specific sections. Perhaps the wording should be "The design and installation of ESS and related equipment shall comply with Chapter 4, unless specifically exempted in Chapter 9 through Chapter 17." (From IFC proposal Section 1206.2)




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4.2.2 Repairs. Repairs of energy storage systems shall only be done by qualified personnel. Repairs with other than identicalparts shall be considered retrofitting and comply with Section

4.2.2.1 Repairs shall be documented in the maintenance, testing and events log required under Section 4.17.3.

4.2.3 Retrofits . Retrofitting of an existing energy storage system shall comply with the following:

1. An installation permit shall be obtained in accordance with Section 105.7.6

2. Energy storage system units such as batteries, battery modules, and capacitors shall be listed in accordance with UL1973.

3. Battery management and other monitoring systems shall be connected and installed in accordance with themanufacturer’s instructions.

4. The overall installation shall continue to comply with UL 9540 listing requirements, where applicable.

5. Retrofits shall be documented in the maintenance, testing and events log required under Section 4.17.3.

Exception: Requirements do not apply to retrofitting of lead acid and Ni-Cad battery systems at telecommunicationsfacilities that comply with NFPA 76 and operate at less than 50 VAC and 60 VDC with other lead acid or Ni-Cadbatteries.

4.2.3.1 Retrofits shall be documented in the maintenance, testing and events log required under Section 4.17.3.

4.2.4 Replacements. Replacements of energy storage systems shall be considered new energy storage system installationsand shall comply with the provisions applicable to new energy storage systems. The energy storage system being replacedshall be decommissioned in accordance with Chapter 8.


This proposal provides guidance on how to handle repairs, retrofits and replacements of ESS. The proposed text is based on requirements developed by the FCAC ESS work group.




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4.2.1* Listings.

ESS shall be listed in accordance with UL 9540, unless specifically exempted in other sections of this standard.

Telecommunications facilities with lead-acid and nickel-cadmium battery storage less than 50-V ac, 60-V dc and in compliancewith NFPA 76 are exempted from listing requirements.


Telecom Pb acid and NiCd batteries are not routinely listed. The telecom industry follows private standards for product performance as referenced in NFPA 76. Using this alternative path to product design has allowed this industry to maintain reliable service and an exceptional safety record.




Affilliation: ATIS

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4.2.1 * Listings.

ESS shall be listed in accordance with UL 9540, unless specifically exempted in other sections of this standard. Batteries shallbe listed in accordance with UL 1973.


Batteries and battery systems are covered in the standard, giving the impression that they might be considered differently than an ESS. While UL 9540 applies to an ESS and references UL 1973 with respect to the batteries in the ESS, a reference to UL 1973 seems appropriate in case there are some 'systems' that are simply made up of batteries. If not then it seems appropriate to clarify this in the standard and eliminate references to batteries and battery systems.




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4.2.1* Listings.

ESS of less than 1 MWh shall be listed in accordance with UL 9540, unless specifically exempted in other sections of thisstandard. All energy storage systems shall utilize inverters meeting UL 1741 and battery modules meeting UL 1973.


Large-scale ESS are not mass produced but rather each system is custom designed and built to specific customer requirements, thus making UL listing of the complete system challenging and costly. Systems of this scale already undergo detailed compliance review by the AHJ, so a system-level UL certification may add limited value.




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4.2.1* Listings.

ESS components shall be listed in accordance with UL 9540, 1741 or 1973, as appropriate, unless specifically exempted inother sections of this standard.


This proposal clarifies that components to ESS Pre-engineered systems must meet applicable UL standards.





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4.2.1* Listings.

ESS shall be listed in accordance with UL 9540 ( UL 1973 ) , unless specifically exempted in other sections of this standard.

Note: UL 9540 is intended for commoditized systems as opposed to storage configurations specific to each installation,and this may present challenges. The FDNY has expressed interest in UL 1973. UL 9540 may be applicable for one-offsystems through site inspections and approvals, although this is as yet uncertain.


Possible challenges surrounding the requirement of UL 9540.




Affilliation: None

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4.2.1* Listings.

ESS shall be listed in accordance with UL 9540, unless specifically exempted in other sections of this standard.

Exception: Lead-acid and Ni-Cad battery systems installed in telecommunications facilities operating at less than 50VAC and 60 VDC in accordance with NFPA 76 are not required to be listed.


This proposal allows a reasonable exception for these systems and is consistent with requirements being considered by the FCAC ESS working group.




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4.2.3 Charge Controllers.

4.2.3.1

Charge controllers shall be compatible with the battery or ESS manufacturer's electrical ratings and charging specifications.

4.2.3.2

Charge controllers shall be listed and labeled in accordance with UL 1741 or provided as part of a listed pre-engineered orprepackaged ESS.

4.2.3.3

Battery chargers used for the charging of a battery system that is not utility interactive shall be permitted to be listed andlabeled in accordance with UL 1564.


Electrical requirements for ESS are already covered in NFPA 70 Article 706. Repeating them in 855 at best just duplicate text and at worst could create conflicts




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4.2.3.2

Charge controllers shall be listed and labeled in accordance with UL 1741 or provided as part of a listed pre-engineered orprepackaged self-contained ESS.


Updated to match change in definition.



Public Input No. 248-NFPA 855-2017 [Sections 3.3.4.4, 3.3.4.5]




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Sections 4.2.3.2, 4.2.3.3

4.2.3.2

Charge controllers shall be listed and labeled in accordance with UL 1741 or provided as part of a listed pre Pre -engineered orprepackaged Prepackaged ESS.

4.2.3.3

Exception: Battery chargers used for the charging of a battery system that is not utility interactive shall be

permitted to be

listed and labeled in accordance with UL 1564.


This proposal combined 4.2.3.2 and 4.2.3.3 by making the latter an exception to the former. Permissive language like "shall be permitted" is not preferred code text.





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4.2.4 Inverters and Converters.

4.2.4.1

Inverters and converters shall be listed and labeled in accordance with UL 1741.

4.2.4.2 *

Only units listed and labeled for utility interactive system use and identified as interactive shall be allowed to operate in parallelwith the electric utility power system to supply power to common loads.


Electrical requirements for ESS are already covered in NFPA 70 Article 706. Repeating them in 855 at best just duplicate text and at worst could create conflicts




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4.2.4.2*

Only units listed and labeled for utility interactive system use and identified as interactive shall be allowed to operate in parallelwith the electric utility power system to supply power to common loads .


The clause/phrase at the end of the existing language is (1) confusing, (2) and potentially limiting. I believe the language can stand along without the clause at the end.




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4.2.4.2*

Only units listed Listed and labeled for utility interactive system use and identified as interactive shall be allowed to Labeledfor Utility Interactive use may operate in parallel with the electric utility power system to supply power to common loads.


Defined terms are capitalized.

Products that are listed and labeled will, by definition, be identified so the addition clause ("identified") is redundant.





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Telecommunications facilities with lead-acid and Nickel-Cadmium battery storage less than 50-V ac, 60-V dc and incompliance with NFPA 76 shall be exempted from the requirements of 4.2.5.


Telecom facilities using Pb-acid and nickel-cadmium batteries do not utilize a sophisticated ESMS as is envisioned by the standard. In addition, there is no control capable of automatically disconnecting the ESS, nor is such a feature desirable in these applications. The text must be revised accordingly.




Affilliation: ATIS

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4.2.5.1

Where required by the equipment listing in accordance with Section 4.1 or the hazard mitigation analysis in accordance withSection 4.2, an approved ESMS ESMS approved by the ESS manufacturer or AHJ shall be provided for monitoring operatingconditions and maintaining voltages, currents, and temperatures within the manufacturer's specifications.


using the term "approved" without specifying by whom does not provide useful information. If the ESMS must be approved, the language should specify by whom it should be approved. I propose the ESS manufacturer and/or AHJ would be worthy of providing such approval.




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4.2.5.1

Where required by the equipment listing in accordance with Section 4.2. 1 or the hazard mitigation analysis in accordance withSection 4 1 . 2 5.1 , an approved ESMS shall be provided for monitoring operating conditions and maintaining voltages,currents, and temperatures within the manufacturer's specifications.


The section covering listings is 4.2.1 and the section covering hazard mitigation analysis is 1.5.1.




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4.2.5.1

Where required by the equipment listing in accordance with Section 4.1 or the hazard mitigation analysis in accordance withSection 4.2 15 , an approved ESMS shall be provided for monitoring operating conditions and maintaining voltages, currents,and temperatures within the manufacturer's specifications.


The section numbers referenced are not correct. I changed one to 4.15 but I'm not sure where the other should be pointing to, but it's not 4.1.




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4.2.5.1

Where required by the equipment listing in accordance with Section 4.1 or the hazard mitigation analysis in accordance withSection 4.2 15 , an approved ESMS shall be provided for monitoring operating conditions and maintaining voltages, currents,and temperatures within the manufacturer's specifications.


Corrects reference.




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4.2.5.2

The ESMS shall shut down the ESS or place it in a safe condition if thermal runaway or a potentially hazardous temperaturesor other conditions are condition is detected.


This change was made to be more specific about what occurrence produces high temperatures, but leave a general statement regarding other hazardous conditions.

Yvonne Espinoza,PE, Austin Fire Department, 512-974-0185, [email protected]


Submitter FullName:

Carl Wren

Organization: City of Austin Fire Department

Affilliation:Comments submitted by Yvonne Espinoza, PE with AFD. Carl Wren has retired butour AFD account remains in his name

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Submittal Date: Wed Sep 27 20:26:22 EDT 2017


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4.2.5.2

The ESMS shall shut down the electrically isolate the components of the ESS or place it in a safe condition if potentiallyhazardous temperatures or other conditions are detected.


"shut down" is not a conclusive term, the requirement would need to be more demonstrative so it can be easily proven that the requirement is met. Maintaining supervisory control power will create a safer condition as the system will remain monitored in terms of its own temperature and condition in lieu of a complete shut-down.



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4.2.5.2

The ESMS shall shut down the ESS or place it in a safe condition if shall electrically isolate the components of the ESS fromthe electric grid if potentially hazardous temperatures or other conditions are detected.


"shut down" is not a conclusive term, the requirement would need to be more demonstrative so it can be easily proven that the requirement is met. Maintaining supervisory control power will create a safer condition as the system will remain monitored in terms of its own temperature and condition in lieu of a complete shut-down.




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4.2.5.2

The ESMS shall shut down the ESS or place it in a safe condition if potentially hazardous temperatures or other conditionsazardous conditions associated with the ESS are detected.


Clarification that 'other conditions' are hazards associated with the ESS.




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Type your content here ... 4.2.6 Reused and repurposed equipment. Storage batteries previously used in other applications,such as electric vehicle propulsion, shall not be reused in ESS applications unless (1) approved by the AHJ and (2) theequipment is refurbished by a UL 1974 compliant battery refurbishing company.


This proposal fills a void in the code regarding repurposed batteries and reflects protection concepts developed by the FCAC ESS working group.



Public Input No. 64-NFPA 855-2017 [Section No. 2.3.6] companion proposal.




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4.2.5.3*

When required by the AHJ, visible annunciation shall be provided In ESS that has either a flamable electrolyte, or is prone tothermal runaway, visible annunciation of module temperature, voltage, or other hazardous conditions shall be provided ateither the exterior ESS cabinet, or in an approved location to indicate potentially hazardous conditions exist .


The potential for long duration thermal runaway events presents a challenge to fire fighters when responding to incidents involving ESS with either a flammable electrolyte, or is prone to thermal runaway. If an event occurs in a battery room with many racks of batteries that produces enough smoke to trip an alarm but not enough to identify the specific cabinet or rack involved, there is no way to know which cabinet or rack is the source of the fault. A requirement of more granular annunciation of internal conditions of the ESS is needed to meet the requirement of fault annunciation. Additionally, the responding firefighters may have no idea if they are arriving at the beginning of a runaway event, or at the end. The liability of determining that the hazard has been mitigated and turning over an event to the building owner requires more information for the Incident Commander to base their decision on. ESS manufacturers have the data in many instances down to the cell level. Aggregating this real-time data to provide temperature and voltage in a fault notification window would provide operators and responders better situational awareness of the condition of the ESS. The IAFF recommends the presence of visual annunciation of temperature and voltage on the outside of ESS that are capable of thermal runaway.




Affilliation: International Association of Fire Fighters

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4.2.5.3*

When required by the AHJ, visible

Visible annunciation shall be provided

in an approved location to indicate

such that individuals are notified that potentially hazardous conditions exist prior to such individuals entering the ESS area,room, or enclosure .


In the interest of safety, this should be a standard requirement, not just when required by AHJs.




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4.2.5.3 *

When required by the AHJ, visible annunciation shall be provided in an approved location to indicate potentially hazardousconditions associated with the ESS exist.


To be more specific as to the source of the hazardous conditions. There are many possible hazardous conditions associated with the areas surrounding the ESS which could be interpreted as having to be monitored and annunciated.




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4.2.5.3 *

When required by the AHJ, visible annunciation shall be provided in an approved location to indicate potentially hazardousconditions exist. This can be external to the design of the ESSU or system.


Involving the AHJ early in the design process or for equipment that has been standardized for global usage is not practical since this is site specific.




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4.3.1 Electrical Installation.

The electrical installation shall be in accordance with NFPA 70 or IEEE C2 based on the location of the ESS in relation to andits interaction with the electrical grid.

Telecommunications facilities with lead-acid and nickel-cadmium battery storage less than 50-V ac, 60-V dc and in compliancewith NFPA 76 shall be exempt from the requirements in 4.3.1.


Telecommunications equipment, installed in spaces under exclusive control of the telecom utility are outside the scope of NFPA 70 and are not subject to its provisions.

NEC- Section 90.2(B)(4)Article 90 Introduction90.2 Scope(B) Not Covered(4) Installations of communications equipment under the exclusivecontrol of utilities located outdoors or in buildings used exclusivelyfor such installations.

Batteries are part of the telecommunications equipment as they provide backup power and filtering of noise. To maintain effective telecommunications service, this exclusion must remain in place.




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4.3.2* Working Space.

ESS equipment shall be located with adequate working space in accordance with NFPA 70, Article 110 or Article 706 , and themanufacturer’s instructions for operation, inspection, troubleshooting, maintenance, or replacement.


We recommend the explicit and allowed use of Article 706 which is specific to energy storage systems, whereas Article 110 is more generic.


Submitter Full Name: Roger Lin

Organization: NEC Energy Solutions

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4.3.2* Working Space.

ESS equipment shall be located with adequate working space in accordance with NFPA 70, Article 110, and the manufacturer’sinstructions for operation, inspection, troubleshooting, maintenance, or replacement.



Telecommunications equipment installations are outside the scope of NFPA 70. They follow proprietary standards for equipment spacing which has proven to be safe and should not be changed.




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4.3.2 * Working Space.

ESS equipment shall be located with adequate working space in accordance with NFPA 70 , Article 110, and themanufacturer’s instructions for operation, inspection, troubleshooting, maintenance, or replacement.


It's a given that ESS has to comply with NFPA 70 article 706. Repeating that here is teaching the code.




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4.3.5.1

Rooms, buildings, or areas containing free-flowing liquid electrolyte in individual vessels having a capacity of more than 55 gal(208 L) or multiple vessels having an aggregate capacity exceeding 1000 gal (3785 L) shall be provided with spill control toprevent the flow of liquids to adjoining areas as detailed below .


Current wording in this section requires spill control but is very open ended. Not clear if 55 or 1000 gallon control is needed. For clarity, I suggest we include a reference to the subsequent sections.




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4.3.5.1

Rooms, buildings, or areas containing liquid electrolyte that is free-flowing liquid electrolyte at nominal ambient temperaturesin individual vessels having a capacity of more than 55 gal (208 L) or multiple vessels having an aggregate capacity exceeding1000 gal (3785 L) shall be provided with spill control to prevent the flow of liquids to adjoining areas.


Sodium Nickel Chloride batteries have an liquid electrolyte that will not flow out of a vessel at temperatures that would be considered inhabitable. Protection from the hazard of flowing electrolyte when the high temperature is the primary hazard is redundant.




Affilliation: FZSonick Inc

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4.3.5.1

Rooms, buildings, or areas containing free-flowing liquid electrolyte in individual vessels having a capacity of more than 55 gal(208 L) or multiple vessels having an aggregate capacity exceeding 1000 gal (3785 L) shall be provided with spill control toprevent the flow of liquids to adjoining areas subject to the provisions of NFPA1 .


This proposal would sync NFPA 855 with the recent changes to the 2018 IFC.





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4.3.5.1

Rooms, buildings, or areas containing liquide electrolyte that is free-flowing liquid electrolyte in flowing at ambienttemperature in individual vessels having a capacity of more than 55 gal (208 L) or multiple vessels having an aggregatecapacity exceeding 1000 gal (3785 L) shall be provided with spill control to prevent the flow of liquids to adjoining areas.


Sodium Nickel Chloride batteries have a liquid electrolyte only at working temperature (above 150°C). At ambient temperature it is frozen and no spillage from the vessel is possible since is not free flowing



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4.3.5.1

Rooms, buildings, or areas containing free-flowing liquid electrolyte at ambient temperature in individual vessels having acapacity of more than 55 gal (208 L) or multiple vessels having an aggregate capacity exceeding 1000 gal (3785 L) shall beprovided with spill control to prevent the flow of liquids to adjoining areas.


Sodium Nickel chloride contains a liquid electrolyte NaAlCl4. This electrolyte is liquid at the internal operating temperature above 155°C. so there is no risk of freeflowing outside of the battery where the ambient temperature is below 155°C and the electrolyte is solid




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4.3.5.1

Rooms, buildings, or areas containing free-flowing liquid electrolyte in individual vessels having a capacity of more than 55 gal(208 L) or multiple vessels having an aggregate capacity exceeding 1000 gal (3785 L) shall be provided with spill control toprevent the flow of liquids to adjoining areas should provide spill containment and management in accordance with theguidelines in IEEE 1578 .


There is really no justification for the quantities listed; these are mostly taken from other standards which had no justification either. IEEE 1578 was developed by experts in the industry and was approved using the open process of IEEE. There are a lot of factors to consider and if they all were included here it would be several pages of information.



Public Input No. 491-NFPA 855-2017 [Sections 4.3.5.1, 4.3.5.2, 4.3.5.3, 4.3.5.4, 4.3.5.5]




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Public Input No. 491-NFPA 855-2017 [ Sections 4.3.5.1, 4.3.5.2, 4.3.5.3, 4.3.5.4, 4.3.5.5 ]

Sections 4.3.5.1, 4.3.5.2, 4.3.5.3, 4.3.5.4, 4.3.5.5

4.3.5.1

Rooms, buildings, or areas containing free-flowing liquid electrolyte in individual vessels having a capacity of more than 55 gal(208 L) or multiple vessels having an aggregate capacity exceeding 1000 gal (3785 L) shall be provided with spill control toprevent the flow of liquids to adjoining areas.

4.3.5.2

Rooms, buildings, or areas containing ESS containing other hazardous materials shall include spill control as required in NFPA1.

4.3.5.3 *

An approved method and materials for the control of a spill of electrolyte or other hazardous liquid shall be provided that will becapable of controlling a spill from the single largest vessel.

4.3.5.4

Rooms, buildings, or areas protected by water-based fire protection systems shall increase their spill control area to include thecapacity of the expected fire protection system discharge for a period of 10 minutes.

4.3.5.5

Valve-regulated lead-acid (VRLA) batteries and other ESS equipment with immobilized electrolyte and immobilized hazardousliquids shall not require spill control.


See 4.3.5.1 related PI



Public Input No. 490-NFPA 855-2017 [Section No. 4.3.5.1] related




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4.3.5.2

Rooms ESS with free-flowing electrolyte or liquids located in rooms , buildings, or areas containing ESS containing otherhazardous materials shall include spill control as required in NFPA 1.


As written, the text could be interpreted to mean that spill control would be needed for ESS without free-flowing liquids.




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4.3.5.2

Rooms ESS located in rooms , buildings, or areas containing ESS containing other hazardous materials shall include providespill control as required in NFPA 1.


Proposal tries to simplify language.





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4.3.5.4



This will create a cost burden in the design due to cost and space for water. The spilled liquid needs to be contained until tested to be able to be discharged in the sewage. This may create a impractical condition in which more than 10 minutes of water will be needed. This should be a decision on a project basis with the AHJ and local authorities.



Organization: Nema

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4.3.5.4



This will create a cost burden in the design due to cost and space for water. The spilled liquid needs to be contained until tested to be able to be discharged in the sewage. This may create a impractical condition in which more than 10 minutes of water will be needed. This should be a decision on a project basis with the AHJ and local authorities.




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4.3.5.4

Rooms, buildings, or areas protected by water-based fire protection systems shall increase their spill control area to include thecapacity of the expected fire protection system discharge for a period of 10 minutes or for a period of time based on LargeScale Fire Testing .


Includes basing the duration on actual Large Scale Fire Testing.




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4.3.5.5

Valve Sealed valve -regulated lead-acid (VRLA) batteries and other ESS equipment with immobilized electrolyte andimmobilized hazardous liquids shall not require spill control.


This change was made to be consistent with the International Fire Code and the other requirement was eliminated because it is too broad.

Yvonne Espinoza, PE, Austin Fire Department, 512-974-0185, [email protected]


Submitter FullName:

Carl Wren



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4.3.5.5



Recommend definition of immobilized electrolyte for avoidance of doubt.




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4.3.5.5


Informational Note: Valve-regulated lead-acid (VRLA) batteries are an example of batteries using immobilized electrolyte.


Moved the example given to an Informational Note.




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4.3.5.5



Focus should be on electrolyte. No need to add other hazardous liquids to this section.




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4.3.5.5

Valve-regulated lead-acid (VRLA) batteries, Sodium Nickel Choride batteries, and other ESS equipment with immobilizedelectrolyte and immobilized hazardous liquids shall not require spill control.


SMC batteries do not have Electrolyte that can readily flow into an environment, it is immobilized as a solid at nominal ambient temperatures





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4.3.5.5

Valve-regulated lead-acid (VRLA) batteries and , Sodium Nickel Chloride batteries and other ESS equipment with immobilizedelectrolyte and immobilized hazardous liquids shall not require spill control.


SMC batteries do not have Electrolyte that can readily flow into an environment, it is immobilized as a solid at nominal ambient temperatures



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4.3.5.5

Valve-regulated lead-acid (VRLA) batteries, Sodium Nickel Choride batteries and other ESS equipment with immobilizedelectrolyte and immobilized hazardous liquids shall not require spill control.


sodium nickel chloride batteries do not have Electrolyte that can readily flow into an environment, it is immobilized as a solid at nominal ambient temperatures




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4.3.6.1

All ESS systems located in residential areas or where general public has access to shall be located or protected to preventphysical damage.


Would like to provide more clarity on when protection is really needed, which is when system is installed in public places such as parking lot, parking garages, public ways. Systems that are installed and located in dedicated or fenced areas are already protected by a fence or other barriers against physical damage.



Organization: Nema

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4.3.6.1

All ESS systems located in residential areas or where general public has acces to shall be located or protected to preventphysical damage.


Systems that are installed and located in dedicated or fenced areas are already protected by a fence.




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Sections 4.3.6.1, 4.3.6.2

4.3.6.1

All ESS shall be located or protected to prevent physical damage.

4.3.6.2

Vehicle impact protection consisting of guard posts or other approved means shall be provided where ESS are subject toimpact by motor vehicles.


4.3.6.2 basically duplicates 4.3.6.1, if the ESS has to be protected then it has to be protected with bollards if vehicles are a hazard.




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4.3.6.3*

When guard posts are installed, they shall be designed as follows:

(1) Posts shall be constructed of steel not less than 4 in. (100 mm) in diameter and shall be filled with concrete.

(2) Posts shall be spaced not more than 4 ft (1.2 m) on center.

(3) Posts shall be set not less than 3 ft (0.9 m) deep in a concrete footing of not less than 15 in. (380 mm) diameter.

(4) The top of the posts shall be set not less than 3 ft (0.9 m) above ground.

(5) Posts shall be located not less than 3 ft (0.9 m) from the ESS.


Guard posts are a defined term and this should be an extract from [30A:4.3.7.2]




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Type your content here ... 4.3.7 Security of installations. Rooms or areas in which energy storage systems are located shallbe secured against unauthorized entry and safeguarded in an approved manner. Security barriers, fences, landscaping, andother enclosures shall not inhibit the required air flow to or exhaust from the energy storage system and its components.


This proposal fills a void in the code regarding providing security for ESS installations in the general installation section in Chapter 4. It also reflects protection concepts developed by the FCAC ESS working group.




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4.3.6.4 *

For residential garages For attahed or detacked garages associated with one- and two-family dwellings and townhouses , ESSshall not be installed in a location where subject to damage from impact by a motor vehicle.


The use of the term 'residential' could be confusing as it includes multi-family dwellings, hotels, motels, etc. If the intent is to cover attached and detached garages associated with one and two family dwellings and townhouses (which I believe it is), since residential is not defined in the standard and can have varying definitions and sub-classifications it maybe better to be more specific as to what residential buildings are intended to be covered.




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4.3.6.4 *

For residential garages, ESS shall not be installed in a location where subject to damage from impact by a motor vehicle.


This is covered by 4.3.6.2 and is just a duplication of the requirement.




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4.3.7 Means of Egress.

4.3.7.1

All areas containing ESS shall provide egress from the area in which they are located in accordance with the local buildingcode.

4.3.7.2

Required egress doors shall be provided with emergency lighting as required by the local building code.


Egress is covered in NFPA 70 Article 706. Buildings have to comply with the building code, pointing that out again here is teaching the code.




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4.4 Locations.

4.4.1 ESS installed indoors, outdoors, on rooftops and in open parking garages shall comply with this section.

4.4.2 Indoor installations.

4.4.2.1 Indoor ESS installations shall comply with this section.

4.4.2.2 Dedicated use buildings . For the purpose of Table 4.4.2 dedicated use ESS buildings shall be classified as Group F-1or industrial occupancies in accordance with local building codes and comply with all the following. :

1. The building shall only be used for electrochemical energy storage, energy generation, and other electrical grid relatedoperations.

2. Occupants in the rooms and areas containing ESS are limited to personnel that operate, maintain, service, test andrepair the ESS and other energy systems.

3. No other occupancy types shall be permitted in the building, and .

4. Administrative and support personnel shall be permitted in incidental use areas within the buildings that do not containESS, provided:

a. The areas do not occupy more than 10 percent of the building area of the story in which they are located.

b. The areas are separated from the ESS and other energy system rooms and areas by two hour fire barriers andtwo hour horizontal assemblies constructed in accordance with the locally enforced building code, as appropriate.

c. A means of egress is provided from the incidental use areas to the public way that does not require occupantsto traverse through areas containing ESS or other energy system equipment.

4.4.2.3 Non-dedicated use buildings. For the purpose of Table 4.4.3 non-dedicated use buildings include all buildings thatcontain ESS and do not comply with Section 4.4.3.1 dedicated use building requirements.

TABLE 4.4.2

INDOOR ENERGY STORAGE SYSTEMS (ESS)

COMPLIANCEREQUIRED DEDICATED USE BUILDINGS a

NON-DEDICATED USE

BUILDINGS b

Chapters 1 - 8 Yes Yes

4.6 Size andseparation

Yes Yes

4.5 Maximumrated energy

No Yes

4.6 Elevation Yes Yes

4.7 Smoke andfire detection Yes c Yes

4.8 Fire controland suppression

Yes Yes

4.11 Signage. Yes Yes

4.3.7 Security ofinstallations

Yes Yes

4.4.6 Occupiedwork centers

Not allowed Yes

4.3.8 Open rackinstallations

Yes Yes

Chapter 9-17Technology

specific protectionYes Yes

a. See Section 4.4.2.2.

b. See Section 4.4.2.3.

c. When approved, alarm signals are not required to be transmitted to an approved location when local fire alarm annunciation


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is provided and trained personnel are always present.

4.4.3 Outdoor Installations.

4.4.3.1 Outdoor ESS installations shall comply with this section.

4.4.3.2. For the purpose of Table 4.4.3 outdoor ESS installations shall be classified as follows:

(1) Remote locations - Remote outdoor locations include ESS located more than 100 feet (30.5 M) from buildings, lot lines,public ways, stored combustible materials, hazardous materials, high piled stock and other exposure hazards.

(2) Locations near exposures – Include all outdoor ESS locations that do not comply with remote outdoor locationrequirements.

TABLE 4.4.3

OUTDOOR STATIONARY ENERGY STORAGE SYSTEMS a

COMPLIANCE REQUIRED REMOTE LOCATIONS aLOCATIONS NEAR

EXPOSURES b


4.4.3.3 Maximum size Yes Yes

4.4.3.4 Clearance to exposures Yes Yes

4.4.3.5 Means of egress NA Yes

4.4.3.6 Walk in units Yes Yes

4.4.3.7 Vegetation control Yes Yes

4.4.3.8 Enclosures Yes Yes

4.6 Size and separation No Yes c

4.5 Maximum rated energy No Yes

4.7 Smoke and fire detection Yes Yes

4.8 Fire control and suppression Yes d Yes


4.3.7 Security of installations Yes Yes

4.4.6 Occupied work centers Not allowed Not allowed

4.3.8 Open rack installations Yes Yes

Chapter 9 - 17 Technology specificprotection

Yes Yes

NA = Not applicable.

a.. See Section 4.4.3.2, item 1.

b. See Section 4.4.3.2, item 2.

c. In outdoor walk-in units, spacing is not required between electrochemical energy storage units and the walls of the enclosure.

d. When agreeable with the electrochemical energy storage system owner and approved by the AHJ, fire suppression systemsare permitted to be omitted.

4.4.3.3 Maximum size. Outdoor walk-in containers or enclosures housing ESS shall not exceed 45 ft. by 8 ft. by 9.5 ft. high.Units that exceed these dimensions shall be treated as buildings and comply with the requirements in Section 4.4.2.

4.4.3.4 Clearance to exposures. ESS located outdoors shall be separated by a minimum ten feet (3048 mm) from thefollowing exposures:

1. Lot lines

2. Public ways

3. Buildings

4. Stored combustible materials

5. Hazardous materials

6. High-piled stock

7. Other exposure hazards

Exceptions:


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1. Clearances are permitted to be reduced to 3 ft. (914 mm) when a 1-hour free standing fire barrier, suitable for exterioruse, and extending 5 ft. (1.5 m) above and extending 5 ft (1.5 m) beyond the physical boundary of the electrochemicalenergy storage system installation is provided to protect the exposure.

2. Clearances to buildings are permitted to be reduced to 3 ft. (914.4 mm) where noncombustible exterior walls with noopenings or combustible overhangs are provided on the wall adjacent to the electrochemical energy storage system,.The fire-resistance rating of the exterior wall shall be comply with the fire resistance requirements in Table 4.4.3.1.

3. Clearances to buildings are permitted to be reduced to 3 ft. (914.4 mm) where the weatherproof enclosure isconstructed of noncombustible materials and it has been demonstrated that a fire within the enclosure will not ignitecombustible materials outside the enclosure based on large scale fire testing complying with Section 4.5.

4.4.3.5 Means of egress. ESS located outdoors shall be separated from any means of egress as required by the AHJ toensure safe egress under fire conditions, but in no case less than 10 feet (3048 mm).

Exception: The AHJ is authorized to approve smaller separation distances if large scale fire and fault condition testingcomplying with Section 4.5 is provided that shows that a fire involving the ESS will not adversely impact occupant egress.

4.4.3.6 Walk in units. Where an electrochemical energy storage system includes an outer enclosure, the unit shall only beentered for inspection, maintenance and repair of energy storage units and ancillary equipment, and shall not be occupied forother purposes.

4.4.3.7 Vegetation control. Areas within 10 ft. (3 m) on each side of outdoor electrochemical energy storage systems shall becleared of combustible vegetation and other combustible growth. Single specimens of trees, shrubbery, or cultivated groundcover such as green grass, ivy, succulents, or similar plants used as ground covers shall be permitted to be exempt providedthat they do not form a means of readily transmitting fire.

4.4.3.8 Enclosures. Enclosures of ESS used in outdoor locations shall be of noncombustible construction.

4.4.4 Rooftop and Open Parking Garage Installations.

4.4.4.1 Rooftop and open parking garage ESS installations shall comply with this section.

4.4.4.2 For the purpose of Table 4.4.4, special ESS installations shall be classified as follows:

1. Rooftop installations. Rooftop ESS installations are those located on the roofs of buildings.

2. Open parking garage installations. Open parking garage ESS installations are those located in a structure orportion of a structure as defined in Section 3.3.10.

TABLE 4.4.4

SPECIAL ENERGY STORAGE SYSTEMS (ESS) INSTALLATIONS

COMPLIANCE REQUIRED ROOFTOPS aOPEN PARKING

GARAGES b


4.4.3.3 Maximum size Yes Yes

4.4.3.5 Means of egress Yes Yes

4.4.3.6 Walk in units Yes Yes

4.4.3.8 Enclosures Yes Yes

4.4.4.3 Clearance to exposures. Yes Yes

4.4.4.4 Fire suppression systems Yes Yes

4.4.4.5 Rooftop installations Yes No

4.4.4.6 Open parking garages No Yes

4.6 Size and separation Yes Yes

4.5 Maximum rated energy Yes Yes

4.4 Location No Yes

4.7 Smoke and fire detection Yes Yes


4.3.7 Security of installations Yes Yes

4.4.6 Occupied work centers Not allowed Not allowed

4.3.8 Open rack installations Not allowed Not allowed

Chapter 9 - 17 Technology specificprotection

Yes Yes


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NA = Not applicable.

a. See Section 4.4.4.2, item 1.

b. See Section 4.4.4.2, item 2.

4.4.4.3 Clearance to exposures. ESS located on rooftops and in open parking garages shall be separated by a minimum tenfeet (3048 mm) from the following exposures:

1. Buildings, except the building on which rooftop ESS is mounted

2. Lot lines

3. Public ways


5. Locations where motor vehicles can be parked



Exceptions:

1. Clearances are permitted to be reduced to 3 ft. (914 mm) when a 1-hour free standing fire barrier, suitable for exterioruse, and extending 5 ft. (1.5 m) above and extending 5 ft. (1.5 m) beyond the physical boundary of the ESS installationis provided to protect the exposure.

2. Clearances are permitted to be reduced to 3 ft. (914.4 mm) the weatherproof enclosure is constructed ofnoncombustible materials and it has been demonstrated that a fire within the enclosure will not ignite combustiblematerials outside the enclosure based on large scale fire testing complying with Section 4.6.

4.4.4.4 Fire suppression systems. ESS located in walk-in enclosures on rooftops or in open parking garages shall beprovided with automatic fire control and suppression systems within the ESS enclosure in accordance with Section 4.8. Areascontaining ESS other than walk-in units in open parking structures not open above to the sky shall be provided with anautomatic fire suppression system complying with Section 4.8.

4.4.4.5 Rooftop installations. ESS and associated equipment that are located on rooftops and not enclosed by buildingconstruction shall comply with the following:

1. Stairway access to the roof for emergency response and fire department personnel shall be provided either through abulkhead from the interior of the building or a stairway on the exterior of the building.

2. Service walkways at least 5 ft. (1524 mm) in width shall be provided for service and emergency personnel from thepoint of access to the roof to the system.

3. Energy storage systems and associated equipment shall be located from the edge of the roof a distance equal to atleast the height of the system, equipment, or component but not less than 5 ft (1.5 m).

4. The roofing materials under and within 5 ft (1524 mm) horizontally from an energy storage systems or associatedequipment shall be noncombustible or shall have a Class A rating when tested in accordance with ASTM E108 or UL790.

5. A Class I standpipe outlet shall be installed at an approved location on the roof level of the building or in the stairwaybulkhead at the top level.

4.4.4.6 Open parking garages. ESS and associated equipment that are located in open parking garages shall comply with allof the following:

1. ESS shall not be located within 50 ft. (25.3 M) of air inlets for building HVAC equipment.

Exception: This distance shall be permitted to be reduced to 25 feet if the automatic fire alarm systemmonitoring the radiant-energy sensing detectors de-energizes the ventilation system connected to the airintakes upon detection of fire.

2. ESS shall not be located within 25 ft. (7620 mm) of exits leading from the attached building when located on acovered level of the parking structure not directly open to the sky above. Means of egress shall also comply withSection 4.3.7.

3. An approved fence with a locked gate or other approved barrier shall be provided to keep the general public at leastfive ft. (1024 mm) from the outer enclosure of the ESS.

4.5 Mobile ESS Equipment and Operations.

4.5.1 Mobile ESS equipment and operations shall comply with this section.

4.5.2 Operations. Mobile ESS operations shall be classified as follows:

1. Charging and storage. Charging and storage covers the operation where mobile ESS are charged and stored sothey are ready for deployment to another site, and where they are charged and stored after a deployment.

2. Deployment. Deployment covers operations where mobile ESS are located at a site other than the charging andstorage site and are being used to provide power.

4.5.3 Permits. Installation and operational permits shall be provided for charging and storage of mobile ESS and operationalpermits shall be provided for deployment of mobile ESS if so required by the local jurisdiction.

4.5.4 Construction documents. The following information shall be provided with the permit applications:


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(1) Location and layout diagram of the area in which the mobile electrochemical energy storage system is to be located.

(2) The quantities and types of energy storage system units.

(3) Manufacturer's specifications, ratings and listings of energy storage systems

(4) Description of battery management systems and their operation.

(5) Location and content of signage

(6) Details on fire suppression, smoke detection, fire detection, thermal management, ventilation, exhaust and deflagrationventing systems, if provided.

(7) For deployment, the intended duration of operation, including anticipated connection and disconnection times and dates,

(8) Location and description of planned parking stops as covered in Section

(9) Description of the electrical load, connection methods, conductor type and size, and circuit overcurrent protection to beprovided.

4.5.5 Approved locations. Locations where mobile ESS are charged, stored and deployed shall be restricted to the locationsestablished on the operational permit.

4.5.6 Smoke and automatic fire detection. An approved automatic smoke detection or radiant energy–sensing fire detectionsystem shall be installed to protect mobile ESS equipment.

4.5.7 Alarm activation. Alarm signals generated by the detection system or by activation of any fire suppression systemprotecting the ESS shall transmit an alarm signal to an approved location and provide local audible and visible alarm notificationin an approved location outside of the mobile ESS.

Exception: Alarm signals are not required to be transmitted to an approved location for mobile ESS deployed 30 days or less.

4.5.8 Enclosures. Enclosures of mobile ESS shall be of noncombustible construction.

4.5.9 Charging and storage. Installations where mobile ESS are charged and stored shall be treated as permanent ESS, shallcomply with Section 4.5.3 through 4.5.8, and shall comply with the following sections, as applicable:

1. Indoor charging and storage shall comply with Section 4.4.2.

2. Outdoor charging and storage shall comply with Section 4.4.3.

3. Charging and storage on rooftops and in open parking garages shall comply with Section 4.4.4.

Exceptions:

1. Electrical connections shall be permitted to be made using temporary wiring complying with the manufacturer’sinstructions, the UL 9540 listing, and NFPA 70.

2. Fire suppression system connections to the water supply shall be permitted to use approved temporary connections.

4.5.10 Deployed mobile ESS requirements. Deployed mobile ESS equipment and operations shall comply with this sectionand Table 4.5.

4.5.11 Duration. The duration of mobile electrochemical energy storage system deployment shall not exceed 30 days.

Exceptions:

1. Mobile ESS installations that provide temporary power for durations longer than 30 days shall comply with Section4.5.9 and 4.5.12 through 4.5.12.5.

2. Deployed mobile ESS installations shall not exceed 180 days unless additional operational permits are obtained.

4.5.12 Locations. Deployed mobile ESS shall not be located indoors, in covered parking garages, on rooftops, below grade,or under building overhangs.

4.5.12.1 Clearance to exposures. Deployed mobile ESS shall be separated by a minimum 10 feet (3048 mm) from thefollowing exposures:

1. Public ways

2. Buildings



5. High-piled stock


Deployed mobile ESS shall be separated by a minimum fifty feet (15.3 M) from public seating areas and from tents, canopiesand membrane structures with an occupant load of 30 or more.

4.5.12.2 Electrical connections. Electrical connections shall be made in accordance with the manufacturer’s instructions andthe UL 9540 listing. Temporary wiring for electrical power connections shall comply with NFPA 70. Fixed electrical wiring shallnot be provided.

4.5.12.3 Parking in transit . Mobile ESS in transit from the charging and storage location to the deployment location and backshall not be parked within 100 feet (15.3 M) of an occupied building and shall not be parked more than 12 hours in a singlelocation during transit, unless specifically approved by the AHJ when the permit is issued.


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4.5.12.4 Fencing. An approved fence with a locked gate or other approved barrier shall be provided to keep the general publicat least five ft. (1024 mm) from the outer enclosure of the ESS.

4.5.12.5 Smoking. Smoking shall be prohibited within ten feet (3048 mm) of mobile ESS. Signs shall be posted in accordancewith Section 310.

TABLE 4.5

MOBILE ENERGY STORAGE SYSTEMS (ESS)

DEPLOYMENT REQUIREMENTS

COMPLIANCE REQUIRED DEPLOYMENT a

Chapter 1- 8 Yes b

Sections 4.5.3 to 4.5.8 Yes

4.6 Size and separation Yes c

4.5 Maximum rated energy Yes

4.8 Fire control and suppression Yes d

4.11 Signage. Yes

4.3.7 Security of installations Yes

4.4.3.3 Maximum size Yes

4.4.3.5 Means of egress Yes

4.4.3.6 Walk in units Yes

4.4.3.7 Vegetation control Yes

Chapters 9 -17 Technology specific protection Yes

a. See Section 4.5.2, item 2

b. Mobile operations on wheeled vehicle or trailers shall not be required to comply with seismic and structural loadrequirements.

c. In walk-in ESS units, spacing is not required between ESS units and the walls of the enclosure.

d. Fire suppression system connections to the water supply shall be permitted to use approved temporary connections.


The existing draft does not provide much flexibility for determining protection requirements for various installations based on their location, use, hazards and exposures. This proposal uses protection concepts developed by the FCAC ESS work group for various indoor, outdoor, rooftop and open parking garage installations that provides flexibility n design, and the ability to select the protection needed for the specific installations. Also included are requirements for mobile ESS operations also developed by the FCAC ESS work group.




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4.3.8 Open rack installations.

4.3.8.1 Where ESS are installed in a separate equipment room and only authorized personnel have access to the room, theyshall be permitted to be installed on an open rack for ease of maintenance.


Clarifies where open rack ESS can be installed.




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Type your content here ... 4.5 Large scale fire test.

4.5.1 Where required elsewhere in this standard, large scale fire testing shall be conducted on a representative energy storagesystem in accordance with UL 9540A. The testing shall be conducted or witnessed and reported by an approved testinglaboratory and show that a fire involving one energy storage system unit will not propagate to an adjacent unit, and whereinstalled within buildings be contained within the room or enclosed area for a duration equal to the fire resistance rating of theroom separation specified in Table 4.4.3.1. The test report shall be provided to the AHJ for review and approval.


This proposal introduces UL 9540A, which was specifically developed to evaluate fire propagation associated with battery ESS. It reflects protection concepts being developed by the FCAC ESS working group and is provided as a reference for the NFPA 855 committee to consider.



Public Input No. 64-NFPA 855-2017 [Section No. 2.3.6] Companion proposal.





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4.4 Location.

4.4.1 Elevation.

ESS shall be located only on floors that can be accessed by external fire department laddering capabilities.


4.4. 1.1

Installations shall be permitted on higher levels where permitted by the AHJ.

4.4.1.2

Installations shall be permitted on rooftops of buildings that do not obstruct fire department rooftop operations when approved.

4.4.1.3

Installations shall be permitted below grade where the floor level is not more than 30 ft (9144 mm) below the finished floor ofthe lowest level of exit discharge and acceptable to the AHJ.

4.4.2 Dwelling Units and Sleeping Units.

4.4.2.1

Stationary ESS shall not be installed in sleeping units or in habitable spaces of dwelling units unless specifically allowed inChapter 9 through Chapter 16.

4.4.2.2

Portable ESS regulated by this standard shall be permitted to be used in sleeping units and in habitable spaces of dwellingunits provided they are listed.

4.4.3* Multiple-Use Buildings.

ESS shall be permitted to be installed in buildings housing the occupancies noted in 4.4.3.1 in compliance with the multipleoccupancy and incidental use provisions of the locally enforced building code.

4.4.3.1 Separation.

Rooms or spaces containing ESS in other than high hazard occupancies shall be separated from other areas of the building inaccordance with Table 4.4.3.1.

Table 4.4.3.1 Required Separation of Occupancies

Occupancy Minimum Fire Barrier Rating (hr)

Ambulatory health care 2

Assembly 2

Day care centers 2

Detention and correctional 2

Educational 2

Health care 2

Residential 2

Residential board and care 2

All other occupancies 1

4.4.4 Rooftop Installations.

4.4.4.1

ESS and their equipment, components, and controls that are located on rooftops and not enclosed by building constructionshall be installed in accordance with 4.14.2, manufacturer’s installation instructions, and this section.

4.4.4.2

Installations on rooftops over 75 ft (23 m) in height above grade shall be permitted when approved by the AHJ.

4.4.4.3

Access to the roof for emergency response and fire department personnel shall be provided either through the interior of thebuilding or on the exterior of the building.

4.4.4.4 Service Walkways.


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4.4.4.4.1

Service walkways at least 3.3 ft (1 m) in width shall be provided for service and emergency personnel from the point of accessto the roof and around the system.

4.4.4.4.2

Guards and handrails shall be provided where required by the local building and mechanical codes.

4.4.4.5

ESS and their equipment, components, and controls shall be located from the edge of the roof a distance equal to at least theheight of the system, equipment, or component but not less than 5 ft (1.5 m).

4.4.4.6

The roofing materials under and within 12 in. (305 mm) horizontally from an ESS or associated equipment or component shallbe noncombustible or shall have a Class A rating when tested in accordance with ASTM E108 or UL 790.

4.4.5 Open Parking Garages.

ESS shall be permitted in open parking garages without fire separation from the parked vehicles and means of egress wherefull-scale fire and fault condition testing documents the system does not present an exposure hazard when installed inaccordance with manufacturer’s instructions and this standard.

4.4.6* Occupied Work Centers.

ESS in occupied work centers shall comply with this section.

4.4.6.1

ESS shall be permitted in the same room as the equipment that they support.

4.4.6.2

ESS shall be housed in a noncombustible, locked cabinet or other enclosure to prevent access by unauthorized personnelunless located in a separate equipment room accessible only to authorized personnel.


Telecom applications use safe low voltages, but need to keep the power plants in close proximity to the equipment to minimize voltage drops. This requires power plants at elevations beyond the standard is some installations. Current codes exempt Pb-acid and Nickel-Cadmium batteries from similar location restrictions. These have proven to be safe technologies. There is no need to further restrict them.




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4.4.1 Elevation.

ESS shall not be located only on floors that can be accessed by external fire department laddering capabilities.

4.4.1.1


on an occupied building floor more than 75 feet above the lowest level of fire department access in a building classified as ahigh-rise by the local building code.

4.4.1.

2

1

Installations shall be permitted on rooftops of buildings that do not obstruct fire department rooftop operations whenapproved.

4.4.1.

3

2



This change was made because the requirement tying location to laddering capabilities is arbitrary. The requirement to not exceed 75 ft is consistent with upcoming future International Fire Code requirements and existing Factory Mutual standards. The deletion of approval on higher levels when approved by the AHJ was removed because it should not be necessary with the proposed change and did not specify what the approval should be based on.



Submitter FullName:

Carl Wren



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4. 4.1 5 Elevation.

4.5.1 ESS shall

be located only on floors that cannot be located in the following areas in buildings:

1. Where the floor cannot be accessed by external fire department laddering capabilities access, or

2 .

4.4.1.1

Where the floor is located below the lowest level of exit discharge.

Exceptions:

(1) Lead acid and Ni-Cad battery systems less than 50 VAC and 60 VDC installed in telecommunications facilities inaccordance with NFPA 76.

(2) When approved, installations shall be permitted in underground vaults complying with NFPA 70, Article 450, Part III.

4.5.2

Installations shall be permitted on higher and lower levels in buildings where permitted by the AHJ.

4.4 5 .1.2 3

Installations shall be permitted on rooftops of buildings that do not obstruct fire department rooftop operations when approved.

4.4.1.3


in accordance with Section XXX.


This proposal adds flexibility for the location of telecom industry battery rooms, and for installations in underground vaults. It limits the installation of ESS rooms below grade, which represent potential flooding problems and firefighting operations unless approved by the AHJ. It also reflects protection concepts developed by the FCAC ESS working group, but they did not specifically allowed exceptions for other locations in buildings where approved by the AHJ.




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4.4.1.1



The AHJ may authorize any changes to the specifications of any provision of the standard and does not need authorization from the standard to do so.





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Sections 4.4.2.1, 4.4.2.2

4.4.2.1

Stationary and portable ESS shall not be installed in sleeping units or in habitable spaces of dwelling units unless specificallyallowed in Chapter 9 through Chapter 16 .

4.4.2.2

Portable ESS regulated by this standard shall be permitted to be used in sleeping units and in habitable spaces of dwellingunits provided they are listed

In buildings with a use classified as Residential an Energy Storage System shall be located in a Normally Unoccupied BuildingService Equipment Support Area or a Parking Garage .


This change was made to include include portable ESS and not allow in residential dwelling sleeping units based on the high risk involved. A listing does not mitigate all risk. The section allowing ESS in garages and normally unoccupied building service equipment support areas still allows for ESS to be used for residential occupancies.



Submitter FullName:

Carl Wren



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Flammable and Toxic Gasses

Rooms containing electro-chemical energy storage systems shall be sealed such that flammable and toxic gasses do notmigrate to other areas of the building.


Electro-chemical battery energy storage systems will generate flammable and toxic gasses during fire and fault conditions. This proposed change will ensure that these generated gasses will be adequately contained without affecting other areas of the building, building occupants, and first responders.



Organization: New York City Fire Department, Director of Technology Management

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4.4.3.1 Separation.





Assembly 2

Day care centers 2


Educational 2

Health care 2

Residential 2 Residential board and care 2



Considering the cost to upgrade an existing residential wall to 2 hour fire rating this will most likely prevent most installations in residential garages due to financial considerations. I recommend this be changed to a remove residential or that an alternative path be added to allow a UL listed ESS that has been tested to allow installation in a garage without the modified wall.




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4.4.3.1 Separation.





Assembly 2

Day care centers 2


Educational 2

Health care 2

Residential One and two family dwellings 2

Multi-family dwellings 2

Residential board and care 2



It's going to be helpful to split out one and two family dwellings from larger multi-family dwellings since the two often have different requirements.




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4.4.4.1

ESS and their equipment, components, and controls that are located on rooftops and not enclosed by building constructionshall be installed in accordance with 4.14.2 , manufacturer’s installation instructions, and this section.

4.4.4.2


4.4.4.3

Access to the roof for emergency response and fire department personnel shall be provided either through the interior of thebuilding or on the exterior of the building.

4.4.4.4 Service Walkways.

4.4.4.4.1

Service walkways at least 3.3 ft (1 m) in width shall be provided for service and emergency personnel from the point of accessto the roof and around the system.

4.4.4.4.2


4.4.4.5


4.4.4.6



4.14.8 also covers roof installations. It only needs to be covered once, consolidate this section with 4.14.8.




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4.4.4.2

Installations on rooftops over 75 ft (23 m) in height above grade shall be permitted when a hazard mitigation analysis isapproved by the AHJ and the Maximum Rated Energy does not exceed 25% of the value in Table 4 .5.


The current section offers no guidance to any AHJ. Rooftop equipment may present benefits to emergency responders and owners. Conversely roof top installations may not always be acceptable because a building can employ stair-step roof designs where floors of different elevations are within the same building footprint. The permitted occupancies in the building, the available resources of the responders, the hazards of stored energy system, the presence of more than one energy storage system on the same building roof, and the degree they are protected are some of the influencing variables.

A reduction in the Maximum Rated Energy is warranted given that certain ESSs present thermal runaway hazards that can result in fire where fire growth and spread is dependent on if the ESS is inside or outside of an the enclosure. However, it could also be dependent on the design and reliability of the primary and secondary containment if the ESS uses liquid electrolytes. This proposal requires that a Hazard Mitigation Analysis be provided. If the total stored energy in a given design is required to exceed 25% of the MRE, then this should be part of the engineering and technical review to demonstrate how the risk of increasing the MRE for a particular ESS will being managed.





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Public Input No. 146-NFPA 855-2017 [ Section No. 4.4.4.4.1 ]

4.4.4.4.1

Service walkways at least 3.3 ft (1 m) in width shall be provided for service and emergency personnel from the point of accessto the roof and around to any service or access panels on the system.


Service walkways should be available to access panels and service panels or doors on the system, not all around the system. For instance there are cases where end-users want to place systems with their 'back' against a wall to conserve space on rooftops.




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4.4.4.4.1

Service walkways at least 3.3 ft (1 m) in width shall be provided for service and emergency personnel from the point of accessto the roof and around the system ESS .


adds clarity





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4.4.4.5

ESS and their equipment, components, and controls shall be located from the edge of the roof a distance equal to at least theheight of the system, equipment, or component but not less than 5 ft (1.5 m) from the edge of the roof where guards orhandrails are not installed in accordance with 4 .4.4.4.2.


Where roof edge guards or handrails are required by the local building code then the ESS should be allowed to be mounted closer to the roof edge. I do not see any safety reason to require the equipment to be mounted a distance at least equal to the height. It's also poorly defined. If an ESS box that is 3ft tall is mounted to a wall so the top is 5ft off the ground what's the height of the equipment?




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ESS in occupied work centers shall comply with this section. Telecommunications equipment rooms are not consideredoccupied work centers.


Occupied work centers is not a defined term. It would be good to clarify that telecommunications equipment rooms are not considered occupied work centers as they don't conform to items in this section such as ESS in cabinets. They are controlled access locations with trained workers. Having the ESS in the same room as other equipment and telecommunications workers does not present an abnormal concern.




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4.4.6.2

ESS shall be housed in a noncombustible, locked cabinet or other enclosure to prevent access by unauthorized personnelunless located in a separate an equipment room accessible only to authorized personnel.


Remove the word "seperate" as I don't know what it is separate from and it seems unnecessary to the requirement.




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Exceptons

Type your content here ...For lithum batteres where secondary fire suppressions systems exist within the ESSU in addtion tothe fire suppression system of th battery room the power requirement shall have a maximum of 1500 kWh for locations that arenot continuously occupied.


Large power substations require much more power than 600kWh and are monitored remotely. They are not continuously occupied. Only when maintenance or installation of equipment is need are there personnel present




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4.5 Maximum Rated Energy.

4.5.1 Fire areas within buildings containing stationary storage battery systems and containers housing electro-chemical ESSexceeding the maximum rated energy values in Table 4.5 shall comply with all applicable high hazard requirements asidentified in 6.2.2 of NFPA 101 and the building code.

Exceptions:

1. Where approved by the AHJ, areas containing electro-chemical ESS that exceed the amounts in Table 4.5 shall bepermitted to be treated as incidental use areas and not high hazard occupancies based on a hazardous mitigation analysis inaccordance with Section 4.2 and large scale fire testing complying with Section 4.5.

2. Dedicated use buildings in compliance with Section 4.4.3.

Table 4.5 Maximum Rated Energy for Battery Electro-chemical ESS

Type Maximum Rated Energy* (kWh KWh )

Lead acid, all types 600

Nickel-cadmium (Ni-Cd) 600

Lithium-ion batteries, all types 600

Sodium batteries, all types 600

Flow batteries† 600

Other battery technologies 200

*For batteries rated in amp-hrs, kWh should equal rated voltage times amp-hr rating divided by 1000.

†Includes vanadium, zinc-bromine, polysulfide, and other flowing electrolyte-type technologies.

4.5. 1

Lead-acid and nickel-cadmium battery systems lower than 50-V ac, 60-V dc nominal shall be considered ordinary hazard.

4.5. 2

Where approved by the AHJ, areas containing stationary storage battery systems electro-chemical ESS that exceed theamounts in Table 4.5 shall be permitted to be treated as an ordinary hazard and not a high hazard classification based on ahazardous mitigation analysis in accordance with Section 4.2 and large-scale fire and fault condition testing conducted orwitnessed and reported by an approved testing laboratory. complying with Section 4.5.

3

Fire areas within buildings containing stationary storage capacitor or acetonitrile systems exceeding 20 kWh shall comply withall applicable high hazard requirements as identified in 6.2.2 of NFPA 101 and the building code.

4.5. 4 3

Where areas within buildings contain a combination of energy systems covered in Section 4.5 and 4.5.3 different electro-chemical ESS , the total aggregate quantities shall be determined based on the sum of percentages of each type divided by themaximum allowable quantity rated energy of each type.

4.5.5 4

Where the sum of the percentages calculated in 4.5.4 exceeds 3 exceeds 100 percent, the area shall be treated as a highhazard classification.



NFPA_855_Table_4.5.docxTable 4.5


This proposal treats MRE requirements for both batteries and capacitors in a more consistent fashion, and allows additional exceptions on when MREs can be waived or increased. It reflects protection concepts developed by the FCAC ESS working group.



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TABLE 4.5 Maximum Rated Energy for Electro‐chemical ESS

Type Maximum Rated Energy*

(KWh)


Nickel‐cadmium (Ni‐Cd) 600

Lithium‐ion batteries, all

types

600




Capacitors, all types 200

NFPA staff – need to add the last row, I entered other changes into terra view.


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Fire areas within buildings containing stationary storage battery systems exceeding the maximum rated energy values in Table4.5 shall comply with all applicable high hazard requirements as identified in 6.2.2 of NFPA 101 and the building code.

Table 4.5 Maximum Rated Energy for Battery ESS

Type Maximum Rated Energy* (kWh)










There should be a method by which the energy density of the system or the size of the building be taken into account - for instance, "600kWh for every 10,000 sq ft".




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Fire areas within buildings containing stationary storage battery systems exceeding the maximum rated energy values in Table4.5 shall comply with all applicable high hazard requirements as identified in 6.2.2 of NFPA 101 and the building code. Wherean ESS has been subject to a Hazard Mitigation analysis in accordance with Section 4.2 and large-scale fire and faultcondition testing conducted or witnessed and reported by an approved testing laboratory, the maximum rated energylimitations found in Table 4.5 shall not apply consistent with such hazard Mitigation analysis, and the fire areas containing suchESS shall be considered ordinary hazard.












Moved from 4.5.2 for clarity.




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These numbers are arbitrary and have no technical basis. The maximum energy capacity will vary by battery type based on energy density and flammability, and instead should be limited by the demonstrated ability of the system to prevent cascading failure, and the availability of ventilation and extinguishing in the space.


Submitter Full Name: Davion Hill

Organization: DNV GL

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Type Maximum RatedEnergy* (kWh)

Lead acid , ( all types 600Nickel-cadmium (Ni-Cd) ) and Nickel-cadmium systems lower than 50-V ac, 60-Vdc nominal

Unrestricted

Lead acid (all types) and Nickel-cadmiumsystems greater than 50-V ac, 60-V dcnominal

600



Flow batteries† † 600



† † Includes vanadium, zinc-bromine, polysulfide, and other flowing electrolyte-type technologies.


Incorporate footnote into table for clarity. Tables can be read easily while footnotes are often missed or ignored.




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Fire areas within buildings, excluding Normally-Unoccupied Facilities, containing stationary storage battery systems exceedingthe maximum rated energy values in Table 4.5 shall comply with all applicable high hazard requirements as identified in 6.2.2 ofNFPA 101 and the building code.












This section should not apply to Normally-Unoccupied Stand-Alone installations.




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Sodium and zinc a batteries, all types 600




a Zinc-based batteries of a non-flowing configuration (zinc air, nickel zinc, zinc manganese dioxide).



See similar reasoning in public input No. 429-NFPA 855-2017, in section 1.3




Affilliation: None

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Exceptions: 1. ESS using exclusively lead-acid or nicker-cadmium batteries shall be considered ordinary hazard and shall notbe subject to the maximum rated energy limitations found in Table 4.5.

2. Where an ESS has been subject to a Hazard Mitigation analysis in accordance with Section 4.2 and large-scalefire and fault condition testing conducted or witnessed and reported by an approved testing laboratory, the maximum ratedenergy limitations found in Table 4.5 shall not apply consistent with such hazard Mitigation analysis, and the fire areascontaining such ESS shall be considered ordinary hazard.



Lead acid, all types

600

unlimited

Nickel-cadmium (Ni-Cd)

600

unlimited

Lithium-ion batteries, all types

600

1,000

Sodium batteries, all types

600

1,000

Flow batteries †

600

1,000

Other battery technologies

200

600




This proposal excludes lead acid and nickel-cadmium batteries consistent with the equivalent provisions of the IFC 2018. In addition, It would raise the limit for covered batteries from 600 to 1,000 kWh's to trigger designation as a high-hazard occupancy. This is a reasonable value based on the ESS industry's experience and tends to separate commercial ESS from utility scale ESS.





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What is the justification for these levels? Is there any data to support these levels? Li Ion is a family of technologies, some of them are much more dangerous than others. Li Ion should be separated by the chemistry just like lead-acid and NiCad. There should be data presented to justify these levels. Lead Acid and NiCad have 100 years of history as to their high level of safety and should not be limited by size.




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Lithium-ion batteries, all types 600 (Equivalent to Flow batteries? See attached)


Flow batteries† 600 (Equivalent to Li-ion batteries? See attached)






NFPA_855_Comments_from_Primus_Power.pdf Comments from Primus Power or relative hazard levels


Revise values in Table 1.3 Stationary ESS Threshold Quantities and Table 4.5 Maximum Rated Energy for Battery ESS to accurately reflect that flow batteries are inherently safer



Public Input No. 500-NFPA 855-2017 [Section No. 1.3] Same justification and attachment




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†Includes vanadium, zinc-bromine, polysulfide bromide , and other flowing electrolyte-type technologies.


The battery technology term was incomplete. It should be polysulfide bromide.




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4.5.1

Lead-acid and nickel-cadmium battery systems lower than 50-V ac, 60-V dc nominal shall be considered ordinary hazard.


Since there is no enforced relationship between the AC voltage of an inverter output and the DC voltage on the input by providing a max 50VAC you leave open the possibility that the DC battery string voltage can be significantly higher than 60VDC and the DC voltage is the actual indicator of hazard. That being said 60VDC is most likely too low a cutoff. ESS battery voltages are on the increase and few will pass this test. If we allow 600V and 1,000VDC PV systems limiting battery voltages to 60VDC to get the ordinary hazard rating seems a might conservative.




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4.5.1

Lead-acid and nickel-cadmium battery Battery systems lower than 50-V ac, 60-V dc nominal shall be considered ordinaryhazard.


The primary requirement of this statement is the voltage levels below 50VAC or 60 VDC. This is battery chemistry independent.





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4.5.1



The primary requirement of this statement is the voltage levels below 50VAC or 60 VDC. This is battery chemistry independent



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4.5.1



The primary requirement of this statement is the voltage levels below 50VAC or 60 VDC. This is battery chemistry independent.




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4.5.1

Lead-acid and nickel-cadmium battery systems lower than 50-V ac, 60 100 -V dc nominal shall be considered ordinary hazardfrom a electric shock standpoint .


The data is clear that dc voltages below 100 volts are as safe or safer than 50 volts ac in terms of electric shock. There are other hazards for extremely large batteries below 100 volts and there should not be a voltage cutoff for safety other than electric shock.



Public Input No. 534-NFPA 855-2017 [Section No. B.2.4]




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4.5.2

Where approved by the AHJ, areas containing stationary storage battery systems that exceed the amounts in Table 4.5 shall bepermitted to be treated as an ordinary hazard and not a high hazard classification based on a hazardous mitigation analysis inaccordance with Section 4.2 and large-scale fire and fault condition testing conducted or witnessed and reported by anapproved testing laboratory. the system being UL 9540 listed.


If system is UL 9540, system has already been verified and tested per the safety clauses of this standard plus its sub-standards (UL 1741, UL 1973, etc).



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4.5.2

Where approved by the AHJ, areas containing stationary storage battery systems that exceed the amounts in Table 4.5 shall bepermitted to be treated as an ordinary hazard and not a high hazard classification based on a hazardous mitigation analysis inaccordance with Section 4 3 .2 3.6 and large-scale fire and fault condition testing conducted or witnessed and reported by anapproved testing laboratory.


Incorrect Section reference.




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4.5.2

Where approved by the AHJ, areas containing stationary storage battery systems that exceed the amounts in Table 4.5 shall bepermitted to be treated as an ordinary hazard and not a high hazard classification based on a hazardous mitigation analysis inaccordance with Section 4.2 and large-scale fire and fault condition testing conducted or witnessed and reported by anapproved testing laboratory. the system being UL9540 listed.


If system is UL9540, system has already been verified and tested per the safety clauses of this standard plus its sub-standards (UL1741, UL1973, etc)




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4.5.2

Where approved by the AHJ, areas containing stationary storage battery systems that exceed the amounts in Table 4.5 shallbe permitted to be treated as an ordinary hazard and not a high hazard classification based on a hazardous mitigation analysisin accordance with Section 4.2 and large-scale fire and fault condition testing conducted or witnessed and reported by anapproved testing laboratory.


Moved to 4.5 for clarity.




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4.5.2

Where approved by the AHJ, areas containing stationary storage battery systems that exceed the amounts in Table 4.5 shallbe permitted to be treated as an ordinary hazard and not a high hazard classification based on a hazardous mitigation analysisin accordance with Section 4.2 and large-scale fire and fault condition testing conducted or witnessed and reported by anapproved testing laboratory.


Relocated as an exception.





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4.5.3

Fire areas within buildings containing stationary storage capacitor or acetonitrile systems exceeding 20 kWh shall comply withall applicable high hazard requirements as identified in 6.2.2 of NFPA 101 and the building code.


A common misconception among some designers and a lot of owners is that if one builds a high hazard occupancy that the fire, spill and toxicity risks of a stored hazardous material are mitigated. This is not true and sufficient evidence of this exists in the several of the investigation reports published by the US Chemical Safety and Hazards Investigation Board.

In processes where the stored hazardous material is in Use, such as an energy storage system using acetonitrile as a solvent with lithium based salts, none of the academic research papers reviewed by Austin FD examine the flammability or toxicity hazards. The issue with acetonitrile (C2H3N) is it’s molecular structure results in a triple bond between carbon and nitrogen. Upon heating, it liberates hydrogen cyanide. Not all high-hazard occupancies are designed for toxic and highly toxic gases so a general categorization of an occupancy as a means of managing this risk without a assessment of the hazard may not address all the potential issues.

The proponent suggests that if one wants to employ C2H3N as a solvent in a battery system, that this be evaluated as part of the FMEA employed during its listing and a hazard risk analysis. Sanctioning one solvent defeats the intent of the NFPA 855 standard.





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4.5.4

Where areas within buildings contain a combination of energy systems covered in Section in Table 4.5 and Section 4.5.3, thetotal aggregate quantities shall be determined based on the sum of percentages of each type divided by the maximumallowable quantity of each type.


Section 4.5.3 is a subsection of 4.5 so it seems unnecessary to call out 4.5.3. Given the intent of the provisions it does, however, seem more appropriate and less confusing to refer to Table 4.5 and then Section 4.5.3 (which does contain additional battery types not in the table).




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Exemption 2

Type your content here ...If the battery module has passed the fire propagation test of IEC 62619 Section 7.3.3 there shall be nomaximum kWh requirement.


If you demonstrate that your product does not propagate by chemistry ( LTO, LMO, ect.) or by design means (Thermal foam) then why is there a limit since there would be no fire.




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4.6* Size and Separation.

4.6.1

ESS installed indoors shall comply with 4.6.2 and through 4.6.3 4 unless otherwise permitted by 4.6.5 .

4 .6.2

ESS Listed by a NRTL shall be installed in accordance with the size and separation limitations identified by the listingrestrictions. If no size or separation restrictions are provided by the listing, then Listed ESS shall be installed in accordancewith the manufacturer's installation instructions.

4.6.2 3

If not Listed, ESS shall be comprised of groups to a maximum energy level of 250 kWh each.

4.6.3

Each

4

If not Listed, each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room orarea.

4.6.4 5

The AHJ shall be permitted to approve listed pre-engineered and prepackaged unlisted ESS groups with larger capacities orsmaller groups spacing if large representative -scale fire and fault condition testing conducted, or witnessed and reporteddocumented by an approved testing laboratory is provided , showing that a fire involving within any one array fire enclosurewill not propagate to an adjacent array equipment and be contained within the room for a duration equal to the fire resistancerating of the room separation required by 4.4.2.1.


Section 4.2.1 requires ESS to be Listed to UL 9540, which requires listing to UL 1973 for the battery equipment. UL 1973 is the ANSI approved standard which outlines fire spread testing for stationary battery equipment. Therefore, Listed equipment inherently complies with the intent of preventing fire propagation. “Representative-scale” testing should replace “Large-scale” testing to allow for tests appropriately sized, while reducing the total costs of performing such tests. The definition in 3.3.7 Large-Scale Fire and Fault Condition Testing does not allow for a smaller, representative test to proxy for a complete system. It is not feasible to damage a multi-million dollar system when a smaller, much less expensive test could provide the same results. This clause will block many suppliers from entering the large-scale ESS market, reducing competition, increasing customer costs, and ultimately reducing safety.



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4.6 * Size and Separation.

4.6.1

ESS installed indoors shall (where the battery is located indoors) shall comply with 4.6.2 and 4.6.3 4 unless otherwisepermitted by 4.6.4 5 .

4.6.2

If not listed, ESS shall be comprised of groups to a maximum energy level of 250 kWh each.

4.6.3

Each If not listed, each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage roomor area.

4.6.4

The AHJ shall be permitted to approve listed pre-engineered and prepackaged unlisted ESS groups with larger capacities orsmaller groups spacing if large representative -scale fire and fault condition testing conducted, or witnessed and reportedand documented by an approved testing laboratory is provided , showing that a fire involving one array will within anyone fire enclosure will not propagate to an adjacent array and equipment and be contained within the room for a durationequal to the fire resistance rating of the room separation required by 4.4.2.1.


Section 4.2.1 requires ESS to be Listed to UL 9540, which requires listing to UL 1973 for the battery equipment. UL 1973 is the ANSI approved standard which outlines fire spread testing for stationary battery equipment. Therefore, Listed equipment inherently complies with the intent of preventing fire propagation. “Representative-scale” testing should replace “Large-scale” testing to allow for tests appropriately sized, while reducing the total costs of performing such tests. The definition in 3.3.7 Large-Scale Fire and Fault Condition Testing does not allow for a smaller, representative test to proxy for a complete system. It is not feasible to damage a multi-million dollar system when a smaller, much less expensive test could provide the same results. This clause will block many suppliers from entering the large-scale ESS market, reducing competition, increasing customer costs, and ultimately reducing safety.




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4.6* Size and Separation.

4.6.1

ESS installed indoors shall comply with 4.6.2 and 4.6.3 unless otherwise permitted by 4.6.4 .

4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 kWh each.

4.6.3

Each group shall be spaced a minimum 3 ft , or in walk-in containers outdoors, shall be segregated into groups not exceeding50 KWh (180 Mega joules) Each group shall be separated a minimum three feet (914 mm) from other groups and from walls inthe storage room or area.

4.6.4

The AHJ shall be permitted to approve listed pre-engineered and prepackaged ESS groupsExceptions:

1. Lead acid and Ni-Cad battery systems less than 50 VAC and 60 VDC installed in telecommunication facilities inaccordance with NFPA 76.

2. The AHJ is authorized to approve ESS with larger capacities or smaller

groups spacing if large-separation based on large scale fire

and fault condition testing conducted or witnessed and reported by an approved testing laboratory is provided showing that afire involving one array will not propagate to an adjacent array and be contained within the room for a duration equal to the fireresistance rating of the room separation required by 4.4.2.1 .

testing complying with Section 4.5.


This proposal adds an option for waiving size and separation requirements for certain telecom facilities. It also allows an option for relaxing size and separation requirements based on large scale fire testing, and streamlines the requirements in a single section. The one substantive change is changing the maximum group size to 50 KWh, which can be increased with large scale fire testing. This reflects the protection concept developed by the FCAC ESS committee, which also had divided opinions on the proper KWh level.




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4.6.1

ESS installed indoors, except for Normally-Unoccupied Utility Scale Stand-Alone ESS, shall comply with 4.6.2 and 4.6.3 unlessotherwise permitted by 4.6.4.


Normally-unoccupied Utility-scale (>1MWh) Stand-Alone Installations may be located outdoor enclosures or stand-alone energy storage buildings. Such installations should be equipped with fire detection and fire suppression per sections 4.7 and 4.8 of this standard. These systems and the associated risks are fundamentally different from smaller systems installed inside occupied buildings and should not be subject to this section 4.6. Current industry standard for such large-scale installations includes rack-mounted battery modules laid out in rows with no spacing or separation between adjacent racks. In a building configuration, these rows are separated by aisles, much like a data center. An individual rack could hold anywhere from ~40 kWh to a few hundred kWh, depending on the application. Adding 3ft spacing between adjacent racks in a row would more than double the required footprint for these installations, dramatically increasing costs and rendering many projects unfeasible.




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4.6.1

ESS installed indoors in buildings housing the occupancies noted in 4.4.3.1 shall comply with 4.6.2 and 4.6.3 unless otherwisepermitted by 4.6.4.


Indoors is too vague. I think this section needs to be better defined/clarified.




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4.6.1

ESS installed indoors shall comply with 4.6.2 and 4.6.3 unless otherwise permitted by 4.6.4.

Exception: Listed Pre-engineered and Prepackaged ESS with larger capacities or smaller group spacing than thatprovided in 4.6.2 and 4.6.3 may be used where large-scale fire and fault testing is conducted or witnessed and reported by anapproved testing laboratory demonstarting that a fire involving one group will not propagte to an adjacent group and becontained within the room for a duration equal to the fire resistence rating of the room separation requuired by 4.4.2.1.


The proposal re-expresses 4.6.4 in the form of an exception.





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4.6.2

ESS listed by a NRTL (UL9540) shall be installed in accordance with the size and separation limitations identified by the listingrestrictions. If no size or separation restrictions are provided by the listing, then listed ESS shall be installed in accordance withthe manufacturer's installation instructions.


Section 4.2.1 requires ESS to be Listed to UL 9540, which requires listing to UL 1973 for the battery equipment. UL 1973 is the ANSI approved standard which outlines fire spread testing for stationary battery equipment. Therefore, Listed equipment inherently complies with the intent of preventing fire propagation.




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4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 1,000 kWh each.


The 250 kWh size limitation is arbitrary and not based in science or current practice. The state of the industry has found large-scale installations are concentrated at 1,000 kWh packages. At this level, fire detection is provided and many times active fire suppression and containment is also provided. Requiring these features at 250 kWh size would be cost prohibitive and likely result in less protection being applied due to the increased cost.



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4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 kWh each or the maximum energy level associated withthe equipment’s listing, whichever is larger .


Listing entails safety testing and should govern size and separation requirements.





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4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 kWh each. determined by

- the smallest unit of failure

- demonstrated ability to defeat cascading failure between units

- total ventilation capability of the room

- total extinguishing capability of the room


An arbitrary number like 250 kWh completely defeats the value proposition of energy storage by forcing it into larger footprints with no technical justification. Because energy density increases up to 15% per year, this number will be outdated before NFPA 855 is finalized. The prescription of a single number is an unintelligent solution that could instead be addressed by obligating AHJ's to think through the hazards that actually matter, such as whether the system has adequate cascading protections, and if the available ventilation and extinguishing capability of the site is well-matched to the fire load.




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4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 kWh each. Unless a secondary fire suppression systemexists within the ESS and verfied to prevent propagation or by chmistry chose through testing by a NRTL.


If no fire propagation exists why do we have to limit




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4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 300 kWh each.


Product road maps from tier-1 vendors indicate future battery racks may be rated more than 250 kWh, but I am yet to see anything greater than 300 kWh.




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4.6.2


ESS maximum grouping levels may be based on application and location


The 250 kWh limit is a deterrent to the whole Energy Storage Systems industry and puts majority of companies at risk of existence. There is no reasoning for this limitation because most of the ESS are rated for above this limit. Each ESS system may be size limited based on risk to life and property



Organization: General Electric Distributed Grid Systems, North America Energy Storage

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4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 kWh each. This maximum energy shall not apply toEnergy Storage Systems where the risk of fire does not scale with system energy rating.


Explicitly tying ESS group size and spacing to energy rating implies that the fire hazard for the ESS scales with energy. This is not universally true. Flow battery energy scales with the volume of the electrolytes. For systems that use non-flammable, aqueous electrolytes, increasing this volume does not increase the fire hazard.







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4.6.2



What is the basis of this limit? Why is this the same for all battery technologies? If there is no basis it should be deleted.




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4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 kWh each when the ESS is constructed of discrete self-contained cells . This shall not apply to technologies such as flow batteries where electrolyte is stored in large tanks.


The hazard being addressed by 4.6.2 is the spread of fire in a large system such as lithium ion. However, with flow batteries such as vanadium redox, the aqueous electrolyte is stored in tanks separate from the stacks which convert the stored chemical energy to electrical. Such systems can store a large amount of energy for a small amount of power (can run for an extended amount of time). First, there is no fire hazard from the electrolyte (third party DNGL verified) and second the size of the electrolyte tanks is completely irrelevant to the hazard of fire. It would be completely impractical for a 1 MW 10 hour system with 10 MWH of energy storage to be broken into forty 250 kWh chunks especially when real-life systems can be in the tens of MW and hundreds of MWH.


Submitter Full Name: Peter Gottlieb

Organization: Vionx Energy Corp

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Sections 4.6.2, 4.6.3

4.6.2

ESS shall be comprised of groups to a maximum energy level of 250 kWh each, unless a larger level is allowed under the ESSlisting .

4.6.3

Each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room or area, unless asmaller spacing is allowed under the ESS listing .


UL 9540 listing covers safety and should dictate separation requirements.




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4.6.3

Each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room or area or thedistance associated with the equipment's listing, whichever is shorter .


Listing should prevail.





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4.6.3

Each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room or area . unless

- the system has demonstrated that cascading failure is limited to the smallest possible modular unit

- additional fire blocking or non-flammable protective barriers are installed according to the AHJ


3 ft is an arbitrary number that defeats the value proposition of energy storage by inflating its footprint. The intent of this rule is to prevent cascading failures and therefore it should prescribe that 3ft is the rule unless the system demonstrates that it has a low probability of cascading.




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4.6.3

Each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room or area.



The spacing requirement is burdensome for telecommunications and not warranted based on the excellent fire safety record for the noted chemistries when installed per NFPA 76.




Affilliation: ATIS

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4.6.3

Each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room or area. Ifequipement with supplemental fire surpression system and verified by test by a NRTL that no propagation occurs. Or byselection of chemistry that no propagation occurs then the ESS spacing is exempt from this requirement.


If no propagation occurs and spacing is met by standard electrical cabinet requirements then the ESS should not be subject to this requirement. Space utilization in installations can be extremely difficult to space at these values so other options such as FSS or Chemistry need to be used.




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4.6.3

Each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room or area per theESS manufacturer's installation instructions .


Specifying 3' seems arbitrary. Setbacks and clearances between equipment should be specified per the manufacturer, and will be based on testing and certifications approvals, thus should be adequate to meet the intent of the code.




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4.6.3

Each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room or area. Spacingrequirements shall be applied as mandated by the manufacturer’s installation procedures or as listed


Spacing requirements puts a strain on real estate needs and increases the footprint of layout by 3x to 4x in some cases. The additional real estate requirement could be cost prohibitive in some cases and lead to complete elimination of the project. If the goal of this clause is to prevent fire propagation, this is already addressed in section 4.8.2 by means of Fire Suppression System




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4.6.3

Each group shall be spaced a minimum 3 ft (914 mm) from other groups and from walls in the storage room or area except forlead-acid and ni cad batteries where only one side must be accessible and have spacing of 3 ft or greater .


Lead-acid and Ni-Cad batteries have been installed within inches of walls for a century without any major issues. These battery types should be exempted.




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4.6.4

The AHJ shall be permitted to approve listed pre-engineered and prepackaged ESS groups with larger capacities or smallergroups spacing if large-scale fire and fault condition testing conducted or witnessed and reported by an approved testinglaboratory is provided showing that a fire involving one array will not propagate to an adjacent array and be contained within theroom for a duration equal to the fire resistance rating of the room separation required by 4.4.2 3 .1.


Incorrect reference.




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4.6.4

The AHJ Approval shall be permitted provided to approve listed pre-engineered and prepackaged ESS groups with largercapacities or smaller groups spacing if large-scale fire and fault condition testing conducted or witnessed and reported by anapproved testing laboratory is provided showing that a fire involving one array will not propagate to an adjacent array and becontained within the room for a duration equal to the fire resistance rating of the room separation required by 4.4.2.1.


Clarifies that listed systems will be approved.




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4.6.4

The AHJ shall be permitted to approve listed pre-engineered and prepackaged self-contained ESS groups with largercapacities or smaller groups spacing if large-scale fire and fault condition testing conducted or witnessed and reported by anapproved testing laboratory is provided showing that a fire involving one array will not propagate to an adjacent array and becontained within the room for a duration equal to the fire resistance rating of the room separation required by 4.4.2.1.


Changed to match changed definition.







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4.6.4

The AHJ shall be permitted to approve listed pre-engineered and prepackaged ESS groups with larger capacities or smallergroups spacing if large-scale fire and fault condition testing conducted or witnessed and reported by an approved testinglaboratory is provided showing that a fire involving one array will not propagate to an adjacent array and be contained withinthe room for a duration equal to the fire resistance rating of the room separation required by 4.4.2.1 .


relocated as an exception to 4.6.1.





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4.6.4

The AHJ shall be permitted to approve listed pre-engineered and prepackaged ESS groups

with larger capacities or smaller groups spacing if large-scale fire and fault conditionif representative testing conducted or witnessed and reported by an approved testing laboratory is provided showing that afire involving one

array willunit will not propagate to an adjacent

arrayunit and be contained within the room for a duration equal to the fire resistance rating of the room separation required by4.4.2.1 .


There is no clear definition on the scope of Large Scale Fire testing and this may lead to confusion and misinterpretation of the clause. Testing of a whole ESS system is cost prohibitive and unnecessary to prove fire propagation between adjacent units. Clause 3.3.7 should be reworded to have testing done, witnessed and reported by an approved testing laboratory to demonstrate fire involving one unit will not propagate to an adjacent battery unit and be contained within the room




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Identification

When detectors are actuated they shall identify the location of the fire (specific cabinet etc.)


The ability of detectors to identify the location of a fire is a critical aspect for the proper operation of fire suppression system. Additionally, emergency response personnel will be able to pinpoint the affected installation or portion thereof.



Organization: Director of Technolgoy Management, New York City Fire Department

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4.7.1

All fire areas containing ESS systems located within buildings or structures shall be provided with a smoke detection system inaccordance with NFPA 72.

Cabinets shall be provided with a fire detection system in accordance with NFPA 72


In some instances (especially in outdoor installations) the existing conditions may negatively impact the use of smoke detection systems. Requiring a fire detection system will allow the manufacturer to select a fire detection system that will adequately work for the situation.




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4.7.1

All fire areas containing ESS systems located within buildings or structures shall be provided with a smoke detection system inaccordance with NFPA 72.

Exceptions: 1. Smoke detection system is not required where a radiant energy-sensing detection system is installed inaccordance with NFPA in open parking garages and similar occupancies where conditions negatively impact the use ofsmoke detection technologies.

2. Telecommunications facilities with lead-acid and VRLA battery storage less than 50-V ac, 60-V dc shallhave fire dtection installed in accordance with NFPA 76.


Rewrites 4.7.3 as an exception.





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4.7.2

Normally unoccupied, remote stand-alone telecommunications structures with a gross floor area of less than 1500 ft2 (139 m2)utilizing lead-acid battery technology, nickel-cadmium battery technology, or nickel-metal hydride battery technology shall notbe required to have the detection required in 4.7.1.


This language already exists in other codes and the limitation on detection is not dependent on the use of batteries of any technology. The revised language is more consistent with current codes.




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4.7.3

The smoke detection system shall be permitted to be replaced with a radiant energy–sensing detection system installed inaccordance with NFPA 72 in open parking garages and similar occupancies where conditions negatively impact the use ofsmoke detection technologies.


relocated as an exception to 4.7.1.





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4.7.4

Telecommunications facilities with lead-acid and VRLA nickel-cadmium battery storage less than 50-V ac, 60-V dc shall havefire detection installed in accordance with NFPA 76.


Lead acid includes VRLA. Nickel-Cadmium technologies are also used in telecom applications complying to NFPA 76 and should be included in any telecommunications references and exceptions.




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4.7.4

Telecommunications facilities with lead-acid and VRLA battery storage less than 50-V ac, 60-V dc shall have fire detectioninstalled in accordance with NFPA 76.


relocated as an exception in 4.7.1.





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4.8 Fire Control and Suppression.

4.8.1

Fire protection for ESS shall be provided in accordance with this section.

4.8.2

All nonmechanical ESS located within buildings or structures shall be protected with

Rooms and areas within buildings and outdoor walk-in enclosures containing electro-chemical ESS shall be protected by anautomatic fire suppression system

installed as follows: In

designed and installed in accordance with one of the following:

1. An automatic sprinkler systems designed and installed in accordance with NFPA 13

with a minimum density of 0.3 gpm/ft 2 (12.2 mm/min) based on fire areaInfor the hazard category specified in Table 4.8.

2. When approved, an automatic sprinkler system designed and installed in accordance with NFPA 13 with a

minimum densitysprinkler hazard classification based on large

-scale

testingOther fixedfire

suppression method documented to be effective by large-scale fire testing

4.8.2.1

When other fixed fire suppression methods are used, based on reports issued as a result of full-scale testing as provided in4.8.2 , the fixed fire suppression systems shall comply with the following standards, as appropriate, unless specifically notedotherwise in this standard:testing in accordance with Section 4.5.

3. The following alternate automatic fire extinguishing system designed and installed in accordance with the standardsreferenced, provided the installation is approved by the AHJ based on large scale fire testing complying with Section 4.5.

· NFPA 12, Standard on Carbon Dioxide Extinguishing Systems

NFPA 13, Standard for the Installation of Sprinkler Systems

NFPA· NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection

· NFPA 750, Standard on Water Mist Fire Protection Systems

· NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems

· NFPA 2010, Standard for Fixed Aerosol Fire-Extinguishing

Systems

4.8.2.1.1 *

Foam fire suppression systems shall be designed to provide a foam blanket or foam submergence until it can be demonstratedthat the ESS has cooled to below the temperature that can cause thermal runaway and below the autoignition temperature ofcombustible material present.

4.8.2.1.2 * Gaseous Agent Fire Suppression Systems.

4.8.2.1.2.1 *

Total flooding gaseous agent systems shall be designed to take into consideration both of the following factors:

(1) The agent concentrations required for the specific combustible materials involved

(2) The specific configuration of the equipment and enclosure

4.8.2.1.2.2 *

Total flooding gaseous suppression systems shall be designed to maintain the design concentration within the enclosure for atime sufficient to ensure that the fire is extinguished and that temperatures of the ESS have cooled to below the autoignitiontemperature of combustible material present and the temperature that can cause thermal runaway.


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4.8.2.1.2.3 *

Local application gaseous agent suppression systems shall be designed to operate for a time sufficient to ensure that the fire isextinguished and that temperatures of the ESS have cooled to below the autoignition temperature of combustible materialpresent and the temperature at which thermal runaway can occur.

4.8.2.1.3

Dry chemical fire suppression systems shall be designed to operate until it can be demonstrated that the ESS has cooled tobelow the autoignition temperature of combustible material present and the temperature at which thermal runaway can occur.

4.8.2.1.4 *

Water mist suppression systems shall be designed and installed in accordance with their listing for the specific hazards andprotection objectives specified in the listing

Systems

Exception: Fire suppression systems for lead acid and Ni-Cad battery systems at telecommunications facilities thatcomply with NFPA 76 and operate at less than 50 VAC and 60 VDC shall only be provided when required by NFPA 76.

TABLE 4.8 AUTOMATIC SPRINKLER PROTECTION FOR

ELECTROCHEMICAL ENERGY STORAGE SYSTEMS (EESS)

TECHNOLOGY SPRINKLER HAZARD CLASSIFICATION

Lead acid batteries, all types Ordinary hazard (Group 2)

Nickel cadmium batteries (Ni-Cd), Ordinary hazard (Group 2)

Lithium batteries, all types Extra hazard (Group 1)

Sodium batteries, all types a Extra hazard (Group 1)

Flow batteries Ordinary hazard (Group 2)

Other battery technologies Extra hazard (Group 1)

Capacitor energy storage systems Extra hazard (Group 1)

a. Ordinary hazard (Group 2) for sodium-ion technologies .

4.8.2

.2

Telecommunications facilities with lead-acid and VRLA battery storage less than 50-V ac, 60-V dc and in compliance withNFPA 76 shall not be required to have a fire suppression system installed.

4.8.3

When approved by the AHJ, ESS shall be permitted to be installed in open parking garages without the protection of anautomatic fire suppression system where full-scale fire and fault condition testing documents the system does not present anexposure hazard to parked vehicles when installed in accordance with manufacturer’s instructions and this standard.

4.8.4

Hazardous exhaust and deflagration venting for ESS using lithium-ion, flooded lead-acid, or VRLA batteries shall be providedin accordance with this section.

4.8.4.1

Lithium-ion technology ESS installed within a room, enclosure, or container shall be provided with deflagration prevention bycombustible concentration reduction measures in accordance with NFPA 69 or shall be provided with deflagration venting inaccordance with NFPA 68.

4.8.4.2 *

Deflagration prevention and deflagration venting shall not be required when documentation is presented that the systemdischarge cannot exceed 25 percent of the lower explosive limit (LEL) anywhere in the room, enclosure, or container.

4.8.4.3 *

Flooded lead-acid and VRLA batteries installed within a room, enclosure, or container shall be provided with deflagrationprevention by combustible concentration reduction measures in accordance with NFPA 69 or shall be provided withdeflagration venting in accordance with NFPA 68.

4.8.4.3.1



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4.8.4.3.2

Telecommunications facilities with lead-acid and VRLA battery storage less than 50-V ac, 60-V dc and in compliance with NFPA76 shall be permitted to be exempt from the requirements in 4.8.4.2 .Water reactive systems. Electro-chemical ESS that utilize water reactive materials shall be protected by an approvedalternative automatic fire-extinguishing system in accordance with applicable NFPA installation standards, where the installationis approved by the AHJ based on large scale fire testing complying with Section 4.5.

4.8.3 Integral protection systems. Fire control and suppression systems provided as an integral part of ESS equipmentshall be maintained in an operable condition and tested in accordance with the listing and the manufacturer’s instructions

4.8.4 Testing and maintenance. Fire control and suppression systems covered by this Section shall be maintained in anoperable condition and tested in accordance with applicable installation codes and standards.



NFPA_855_Table_4.8.docx


This proposal reflects fire control and suppression requirements developed by the FCAC ESS committee and is provided for the 855 committee’s consideration. Among other things it establishes specific fire sprinkler design criteria, but allows flexibility for lesser sprinkler densities, and other fire control and suppression systems to be used where their effectiveness is established based on large scale fire testing.




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TABLE 4.8 AUTOMATIC SPRINKLER PROTECTION FOR


TECHNOLOGY SPRINKLER HAZARD CLASSIFICATION

Lead acid batteries, all types Ordinary hazard (Group 2)

Nickel cadmium batteries (Ni-Cd), Ordinary hazard (Group 2)

Lithium batteries, all types Extra hazard (Group 1)

Sodium batteries, all types a Extra hazard (Group 1)

Flow batteries Ordinary hazard (Group 2)

Other battery technologies Extra hazard (Group 1)

Capacitor energy storage systems Extra hazard (Group 1)

a. Ordinary hazard (Group 2) for sodium-ion technologies.


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4.8.1

Fire protection for indoor ESS shall be provided in accordance with this section.


Outside equipment with proper setback from other buildings or structures typically does not require fire protection systems. This is generally unoccupied space, the protection of which is a customer risk appetite decision or a supplier market differentiator.



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4.8.1

Fire protection for indoor ESS shall be provided in accordance with this section.


Outside equipment with proper setback from other buildings or structures typically has its own fire protection systems, based on manufacturer's recommendations and would be certified by UL9540.




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All nonmechanical ESS located within buildings, cabinets or structures shall be protected with an automatic fire suppressionsystem installed as follows:

(1) In accordance with NFPA 13 with a minimum density of 0.3 gpm/ft2 (12.2 mm/min) based on fire area

(2) In accordance with NFPA 13 with a minimum density based on large-scale testing

(3) Other fixed fire suppression method documented to be effective by large-scale fire testing


Electrochemical ESS located within cabinets will also generate flammable gas and become a severe fire hazard. If left uncontrolled, fire can spread from one cabinet to another adjacent cabinet, therefore they should be provided with fire suppression systems as other ESS installations.




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All nonmechanical ESS located within buildings or structures shall be protected with an automatic fire suppression systeminstalled as follows installed in accordance with one of the following :





Clarification that one of the listed three items is to be satisfied. While obvious to most readers it would be more accurate to clarify that only one of the three listed must be accomplished.




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All nonmechanical ESS located within buildings or structures or greater than 1 MWh (in aggregate) shall be protected with anautomatic fire suppression system installed as follows:





AES firmly believes it is prudent and responsible to include automatic fire suppression on all large-scale ESS. All AES energy storage installations, dating back nearly 10 years, have included fire suppression.




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All nonmechanical ESS located within buildings or structures shall be protected with an automatic fire suppression systeminstalled as follows:

(1) In accordance with NFPA 13 with a minimum density of 0.3 gpm/ft2 (12.2 mm/min) based on fire area for the protection ofLithium Ion energy storage systems based over the area of the room or 2,500 Ft.² design area, whichever is smaller.




The indicated discharge density is for Lithium Ion batteries. This discharge density was validated by Factory Mutual International and confirmed in research by the National Institute for Energy and Risk Assessment in France (see Ribière, P., et.al., Investigation on the fire-induced hazards of Li-ion battery cells by fire calorimetry. Energy Environ. Sci., 2012, 5, 5271). This discharge density is not required for flooded lead acid or VRLA batteries. NFPA 13 (2016 edition) Table A.5.6.3 has different commodity hazard classes for batteries. In the case of batteries using sulfuric acid as an electrolyte, the standard classifies these as a Class I commodity, which would equate to an Ordinary Hazard Group I discharge density in NFPA 13 Table 13.2.1.





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(1) In accordance with NFPA 13 with a minimum density of 0.3 1 gpm/ft2 (12.2 mm/min) based on fire area, or

(2) In accordance with NFPA 13 with a minimum density based on large-scale testing, or

(3) Other fixed fire suppression method documented to be effective by large-scale fire testing.

Exceptions: 1. Telecommunications facilities with lead-acid and VRLA battery storage less than 50 -V ac, 60-V dc are notrequired to install a fire suppression system.

2. An automatic fire suppresion system is not required where full-scale fire and fault condition testing demonstratesthat an ESS installed in an open parking garage does not present an exposure hazard to parked vehicles.


rewrites section as an exception plus reduces gpm from .3 to the standard .1 gpm, consistent with NFPA 13. The .3 gpm rate would not provide greater safety but would require an infrastructure change to handle the higher flow rate.





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(3) Other fixed fire suppression method documented to be effective by large-scale fire representative scale fire testing


Some of the ESS could be installed in remote locations where the feasibility of access to water is very unlikely. In such cases, other fixed fire suppression methods tested and documented by approved testing laboratory could be installed to mitigate this risk.




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(4) No automatic fire suppression is required if a fire risk assessment and large-scale fire testing demonstrate that it isunecessary


The inclusion of an automatic fire suppression system adds risk, complexity, and cost to energy storage that has built in secondary liquid containment. UL 9540 requires a fire risk assessment to determine the “level and type of fire detection and fire suppression systems required”. This type of assessment, conducted by an independent 3rd party, is a much better method for determining appropriate fire safety systems than a universal prescription for automated fire suppression.







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Public Input No. 19-NFPA 855-2017 [ Section No. 4.8.2.1 [Excluding any Sub-Sections] ]

When other fixed fire suppression methods are used, based on reports issued as a result of full large -scale testing as providedin 4 3 .8 3 .2 7 , the fixed fire suppression systems shall comply with the following standards, as appropriate, unless specificallynoted otherwise in this standard:

(1) NFPA 12, Standard on Carbon Dioxide Extinguishing Systems

(2) NFPA 13, Standard for the Installation of Sprinkler Systems

(3) NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection

(4) NFPA 750, Standard on Water Mist Fire Protection Systems

(5) NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems

(6) NFPA 2010, Standard for Fixed Aerosol Fire-Extinguishing Systems


Incorrect reference, corrected language to align with definition.




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Public Input No. 260-NFPA 855-2017 [ Section No. 4.8.2.1.2.1 ]

4.8.2.1.2.1*

Total flooding gaseous agent systems shall be designed to take into consideration both all of the following factors:



(3) The total probable heat and fire load that can be managed by the gas system


Present designs for fixed suppression systems can only suppress an incipient fire and should not be marketed as a total extinguishing solution. Their documentation should expressly state what probable fire scenario they are designed for. In most cases this is a single cell.




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4.8.2.1.2.1*

Total flooding gaseous agent systems shall be designed to take into consideration both of based on the following factorsincluding but not limited to :




When applying NFPA 2001 the selection of the agent is equally important as is the design of the fire detection system, control of the mechanical ventilation systems, and the integrity of the enclosure. The proposed text ensures that all of the requirements of NFPA 2001 are considered.

PROPONENT: Scott Stookey, Graduate A – Hazardous Materials, City of Austin (TX) Fire Department. V: 512-974-0157, C: 512-767-5425



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4.8.2.1.2.2*

Total flooding gaseous suppression systems shall be designed to maintain the design concentration within the enclosure for atime sufficient sufficient time as described in existing NFPA gaseous suppression system standards to ensure that the fire isextinguished and that temperatures of the ESS have cooled to below the autoignition temperature of combustible materialpresent and the temperature that can cause thermal runaway.


Reference existing standards as opposed to redefining hold times for gaseous agent fire suppression systems.




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4.8.2.1.2.2*

Total flooding gaseous suppression systems shall be designed to maintain the design concentration within the enclosure for atime sufficient to ensure that the fire is extinguished and that temperatures of the ESS have cooled to below the autoignitiontemperature of combustible material present and the temperature that can cause thermal runaway. For Normally-unoccupiedstandalone installations with a fire bridage in proximity, the required hold time shall be equal to the expected time required forthe fire brigade to arrive on site.


For large enclosures maintaining the design concentration while the system cools is not practical. Where these installations are Normally-unoccupied and removed from other exposures (stand-alone) it should be permissible to utilize the gaseous suppression system to control the initial event and hold until the fire brigade arrives on site. They can then assess the situation and apply water if needed.




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4.8.2.2



Telecommunications facilities have exemptions from fire sprinklers independent of battery technologies and compliance with NFPA 76. These exemptions are in NFPA 101, 13, 5000 as well as the IFC and are due to concerns with the impact of water on telecommunications services. There is no need to 855 to restrict this exemption by limiting it to particular types of installations containing batteries.

Sprinkler Exemption in NFPA 101 Life Safety CodeChapter 40 Industrial Occupancies40.1 General Requirements.40.1.1 Application.40.1.1.1 The requirements of this chapter shall apply to both new and existingindustrial occupancies.40.3 Protection40.3.5 Extinguishment Requirements. (Reserved)Richard Kluge editing note: No requirements are provided NFPA 101 for sprinklers in industrial occupancies.

Sprinkler Exemption in NFPA 13 Standard for the Installation of SprinklerSystemsSection 8.15.11.28.15.11.2 Sprinklers shall not be required in electrical equipment rooms where all of the following are met:(1) The room is dedicated to electrical equipment only.(2) Only dry-type electrical equipment is used.(3) Equipment is installed in a 2-hour fire rated enclosure including protection and penetrations.(4) No combustible storage is permitted to be stored in the room.

Sprinkler Exemption in NFPA 5000 Building Construction and Safety CodeChapter 6 Classification of Occupancy, Classification of Hazard of Contents, and Special Operations6.1 Classification of Occupancy6.1.12 Industrial. For requirements, see Chapter 29.6.1.12.1* Definition – Industrial Occupancy. An occupancy in which products aremanufactured or in which processing, assembling, mixing, packaging, finishing,decorating, or repair operations are conducted.A.6.1.12.1 Industrial uses that can be considered as low hazard industrial occupanciesinclude the following:(1) Beverages (nonalcoholic)(2) Brick and masonry(3) Ceramic(4) Foundries(5) Glass products(6) Gypsum(7) Ice(8) Metal products (fabrication and assembly)(9) Telecommunications signal processing(10) Telephone exchanges

Sprinkler Exemption in the International Fire Code (Sections 403.2 and 903.2)Section 403.2 for high rise buildingsException: An automatic sprinkler system shall not be required in spaces or areas of:1. Open parking garages in accordance with Section 406.3.2. Telecommunications equipment buildings used exclusively for telecommunications equipment,associated electrical power distribution equipment, batteries and standby engines, provided thatthose spaces or areas are equipped throughout with an automatic fire detection system inaccordance with Section 907.2 and are separated from the remainder of the building with firebarriers consisting of 1-hour fire resistance rated walls and 2-hour fire resistance ratedfloor/ceiling assemblies.Section 903.2 for low rise buildingsException: Telecommunications equipment buildings used exclusively for telecommunications


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equipment, associated electrical power distribution equipment, batteries and standby engines,provided that those spaces or areas are equipped throughout with an automatic fire detectionsystem in accordance with Section 907.2 and are separated from the remainder of the buildingwith fire barriers consisting of 1-hour fire resistance rated walls and 2-hour fire resistance ratedfloor/ceiling assemblies.




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4.8.2.2



Relocated to 4.8.2 as exception 1.





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4.8.2.2

Telecommunications facilities with lead-acid, Ni Cad and VRLA battery storage less than 50-V ac, 60 100 -V dc and incompliance with NFPA 76 shall not be required to have a fire suppression system installed.


Ni Cads should be included here as they are used in telco offices as well. The limit should be 100 volts.




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4.8.3

When approved by the AHJ, ESS shall be permitted to be installed in open parking garages without the protection of anautomatic fire suppression system where full-scale fire and fault condition testing documents the system does not present anexposure hazard to parked vehicles when installed in accordance with manufacturer’s instructions and this standard.


Relocated to 4.8.2 as exception 2.





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Hazardous exhaust and deflagration venting for ESS using lithium-ion , flooded lead-acid, or VRLA batteries shall be providedin accordance with this section.


Lead acid batteries should be removed from this section. There have been few problems with lead acid batteries that warrant such systems. Cases such as the Rancho Cordova data center explosion were created by abuse conditions (batteries abandoned, on charge, no air conditioning, no ventilation, for weeks or months) already addressed elsewhere by this standard.




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Hazardous exhaust and deflagration venting for ESS using lithium-ion, flooded vented lead-acid, or VRLA batteries shall beprovided in accordance with this section.


The accepted term is vented, not flooded.




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4.8.4.1 *

Lithium-ion technology ESS installed within a room, enclosure, or container shall be provided with deflagration prevention bycombustible concentration reduction measures in accordance with NFPA 69 or shall be provided with deflagration venting inaccordance with NFPA 68.


Link Section 4.8.4.1 to its counterpart in the appendix, A4.8.4.1




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4.8.4.2 * 1.1



Move asterisk to Section 4.8.4.1. Incorrect section was originally linked to information in the appendix.




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4.8.4.2*


Exception: 1. Telecommunications facilities with lead-acid and VRLA battery storage less than 50 -V ac, 60-V dc are exemptfrom the requirements of 4.8.4.2.


Rewrites section as an exception.





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Flooded lead-acid and VRLA batteries installed within a room, enclosure, or container shall be provided with deflagrationprevention by combustible concentration reduction measures in accordance with NFPA 69 or shall be provided with deflagrationventing in accordance with NFPA 68.


Lead acid batteries should be removed from this section. There have been few problems with lead acid batteries that warrant such systems. Cases such as the Rancho Cordova data center explosion were created by abuse conditions (batteries abandoned, on charge, no air conditioning, no ventilation, for weeks or months) already addressed elsewhere by this standard.




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Flooded Vented lead-acid and VRLA batteries installed within a room, enclosure, or container shall be provided withdeflagration prevention by combustible concentration reduction measures in accordance with NFPA 69 or shall be provided withdeflagration venting in accordance with NFPA 68.


Vented is the correct terminology for lead-acid batteries with free flowing electrolyte.




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4.8.4.3.2

Telecommunications facilities with lead-acid and VRLA battery storage less than 50-V ac, 60-V dc and in compliance with NFPA76 shall be permitted to be exempt from the requirements in 4.8.4.2.


Clarified wording. Shall be permitted to be exempt is very weak. The intent is to have them exempt.




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4.8.4.3.2

Telecommunications facilities with lead-acid, Ni Cad and VRLA battery storage less than 50-V ac, 60 100 -V dc and incompliance with NFPA 76 shall be permitted to be exempt from the requirements in 4.8.4.2.


Ni-Cad should be exempted also and 100 volts should be the limit.




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4.8.4.3.2

Telecommunications facilities with lead-acid and VRLA battery storage less than 50-V ac, 60-V dc and in compliance withNFPA 76 shall be permitted to be exempt from the requirements in 4.8.4.2 .


Rewritten as an exception in 4.8.4.2.





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4.9 Water Supply. Systems with Water-based Fire Suppression

4.9.1*

Sites where nonmechanical ESS are installed shall be provided with a permanent source of water for fire protection.

4.9.2

Where no permanent adequate and reliable water supply exists for fire-fighting purposes, the requirements of NFPA 1142 shallapply.

4.9.3

Fire hydrants in accordance with NFPA 24 shall be provided for site ESS installations where a public or private water supply isavailable.


Section 4.8 allows the use of non-water based fire suppression. Therefore this section should be meant for systems using water-based fire suppression only.



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4.9 Water Supply Systems with w ater-based fire suppression .

4.9.1 *


4.9.2

Where no permanent adequate and reliable water supply exists for fire-fighting purposes, the requirements of NFPA 1142 shallapply.

4.9.3

Fire hydrants in accordance with NFPA 24 shall be provided for site ESS installations where a public or private water supply isavailable.


Section 4.8 allows the use of non-water based fire suppression. For improved clarity, this section should be meant for systems using water-based fire suppression only.




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4.9.1*


Normally unoccupied, remote stand-alone telecommunications structures with a gross floor area of less than 1500 ft2 (139 m2)utilizing lead-acid battery technology, nickel-cadmium battery technology, or nickel-metal hydride battery technology shall notbe required to have the permanent source of water required in 4.9.1.


Small, normally unoccupied, remote stand-alone telecommunications structures are often constructed without a water supply. This has not been a problem and should be allowed by the standard.




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4.9.1*

Sites where nonmechanical ESS are installed shall be provided with a permanent source of water for fire protection . or installfixed fire suppression method documented to be effective by representative - scale fire testing


This could be a deterrent to ESS installations because some of these systems may be installed in remote locations where the feasibility of access to water is very unlikely. So, in such cases, other fixed fire suppression methods tested and documented by approved testing laboratory would be an alternate solution to meet the requirement of this clause. Water pipes could also freeze and result in water damage, electrical hazard and ineffective fire suppression.




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4.10.1

ESS installations shall be provided with dedicated environmental ventilation and dedicated exhaust ventilation as required bythis section.


A dedicated ventilation system will prohibit the re-circulation of air contaminated with flammable or toxic gasses generated post fire or failure event to other areas of the building that could possibly affect building occupants.

A dedicated exhaust system will safely exhaust flammable or toxic gasses generated post fire or failure event directly to the outdoors without mixing with any other potentially hazardous exhaust gasses.




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4.10.5

Required mechanical exhaust ventilation systems for rooms, enclosures, containers, and cabinets containing storage batteriesshall be supervised by an approved central station, proprietary, or remote station service or shall initiate an audible and visualsignal at an approved constantly attended on-site location complying with NFPA 72. the exhaust shall be powered by aseparate dedicated power source that shall be separate from the ESS itself.


In the event a first responder were to remove power from the ESS during a system failure the exhaust should continue and should not be powered by the ESS that has the potential of failure.


Submitter Full Name: Paul Rogers

Organization: Fire Department City of New Yo

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4.10.6

One or more listed devices or other approved method shall be provided to preclude, detect, and control thermal runaway forESS with the potential for thermal runaway.


This section was deleted because it is duplicated in Chapter 9 and is not related to ventilation and exhaust.



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Carl Wren



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4.10.6

One or more listed devices or other approved method shall be provided to preclude, detect, and control thermal runaway forESS with the potential for thermal runaway VRLA lead-acid and lithium-ion ESS .


Improve code by listing which technologies require thermal runaway control. This will prevent miss application of the requirement.




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4.10.6

One or more listed devices or other method approved method by the ESS manufacturer shall be provided to preclude, detect,and control thermal runaway for ESS with the potential for thermal runaway.


The term "approved" is too vague. Approval from the ESS manufacturer should ensure comprehensive understanding of the product and necessary methods to avoid thermal issues.




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4.10.6

One or more listed devices or other approved method shall be provided to preclude, detect, and control thermal runaway forESS with the potential for thermal runaway. ESSs that utilize VRLA technology. A common method is to utilize temperaturecontrolled chargers that reduce the voltage when the temperature of the battery increases above normal.


Many battery chemistries and types, including vented lead-acid, have the potential for thermal runaway. That is way too broad of characterization. The real issue is with VRLA batteries and should be stated as such. This requirement in the fire codes has caused a great deal of confusion in the industry because of the vague wording. Providing a common method, that many use, will go a long way to resolving the confusion. This is redundant with 9.2.2.3.








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ESS utilizing flow battery technology, sodium beta battery technology, capacitor technology, or other battery technology notspecifically addressed in Section 4.10 shall be provided with exhaust ventilation in accordance with 4.10.5 7 .1 when flammablegases can be produced during charging, discharging, and normal system use.


Corrected the reference.


Submitter Full Name: Sercan Teleke

Organization: Eaton

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ESS utilizing flow battery technology, sodium beta battery technology, capacitor technology, or other battery technology notspecifically addressed in Section 4.10 shall be provided with exhaust ventilation in accordance with 4.10.5 7 .1 when flammablegases can be produced during charging, discharging, and normal system use.


Incorrect section was mentioned. Revised to reflect correct section.




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ESS utilizing flow battery technology, sodium beta battery technology, capacitor technology, or other battery technology notspecifically addressed in Section 4.10 shall be provided with exhaust ventilation in accordance with 4.10.5 .1 when flammablegases can be produced during charging, discharging, and normal system use.


Sodium Nickel Chloride batteries are included in the general description of Sodium Beta batteries. Sodium Nickel Chloride or any Sodium beta batteries do not produce flammable gasses during charging, discharging and normal operation. They are sealed cell systems that do not produce any flammable gasses.





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ESS utilizing flow battery technology, sodium beta battery technology, capacitor technology, or other battery technology notspecifically addressed in Section 4.10 shall be provided with exhaust ventilation in accordance with 4.10.5 .1 when flammablegases can be produced during charging, discharging, and normal system use.


To reference the correct section number.




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ESS utilizing flow battery technology, sodium beta battery technology, capacitor technology, or other battery technology notspecifically addressed in Section 4.10 shall be provided with exhaust ventilation in accordance with 4.10.5.1 when flammablegases can be produced during charging, discharging, and normal system use.


SOdium beta battery does not produce any gas during operation. cells are hermetically sealed and there is no gas emission during operation. this is also written in section B.5.7




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Sodium Nickel Chloride batteries are included in the general description of Sodium Beta batteries. Sodium Nickel Chloride or any Sodium beta batteries do not produce flammable gasses during charging, discharging and normal operation. They are sealed cell systems that do not produce any flammable gasses, like highlighted in 4.8.4 and with B4.1



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sodium beta technologies are hermetically sealed and do not require special ventilation criteria such as vented lead acid that are open systems where hydrogen gas can be off gassed from the electrolyte.




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4.10.7.1

Ventilation shall be provided for rooms, enclosures, containers, and cabinets in accordance with the local mechanical code andone of the following:

(1) The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the lowerflammable limit (LFL) of the total volume of the room, enclosure, container, or cabinet during the worst-case event ofsimultaneous “boost” charging of all the batteries, in accordance with manufacturers data sheets or with nationallyrecognized standards.

(2) Mechanical ventilation shall be provided at a rate of not less than 1 ft3/min/ft2 (5.1 L/sec/m2) of floor area of the room,enclosure, container, or cabinet. The ventilation can be either continuous or activated by a gas detection system inaccordance with 4.10.5.2.


This change was made to include manufacturer's information because if the manufacturer can provide this data it will be more specific to the battery type.



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Carl Wren



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4.10.7.1


(1) The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the lowerflammable limit (LFL) of the total volume of the room, enclosure, container, or cabinet during the worst-case event ofsimultaneous “boost” charging of all the batteries, in accordance with nationally recognized standards.

(2) Mechanical ventilation shall be provided at a rate of not less than 1 ft3/min/ft2 (5.1 L/sec/m2) of floor area of the room,enclosure, container, or cabinet. The ventilation can be either continuous or activated by a gas detection system inaccordance with 4.10.5 7 .2.


Corrected wrong reference.



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4.10.7.1


(1) The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the lowerflammable limit (LFL) of the total volume of the room, enclosure, container, or cabinet during the worst-case event ofsimultaneous “boost” charging of all the batteries, in accordance with NFPA 69 and nationally recognized standards.



NFPA 69 very specifically dictates the means to design a system that will limit the maximum concentration of flammable gas to 25 percent of the lower flammable limit (LFL) of total room volume.




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4.10.7.1


(1) The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the lowerflammable limit (LFL) of the total volume of the room, enclosure, container, or cabinet during the worst-case event ofsimultaneous “boost” charging of all the batteries, in accordance with nationally recognized standards IEEE 1635/ASHRAE21 .



The definitive guide for battery ventilation is IEEE 1635/ASHRAE 21. This has been developed by battery and ventilation experts in the industry and provides calculations that cannot be found in any other national standard.








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4.10.7.2

Where required by 4.10.6 7 .1(2), rooms, enclosures, containers, and cabinets containing ESS shall be protected by anapproved continuous gas detection system.


Corrected wrong reference.



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4.10.7.2



Incorrect reference




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4.10.7.2



Incorrect section was mentioned. Revised to reflect correct section.




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4.10.7.2



Reference was incorrect




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Sections 4.10.7.2, 4.10.7.3

4.10.7.2

Where required by 4.10.6.1(2), rooms, enclosures, containers, and cabinets containing ESS shall be protected by an approvedcontinuous gas detection system .

4.10.7.3

The gas detection system shall be designed to activate the mechanical ventilation system when the level of flammable gas inthe room, enclosure, container, and cabinet exceeds 25 percent of the LFL.


combined two sections





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4.10.7.3

The gas detection system shall be designed to activate the mechanical ventilation system when the level of flammable gas inthe room, enclosure, container, and or cabinet exceeds 25 percent of the LFL.


Editorial and consistency with other sections also listing these locations.




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4.10.7.5

The gas detection system shall be provided with a minimum of 2 hours of standby power and must be supervised per NFPA72 .


This change was made to be consistent with the current requirements in the International Fire Code.



Submitter FullName:

Carl Wren



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4.10.8.1*

Ventilation shall be provided for rooms, enclosures, containers, and cabinets in accordance with the mechanical code and oneof the following:

(1) The ventilation system shall be designed to limit the maximum concentration of hydrogen to 1.0 percent of the total volumeof the room, enclosure, container, and cabinet during the worst-case event of simultaneous “boost” charging of all thebatteries, in accordance with manufacturers data sheet or nationally recognized standards.

(2) Continuous ventilation shall be provided at a rate of not less than 1 ft3/min/ft2 (5.1 L/sec/m2) of floor area of the room,enclosure, container, or cabinet.


This change was made to include manufacturer's information because if the manufacturer can provide this data it will be more specific to the battery type.



Submitter FullName:

Carl Wren



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4.10.8.1 *


(1) The ventilation system shall be designed to limit the maximum concentration of hydrogen to 1.0 percent of the total volumeof the room, enclosure, container, and or cabinet during the worst-case event of simultaneous “boost” charging of all thebatteries, in accordance with nationally recognized standards.



Editorial and for consistency with other sections having the requirement and using 'or' instead of 'and'.




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4.10.8.1*


(1) The ventilation system shall be designed to limit the maximum concentration of hydrogen to 1.0 percent of the total volumeof the room, enclosure, container, and cabinet during the worst-case event of simultaneous “boost” charging of all thebatteries, in accordance with nationally recognized standards with IEEE 1635/ASHRAE 21 .










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4.11 * Signage.

4.11.1

Approved signage shall be provided in the following locations:

(1) On the front of doors to rooms or areas containing ESS or in approved locations near entrances to ESS rooms

(2) On the front of doors to outdoor occupiable ESS containers

(3) In approved locations on outdoor nonoccupiable ESS units

4.11.2 *

The signage required in 4.11.1 shall be in compliance with ANSI Z535 and shall include the following information as shown inFigure 4.11.2 :

(1) Labeled “Energy Storage System” with symbol of lightning bolt in a triangle

(2) Type of technology associated with the ESS

(3) Special hazards associated as identified in Chapter 5 through Chapter 16

(4) Type of suppression system installed in the area of the ESS

(5) Emergency contact information

Figure 4.11.2 Example of ESS Signage.

4.11.3

A permanent plaque or directory denoting the location of all electric power source disconnecting means on or in the premisesshall be installed at each service equipment location and at the location(s) of the system disconnect(s) for all energy sourcescapable of being interconnected.

4.11.4

Installations with large numbers of energy sources shall be allowed to be designated by groups.

4.11.5

A disconnecting means shall be provided for all ungrounded conductors derived from an ESS. A disconnecting means shall bereadily accessible and located within sight of the ESS. [ 70 :706.7(A)]

4.11.6

Existing ESS shall be permitted to retain the hazard identification signage required at the time it was installed, except asmodified by 4.11.5 .

4.11.7

System hazard identification signage shall be modified for existing installations to meet the requirements of 4.10.3 when thesystem is modified or existing signs need to be replaced.


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4.11.8

A permanent plaque or directory denoting the location of all electric power source disconnecting means on or in the premisesshall be installed at each service equipment location and at the location(s) of the system disconnect(s) for all electric powerproduction sources capable of being interconnected. Installations with large numbers of power production sources shall bepermitted to be designated by groups.

4.11.9

Battery and ESS cabinets in occupied work centers covered by 4.4.5 shall be provided with exterior signs that identify themanufacturer and model number of the system and electrical rating (voltage and current) of the contained system, and anyrelevant electrical, chemical, and fire hazard.


Electrical and signage requirements for ESS are already covered in NFPA 70 Article 706. Repeating them in 855 at best just duplicate text and at worst could create conflicts.




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4.11.1

Approved signage shall be provided in the following locations:

(1) On the front of doors to rooms or areas containing ESS or in approved locations near entrances to ESS rooms

(2) On the front of doors to outdoor occupiable ESS containers

(3) In approved locations on outdoor nonoccupiable ESS units outdoor ESS that are not enclosed in occupable containers orotherwise enlosed


Clarification. The proposed language describes the intended scenario in more specific terms than 'other non-occupiable ESS units'.




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4.11.4

Installations with large numbers of with multiple energy sources shall be allowed to be designated by groups.


The term 'large' is subjective and will be challenging to uniformly interpret and implement. If the issue is allowing multiple energy sources, if they exist on the site, to have one sign to cover them then it seems appropriate and more specific to simply say multiple sources (meaning more than one - or - two or more).




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4.11.5

A disconnecting means shall be provided Signage for all ungrounded conductors derived from an ESS. A the disconnectingmeans shall be readily accessible and located within sight of the ESS. [ 70 :706.7(A)] Additional signage is allowed asnecessary.


This section is on signage requirements; signage and labels pointing to the disconnect means shall be available to the user near the equipment and entry points.



Organization: Nema

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4.11.5

A disconnecting means shall be provided Signage for all ungrounded conductors derived from an ESS. A the disconnectingmeans shall be readily accessible and located be located within sight of the ESS. [ 70 :706.7(A)] of ESS. Additional signage isallowed as necessary.


For improved clarity, this section is on signage requirements; signage and labels pointing to the disconnect means shall be available to the user near the equipment and entry points.




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4.11.6

Existing ESS shall be permitted to retain the hazard identification signage required at the time it was installed, except asmodified by 4.11.5.


Convey the requirement without addition of inflammatory wording.




Affilliation: ATIS

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4.11.8

A permanent plaque or directory denoting the location of all electric power source disconnecting means on or in the premisesshall be installed at each service equipment location and at the location(s) of the system disconnect(s) for all electric powerproduction sources capable of being interconnected. Installations with large numbers of power production sources shall bepermitted to be designated by groups. Telecommunications facilities with lead-acid and nickel-cadmium battery storage lessthan 50-V ac, 60-V dc and in compliance with NFPA 76 shall be exempt from the requirements in 4.11.8 as such installationsdo not utilize system disconnects.


Telecom installations do not have system disconnects on ESS. These installations have been proven safe. Battery disconnects are a reliability concern in the telecommunications network and are not desirable for these applications.




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4.11.8

A permanent plaque or directory denoting the location of all electric power source disconnecting means on or in the premisesshall be installed at each service equipment location and at the location(s) of the system disconnect(s) for all electric powerproduction sources capable of being interconnected. Installations with large numbers of with multiple power productionsources shall be permitted to be designated by groups.


See reason for proposed revision to Section 4.11.4.




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4.12 Fire Command Centers.

Fire command centers in buildings containing ESS shall include signage or readily available documentation that describes thelocation and type of ESS, operating voltages, and location of electrical disconnects as required by NFPA 70.


Need to define Fire Command Center.




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4.13.3

Combustible materials in occupied work centers shall not be stored within 3 ft (915 mm) of ESS equipment and comply withSection 10.18 of NFPA 1 or other applicable fire codes.


To provide a reference point for the measurement (to the ESS equipment).




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4.13.4

Section 4.14 shall not comply with ESS in dwelling units.


This section was eliminated because of the proposed change to section 4.4.2 that prohibits ESS inside dwelling units.



Submitter FullName:

Carl Wren



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4.13.4

Section 4.14 shall 13 shall not comply with ESS in dwelling units.


This seems like it should be referring to 4.13 rather than 4.14.




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4.13.4

Section 4.14 shall not comply with ESS in dwelling units.


It is unclear why this section is located in the section on combustible storage and how to apply the intent of the section to dwelling units. I recommended deleting it unless there is another location in the standard more relevant to the intent of what is contained in the deleted text.




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4.13.4

Section 4.14 shall not comply with apply to ESS in dwelling units.


editorial





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4.14 Outdoor Installation.

4.14.1 General.

ESS located outdoors shall be installed in accordance with this standard and the manufacturer’s installation instructions,including spacing between adjacent ESS.

4.14.2* Occupiable ESS.

Occupiable ESS containers or enclosures shall be considered buildings and shall comply with this standard and local buildingcode requirements.

4.14. 3 * Security.

ESS located outdoors shall be secured in an approved manner against unauthorized physical access.

4 .14.4 Enclosures.

ESS electrical circuitry shall be within weatherproof enclosures marked with the environmental rating suitable for the type ofexposure required by NFPA 70.

4.14.5 Siting . 4.14.5. 1 Separation .

ESS located outdoors shall be separated by a minimum 10 ft (3 m) from the following:

(1) Lot lines

(2) Public ways

(3) Buildings

(4) Stored combustible materials

(5) Hazardous materials

(6) High-piled stock

(7) Other exposure hazards

(8) Means of egress from buildings or structures

4 .14.5.1.1

A 1-hour free standing fire barrier extending 5 ft (1.5 m) above and extending 5 ft (1.5 m) beyond the physical boundary of thecomplete ESS installation that is suitable for exterior use shall be used to reduce the distance in 4.14.5.1 to 3 ft (914 mm).

4.14.5.1.2

The distance to buildings is permitted to be reduced to 3 ft (914.4 mm) where noncombustible exterior walls with no openingsor combustible overhangs meet the fire resistance ratings in Table 4.4.3.1 .

4.14.5.1.3

The AHJ is authorized to approve a reduction in required separation distances when large-scale fire and fault condition testingconducted or witnessed and reported by an approved testing laboratory is provided showing that a fire involving anycomponent of the ESS will not adversely impact adjacent buildings, stored materials, structures, or means of egress and anyfire associated with the environment adjacent to the ESS installation will not adversely impact the system or its components.

4.14.5.1.4

Outdoor oil-insulated transformers shall be separated from adjacent structures and from each other by firewalls, spatialseparation, or other approved means for the purpose of limiting the damage and potential spread of fire from a transformerfailure.


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4.14.5.1.5

Determination of the type of physical separation to be used between transformers, control equipment, and building structuresshall be based on a detailed analysis of the following:

(1) Type and quantity of oil in the transformer

(2) Size of a postulated oil spill (surface area and depth)

(3) Type of construction of adjacent structures

(4) Type and amount of exposed equipment, including high line structures, motor control center (MCC) equipment, breakers,other transformers, and so forth

(5) Power rating of the transformer

(6) Fire suppression systems provided

(7) Type of electrical protective relaying provided

(8) Availability of replacement transformers (long lead times)

(9)

4.14.5.1.6

Unless consideration of the factors in 4.14.5.1.5 indicates otherwise, any oil-insulated transformer containing 500 gal (1893 L)or more of oil shall be separated from adjacent structures by a 2-hour-rated firewall or by spatial separation in accordance withTable 4.14.5.1.6.

Table 4.14.5.1.6 Outdoor Oil-Insulated Transformer Separation Criteria

Transformer Oil Capacity Minimum (Line-of-Sight) Separation Without Firewall

gal L ft m

<500 <1893 See 4.14.5.1.5

500–5000 1893–18,925 25 7.6

>5000 >18,925 50 15

4.14.5.1.7

Where a firewall is provided between structures and a transformer, it shall extend vertically and horizontally as indicated inFigure 4.14.5.1.7.

Figure 4.14.5.1.7 Illustration of Oil-Insulated Transformer Separation Requirements.

4.14.5.1.8

Unless consideration of the factors in 4.14.5.1.5 indicates otherwise, it is recommended that adjacent oil-insulated transformerscontaining 500 gal (1893 L) or more of oil be separated from each other by a 2-hour-rated firewall or by spatial separation inaccordance with Table 4.14.5.1.6.

* The existence of fast depressurization systems


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4.14.5.1.9

When the oil containment, as shown in Figure 4.14.5.1.9, consists of a large, flat concrete containment area that holds severaltransformers and other equipment in it without the typical pit containment areas, specific containment features to keep the oil inone transformer from migrating to any other transformer or equipment shall be provided. Where a firewall is provided betweentransformers, it shall extend at least 1 ft (0.31 m) above the top of the transformer casing and oil conservator tank and at least 2ft (0.61 m) beyond the width of the transformer and cooling radiators, or to the edge of the containment area, whichever isgreater.

Figure 4.14.5.1.9 Outdoor Oil-Insulated Transformer Separation Criteria.

4.14.5.1.10

Where a firewall is provided, it shall be designed to withstand the effects of projectiles from exploding transformer bushings orlightning arresters.

4.14.5.1.11

For transformers with less than 500 gal (1893 L) of oil and where a firewall is not provided, the edge of the postulated oil spill(i.e., containment basin, if provided) shall be separated by a minimum of 5 ft (1.5 m) from the exposed structure to preventdirect flame impingement on the structure.

4.14.5.1.12

Outdoor transformers insulated with a less flammable liquid shall be separated from each other and from adjacent structuresthat are critical to power generation by firewalls or spatial separation based on consideration of the factors in 4.14.5.1.5 and4.14.5.1.10.

4.14.5.2

Fire department access roads shall be provided to outdoor ESS installations in accordance with the local fire code.

4.14.5.3

The system shall not be located inside or in a manner where it could be affected by potentially hazardous atmospheres asdefined in NFPA 70 or IEEE C2 unless listed and approved for the specific installation.

4.14. 6 Size and Separation.

ESS located more than 100 ft (30.5 m) from the exposures in 4.14.5.1 shall not be required to comply with the size andseparation requirements in 4.14.5 .

4.14. 7 Exposures .

4.14.7.1

Areas within 10 ft (3.048 m) on each side of an outdoor ESS or components of an ESS shall be cleared of combustiblevegetation and other combustible growth. Single species of trees, shrubs, or cultivated ground cover such as green grass, ivy,succulents, or similar plants used as ground covers shall be permitted to be exempt provided that they do not form a means ofreadily transmitting fire.

4.14.7. 2

Exhaust outlets from an ESS that exhaust other than ventilation air shall be located at least 15 ft (4.572 m) from heating,ventilating, and air conditioning (HVAC) air intakes, windows, doors, loading docks, ignition sources, and other openings intobuildings and facilities.

4.14.7.3

Exhaust outlet(s) from an ESS shall not be directed onto means of egress, walkways, or pedestrian or vehicular travel paths.

4.14. 7.4

Security barriers, fences, landscaping, and other enclosures shall not inhibit the required air flow to or exhaust from the ESSand its components.

4.14. 8 Rooftop Installations .

4.14.8.1

ESS and their equipment, components, and controls that are located on rooftops and not enclosed by building constructionshall be installed in accordance with 4.14.1 through 4.14.7 and this section.

4.14.8.2



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4.14.8.3

Stairway access to the roof for emergency response and fire department personnel shall be provided either through the interiorof the building or on the exterior of the building.

4.14.8.4

Service walkways at least 3.1 ft (915 mm) in width shall be provided for service and emergency personnel from the point ofaccess to the roof to and around the system.

4.14.8. 5


4.14.8.6


4.14.8.7


4.14.8.8

When ESS are installed upon the roof of a building equipped with fire protection standpipes, the standpipes shall be extendedto the roof level of the building.


If the committee chooses to approve the Locations requirements proposed for Section 4.4 that cover outdoor and rooftop locations the entire Section 4.14 is not needed and can be deleted. However there are a few items not deleted in this section that weren't in that proposal, and these are not shown as being deleted so the committee can compare the differences. Among these are protection of oil filled transformers, which appear to have been included in the draft for reference. Suggest this entire section be deleted, and anything worth retaining be moved to Section 4.4.




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4.14.1 General.

ESS located outdoors or in stand-alone Normally-unoccupied ESS structures shall be installed in accordance with thisstandard and the manufacturer’s installation instructions, including spacing between adjacent ESS.


Normally-unoccupied Utility-scale (> 1MWh) Stand-Alone Installations may be located in outdoor enclosures or stand-alone energy storage buildings. As mentioned previously, such installations are fundamentally different from those installed inside occupied buildings.




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4.14.1 General.

ESS located outdoors shall be installed in accordance with this standard and the manufacturer’s installation instructions,including spacing between adjacent ESS .Installations in non-combustible outdoor enclosures or containers which areoccupied only occasionally by personnal familiar with the ESS for servicing, testing, mainteneance and other functions shall notbe subject to size and separation requirements of this standard .


Outdoor ESS are secured facilities in incombustible structures separated by fire walls and distance from the buildings they serve. Limiting their size to 250 kWh arrays with 3 ft separation, further subject to a 600 kWh MAQ is oppressive for an outside installation. At the very least, there should be an exception for ESS that are maintainable without full body entry into the structure.





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4.14.2.1 Size and Separation for Outdoor Containerized ESS.

Stationary battery arrays installed in noncombustible containers shall be allowed to be installed with no separation betweenarrays or container walls.


The problem with this section is that there is no allowance for normally unoccupied service equipment support areas such as those inside outdoor ESS containers or enclosures without the 3 ft separations between arrays or walls, which are the standard installed designs in the industry today.




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Occupiable ESS containers or enclosures shall be considered buildings and shall comply with this standard and local buildingcode requirements. Large equipment with service access panels or doors where operation is not permitted during operationshall not be considered Occupiable.


Large equipment such as transformers and the ESS I am designing have access doors for wiring and maintenance, however it is not permitted to operate the equipment when these doors (or panels) are open due to internal personnel hazards. On large systems the internal spaces may be substantial enough for qualified and trained personnel to enter yet it is completely impractical to consider these spaces as occupiable and they should not have to comply with regular building codes. As an example, all air cooled large transformers require personnel to crawl inside to make connections or inspections while de-energized and the same would be the case for densely packed ESS containers that I work with. Access panels and doors are usually interlocked and any attempt to enter, whether authorized or not, will cause immediate system shutdown. Thus, while such items are enterable, they should not be considered occupiable.


Submitter Full Name: Peter Gottlieb

Organization: Vionx Energy Corp

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Occupiable ESS containers or enclosures (occupied for reasons other than service and maintenance) shall be consideredbuildings and shall comply with this standard and local building code requirements.


The definition of occupiable ESS should be clearly stated in the main body of the standard and not in the Annex.




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Occupiable ESS containers or enclosures used as occupied work centers shall be considered buildings and shall comply withthis standard and local building code requirements.


This is to distinguish buildings and enclosures that are used as occupied work centers.




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This definition of “occupiable ESS” as buildings, and it’s inclusion in the section for “outdoor installation” section of the code, is confusing. It will result an unreasonable burden if we are trying to work with AHJ’s to permit large energy storage projects and assure that they are safe.We are looking to a future where electrochemical energy installations commonly reach the 10’s and 100’s of MWh in scale. These large systems are fundamentally outdoor projects, but may often include some very basic enclosures to protect against the elements (precipitation, wind, etc), and to provide access control to the equipment. The language in 4.14.2, and the clarification of that language in A.4.14.2, define all such “enclosures” as “buildings”. (The appendix language is so broad that AHJ’s could interpret a cabinet as being a building.) If these enclosures are “buildings”, then it becomes unclear whether they would be considered outdoor installations at all. This could trigger many of the other preceding requirements that use various language to describe ESS installations, including:• “indoor” installations where size is limited to 250kWh (4.6.2)• “fire areas within buildings” where exceeding a maximum rated energy of 600kWh triggers high hazard requirements in the life safety code (4.5)• ESS in “rooms or spaces” in “other than high hazard occupancies” where strict fire wall separation must be observed (4.4.3.1)• Installations located in “fire areas … within buildings or structures” where smoke detection is required (4.7.1)• Installations “located within buildings or structures” where automatic fire suppression is required (4.8)Particularly objectionable is the size limitation in 4.6.2, which is not a reasonable increment for projects that are 10’s or 100’s of MWh. Fire walls between enclosures and automated suppression systems will add substantial cost to a system, and may not appreciably improve the safety profile of the system. UL 9540 appropriately handles this nuance by requiring a fire risk assessment, preferably according to NFPA 551 and NFPA 550, to determine suitable detection and suppression for a system.







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4.14.2 * Occupiable ESS.


Comment - It is not reasonable to consdier all occupiable containers as a building.


Considering a container as a building code might be too strict.


Submitter Full Name: Md Arifujjaman

Organization: Southern California Edison

Affilliation: Southern California Edison

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4.14.3* Security.

ESS located outdoors shall be secured in an approved manner against unauthorized physical access.


Remove language on "in an approved manner" unless adequately defined elsewhere in this standard.




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4.14.3* Security.

ESS located outdoors shall be secured in an approved manner against unauthorized physical access only accessable byauthorized persons .


More specific wording for who has access.




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4.14.4 Enclosures.

ESS electrical circuitry shall be within weatherproof enclosures marked with the environmental rating suitable for the type ofexposure required by NFPA 70 .


Electrical requirements for ESS are already covered in NFPA 70 Article 706. Repeating them in 855 at best just duplicate text and at worst could create conflicts.




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4.14.5. 1 1 If the ESS system is certified and listed to UL 9540, the siting, separation and protection shall be per themanufacturer's recommendation and per UL 9540 listing recommendations, whichever is more stringent.

4.14.5.1 Separation.

ESS located outdoors shall be separated by a minimum 10 ft (3 m) from the following:

(1) Lot lines

(2) Public ways

(3) Buildings

(4) Stored combustible materials

(5) Hazardous materials

(6) High-piled stock

(7) Other exposure hazards

(8) Means of egress from buildings or structures

4.14.5.1.1

A 1-hour free standing fire barrier extending 5 ft (1.5 m) above and extending 5 ft (1.5 m) beyond the physical boundary of thecomplete ESS installation that is suitable for exterior use shall be used to reduce the distance in 4.14.5.1 to 3 ft (914 mm).

4.14.5.1.2

The distance to buildings is permitted to be reduced to 3 ft (914.4 mm) where noncombustible exterior walls with no openingsor combustible overhangs meet the fire resistance ratings in Table 4.4.3.1.

4.14.5.1.3

The AHJ is authorized to approve a reduction in required separation distances when large-scale fire and fault condition testingconducted or witnessed and reported by an approved testing laboratory is provided showing that a fire involving any componentof the ESS will not adversely impact adjacent buildings, stored materials, structures, or means of egress and any fireassociated with the environment adjacent to the ESS installation will not adversely impact the system or its components.

4.14.5.1.4

Outdoor oil-insulated transformers shall be separated from adjacent structures and from each other by firewalls, spatialseparation, or other approved means for the purpose of limiting the damage and potential spread of fire from a transformerfailure.

4.14.5.1.5










(9)* The existence of fast depressurization systems


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4.14.5.1.6




gal L ft m

<500 <1893 See 4.14.5.1.5

500–5000 1893–18,925 25 7.6

>5000 >18,925 50 15

4.14.5.1.7

Where a firewall is provided between structures and a transformer, it shall extend vertically and horizontally as indicated inFigure 4.14.5.1.7.

Figure 4.14.5.1.7 Illustration of Oil-Insulated Transformer Separation Requirements.

4.14.5.1.8

Unless consideration of the factors in 4.14.5.1.5 indicates otherwise, it is recommended that adjacent oil-insulated transformerscontaining 500 gal (1893 L) or more of oil be separated from each other by a 2-hour-rated firewall or by spatial separation inaccordance with Table 4.14.5.1.6.

4.14.5.1.9

When the oil containment, as shown in Figure 4.14.5.1.9, consists of a large, flat concrete containment area that holds severaltransformers and other equipment in it without the typical pit containment areas, specific containment features to keep the oil inone transformer from migrating to any other transformer or equipment shall be provided. Where a firewall is provided betweentransformers, it shall extend at least 1 ft (0.31 m) above the top of the transformer casing and oil conservator tank and at least 2ft (0.61 m) beyond the width of the transformer and cooling radiators, or to the edge of the containment area, whichever isgreater.

Figure 4.14.5.1.9 Outdoor Oil-Insulated Transformer Separation Criteria.

4.14.5.1.10

Where a firewall is provided, it shall be designed to withstand the effects of projectiles from exploding transformer bushings orlightning arresters.

4.14.5.1.11

For transformers with less than 500 gal (1893 L) of oil and where a firewall is not provided, the edge of the postulated oil spill(i.e., containment basin, if provided) shall be separated by a minimum of 5 ft (1.5 m) from the exposed structure to preventdirect flame impingement on the structure.


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4.14.5.1.12

Outdoor transformers insulated with a less flammable liquid shall be separated from each other and from adjacent structuresthat are critical to power generation by firewalls or spatial separation based on consideration of the factors in 4.14.5.1.5 and4.14.5.1.10.


If the equipment is tested and listed per UL 9540, then safety considerations will have been considered with regards to distance, siting, etc and adherence to National Electrical Code which brings this requirement for equipment separation. UL9540 brings requirements for utilization of transformer.



Organization: Nema

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Public Input No. 488-NFPA 855-2017 [ New Section after 4.14.5.1.1 ]

4.14.5.1.1

If the ESS system is certified and listed to UL9540, the siting, separation and protection shall be per the manufacturer'srecommendation and per UL9540 listing recommendations, whichever is more stringent.


If the equipment is tested and listed per UL9540, then safety considerations will have been considered with regards to distance, siting, and adherence to National Electrical Code which brings requirements for equipment separation. For clarity, UL9540 brings requirements for utilization of transformer.




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4.14.5.1.1

A 1-hour free standing fire barrier extending 5 ft (1.5 m) above and extending 5 ft (1.5 m) beyond the physical boundary of thecomplete ESS installation that is suitable for exterior use, or having an enclosure fire barrier rating of at least 2 hours, shall beused to reduce the distance in 4.14.5.1 to 3 ft (914 mm).


A 2-hour fire barrier enclosure wall (which is used in Section 4.4.3.1 on Separations) should suffice to reduce separations to 3 feet.




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4.14.5.1.1

A 1-hour free standing fire barrier extending 5 extending 3 ft (1.5 m 914 mm ) above and extending 5 extending 3 ft (1.5m 914 mm ) beyond the physical boundary of the complete ESS installation that is suitable for exterior use shall be used toreduce the distance in 4.14.5.1 to 3 ft (914 mm).


5ft barrier with still 3ft clearance requires 8 ft total clearance which I think is too high for behind the meter ESS installations. Hence, suggesting to change it to 3ft.



Organization: Eaton

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4.14.5.1.1

A 1-hour free standing fire barrier extending 5 ft (1.5 m) above and extending 5 ft (1.5 m) beyond the physical boundary of thecomplete ESS installation that is suitable for exterior use shall be permitted to be used to reduce the distance in 4.14.5.1 to 3 ft(914 mm).


As drafted the provision reads as a mandatory requirement - meaning all installations must be provided with the barrier and the clearance distance reduced. The revision clarifies that this is an option if one desires a reduced clearance.




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Public Input No. 84-NFPA 855-2017 [ Sections 4.14.5.1.1, 4.14.5.1.2, 4.14.5.1.3 ]

Sections 4.14.5.1.1, 4.14.5.1.2, 4.14.5.1.3

Exception: 1. The distance in 4.14.5.1 .1

A 1

may be reduced to 3 ft (914 mm) where a 1 -hour free standing fire barrier

extending

suitable for exterior use extends 5 ft (1.5 m) above and

extending 5 ft (1.5 m)

beyond the physical boundary of the complete ESS installation

that is suitable for exterior use shall be used to reduce the distance in 4

.

14.5.1 to 3 ft (914 mm).

4.14.5.1.2

2. The distance to buildings

is permitted to

msy be reduced to 3 ft (914.4 mm) where noncombustible exterior walls with no openings or combustible overhangs meet thefire resistance ratings in Table 4.4.3.1 .

4.14.5.1.3

The AHJ is authorized to approve a reduction in required separation distances when

3. When large-scale fire and fault condition testing is conducted or witnessed and reported by an approvedtesting laboratory

is provided showing

which demonstrates that a fire involving any component of the ESS will not adversely impact adjacent buildings, storedmaterials, structures, or means of egress and any fire associated with the environment adjacent to the ESS installation will notadversely impact the system or its components , the distance in 4 . 14.5.1.1 may be reducted consistent with said testing.


Rewrites these three provisions as exceptions.





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4.14.5.1.5










(9)


Detail analysis criteria is needed otherwise it is wise to remove.





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* The existence of fast depressurization systems

Comment - Unless specific critria are proposed, this requirement is not specific enough and should be removed. This type ofdesign decisions should be left up to manufacturer and rquirement of the customer.


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4.14.5.1.6




gal L ft m

<500 <1893 See 4.14.5.1.5

and 4.14.5.1.11

500–5000 1893–18,925 25 7.6

>5000 >18,925 50 15


The addition reference helps to clarifies the minimum requirement of 5 ft. Have seen this clarification missed and thought it would be helpful to add to the table.


Submitter Full Name: Scot Pruett

Organization: Black Veatch Corporation

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4.14.5.1.12

Outdoor transformers insulated with a less flammable liquid than oil-insulated transformers shall be separated from each otherand from adjacent structures that are critical to power generation by firewalls or spatial separation based on consideration ofthe factors in 4.14.5.1.5 and 4.14.5.1.10.


The criterion 'less flammable' requires a metric upon which to determine if flammability is less. The proposed revision provides that basis of comparison as 'less than an oil-insulated' transformer.




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4.14.6 Size and Separation.

ESS located more than 100 50 ft (30 15 .5 24 m) from the exposures in 4.14.5.1 shall not be required to comply with the sizeand separation requirements in 4.14.5 . this Chapter.


This distance was reduced based on the outdoor location.




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ESS Outdoor and Stand-alone ESS equipped with fire detection and suppression in accordance with sections 4.7 and 4.8 andlocated more than 100 20 ft (30 6 .5 1 m) from the exposures in 4.14.5.1 shall not be required to comply with the size andseparation requirements in 4.6. Smaller setbacks shall be allowed with the use of fire-rated barriers pursuant to section4. 14.5. 1.1, or with AHJ approval.


AES feels that this arbitrary 100’ requirement is much too large and, provided that systems are equipped with fire suppression and enclosed in non-combustible buildings or enclosures, a smaller setback will be sufficient to protect nearby exposures in the event of a fire. It should be possible to further reduce this setback with the use of fire-rated barriers as in 4.14.5.1.1.




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ESS located more than 100 50 ft (30.5 m) from the exposures in 4.14.5.1 shall not be required to comply with the size andseparation requirements in 4.14.5 . this Chapter.


This proposal would reduce the distance from various items from 100 ft to 50 ft. Compliance with this section would simply allow the installation of ESS without limitation to size and separation. this is reasonable given that the installation is outdoors in a non-combustible structure.





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4.14.7.1

Areas within 10 ft (3.048 m) on each side of an outdoor ESS or components of an ESS shall be cleared of combustiblevegetation and other combustible growth. Single species of trees, shrubs, or cultivated ground cover such as green grass, ivy,succulents, or similar plants used as ground covers shall be permitted to be exempt provided that they do not form a means ofreadily transmitting fire.

Comment - 10FT is extreme, while 3FT is more reasonable for non-vented enclosures. Vented enclosures may require moreclerance.


More area will be required that might be not necessary.





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4.14.7.3

Exhaust outlet(s) that exhaust other than ventilation air from an ESS ESS shall not be directed onto means of egress,walkways, or pedestrian or vehicular travel paths.


For avoidance of doubt, refer to previous definition of exhaust as "other than ventilation air", in other words, air being used for thermal management of the ESS.




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4.14.7.3

Exhaust outlet(s) from an ESS shall not be directed onto means of egress, walkways, or pedestrian or vehicular travelpaths.The separation distances from egress for the exhaust outlets shall follow the local mechanical code


Locally adopted mechanical codes dictate the minimum required separation distances from exhaust terminations to operable openings, means of egress, adjacent occupancies, etc.




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4.14.8.1


4.14.8.2


4.14.8.3


4.14.8.4


4.14.8.5


4.14.8.6


4.14.8.7


4.14.8.8



This section was eliminated because it was previously addressed in Section 4.4.4.2.



Submitter FullName:

Carl Wren



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4.

14.8 Rooftop Installations.

4.

14.8.1


4.14.8.2


4.14.8.3

Stairway access to the roof for emergency response and fire department personnel shall be provided either through theinterior of the building or on the exterior of the building.

4.14.8.4


4.14.8.5


4.14.8.6


4.14.8.7


4.14.8.8

4.X



It appears that sections 4.14.8 and 4.4.4 are identical, except that the last subsection in 4.14.8 does not appear to be included in the former section. To eliminate duplication it is suggested that section 4.4.4 cover all the provisions associated with rooftop installations and then the last subsection in 4.14.8 dealing with standpipes be moved into 4.4.4 as a new subsection.




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4.14.8.3



Are we not expecting firefighters to have ladder trucks anymore? This needs to be deleted or modified to require stair access only for buildings too high for a ladder truck and maybe have it apply only to larger ESS. Most single and two story building will not have stair access to the roof and requiring that it be added to install an ESS system will basically prevent any installations.




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4.14.8.7

The roofing materials under and within 12 36 in. (305 mm 914mm ) horizontally from an ESS or associated equipment orcomponent shall be noncombustible or shall have a Class A rating when tested in accordance with ASTM E108 or UL 790.Thesupports for the ESS shall be fire rated to 1 or 2 hours.


Roof materials under and within 36 inches (3 feet) shall be protected from fire. Often times, heat and molten equipment generated from a fire will not only fall perfectly vertically downwards, but in an outwards umbrella fashion. This horizontal projection will ensure that these components are not affected from a fire.

Roof-top equipment is often mounted on beams spanning load bearing walls in order to adequately distribute the equipment load. These beams can be structurally compromised during a fire due to their proximity to the equipment that they support and shall be adequately protected from fire in order to prevent equipment from falling onto or through the roof. A 1 hr. rating may suffice for small cabinets while a 2 hr. rating will be a more appropriate rating for larger installations




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4.15.1*

An approved hazard mitigation analysis shall be provided to the AHJ when any of the following conditions are present:

(1) Battery technologies as covered in Section 5.8 are (incorrect reference?) are provided.

(2) More than one ESS technology is provided in a room or indoor area where there is a potential for adverse interactionbetween technologies.

(3) When allowed as a basis for increasing maximum allowable quantities as specified in 4.6.1.


Section 5.8 does not list any battery technologies. This reference should point to something else in 855, but I can’t tell what it should be.




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Submittal Date: Thu Aug 24 23:15:48 EDT 2017


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4.15.1*

An approved A hazard mitigation analysis shall be provided to the AHJ when any of the following conditions are present:

(1) Battery technologies as covered in Section 5.8 are provided.

(2) More than one ESS technology is provided in a room or indoor area where there is a potential for adverse interactionbetween technologies .



The hazard mitigation analysis needs to be reviewed by the AHJ before it is approved. Simplified text for #2 since the hazard mitigation analysis will evaluate the potential between two or more technologies.




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4.15.1*



(2) More than one ESS technology is provided in a room or indoor area where there is a potential for adverse interactionbetween technologies. Lead-acid and Nickel-cadmium ESS can be mixed without restrictions.



Lead-acid and nickel-cadmium ESS have been mixed in the past with no adverse affects. No reason to restrict them in this standard.




Affilliation: ATIS

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4.15.1 *





(4) When a hzard mitigation analysis is required as covered in Section 1.5.1.


Section 1.5.1 provides an initial basis for requiring an HMA and Section 4.15 provides the details associated with any HMA conducted as a basis for documenting compliance with the standard. It seems appropriate to connect these two sections and since Section 1.5.1 allows for an HMA making that a 4th condition in this section.




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4.15.1*

An approved hazard mitigation analysis shall be provided to the AHJ A Hazard Mitigation Analysis is required when any of thefollowing conditions are present:





Capitalize a defined term.

The HMA cannot be "approved" when submitted, only after AHJ review.





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The analysis shall evaluate the consequences of the following failure modes and others deemed necessary by the AHJ:

(1) Thermal runaway condition in a single module or array of lead-acid VRLA or lithium-ion ESS

(2) Failure of an energy storage management system

(3) Failure of a required ventilation or exhaust system

(4) Voltage surges on the primary electric supply

(5) Short circuits on the load side of the ESS

(6) Failure of a required smoke detection, fire detection, fire suppression, or gas detection system


For ease of use, we should stipulate when thermal run away is needed if we can anticipate this. This would be helpful and prevent less knowledgeable users from requesting thermal runaway control when it is not needed, such as for flooded lead-acid batteries.




Affilliation: ATIS

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The analysis shall evaluate the consequences of the following failure modes and others deemed necessary by the AHJ:

(1) Thermal runaway condition in a single module or array

(2) Failure of an energy storage management system

(3) Failure of a required ventilation or exhaust system

(4) Voltage surges on the primary electric supply

(5) Short circuits on the load side of the ESS

(6) Failure of a required smoke detection, fire detection, fire suppression, or gas detection system

(7) Loss of primary containment when the ESS employs liquid electrolytes

?PRIMARY CONTAINMENT. The inside portion of a container which comes into immediate contact on its inner surface with thematerial being contained.


Liquid electrolytes that are not immobilized or may separate upon fire exposure could produce a hazardous materials spill if the primary containment is lost. This can impact those who are in the immediate of the fire and can complicate the emergency response. If the spill involves an electrolyte that is a hydrocarbon, the size of the liquid pool could exceed the design of the automatic sprinkler or fire suppression system. Therefore, the integrity of the primary containment for the electrolyte (when employed) should be part of the hazard assessment.

A new definition for Primary Containment is proposed to help users understand the intent of this requirement.





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4.15.2.1

Only single failure modes consequences shall be considered for each mode given in 4.15.2.


The change was made to this section to clarify that a single consequence shall be considered, not a single mode.



Submitter FullName:

Carl Wren



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4.15.3

The AHJ shall be permitted to approve the hazardous mitigation analysis as documentation of the safety of the ESS installationprovided the consequences of the analysis demonstrate the following:

(1) Fires or explosions will be contained within unoccupied ESS rooms for the minimum duration of the fire resistance ratingspecified in 4.5 4 .2 3 . 1 .

(2) Fires and explosions in ESS cabinets in occupied work centers allow occupants to safely evacuate.

(3) Toxic and highly toxic gases released during normal charging, discharging, and operation will not exceed the PEL in thearea where the ESS is contained.

(4) Toxic and highly toxic gases released during fires and other fault conditions will not reach concentrations in excess ofimmediately dangerous to life or health (IDLH) level in the building or adjacent means of egress routes during the timedeemed necessary to evacuate from that area.

(5) Flammable gases released during charging, discharging, and normal operation will not exceed 25 percent of the LFL.


Possible incorrect section reference




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4.15.3

The AHJ shall be permitted to approve the hazardous mitigation analysis as documentation of the safety of the ESS installationprovided the consequences of the analysis A Hazardous Mitigation Analysis shall demonstrate the following:

(1) Fires or explosions will be contained within unoccupied ESS rooms for the minimum duration of the fire resistance ratingspecified in 4.5.2.

(2) Fires and explosions in ESS cabinets in occupied work centers will allow occupants to safely evacuate.

(3) Toxic and highly toxic gases released during normal charging, discharging, and operation will not exceed the PEL in thearea where the ESS is contained.

(4) Toxic and highly toxic gases released during fires and other fault conditions will not reach concentrations in excess ofimmediately dangerous to life or health (IDLH) level in the building or adjacent means of egress routes during the timedeemed necessary to evacuate from that area.

(5) Flammable gases released during charging, discharging, and normal operation will not exceed 25 percent of the LFL.


editorial - makes section easier to read without losing any substantive impact.





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4.15.4 *

The hazard mitigation analysis shall be prepared by a registered design professional.


Industry experts, manufacturers, and systems integrators have information, knowledge, and experience that can be used to prepare the analysis. Being a registered design professional does not necessarily mean ESS expertise.




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4.15.4 *

The hazard mitigation analysis shall be prepared by or approved by a registered design professional.


The design professional should only have to approve. Does not matter if they write it if they put their stamp of approval on it. Second, there is no definition of what type of design professional. Professional of what? and certified like a PE?




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4.15.4*

The hazard mitigation analysis shall be prepared by a registered design professional engineer .


See related PI, my PI on the Registered Design Professional, should be Professional Engineer. There might be other references to "Registered Design Professional" I did not catch with a PI but they should all be changed.







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4.15.4 *

The hazard mitigation analysis shall be prepared by a registered design professional.


PE's are certainly qualified to perform a HMA, but so or others like the manufacturer of a Pre-engineered system. Striking this section does not remove any substantive provision but instead provides market flexibility.





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4.15.5

The hazard mitigation analysis shall be documented and made available to the AHJ and those authorized to design, construct,install, inspect, maintain, and operate the system.


For consistency with the scope of the standard, which includes construction of the system.




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Sections 4.15.5, 4.15.6

4.15.5

The hazard mitigation analysis Hazard Mitigation Analysis shall be documented and made available to the AHJ and thoseauthorized to design, install, inspect, maintain, and operate the system.

4.15.6*

Construction, equipment, and systems that are required for the ESS to comply with the hazardous mitigation analysisHazardous Mitigation Analysis shall be installed, tested, and maintained in accordance with nationally recognized standardsand specified design parameters.


Defined terms are capitalized.





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4.15.6*

Construction, equipment, and systems that are required for the ESS to comply with the hazardous mitigation analysis shall beinstalled, tested, and maintained in accordance with nationally recognized standards and specified design parameters.


Modified so that there is not compliance with the hazard mitigation analysis (an analysis does not involve compliance).




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4.15.6 *

Construction, equipment, and systems that are required for the ESS to comply with the hazardous mitigation analysis shall beinstalled, tested, and maintained in accordance with nationally recognized standards and specified design parameters.


This section provides no guidance. It should be replaced by a similar provision that specifies known standards.





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4.16.1* General.

Emergency planning and training shall be provided by the owner of the ESS so ESS facility staff and emergency responderscan effectively address foreseeable hazards associated with the on-site systems.


Include more clarity on who is responsible for this section. The equipment owner should be responsible for training of emergency responders or arranging for the training of emergency responders.



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4.16.1 * General.

Emergency planning and training shall be provided so ESS provided by the owner of the ESS system, so ESS facility staff andemergency responders can effectively address foreseeable hazards associated with the on-site systems.


Include more clarity on who is responsible for this section. The equipment owner should be responsible for training of emergency responders or arranging for the training of emergency responders.




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4.16.2.1.1

An emergency operations plan shall be developed and be readily available at an approved on-site location for use by facilitystaff.


editorial





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4.16.2.1.3

The emergency operations plan shall include the following:

(1) Procedures for safe shutdown, de-energizing, or isolation of equipment and systems under emergency conditions toreduce the risk of fire, electric shock, and personal injuries, and for safe start-up following cessation of emergencyconditions.

(2) Procedures for inspection and testing of associated alarms, interlocks, and controls.

(3)

(4) Emergency procedures to be followed in case of fire, explosion, release of liquids or vapors, damage to critical movingparts, or other potentially dangerous conditions. Procedures can include sounding the alarm, notifying the fire department,evacuating personnel, de-energizing equipment, and controlling and extinguishing the fire.

(5) Response considerations similar to a safety data sheet (SDS) that will address response safety concerns andextinguishment when an SDS is not required.

(6) Procedures for dealing with ESS equipment damaged in a fire or other emergency event, including maintaining contactinformation for personnel qualified to safely remove damaged ESS equipment from the facility.

(7) Other procedures as determined necessary by the AHJ to provide for the safety of occupants and emergency responders.

(8) Procedures and schedules for conducting drills of these procedures.


Not all ESS have an ESMS. The standard should recognize this.




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* Procedures to be followed in response to notifications from the energy storage management system (ESMS), whenavailble, that could signify potentially dangerous conditions, including shutting down equipment, summoning service andrepair personnel, and providing agreed upon notification to fire department personnel for off-normal potentially hazardousconditions.


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4.16.2.2.1

Personnel responsible for the ESS operation, use, maintenance, repair, servicing, and response shall be trained in theprocedures included in the emergency operations plan in 4.11 16 .2.1.


Incorrect section reference.




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Public Input No. 78-NFPA 855-2017 [ New Section after 4.16.2.2.2 ]



4.17 Remediation measures.

4.17.1 In the event of a fire or other event has damaged the energy storage system and it is possible that ignition or re-ignitionof the energy storage system is possible, the owner , agent, or lessee shall immediately dispatch authorized service personnelto mitigate the hazard or remove damaged equipment from the premises to a safe location.

4.17.2 Fire mitigation personnel. When, in the opinion of the AHJ, it is essential for public safety that trained personnel be onsite to respond to possible ignition or re-ignition of damaged the energy storage systems, the owner , agent or lessee shallprovide one or more fire mitigation personnel, as required and approved , at their expense. These personnel shall remain onduty continuously after the fire department leaves the premise until the damaged energy storage equipment is removed fromthe premises, or the AHJ indicates they can leave.

4.17.3 Duties. On-duty fire mitigation personnel shall have the following responsibilities:

1. Keep diligent watch for fires, obstructions to means of egress and other hazards.

2. Immediately contact the fire department if their assistance is needed to mitigate any hazards.

3. Take prompt measures for remediation of hazards and extinguishment of fires that occur.

4. Take prompt measures to assist in the evacuation of the public from the structures.


These requirements are needed to help the fire service with remediation of a fire damaged ESS installation. The wording is based on requirements developed by the FCAC ESS work group.




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4.16.2.2.2

Refresher training shall be conducted at least annually and records of such training retained in an approved manner.


ESS systems, particularly small systems, should be viewed as an appliance with multiple parts assembled into a functioning unit. as such, annual training is excessive just as it would be for an air conditioner or a water heater. at the very least there should be an exception for smaller systems.





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4.17 Construction Documents and Manuals .

4.17.1 Construction Details Documents .

4.17.1.1

The plans and specifications associated with an ESS and its intended installation, replacement or renewal, commissioning, anduse shall be submitted to the AHJ AHJ for approval and shall include the following information .

4.17.1.2

The plans and specifications shall show all the pertinent data and features of the ESS and any buildings and facilitiesassociated with the system installation in sufficient detail to document compliance with the requirements of this standard andpermit a determination of compliance with this standard by the AHJ1. Location and layout diagram of the room or area in which the energy storage system is to be installed

2. Details on hourly fire-resistant rated assemblies provided or relied upon in relation to the energy storage system.

3. The quantities and types of energy storage system units.

4. Manufacturer's specifications, ratings and listings of energy storage systems

5. Description of battery management systems and their operation.

6. Location and content of required signage

7. Details on fire suppression, smoke or fire detection, thermal management, ventilation, exhaust and deflagration ventingsystems, if provided..

8. Support arrangement associated with the installation, including any required seismic support.

4.17.1.2

The construction documents described in this section shall be provided to the building owner or the owner’s authorized agentprior to the system being put in service .

4.17.2 Supplemental Information.

Supplemental information necessary to verify compliance with this standard shall include the following items and other relevantdata, as appropriate, to the type of ESS and its intended installation:

(1) Large-scale fire testing

(2) Reports associated with system or component testing or listing

(3) Failure modes and effects analyses

(4) Hazard mitigation analyses

(5) Calculations

(6) Worksheets

(7) Compliance forms

(8) Manufacturer literature


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4.17.3 Manuals.

OperatingAn operating and maintenance

information meeting the provisions of Chapter 14manual shall be provided to both the

buildingenergy system owner or their

designated agent and verification of its receipt by the building owner shall be provided to the AHJ.authorized agent and system operator before the system is put into operation and shall include the following:

1. Submittal data stating the energy storage system size and selected options for each component of the system.

2. Manufacturer’s operation manuals and maintenance manuals for the entire energy storage system or for eachcomponent of the system requiring maintenance that clearly identify the required routine maintenance actions.

3. Name and address of a contracted service agency.

4. Maintenance and calibration information, including wiring diagrams, control drawings, schematics, system programminginstructions and control sequence descriptions, for all energy storage control systems.

5. Desired or field-determined control set points that are permanently recorded on control drawings at control devices or,for digital control systems, in system programming instructions.

6. A schedule for inspecting and recalibrating all energy storage system controls.

7. A narrative of how the energy storage system and its components and controls are intended to operate, includingrecommended operational set points.

8. A service record log form that lists the schedule for all required servicing and maintenance actions and space forlogging such actions that can be completed over time and retained on site.

4.17.3.1 The operations and maintenance manual shall be prepared prior to final approval of the energy storage system andshall be retained at an onsite location where readily accessible to personnel responsible for the energy storage system. . Acopy shall be placed in an approved location to be accessible to AHJs and emergency responders.

4.17.4 Commissioning Plan.

A commissioning plan meeting the provisions of Chapter 13 6 shall be provided to the building owner or their designatedagent and a copy of the commissioning plan shall be provided to the AHJ.

4.17.5 Labeling.

ESS shall be labeled in a manner that will allow for a determination of their compliance with the applicable provisions of thisstandard.


This proposal fixes an incorrect reference to Chapter 6. It also documentation concepts developed by the FCAC ESS working group for consideration by the NFPA 855 committee.




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4.17.2 Supplemental Information.

Supplemental information necessary to verify compliance with this standard shall include the following items and other relevantdata, as appropriate, to the type of ESS and its intended installation:

(1) Large-scale fire testing

(2) Reports associated with system or component testing or listing

(3) Failure modes and effects analyses

(4) Hazard mitigation analyses

(5) Calculations

(6) Worksheets

(7) Compliance forms

(8) Manufacturer literature


Failure Modes and Effects Analysis reports usually contain detailed, proprietary information. The Hazard Mitigation Analysis will contain sufficient information.




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4.17.3 Manuals.

Operating and maintenance information meeting the provisions of Chapter 14 shall 7 shall be provided to the building owneror their designated agent and verification of its receipt by the building owner shall be provided to the AHJ.


Operations and maintenance are covered in Chapter 7.




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4.17.3 Manuals.

Operating and maintenance information meeting the provisions of Chapter 14 Chapter 7 shall be provided to the buildingowner or their designated agent and verification of its receipt by the building owner shall be provided to the AHJ.


Chapter 7 covers O&M.




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A commissioning plan meeting the provisions of Chapter 13 shall 6 shall be provided to the building owner or their designatedagent and a copy of the commissioning plan shall be provided to the AHJ.


Commissioning is now covered in Chapter 6 rather than Chapter 13.




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A commissioning plan meeting the provisions of Chapter 13 7 shall be provided to the building owner or their designatedagent and a copy of the commissioning plan shall be provided to the AHJ.


Chapter 7 covers commissioning.




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4.17.5 Labeling.

ESS shall be labeled in a manner that will allow for a determination of their compliance with the applicable provisions of thisstandard.


It is not clear how a field assembled ESS would be labeled for compliance with the standard. Who will label it? The AHJ? In telecom applications, the rectifier may be from one supplier, the batteries from another, the wire from another, the stand or rack from another. Does each party label their own piece? This would only work if the approving AHJ signs off an labels the entire installation. I propose we remove this or clarify it.




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Public Input No. 593-NFPA 855-2017 [ Chapter 5 ]

Chapter 5 System Interconnections

5.1 General.

An ESS being installed in compliance with the NFPA 70 shall comply with the applicable general installation requirementarticles, as well as any other applicable articles, such as 695 Fire Pumps, 700 Emergency Systems, 701 Legally RequiredStandby Systems, 705 Interconnected Electric Power Production Sources, 706 Energy Storage Systems, 708 CriticalOperations Power Systems (COPS), 710 Stand-Alone Systems, 712 Direct Current Microgrids, and 750 Energy ManagementSystems.

5.2 Electrical Interconnections.

5.2.1

All electrical connections and wiring to and from a self-contained prepackaged ESS or the components of a pre-engineeredESS shall be in accordance with NFPA 70 or IEEE C2 based on the location of the ESS in relation to and its interaction with theelectrical grid.

5.2.2

All electrical connections and wiring to, from, and within engineered and field-constructed ESS shall be in accordance withNFPA 70 or IEEE C2 based on the location of the ESS in relation to and its interaction with the electrical grid.

5.3 Disconnecting Means.

5.3.1

A readily accessible disconnecting means for the ESS shall be provided within sight of the ESS in accordance with NFPA 70,706.7, including field marking the disconnecting means with information for determining the arc-rated PPE.

5.3.2

Where controls to activate the disconnecting means are not located within sight of the system, the disconnecting means shallbe capable of being locked in the open position and the location of the controls shall be field marked on the disconnectingmeans.

5.4 Nonelectrical Systems.

5.4.1 Natural Gas.

Piping, valves, and fittings from the outlet of the supplier’s piping to the outlet of the ESS system’s shutoff valve shall be inaccordance with NFPA 54.

5.4.2 Compressed Natural Gas (CNG).

The design, location, and installation of piping, valves, and fittings from the outlet of the point of delivery from the supplier to theinlets of the equipment shutoff valves shall be in accordance with NFPA 52.

5.4.3 Liquefied Petroleum Gas (LP-Gas) Systems and Storage.

The design, location, and installation of liquefied petroleum gas (LP-Gas) storage and piping systems shall comply with NFPA58.

5.4.4 Hydrogen Fuel Systems and Storage.

The design, location, and installation of hydrogen gas and liquid hydrogen storage and piping systems shall comply with NFPA2.

5.4.5 Biogas.

Storage tanks and their associated equipment, piping, valves, and regulators shall be designed and installed in accordancewith NFPA 54.

5.4.6 Liquid Fuels.

The design of liquid fuel piping systems and the location and storage of liquid fuels shall be in accordance with NFPA 30.

5.4.7

Where the ESS requires water to operate, it shall be provided through a connection to an on-site water supply in accordancewith ICC IPC (International Plumbing Code), IAPMO UPC (Uniform Plumbing Code), or local regulations, or through a self-contained water source.

5.5 Communication Systems.

Engineered and field-constructed ESS shall have appropriate communication interconnections between the ESS componentsand site located systems, which will allow for safe operation of the system.

5.6 Notification.

Notifications shall be present per the requirements of NFPA 70, 706.7(D).


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5.7 Mechanical Systems.

5.7.1

All connections to and from a self-contained prepackaged ESS or the components of a pre-engineered ESS to requiredplumbing, fire alarm, detection, or control circuits or to mechanical systems shall be in accordance with nationally recognizedstandards applicable to those systems, listed equipment instructions, and the applicable provisions of Chapter 5 and Chapter 6.

5.7.2

All connections to, from, and within engineered and field-constructed ESS to required plumbing, fire alarm, detection, or controlcircuits or to mechanical systems shall be in accordance with the listed equipment instructions and applicable provisions ofChapter 5 and Chapter 6.

5.8 Emergency and Standby Systems.

All energy storage–based emergency and standby systems shall comply with NFPA 111.

Comment - Isn't section 5 already in NEC?


Duplication may be from NEC.





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5.1 General.

An ESS being installed in compliance with the NFPA 70 shall comply with the applicable general installation requirementarticles, as well as any other applicable articles, such as 695 Fire Pumps, 700 Emergency Systems, 701 Legally RequiredStandby Systems, 705 Interconnected Electric Power Production Sources, 706 Energy Storage Systems, 708 CriticalOperations Power Systems (COPS), 710 Stand-Alone Systems, 712 Direct Current Microgrids, and 750 Energy ManagementSystems.

Installations of communications equipment under the exclusive control of utilities located outdoors or in buildings used

exclusively for such installations are outside the scope of NFPA 70 and are not addressed in this section.


Wording from NEC is added to clarify that the NEC does not address telecommunications equipment installations in these instances.




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5.2.1



Cleaning up inconsistencies.







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Sections 5.2.1, 5.2.2

5.2.1


Installations of communications equipment under the exclusive control of utilities located outdoors or in buildings usedexclusively for such installations are outside the scope of NFPA 70 and are not addressed in this section.

5.2.2

All electrical connections and wiring to, from, and within engineered and field-constructed ESS shall be in accordance withNFPA 70 or IEEE C2 based on the location of the ESS in relation to and its interaction with the electrical grid.







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5.3 Disconnecting Means.

5.3.1


5.3.2



Electrical requirements for ESS are already covered in NFPA 70 Article 706. Repeating them in 855 at best just duplicate text and at worst could create conflicts.




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5.3.1

A readily accessible disconnecting means for the ESS shall be provided within sight of the ESS in accordance with NFPA 70,706.7, including field marking the disconnecting means with information for determining the arc-rated PPE. in accordance withNFPA 70, 706.7(D). Systems under 100 V dc are exempt from this requirement.


The field marking was confusing so referencing the details in the NEC, as is done in the first part of the sentence, is appropriate. NEC articles 480 and 706 already exempt low voltage systems and this document should also exempt them. 100 volts is more appropriate than 60 because some of the '48 volt' systems can float at or above 60 volts. There really are not any systems below 100 volts except '48 volt' systems or lower. The next higher standard voltage is 120 volts.




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Sections 5.3.1, 5.3.2

5.3.1



5.3.2








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5.6 Notification.

Notifications shall be present per the requirements of NFPA 70, 706.7(D).







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6.1.1.1

The system installer shall system owner or their designated agent shall prepare a written commissioning plan acceptable to allAHJs that provides the organization with documentation requirements and methods and tools necessary plan that providesthe a description of the means and methods necessary to document and verify that the system and its associated controls andsafety systems as required by this standard are in proper working condition.


The responsibility for the preparation of a commissioning plan should ultimately rest with the system owner, who can perform the function or designate someone to conduct that task for them (which could include but need not necessarily be the system installer). In some cases the system manufacturer might be more appropriate to prepare the commissioning plan, yet the current draft would not allow them to prepare the plan.

Given the number of AHJs likely to be involved in verifying compliance with the standard (federal, state, local, tribal and territorial government and utilities for instance) it seems impossible for an installer (or anyone else to prepare a commissioning plan that would be acceptable to all AHJs. If the intent is acceptable to the AHJs responsible for the specific ESS installation then the language could be revised to convey that. As written 'acceptable to all AHJs' can be interpreted to include all possible AHJs throughout the US.

The remaining revisions are intended to provide further clarification and editorial enhancement to the text.




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6.1.1.2

The commissioning plan shall be approved by the owner of the ESS or its designated agent and include shall include aprocess for considering and , describing and documenting subsequent revisions to the commissioning plan necessitated byactivities such as but not limited to ongoing servicing and maintenance of the system and addiions to or renovations/renewalsof the system or any of its components .


The proposed revision to Section 4.1.1 addresses the preparation and approval of the commissioning plan. This section is intended to ensure the plan includes a way to keep the plan updated over time as the system changes.




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6.1.1.3

The commissioning plan shall include the following information:

(1) An overview of the commissioning process developed specifically for the ESS to be installed

(2) Roles and responsibilities for all those involved in the planning, design, installation or operation of the system(s)

(3) Means and methods whereby the commissioning plan will be made available during the implementation of the ESSproject(s)

(4) Plans and specifications necessary to understand the installation and operation of the ESS and all associated operationalcontrols and safety systems

(5) A detailed description of each activity to be conducted during the commissioning process, who will perform each activity,and at what point in time the activity is to be conducted

(6) Procedures to be used in documenting the proper operation of the ESS and all associated operational controls and safetysystems

(7) Guidelines and format for a commissioning checklist and relevant operational testing forms and necessary commissioninglogs and progress reports

(8) Information on disposal of materials in the ESS


This should be in the MSDS and system safety plan, not in the commissioning plan document.



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6.1.1.3











This should be in the MSDS and system safety plan, not in the commissioning plan document




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6.1.1.3











Disposal is typically handled in the decommissioning plan rather than in the commissioning plan.




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6.1.1.3











Very vague and also part of decommissioning. Suggest we remove from here or add more details, or a reference to the decommissioning plan. Any high-level information included at the time of commissioning on disposal is likely to change over the life of the ESS.




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6.1.1.3


(1) An overview of the commissioning process developed specifically for the ESS to be installed and narrative description ofthe activities to be conducted

(2) Roles and responsibilities for all those involved in the planning, design, construction, installation or operation of thesystem(s)





(7) Testing for any requied fire detection or suppression and thermal management, ventilation or exhaust systems associatedwith the installation


Information on disposal of materials in the

(9) Means and methods whereby facilty operating and maintenance staff will be trained on the system

(10) Identification of personnel who are qualified to service and maintain the system and respond to incidents involving thesystem

(11) A decommissioning plan meeting the provisions of Section 8.1 and covering the removal of the system from sevice andfrom the facility in which it is located and i nformation on disposal of materials associated with the ESS


To clarify some of the provisions in the draft standard and also to add some new provisions that are relevant to commissioning. In addition a criterion to prepare a decommissioning plan should be part of the commissioning process, as those doing the commissioning and preparing the plan are in the best position at that time to outline how to decommission the system. the details associated with the preparation of the decommissioning plan are provided in Section 8.1. The addition of item (11) ensures that those are followed and available at the time the system is initially installed and commissioned as opposed to possibly years later when the system is decommissioned but those involved at that time were not involved in the initial installation and commissioning of the system.




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6.1.1.3








(7) Guidelines and format for a commissioning checklist and relevant operational testing forms and necessary commissioninglogs and progress reports reports

(8) Expected and acceptable values, or a defined range of values, for each test conducted during the commissioning process



It is important that the Commissioning Documentation include project-specific expected and acceptable values, so AHJs and owners can confirm the test results are acceptable.




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6.1.2.1

ESS shall be evaluated for their proper operation by the system installer in accordance with the commissioning plan developedunder 6.1.1 and a commissioning report documenting the commissioning process prepared by the system installer andprovided to the system owner and applicable AHJs .


The beginning of the requirement has a specific action and responsibility. The end requirement does not seem to have an indication of who is to prepare the commissioning report and who is to receive it. The proposed change fills that gap in the current draft.




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6.1.3.2

The report shall include the commissioning report shall be included in the final commissioning plan required by Secion 6.1.1 ,and include the results of the commissioning process , as well as a copy of the plans and specifications associated with theas-built system design and installation.


It seems more appropriate for the commissioning report to be a component of the final commissioning plan as opposed to the commissioning plan being part of the commissioning report.




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6.3 Operations and Maintenance Documentation .

6.3.1

Operations and maintenance documentation shall be provided to The system installer shall prepare an operations andmaintenance manual and provide it to the ESS owner.

6.3.2

The documentation The manual shall include design, construction, installation, testing, and commissioning informationassociated with the ESS as initially approved after being commissioned.

6.3.3

A copy of the manual shall be placed in an approved location to be accessible to facillity personnel, fire code officials andemergency responders.

6.3.4

ESS shall be inspected, tested, operated and maintained in accordance with the manufacturer's instructions and theoperations and maintenace manual.

6.3.5

An ongoing record of maintenance, testing, failures, repairs, retrofits, problems and resolutions associated with the systemshall be maintained on site in the operations and maintenance manual by the system owner or their designated agent.


The title should be broader than O&M documentation, to allow all O&M relevant information to be included in the section Rather than documentation the focus should be on the preparation of an O&M manual that is dynamic in nature and stays with the project. New provisions are suggested to ensure the O&M manual is available to those who need it, that it be followed (beyond requiring an O&M manual be prepared there does not appear to be anything in the standard now to require its use and updating), and that it be updated over time as the system is operated and maintained in proper working condition.




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6.3.2

The documentation shall include site design, construction, installation, testing, and commissioning information associated withthe ESS as initially approved after being commissioned.


The issue is the distinction between design of the pre-engineered or pre-packaged ESS product vs the site-specific design concerning site layout, equipment placement, cabling runs, etc. This requirement is intended to cover the design of the site and not the product. Disclosure of product design documentation may result in intellectual property or proprietary information issues.




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6.4 Recommissioning of Existing Systems.

6.4.1

Recommissioning shall meet the provisions of Section 6.1 and include the entire system with issuance of a newcommissioning report, identification of any new issues and resolutions documentation, and identification of any revisions to theoperations and maintenance documentation.

6.4.2 *

When alterations, additions, repositioning, repairs, renewals, or renovations to the system or any of its components arewarranted, they shall be permitted in accordance with Chapter 4 and be performed by qualified entities and the systemrecommissioned commissioned in accordance with Section 6.1.

6.4. 2

Commissioning of existing systems shall include the entire system after any work done to the system and shall include theissuance of an updated commissioning report that includes any new issues and resolutions and documentation of how theywere handled.

6.4. 3

The operations and maintence manual required in Section 6.3 shall be updated to include the details associated with the workdone to the system and any new or revised operations and maintenance activities necessitated by the work done to thesystem.

6.4.4

Repairs or renewals to systems utilizing identical components shall not require recommissioning the system to becommissioned .

6.4. 4 5 *

Listed ESS that has been modified in the field beyond the field-installed options that are part of the listing shall be investigatedand found suitable by the organization that listed the equipment.


The term commissioning is defined and there are provisions in the standard for system commissioning. It seems more appropriate to simply apply those to an existing system under specific conditions. For instance in conducting safety inspections over time I believe there is no distinction between inspection and re-inspection other than if something upon inspection fails. It seems then commissioning should apply to new systems and under certain conditions also existing systems. The text has been revised to embrace this concept. First 6.4.1 indicates what work on an existing system triggers code compliance and the need to commission the existing system after the work. Then 6.4.2 points the user to the commissioning provisions that already exist in the standard in 6.1 and then require the commissioning report be updated. Section 6.4.3 ensures that the required O&M manual is updated accordingly and then 6.4.4 and 6.4.5 retain specific details that are needed and are currently in the draft standard.




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6.4.2*

When alterations to an ESS not covered by an existing or updated listing , additions, repositioning, renewals, or renovations tothat increase the system power or any capacity of its components are warranted to the beyond its original permit limits (kWhor kW) , they shall be permitted in accordance with Chapter 4 and be performed by qualified entities and the systemrecommissioned in accordance with Section 6.1. Listed software upgrades or replacement of the inverter module, BMS, batterymodule or other component like-for-like replacements shall be considered maintenance and not subject to recommissioning.


Like-for-like replacement of parts of an ESS shall not trigger re-commissioning. This is similar to replacing a motor in a furnace or a thermostat for a water heater.





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6.4.4 *

Listed ESS that has been modified in the field beyond the field-installed options that are part of the listing shall be investigatedand found suitable by the organization that listed the equipment.

This requirement does not petain to replacement of like parts with parts of matching functions and certifications caused byparts obsolesence or availability. Only parts that are a change in form, fit, or function shall required investigaton.


If a breaker or fuse is no longer available on the market or if the availability is to long an alternate should be able to be used as determined by the OEM engineering team. Some of the installations have liquidated damages if the system is off-line that exceeds a specified time. Typically these are 24 hours and damages or in the thousands of dollars per day.




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Chapter 7 Operation, Testing and Maintenance

7.1 System Operation.

All ESS shall be operated in accordance with the system instructions and the operation and maintenance documentation.

7.1.1

The documentation provided concerning system operation shall include the following:

(1) Procedures for the safe startup of the ESS system and associated equipment

(2) Procedures for inspection and testing of associated alarms, interlocks, and controls

(3) Procedures for maintenance and operation of the following:

(4) Energy storage management systems (ESMS)

(5) Fire protection equipment and systems

(6) Spill containment and neutralization systems

(7) Exhaust and ventilation equipment and systems

(8) Gas detection systems

(9) Other required safety equipment and systems

(10) Response considerations similar to a safety data sheet (SDS) that will address response safety concerns andextinguishment when an SDS is not required

(11) An indication of which changes would necessitate re-permitting

(12)

7.1.2

Copies of SDS for hazardous materials contained in the ESS shall be posted within sight of the disconnecting means of anyESS arrays.

7.1.3

Where the operations and maintenance documentation calls for detailed procedures to be used for specific scheduledoperational checks or assessments, an operations record that includes data associated with configurable system settings,system start-up, system shutdown (including emergency shutdown), and long-term shutdown (storage mode) shall be kept bythe system owner or their designated agent.

7.1.4

The operations record shall indicate the maintenance action taken, the date of the action, who implemented the action, and theresults associated with the action.

7.1.5

The operations record shall be kept in a readily accessible location, or a sign indicating where the record is located shall beposted adjacent to the system.

7.1.6

Safety precautions for external control and interaction shall be clearly outlined and made available adjacent to the positionswhere such control and interaction are intended to occur.

7.2 System Maintenance.

The ESS shall be maintained in accordance with the system manufacturer’s instructions and the operations and maintenancedocumentation.

7.2.1

The maintenance documentation shall include a detailed maintenance schedule covering all affected equipment and theactivities to be performed.

7.2.2

Maintenance shall be performed by qualified individuals.

* A notification that changes to the system are required to be recorded by updating any engineering documentation


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7.2.3

Where the operations and maintenance documentation calls for specific scheduled maintenance inspections, a maintenancerecord shall be kept indicating the maintenance action taken, the date of the action, who implemented the action, and theresults associated with the action.

7.2.4

Maintenance documentation shall be revised to include information on any repair, renewal, or renovation.

7.2.5 Training.

Training on system operation and maintenance shall be provided by the system owner or their designated agent.

7.2.5.1

Training shall be provided to all those responsible for system operation and maintenance.

7.2.5.2

After recommissioning the system, training on any changes to the operation and maintenance documentation shall be provided.

7.2.5.3

Records of training shall be retained and accessible, indicating the training taken, the name(s) of those taking the training, andthe date of the training.

7.3 System Testing.

7.3.1 Initial functional performance and acceptance testing. Energy storage systems shall be evaluated for their properoperation by the system installer in accordance with the manufacturer’s instructions, the commissioning plan and therequirements of this section after the installation is complete but prior to final approval. A report documenting thecommissioning process and the results shall be prepared by the entity commissioning the system and a copy shall be providedto the AHJ prior to final inspection and approval.

7.3.1.1 Functional performance testing shall be conducted as a component of the commissioning process and include thefollowing:

1. Functional performance testing of the energy storage system that demonstrates that the installation andoperation of the system and associated components, controls and safety related systems are in accordance withapproved plans and specifications and that the operation, function, maintenance serviceability for each of thecommissioned energy storage systems is confirmed.

2. Testing all modes and sequence of operation, including under full and partial load conditions.

3. Testing of all control systems to document that control devices, sensors and other components that controlthe system or have an impact on system operation are calibrated and adjusted to operate in accordance withapproved plans and specifications.

4. Preparation of a report detailing the results of the functional performance tests that is prepared by the systemowner or their designated agent and provided to the code official and included in the manual required by Section4.17.3.

7.3.2 Ongoing inspection, testing, operation and maintenance. Energy storage systems shall be inspected, tested,operated and maintained in accordance with the manufacturer's instructions and the manual required by Section 4.17.3. Aformal and ongoing record of maintenance, testing, failures, repairs, retrofits, problems and resolutions shall be maintained onsite by the system owner or their designated agent and made readily available to the AHJ.


Adds necessary testing criteria. Based on testing requirements developed by the FCAC ESS work group.




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All ESS shall be operated in accordance with the system manufacturer's instructions and the operation and maintenancedocumentation.


changed for consistency with wording elsewhere in the document. We should check for consistency of phrasing throughout the document.




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All ESS shall be operated in accordance with the system instructions and the operation and maintenancedocumentation. manual reqiured by Section 6.3.


For consistency with a change to Section 6.3 suggesting the use of manual as opposed to documentation and to refer back to that section where the O&M manual is required.




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7.1.1




(3) Procedures for maintenance and operation of the following, when applicable :









(12)


Not all systems will have all of the components or subsystems listed. Only the available components/subsystems are applicable.




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7.1.1











(10) Response considerations similar to a safety data sheet (SDS) that will address response safety concerns andextinguishment when an SDS is not required Sufficient information that is satisfactory to the AHJ to assess theflammability, toxicity and chemical instability hazards of the electrolyte or anodes in the ESS and presented in a formatthat is understood by emergency responders.


(12)


Excluding flooded lead acid and VRLA batteries, the assembly of most Energy Storage Systems involves an assembly of individual cells into modules that are used to store the power. As a result, SDSs are not commonly available because the cells are classified as Simple Devices under the US OSHA Hazardous Communication requirements. SDSs, when provided, generally offer very little detail on exactly what is used to formulate the cell.

Austin FD understands and respects this. However, from the perspective of evaluating the hazards, two sentences in a 8 page SDS results in a lot of speculation. Further, we believe the pace of technological changes is such that more exotic materials will be employed. While this proposed standard requires the ESS to be listed, that does very little to clearly explain the potential hazards to emergency responders.

The proposed change clarifies that AHJs are going to need to be provided with sufficient information to assess the possibly outcomes of if an ESS malfunctions or is subject to fire exposure or mechanical damage. The proposed text in the draft refers to SDS but the issue with this is some ESS suppliers will strictly rely on the listing and essentially tell the AHJ that NFPA 855 doesn’t require the information currently proposed in Section 7.1.1 item (4).





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7.1.1

The operations and maintenance manual required in Section 6.3 shall include documentation provided concerning systemoperation shall include operation that includes the following:












(12)


The revision to Section 6.3 is intended to ensure there is an actual O&M manual as readers may not necessarily equate 'documentation' to the availability of an actual O&M manual. The revision to this section simply retains the current requirement regarding documentation but further clarifies that it needs to be included in the actual O&M manual.




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7.1.2

Copies of SDS for hazardous materials contained in the ESS shall be posted within sight of the disconnecting means of anyESS arrays or at a location approved by the AHJ .


The change to this section eliminates the work "array" which is not defined in this standard and adds at a location approved by the AHJ to give the AHJ authority to require the SDS's to be kept at another location.



Submitter FullName:

Carl Wren



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7.1.2

Copies of SDS for hazardous materials contained in the ESS shall be posted within sight of the disconnecting means of anyESS arrays, or in a readily accessible location, or a sign indicating where the SDS copies are located shall be posted adjacentto the system .


Telecom does not have disconnecting mean, so it would be best to revise this requirement to mirror section: 7.1.5: The operations record shall be kept in a readily accessible location, or a sign indicating where the record is located shall be posted adjacent to the system. The same approach can be used for the storage of the SDSs.




Affilliation: ATIS

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7.1.3

Where the operations and maintenance documentation calls for detailed procedures to be used for specific scheduledoperational checks or assessments, an operations record that includes data associated with configurable system settings,system start-up, system shutdown (including emergency shutdown), and long-term shutdown (storage mode) shall be keptstored and maintained by the system owner or their designated agent for the service life of the ESS and shall be madeavailable to the AHJ upon request .


The change to this section clarifies what "kept" means and clarifies for what period it should be maintained as well as that it shall be made available to the AHJ.




Organization: Austin City of

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7.1.3

Where the operations and maintenance documentation maintenance manual calls for detailed procedures to be used forspecific scheduled operational checks or assessments, an operations record that includes data associated with configurablesystem settings, system start-up, system shutdown (including emergency shutdown), and long-term shutdown (storage mode)shall be kept by the system owner or their designated agent and included in the manual .


For consistency with other suggested revisions associated with changing documentation to manual. Also the records associated with maintenance should be retained in the O&M manual.




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7.1.6

Safety precautions for external control and interaction shall be clearly outlined and made available adjacent to the positionswhere such control and interaction are intended to occur.


This section was eliminated because it is unclear what is this is supposed to address or who is supposed to take action.



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Carl Wren



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7.2.1

The maintenance documentation maintenance manual shall include a detailed maintenance schedule covering all affectedequipment and the activities to be performed.


For consistency with other proposed revisions to change documentation to manual.




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7.2.2

Maintenance shall be performed by qualified individuals. Guidance for qualified personnel on batteries can be found in IEEE1657.


1657-2009 - IEEE Recommended Practice for Personnel Qualifications for Installation and Maintenance of Stationary Batteries. This is a consensus document concerning qualified battery personnel.




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7.2.3

Where the operations and maintenance documentation maintenance manual calls for specific scheduled maintenanceinspections, a maintenance record shall be kept indicating the maintenance action taken, the date of the action, whoimplemented the action, and the the results associated with the action and the record included in the maintenance manual .


For consistency with other suggested revisions to change documentation to manual. Also the maintenance record will be more likely to be available for future reference if then included in the O&M manual, which is a document intended to stay with the project over its lifetime.




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7.2.4

Maintenance documentation The required maintenance manual shall be revised to include information on any repair, renewal,or renovation.


For consistency with the proposed change from documentation to manual.




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7.2.5 Training.

Training on shall be provided to all those responsible for system operation and maintenance shall be provided by the systemowner or their designated agent .

7.2.5.1

Training on system operation and maintenance shall be provided to all those responsible for system operation andmaintenance by the system owner or their designated agent .

7.2.5.2


7.2.5.3



Don't bury the headline. First item should be who is trained on what. Who trains should come after.




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7.2.5 Training.

Training on system operation and maintenance shall be provided by the system owner or their designated agent.

7.2.5.1

Training shall be provided to all those responsible for system operation and maintenance.

7.2.5.2


7.2.5.3


Comment - Section 7.2.5 may read "The initial training on system operation an maintenance shall be provided by the systemmanufacturer or their designted agent and subsequent training shall be provided by the system manufcturer or owner or theirdesignted agent."


The initial training would require manufacturer but subsequent may or may not.





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7.2.5.2

After recommissioning the system commissioning an exiting system in accordance with Section 6.4 , training on any changes tothe operation and maintenance documentation maintenance manual necessitated by the work performed on the existingsystem shall be provided by the system owner or their desigated agent .


For consistency with the change from recommissioning to simply commissioning of existing systems and the change from documentation to manual. Also to ensure someone is named as responsible for the required training.




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8.1.1*

The decommissioning plan shall include the following information:

(1) An overview of the decommissioning process developed specifically for the ESS that are to be decommissioned

(2) Roles and responsibilities for all those involved in the decommissioning of the ESS and their removal from the site

(3) Means and methods whereby the decommissioning plan will be made available at a point in time corresponding to thedecision to decommission the ESS

(4) Plans and specifications necessary to understand the ESS and all associated operational controls and safety systems, asbuilt, operated, and maintained

(5) A detailed description of each activity to be conducted during the decommissioning process and who will perform thatactivity and at what point in time

(6) Procedures to be used in documenting the ESS and all associated operational controls and safety systems that have beendecommissioned

(7) Guidelines and format for a decommissioning checklist and relevant operational testing forms and necessarydecommissioning logs and progress reports

(8) A description of how any changes to the surrounding areas and other systems adjacent to the ESS, such as but not limitedto structural elements, building penetrations, When decommissioning of the ESS requires modification of a building’sstructural components, means of egress, and required fire detection and suppression systems, will be protected duringdecommissioning and confirmed as being acceptable after the system is removed fire-resistant construction,environmental controls, or fire protection systems, the plan shall be approved by the AHJ.


Item (8) of Section 8.1.1 is written with the assumption that a fire protection system will always be employed. That’s not always the case, especially in existing buildings. Secondly, if modifications to a building are required that would require modification to certain structural, means of egress or environmental controls such as air handlers, that generally will require some form of construction permit from the AHJ. This proposal attempts to clarify when AHJ approval is required.





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8.2 Decommissioning Process.

ESS shall be decommissioned by the owner of the ESS or their designated agent(s) in accordance with the decommissioningplan developed under Section 8.2 1 .


I believe there is an error in the text, and that this section is intended to reference back to 8.1




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8.2 Decommissioning Process.

ESS shall be decommissioned by the owner of the ESS or their designated agent(s) in accordance with the decommissioningplan developed under Section 8.2 and after noification to applicable authorities having jurisdiction of the intent todecommission the ESS .


When installing a new ESS or performing work on an existing ESS there are required communications with AHJs. Given the work involved in decommissioning an ESS it is also appropriate to notify the applicable AHJs associated with the ESS of the intent to decommission and remove the system.




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9.1 Application.

The requirements of this chapter shall apply to new and existing installations of electro-chemical ESS.

9.1.1 General.

The provisions of Chapter 4 shall apply except as modified by this chapter.

9.1.2 Commissioning Interconnections .


9.1.3 Operation and Maintenance Commissioning .


9.1.4 Decommissioning Operations and Maintenance .


9.1.5 Decommissioning

The provisions of Chapter 8 shall aply except as modified by this chapter.


The revisions are necessary to ensure that Section 9.1 'tracks' with the other chapters of the standard.




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9.1 Application.


9.1.1 General.

The provisions of Chapter 4 shall following provisions shall apply except as modified by this chapter.

9.1.2 Commissioning.


9.1.3 Operation and Maintenance.


9.1.4 Decommissioning.


Chapter 4 General.

Chapter 5 System Interconnections.

Chapter 6 Commissioning

Chapter 7 Operation, Testing and Maintenance

Chapter 8 Decommissioning


This proposal corrects references that were incomplete and incorrect.




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Changing existing installations to be compliant with Chapter 4 would likely mean a complete overhaul of substantially all installed energy storage. I believe this was intended to cover new, not all existing, installations.




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As written this section conflicts with Section 1.4. This proposal allows both Sections to work independently.





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Exhaust

A dedicated exhaust system shall be required for all battery types referenced in this chapter.


All electrochemical battery ESS can potentially release flammable/toxic gasses under fire or fault conditions. These gasses shall be safely exhausted in order to ensure proper fire suppression system operation as well as occupant and first responder safety.




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9.2 Protection features. Electro-chemical ESS installations shall comply with the technology specific requirements specified inTables 9.2.

TABLE 9.2


TECHNOLOGY SPECIFIC REQUIREMENTS

COMPLIANCE

REQUIRED b BATTERY TECHNOLOGY OtherEESS and

BatteryTechno-

logies b

Cap-acitor

EnergyStorage

bLead-acid

Ni-Cador Ni-mH

Lithium Sodium

(hightemp)

Sodiumion

Flow

9.4.2.1Ventilation

systemYes Yes No No Yes Yes Yes No

Spill control andneutralization Yes c Yes c No No No Yes Yes No

TBD Safetycaps

Yes Yes No No No No Yes No

TBD Thermalrunaway

Yes Yes Yes d Yes d Yes d No Yes d No

a. Not required for lead-acid and Ni-Cad batteries at telecommunications facilities that comply with NFPA 76 and operate at lessthan 50 VAC and 60 VDC.

b. Protection shall be provided unless documentation acceptable to the AHJ is provided that provides justification why theprotection is not necessary based on the technology used.

c. Applicable to vented (i.e. flooded) type Ni-cad and lead acid batteries.

d. The thermal runaway protection is permitted to be part of a battery management system that has been evaluated with thebattery as part of the evaluation to UL 1973.


The initial draft of this chapter includes a lot of repetitive requirements, such as repeating detailed ventilation requirements in Sections 4.10, 9.22, 9.3.2, 9.4.2, 9.5.2, 9.6.2, 9.7.2 and 9.8.2. A more effective way to handle this is to include the specific detailed requirements in one location, and a simple cross reference to the requirements for the specific ESS technology involved. If detailed requirements apply to all ESS, or more than one type (Chapter) of ESS, the requirements should be located in Chapter 4. If the requirements only apply to electro-chemical ESS the detailed requirements should be in Chapter 9.This proposal uses a table to describe the specific requirements that apply to specific electro-chemical ESS technologies. If the committee chooses to use this format many (if not all) of the repetitive requirements in Sections 9.2 through 9.8 can be eliminated, This tabular approach was used by the FCAC ESS work group.




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9.2 Lithium-Ion Battery Systems.

Lithium-ion battery systems shall comply with 9.2.1 through 9.2.3.3.

9.2.1 Siting.

9.2.1.1

Outdoor installations shall comply with 4.14.2.

9.2.1.2

Rooftop installations shall comply with 4.14.3.

9.2.2 Ventilation, Thermal Management, and Exhaust.

9.2.2.1

Exhaust for areas containing lithium-ion ESS shall be in accordance with the manufacturer’s installation instructions and localbuilding and fire codes.

9.2.2.2

Environmental controls necessary to maintain the lithium-ion batteries and other components of an ESS within safe operatinglimits as indicated in the installation specifications shall be provided in accordance with the manufacturer’s installationinstructions.

9.2.2.3

A listed device or other approved method shall be provided to preclude, detect, and control thermal runaway.

9.2.3 Fire Protection.

9.2.3.1 Fire Command Centers.

Fire command centers in buildings containing stationary storage battery systems lithium-ion ESS shall include signage orreadily available documentation that describes the location of stationary storage battery systems, the types of batteries present,operating voltages, and location of electrical disconnects. [ 1 :52.3.2.6.5.7]

9.2.3.2 Fire Suppression.

Rooms containing stationary storage battery systems lithium-ion ESS shall be protected by an automatic sprinkler systeminstalled in accordance with NFPA 13.

9.2.3.2.1

Commodity classifications for specific technologies of storage batteries lithium-ion ESS shall be in accordance with Chapter 5of NFPA 13. If the storage battery types lithium-ion ESS are not specifically addressed in Chapter 5 of NFPA 13, the AHJ shallbe permitted to approve the fire suppression system based on full scale fire and fault condition testing conducted or witnessedand reported by an approved laboratory.

9.2.3.3 Smoke Detection.

An approved automatic smoke detection system shall be installed in rooms containing stationary battery storage systemslithium-ion ESS in accordance with NFPA 72. [ 1 :52.2.2.10]

9.2.3.3.1

The required automatic smoke detection system shall be supervised by an approved central, proprietary, or remote stationservice or a local alarm that will give an audible signal at a constantly attended location. [1:52.2.2.10.1]


These requirements make generic references to stationary storage batteries, but are included in the lithium-ion specific section. Where ESS is referenced in this section, it should be lithium-ion specific so text is not taken out of context as applying to all ESS or all battery types. If a requirements is truly intended to apply to all ESS, it should moved to section 4.




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9.2.2.4 Gas Detection

9.2.2.4.1 Rooms containing lithium ion battery energy storage systems shall be protected by an approved continuous gasdetection system capable of monitoring bulk/room-level gas concentrations in addition to localized off-gas detection. Thelocalized off-gas detection system shall be comprised of a distributed network of discrete gas monitors capable of detecting thelithium ion battery off-gas species during a battery failure.

9.2.2.4.2 The bulk/room-level gas detection system shall be designed to activate when the level of flammable gas in the roomexceeds 25 percent of the LFL.

9.2.2.4.3 The localized off-gas detection system shall be installed at a level no higher than the battery rack within the lithiumion battery system hierarchy (cell -> module -> rack -> system).

9.2.2.4.4 Activation of the gas detection system shall result in activation of the mechanical ventilation system, which shallremain on until the gas detection system is no longer activated.

9.2.2.4.5 The gas detection system shall include a minimum of two hours of standby power.

9.2.2.4.6 Failure of the gas detection system shall annunciate a trouble signal at an approved central, proprietary, or remotestation service, or when approved by a constantly attended onsite location.


A lithium ion battery failure progresses through discrete stages and each stage can be detected by a unique detection method.

The initial stage of any failure is detected by a battery management system, which is typically an abuse factor, such as mechanical, electrical, or thermal abuse.

The next stage can be described as an off-gassing event, where an ejection of gaseous battery electrolyte solvents creates a localized flammable atmosphere. This stage often occurs significantly before any smoke or fire is generated by the battery, and, therefore, can provide significant early warning of a battery failure. This stage can be detected by localized off-gas monitors that are sensitive to low concentrations of battery off-gas species. These monitors can be integrated or retrofitted at the rack or module level. By providing a localized and distributed network of gas sensors, first responders can be aware of the failure at an earlier stage and also be aware of precisely where it is occurring in the energy storage system. This provides significant advantages over traditional LFL and smoke detection.

The next stages include both smoke and fire generation which can result in propagation of the failure to other cells. These stages would be detectable by smoke detectors or heat detectors.


Submitter Full Name: Nick Frank

Organization: Nexceris

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9.2.2.3

A listed If system is not listed to UL 9540, a listed device or other approved method shall be provided to preclude, detect, andcontrol thermal runaway.


Systems needs to follow UL 9540 recommendations which will also be in the supplier's manuals and data sheet which are reviewed and approved by the NRTL.



Organization: Nema

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9.2.2.3

A listed If system is not listed to UL9540, a listed device or other approved method shall be provided to preclude, detect, andcontrol thermal runaway.


System needs to follow UL9540 recommendations which will also be in the supplier's manuals and data sheet which are reviewed and approved by the NRTL.




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9.2.2.3

A listed device or other approved method shall be provided to preclude, detect, and control minimize the impact of thermalrunaway.


The definition of thermal runaway is that is an uncontrollable positive feedback event, and thus controlling it is not possible. However, precluding, detecting, and minimizing its impact is.




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9.2.2.3

A listed device or other approved method shall be provided to preclude, detect, and control thermal runaway. TBD


Just stating Listed device can be hundreds of thousands of dollars of testing and up to a year of testing. There needs to be an established minimum set by this standard. UL, CE, CSA, etc. and then set the standard that is minimum.




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9.2.2.3 Thermal Runaway



Sub-section title was missing "Thermal Runaway





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9.2.2.3

Thermal runaway. A listed device or other approved method shall be provided to preclude, detect, and control thermalrunaway.


thermal runaway is in bold character for other technology 9.5.2.1 or 9.4.4.2




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9.2.2.3

A listed device or other method approved method by the ESS manufacturer shall be provided to preclude, detect, and controlthermal runaway.


Approved is too vague. Approval from the ESS manufacturer should ensure no risk of thermal runaway given their in depth understanding of their product and how it operates.




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Fire command centers in buildings containing stationary storage battery systems shall include signage or readily availabledocumentation that describes the location of stationary storage battery systems, the types of batteries present, operatingvoltages, and location of electrical disconnects. [ 1 :52.3.2.6.5.7]


Rooms containing stationary storage battery systems shall be protected by an automatic sprinkler system installed inaccordance with NFPA 13.

9.2.3.2.1

Commodity classifications for specific technologies of storage batteries shall be in accordance with Chapter 5 of NFPA 13. Ifthe storage battery types are not specifically addressed in Chapter 5 of NFPA 13, the AHJ shall be permitted to approve thefire suppression system based on full scale fire and fault condition testing conducted or witnessed and reported by anapproved laboratory.


An approved automatic smoke detection system shall be installed in rooms containing stationary battery storage systems inaccordance with NFPA 72 . [ 1 :52.2.2.10]

9.2.3.3.1

The required automatic smoke detection system shall be supervised by an approved central, proprietary, or remote stationservice or a local alarm that will give an audible signal at a constantly attended location. [ 1 :52.2.2.10.1]


These requirements are inappropriate for residential and small commercial installations. They would be appropriate for large installations. Some differentiation needs to be made between a small residential system and a multi-MW commercial storage system. One size fits all kills small projects.




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This section was deleted because Section 4.12 already addresses the required information to be made available to emergency responders.



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Carl Wren



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Rooms containing stationary storage battery systems shall be protected by an automatic sprinkler system installed inaccordance with NFPA 13. Section 4.8.2.


This change was made to refer back to sprinkler requirements already detailed in this standard.



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Carl Wren



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Rooms containing stationary storage battery systems shall be protected by an automatic sprinkler fire suppression systeminstalled in accordance with NFPA 13. as described in Section 4.8.


This section conflicts with Section 4.8, recommend harmonizing with that section.




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Rooms, structures, containers or cabinets containing stationary storage battery systems shall be protected by an automaticsprinkler system installed in accordance with NFPA 13.


Areas containing electrochemical ESS are hazardous and require automatic sprinkler protection. Whether located in a structure, container, cabinet, or room, the hazards are existent and should be adequately protected, regardless of location of the installation.




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Rooms containing stationary storage battery systems shall be protected by an automatic sprinkler system installed inaccordance with NFPA 13. Outdoor and Stand-alone installations (greater than 1 MWh in aggregate) may utilize alternativesuppression sytems as described in 4.8.2.


Addition for clarity. Section 4.8.2 of this standard should apply to Lithium Ion..




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Rooms containing stationary storage battery systems shall be protected by an automatic sprinkler system installed inaccordance with NFPA 13 Section 4 .8.


Section 9.1.1 indicates Chapter 4 shall be apply except as modified by this chapter. Section 9.2.3.2 reduces the minimum suppression requirement indicated in Section 4.8. to a general application of NFPA 13. One of the main reasons NFPA 855 is being created is because the current codes do not adequately address what protection is needed for the latest ESS technologies being manufactured. Presentations have been provided to the committee of actual tests on lithium-ion batteries. The tests indicated the minimum sprinkler densities required to cool the systems and that has been specified in Section 4.8. That needs to be maintained in chapter 9.


Submitter Full Name: Scot Pruett

Organization: Black Veatch Corporation

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9.3.2. 1 * Ventilation .

Ventilation shall be provided for rooms and cabinets in accordance with the mechanical code and one of the following:

(1) The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the lowerflammable limit (LFL) of the total volume of the room during the worst-case event of simultaneous “boost” charging of allthe batteries, in accordance with nationally recognized standards.

(2) Mechanical ventilation shall be provided at a rate of not less than 1 ft 3 /min/ft 2 (5.1 L/sec/m 2 ) of floor area of theroom or cabinet. The ventilation can be either continuous, or activated by a gas detection system in accordance with9.3.2.1.2 .

9.3.2.1.1

Required mechanical ventilation systems for rooms and cabinets containing storage batteries shall be supervised by anapproved central, proprietary, or remote station service or shall initiate an audible and visual signal at an approved constantlyattended on-site location. [ 1 :52.3.2.8.1]

9.3.2.1.2

Where required by 9.3.2.1 (2), rooms containing stationary storage battery systems shall be protected by an approvedcontinuous gas detection system. [ 1 :52.3.2.8.2]

9.3.2.1.2.1

The gas detection system shall be designed to activate when the level of flammable gas exceeds 25 percent of the LFL.[ 1 :52.3.2.8.2.1]

9.3.2.1.2.2

Activation of the gas detection system shall result in activation of the mechanical ventilation system, which shall remain on untilthe flammable gas detected is less than 25 percent of the LFL. [ 1 :52.3.2.8.2.2]

9.3.2.1.2.3

The gas detection system shall include a minimum two hours of standby power. [ 1 :52.3.2.8.2.3]

9.3.2.1.2.4

Failure of the gas detection system shall annunciate a trouble signal at an approved central, proprietary, or remote stationservice, or when approved at a constantly attended onsite location. [ 1 :52.3.2.8.2.4]

Mechanical ventilation systems shall be in accordance with Section 4.10


This change was made to refer back to Section 4.10. The information in this section is a repeat of the information in 4.10.



Submitter FullName:

Carl Wren



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9.3.2.1 * Ventilation.


(1) The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the lowerflammable limit (LFL) of the total volume of the room during the worst-case event of simultaneous “boost” charging of allthe batteries, in accordance with nationally recognized standards.


9.3.2.1.1


9.3.2.1.2


9.3.2.1.2.1


9.3.2.1.2.2


9.3.2.1.2.3

The gas detection system shall include a minimum two hours of standby power. [ 1 :52.3.2.8.2.3]

9.3.2.1.2.4



These just repeat much of what is in chapter 4. For cleanliness and clarity, I suggest we edit out all but items in ventilation unique to flow batteries. Also, I am not familiar with flow batteries, but I suspect they may not boost charge. If not, at least this portion of ventilation needs to be re-written for technical correctness.




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Public Input No. 289-NFPA 855-2017 [ Section No. 9.3.2.1.2 [Excluding any Sub-Sections] ]

Where required by 9.3.2.1 (2), rooms containing stationary storage Flow battery systems shall be protected by an approvedcontinuous gas detection system. [1:52.3.2.8.2]


The aforementioned systems generate flammable gasses and therefore should require a gas detection system




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Where required When a gas detection system is provided as allowed by 9.3.2.1(2), rooms containing stationary storage batterysystems shall be protected by an approved continuous gas detection system. [1:52.3.2.8.2]


Section 9.3.2.1(2) does not require a gas detection system per se, but instead allows for the use of such a system as an alternative. The proposed revision is intended to align this section of the standard with that criterion in 9.3.2.1(2).




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Fire command centers in buildings containing stationary storage battery systems shall include signage, or readily availabledocumentation, that describes the location of stationary storage battery systems, the types of batteries present, operatingvoltages, and location of electrical disconnects.



9.3.3.2.1

Commodity classifications for specific technologies of storage batteries shall be in accordance with Chapter 5 of NFPA 13.[ 1: 52.3.2.7.1.1]

9.3.3.2.2

If the storage battery types are not specifically addressed in Chapter 5 of NFPA 13, the AHJ shall be permitted to approve thefire suppression system based on full-scale fire and fault condition testing conducted or witnessed and reported by anapproved laboratory. [ 1 :52.3.2.7.1.2]



9.3.3.3.1



These just repeat much of what is in chapter 4. For cleanliness and clarity, I suggest we edit out all but items unique to flow batteries.




Affilliation: ATIS

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Submitter FullName:

Carl Wren



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Rooms, structures, containers, or cabinets containing stationary storage battery systems shall be protected by an automaticsprinkler system installed in accordance with NFPA 13.






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9.4 Sodium Beta Battery Systems, Aqueous .

Sodium beta Aqueous battery systems shall comply with 9.4.1 through 9.4.3.3.

9.4.1 Siting.

9.4.1.1

Outdoor installations shall comply with 4.14.2.

9.4.1.2

Rooftop installations shall comply with 4.14.3.


9.4.2.1* Ventilation.


(1) The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the LFL ofthe total volume of the room during the worst-case event of simultaneous “boost” charging of all the batteries, inaccordance with nationally recognized standards.

(2) Mechanical ventilation shall be provided at a rate of not less than 1 ft3/min/ft2 (5.1 L/sec/m2) of floor area of the room orcabinet. The ventilation is permitted to be either continuous or activated by a gas detection system in accordance with9.4.2.1.2.

9.4.2.1.1

Required mechanical ventilation systems for rooms and cabinets containing storage batteries shall be supervised by anapproved central, proprietary, or remote station service or shall initiate an audible and visual signal at an approved constantlyattended on-site location. [1:52.3.2.8.1]

9.4.2.1.2

Where required by 9.4.2.1(2), rooms containing stationary storage battery systems shall be protected by an approvedcontinuous gas detection system. [1:52.3.2.8.2]

9.4.2.1.2.1

The gas detection system shall be designed to activate when the level of flammable gas exceeds 25 percent of the LFL.[1:52.3.2.8.2.1]

9.4.2.1.2.2

Activation of the gas detection system shall result in activation of the mechanical ventilation system, which shall remain on untilthe flammable gas detected is less than 25 percent of the LFL. [1:52.3.2.8.2.2]

9.4.2.1.2.3

The gas detection system shall include a minimum 2 hours of standby power. [1:52.3.2.8.2.3]

9.4.2.1.2.4

Failure of the gas detection system shall annunciate a trouble signal at an approved central station, proprietary or remotestation service, or when approved at a constantly attended onsite location.

9.4.2.2 Thermal Runaway.




Fire command centers in buildings containing stationary storage battery systems shall include signage or readily availabledocumentation that describes the location of stationary storage battery systems, the types of batteries present, operatingvoltages, and location of electrical disconnects. [1:52.3.2.6.5.7]



9.4.3.2.1

Commodity classifications for specific technologies of storage batteries shall be in accordance with Chapter 5 of NFPA 13.[1:52.3.2.7.1.1]


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9.4.3.2.2

If the storage battery types are not specifically addressed in Chapter 5 of NFPA 13, the AHJ shall be permitted to approve thefire suppression system based on full-scale fire and fault condition testing conducted or witnessed and reported by an approvedlaboratory. [1:52.3.2.7.1.2]


An approved automatic smoke detection system shall be installed in rooms containing stationary battery storage systems inaccordance with NFPA 72. [1:52.2.2.10]

9.4.3.3.1

The required automatic smoke detection system shall be supervised by an approved central, proprietary, or remote stationservice or a local alarm that will give an audible signal at a constantly attended location. [1:52.2.2.10.1]


Section 9.4.1 through 9.4.3.3 discusses the specific requirements for “Sodium Beta Battery Systems” as per section 9.4, but the contents of the aforementioned sections does not correspond to the requirements of a “Sodium Beta Battery system” ( as defined in section B.5.7), the requirements coincide with the requirements for a “Sodium Aqueous system” (as defined in section B.5.6)




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(1) The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the LFLof the total volume of the room during the worst-case event of simultaneous “boost” charging of all the batteries, inaccordance with nationally recognized standards.

(2) Mechanical ventilation shall be provided at a rate of not less than 1 ft 3 /min/ft 2 (5.1 L/sec/m 2 ) of floor area of theroom or cabinet. The ventilation is permitted to be either continuous or activated by a gas detection system inaccordance with 9.4.2.1.2 .

9.4.2.1.1


9.4.2.1.2

Where required by 9.4.2.1 (2), rooms containing stationary storage battery systems shall be protected by an approvedcontinuous gas detection system. [ 1: 52.3.2.8.2]

9.4.2.1.2.1

The gas detection system shall be designed to activate when the level of flammable gas exceeds 25 percent of the LFL.[ 1: 52.3.2.8.2.1]

9.4.2.1.2.2

Activation of the gas detection system shall result in activation of the mechanical ventilation system, which shall remain on untilthe flammable gas detected is less than 25 percent of the LFL. [ 1: 52.3.2.8.2.2]

9.4.2.1.2.3

The gas detection system shall include a minimum 2 hours of standby power. [ 1: 52.3.2.8.2.3]

9.4.2.1.2.4





These just repeat much of what is in chapter 4. For cleanliness and clarity, I suggest we edit out all but items unique to sodium-beta batteries.




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9.4.2.1.1


9.4.2.1.2


9.4.2.1.2.1


9.4.2.1.2.2


9.4.2.1.2.3


9.4.2.1.2.4


Mechanical ventilation systems shall be in accordance with Section 4.10.





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Carl Wren



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9.4.2.1.1


9.4.2.1.2


9.4.2.1.2.1


9.4.2.1.2.2


9.4.2.1.2.3


9.4.2.1.2.4



Sodium Beta batteries do not produce dangerous gasses during charge, discharge, normal operation or severe operational abuse. Ventilation would add unnecessary complexity and cost to the user.





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9.4.2.1.1


9.4.2.1.2


9.4.2.1.2.1


9.4.2.1.2.2


9.4.2.1.2.3


9.4.2.1.2.4



Sodium beta batteries do not produce any gases during operation. Venting and exhaust gas system is not required by sodium beta batteries




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9.4.2.1.1


9.4.2.1.2


9.4.2.1.2.1


9.4.2.1.2.2


9.4.2.1.2.3


9.4.2.1.2.4



Sodium Beta batteries do not produce dangerous gasses during charge, discharge, normal operation or severe operational abuse. Ventilation is not necessary



Organization: RnD

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Ventilation Exhaust for areas containing sodium beta ESS shall be provided for rooms and cabinets in accordance with themechanical code and one of the following:

The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25 percent of the LFL of thetotal volume of the room during the worst-case event of simultaneous “boost” charging of all the batteries, in accordance withnationally recognized standards.

Mechanical ventilation shall be provided at a rate of not less than 1 ft 3 /min/ft 2 (5.1 L/sec/m 2 ) of floor area of the room orcabinet. The ventilation is permitted to be either continuous or activated by a gas detection system in accordance withmanufacturer’s installation instructions and local building and fire codes.

9.4.2.1.

2.

9.4.2. 1.1


Environmental controls necessary to maintain the sodium beta batteries and other components of an ESS within safe operatinglimits as indicated in the installation specifications shall be provided in accordance with the manufacturer’s installationinstructions.

9.4.2.1.2

Where required by

9.4.2.1

(2), rooms containing stationary storage battery systems shall be protected by an approved continuous gas detection system

.

[ 1: 52.3.

2.

8.2]9.4.2.

1

.2.1


9.4.2.1.2.2

Activation of the gas detection system shall result in activation of the mechanical ventilation system, which shall remain onuntil the flammable gas detected is less than 25 percent of the LFL. [ 1: 52.3.2.8.2.2]

9.4.2.1.2.3


9.4.2.1.2.4



Sodium beta batteries (e.g. sodium sulfur NaS and sodium nickel chloride) are hermetically sealed systems so the ventilation and exhaust type controls that one would need for a vented lead acid battery, would not be necessary for these systems. The approach taken for these could mirror that of the lithium ion systems, which are sealed but not hermetically sealed.




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Where required by 9.4.2.1 (2), rooms containing stationary storage Sodium Aquaeos battery systems shall be protected by anapproved continuous gas detection system. [1:52.3.2.8.2]


The aforementioned systems generate flammable gasses and therefore should require a gas detection system.




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Where required by When a gas detection system is provided as allowed by 9.4.2.1(2), rooms containing stationary storagebattery systems shall be protected by an approved continuous gas detection system. [1:52.3.2.8.2]






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Approved is too vague. Approval from the ESS manufacturer should ensure no risk of thermal runaway, given they know their products and are motivated to ensure safe operation of them.




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9.4.3.2.1

Commodity classifications for specific technologies of storage batteries shall be in accordance with Chapter 5 of NFPA 13.[ 1: 52.3.2.7.1.1]

9.4.3.2.2




9.4.3.3.1



These just repeat much of what is in chapter 4. For cleanliness and clarity, I suggest we edit out all but items unique to sodium beta batteries.




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Carl Wren



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VRLA battery systems shall be provided with a listed device or other approved method to preclude, detect, and control thermalrunaway.


For flooded lead-acid and VRLA batteries, ventilation shall be provided for rooms and cabinets in accordance with themechanical code and one of the following:

(1) The ventilation system shall be designed to limit the maximum concentration of hydrogen to 1.0 percent of the totalvolume of the room during the worst-case event of simultaneous “boost” charging of all the batteries, in accordance withnationally recognized standards.

(2) Continuous ventilation shall be provided at a rate of not less than 1 ft 3 /min/ft 2 (5.1 L/sec/m 2 ) of floor area of theroom or cabinet.

9.5.2.3 Environment.

The battery environment shall be controlled or analyzed to maintain temperature in a safe operating range for the specificbattery technology used. [ 1 :52.2.2.7]


These just repeat much of what is in 4. For cleanliness can we edit out all but items unique to Lead acid batteries.




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VRLA battery systems shall be provided with a listed device One or more listed devices or other approved method shall beprovided to preclude, detect, and control thermal runaway for ESSs that utilize VRLA technology . A common method is toutilize temperature controlled chargers that reduce the voltage when the temperature of the battery increases above normal.


Many battery chemistries and types, including vented lead-acid, have the potential for thermal runaway. That is way too broad of characterization. The real issue is with VRLA batteries and should be stated as such. This requirement in the fire codes has caused a great deal of confusion in the industry because of the vague wording. Providing a common method, that many use, will go a long way to resolving the confusion. This is redundant with 4.10.6.



Public Input No. 502-NFPA 855-2017 [Section No. 4.10.6] same requirement




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Gas Detection

Lead-acid battery systems shall be protected by an approved continuous gas detection system






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For flooded lead-acid and VRLA batteries, ventilation shall be provided for rooms and cabinets in accordance with themechanical code and one of the following:








Submitter FullName:

Carl Wren



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For flooded vented lead-acid and VRLA batteries, ventilation shall be provided for rooms and cabinets in accordance with themechanical code and one of the following:

(1) The ventilation system shall be designed to limit the maximum concentration of hydrogen to 1.0 flammable gas to 25percent of the lower flammable limit (LFL) of the total volume of the room, enclosure, container, or cabinet during theworst-case event of simultaneous “boost” charging of all the batteries, in accordance with nationally recognizedstandards standard IEEE 1635/ASHRAE 21 .

(2) Continuous ventilation shall be provided at a rate of not less than 1 ft3/min/ft2 (5.1 L/sec/m2) of floor area of the room orcabinet.





Public Input No. 526-NFPA 855-2017 [Section No. 4.10.7.1] same requirement




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Fire Suppression



Areas containing electrochemical ESS are hazardous and require automatic sprinkler protection. Whether located in a structure, container, cabinet, or room, the hazards are existent and should be adequately protected, regardless of location of the installation. These systems are susceptible to thermal runaway and will generate flammable gasses.




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9.5.3.1.1


9.5.3.1.2

Normally unoccupied, stand-alone telecommunications structures with a gross floor area of less than 1500 ft 2 (140 m 2 ) shallnot be required to have the detection as indicated in 9.5.3.1 . [ 1: 52.2.2.10.2]


These just repeat much of what is in 4. For cleanliness and clarity, we should edit out all but items unique to lead-acid batteries.




Affilliation: ATIS

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For flooded nickel-cadmium systems, ventilation shall be provided for rooms and cabinets in accordance with the mechanicalcode and one of the following:






These just repeat much of what is in 4. For cleanliness and clarity, we should edit out all but items unique to NiCd batteries.




Affilliation: ATIS

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Gas Detection

Nickel-Cadmium battery systems shall be protected by an approved continuous gas detection system


The aforementioned systems generate flammable gasses and therefore should require a gas detection system




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For flooded nickel-cadmium systems, ventilation shall be provided for rooms and cabinets in accordance with the mechanicalcode and one of the following:








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9.6.3.1.1


9.6.3.1.2

Normally unoccupied, stand-alone telecommunications structures with a gross floor area of less than 1500 ft 2 (140 m 2 ) shallnot be required to have the detection as indicated in 9.6.3.1 . [ 1 :52.2.2.10.2]


These just repeat much of what is in 4. For cleanliness and clarity we should edit out all but items unique to NiCd batteries.




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For nickel-metal hydride battery systems, ventilation shall be provided for rooms and cabinets in accordance with themechanical code and one of the following:






These just repeat much of what is in 4. For cleanliness and clarity, edit out all but items unique to NiMH batteries.




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Gas Detection

Nickel-metal hydride battery systems shall be protected by an approved continous gas detection system.






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For nickel-metal hydride battery systems, ventilation shall be provided for rooms and cabinets in accordance with themechanical code and one of the following:








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Fire Suppression



These systems are susceptible to thermal runaway and will generate flammable gasses.




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9.7.3.1.1


9.7.3.1.2

Normally unoccupied, stand-alone telecommunications structures with a gross floor area of less than 1500 ft 2 (140 m 2 ) shallnot be required to have the detection as indicated in 9.7.3.1 . [ 1 :52.2.2.10.2]


These just repeat much of what is in 4. For cleanliness and clarity, edit out all but items unique to NiMH batteries.




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9.8.2.2.1


9.8.2.2.2


9.8.2.2.2.1


9.8.2.2.2.2


9.8.2.2.2.3

The gas detection system shall include a minimum 2 hours of standby power. [ 1 :52.3.2.8.2.3]

9.8.2.2.2.4







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Where required When a gas detection system is provided as allowed by 9.8.2.2(2), rooms containing stationary storage batterysystems shall be protected by an approved continuous gas detection system. [1:52.3.2.8.2]






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Same reasons as stated for li-ion battery.




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Chapter 10 Capacitors

10.1 General.

Capacitor ESS shall comply with the applicable portions of this chapter in addition to the requirements of Chapter 4 .

10.2 Siting.

10.2.1

Outdoor installations shall comply with 4.14.2 .

10.2.2

Rooftop installations shall comply with 4.14.3 .

10.3 Fire Protection.

10.3.1 Fire Suppression.


10.3.1.1

Commodity classifications for specific technologies of storage batteries shall be in accordance with Chapter 5 of NFPA 13.[ 1 :52.3.2.7.1.1]

10.3.1.2


10.3.2 Smoke Detection.

An approved automatic smoke detection system shall be installed in rooms containing stationary battery storage systems inaccordance with NFPA 72 and the required automatic smoke detection system shall be supervised by an approved central,proprietary, or remote station service or a local alarm that will give an audible signal at a constantly attended location.[ 1 :52.3.2.7.2]

10.3.3 Fire Command Centers.

Fire command centers in buildings containing capacitor ESS shall include signage, or readily available documentation, thatdescribes the location of the systems, the types of capacitors present, operating voltages, and location of electricaldisconnects.


Suggest deleting Chapter 10 in its entirety. Capacitor ESS are electro-chemical ESS and they are therefore covered by Chapter 9. Also the requirements in the Chapter 10 draft seemed to be incomplete.




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10.3 Fire Protection.

10.3.1 Fire Suppression.

Rooms containing stationary storage battery systems shall containing capacitor ESS shall be protected by an automaticsprinkler system installed in accordance with NFPA 13.

10.3.1.1

Commodity classifications for specific technologies of storage batteries for capaitor ESS shall be in accordance with Chapter 5of NFPA 13. [1:52.3.2.7.1.1]

10.3.1.2

If the storage battery types are the type of capacitor ESS is not specifically addressed in Chapter 5 of NFPA 13, the AHJ shallbe permitted to approve the fire suppression system based on full-scale fire and fault condition testing conducted or witnessedand reported by an approved laboratory. [1:52.3.2.7.1.2]


An approved automatic smoke detection system shall be installed in rooms containing stationary battery storage systemscontaining capacitor ESS in accordance with NFPA 72 and the required automatic smoke detection system shall be supervisedby an approved central, proprietary, or remote station service or a local alarm that will give an audible signal at a constantlyattended location. [1:52.3.2.7.2]




It appears much of the text may have been adapted from provisions applicable to battery energy storage systems. The intent of the proposed changes is to modify the requirements so they refer to the type of ESS covered in Chapter 10, that being capacitor ESS.




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Rooms containing stationary storage battery systems shall Capacitor ESS shall be protected by an automatic sprinkler systeminstalled in accordance with NFPA 13.


Corrected naming.



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10.3.1.1

Commodity classifications for specific technologies of storage batteries shall of Capacitor ESS shall be in accordance withChapter 5 of NFPA 13. [1:52.3.2.7.1.1]


Corrected wrong naming.



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10.3.1.2

If the storage battery types the Capacitor ESS types are not specifically addressed in Chapter 5 of NFPA 13, the AHJ shall bepermitted to approve the fire suppression system based on full-scale fire and fault condition testing conducted or witnessed andreported by an approved laboratory. [1:52.3.2.7.1.2]





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An approved automatic smoke detection system shall be installed in rooms containing stationary battery storage systems incontaining capacitor ESS in accordance with NFPA 72 and the required automatic smoke detection system shall be supervisedby an approved central, proprietary, or remote station service or a local alarm that will give an audible signal at a constantlyattended location. [1:52.3.2.7.2]





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Need to define Fire Control Center.




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Chapter 16 Hydrogen Energy Storage Systems (Reserved)

16.1 Used lithium-ion Batteries. The storage of used and off specification lithium batteries shall comply with this Chapter.

16.2 Gathering locations . Indoor storage of used and off specification lithium-ion batteries being gathered for shipment torecycling facilities shall be permitted in industrial, mercantile, storage or special hazard occupancies protected by an automaticsprinkler system complying with this standard. Batteries quantities shall not exceed one cubic ft. (0.03 m3) per fire area, andthe batteries shall be stored in open top noncombustible containers spaced a minimum 3 ft. (914 mm) from combustiblematerials and a minimum 10 feet (3048 mm) from exits from the room, space or building.

16.3 Consumer use or battery sale locations. Rooms or spaces not exceeding 100 sq. ft. in size associated with consumeruse locations or mercantile battery sale recycling activities. The rooms or spaces shall be separated from the remainder of thebuilding areas by two-hour fire barriers constructed in accordance with and two-hour horizontal assemblies constructed inaccordance with the local building code. The room or space shall be protected by a radiant-energy detection system installedin accordance with NFPA 72 and shall be protected by an automatic sprinkler system designed and installed in accordancewith this standard.

16.4 Indoor storage in mixed uses. Mixed occupancy indoor storage not meeting the limitations of Section 16.2 or Section

16.3 shall be classified as a high hazard occupancy and shall be in rooms or spaces not exceeding 5000 sq. ft. (464 m 2 ) inarea separated from the remainder of the building areas by three-hour fire barriers constructed in accordance with and three-hour horizontal assemblies constructed in accordance with the local building code.

Individual pile sizes shall be limited to sixty-four cubic ft. (1.81 m 3 ) with a 5 foot separation to the next pile. Piles shall not belocated within 10 feet of exits from the room, space or building.

16.4.1 Prevention and Mitigation . Occupancies storing used and off specification lithium batteries shall have a planapproved by the AHJ that provides for the prevention of fire incidents and includes early detection mitigationmeasures.

16.4.2 Fire detection . The room or space shall be protected by a radiant-energy detection system installed inaccordance with NFPA 72.

16.4.3 Fire suppression . The building the battery storage is located in shall be provided with an automatic firesuppression system installed in accordance with this standard. The high hazard battery storage room or space shallbe protected by a water spray automatic suppression system installed in accordance with this standard.

16.4.4 Explosion Protection . Explosion protection shall be installed in accordance with NFPA 68 or NFPA 69.

16.5 Detached buildings . Indoor storage shall be permitted in high hazard detached buildings located more than 100 feet(30.5 M) from buildings, lot lines, public ways, stored combustible materials, hazardous materials, high piled stock and otherexposure hazards. The storage shall comply with the following:

1. Individual rooms or areas inside the building shall not exceed 7,000 sq ft ( 650 m 2 ) and shall be are separatedfrom other areas by three hour fire barriers and three-hour horizontal assemblies constructed in accordance with thelocal building code.

2. The building shall be protected by a radiant-energy detection system installed in accordance with NFPA 72.

3. Any area containing lithium batteries shall be protected by a NFPA 15 water spray automatic suppressionsystem installed in accordance with this standard.

4. Explosion protection shall be installed in accordance with NFPA 68 or NFPA 69.

5. Individual pile sizes shall be limited to sixty-four cubic ft. (1.81 m3) with a 5 foot separation to other piles, walls,appliances and equipment. Piles shall not be located within 10 feet of exits from the room, space or building. Thereshall be no more than 64 piles per room or space.

6. A plan approved by the fire code official that provides for the prevention of fire incidents and includes earlydetection mitigation measures

16.6 Outdoor storage. Outdoor storage shall comply with the following:

1. Individual pile sizes shall be limited to sixty-four cubic ft. (1.81 m3)

2. Piles located outdoors shall be separated by a minimum 100 feet (30.5 M) from the following exposures:

a) Lot lines

b) Public ways

c) Buildings

d) Stored combustible materials

e) Hazardous materials

f) High-piled stock

g) Other exposure hazards

Clearances are permitted to be reduced to 3 ft. (914 mm) when a 3-hour free standing fire barrier, suitable for exterioruse, and extending 15 ft. (1.5 m) above and extending 15 ft (1.5 m) beyond the physical boundary of the pile isprovided to protect the exposure.



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These provisions are derived from code development work of the FCAC ESS Work Group. It addresses the storage of used (recycled) or off spec batteries. The batteries, modules and/or cells are no longer installed within systems and no longer have the protection features of the systems.



Public Input No. 587-NFPA 855-2017 [Chapter 16 [Title Only]]




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Public Input No. 587-NFPA 855-2017 [ Chapter 16 [Title Only] ]

Hydrogen Energy Storage Systems (Reserved) Storage of Used or off-specification batteries


This chapter heading is not needed, fuel cells of all types are cover by Chapter 11. It is proposed to use this chapter for technical requirements applicable to the storage of used or off-specification batteries.



Public Input No. 588-NFPA 855-2017 [Chapter 16]




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Public Input No. 160-NFPA 855-2017 [ Section No. A.3.3.9 ]

A.3.3.9 Normally Unoccupied Building Service Equipment Support Area.

Normally unoccupied building service support areas are often found in attics, crawl spaces, chases, and interstitial areas wherethe space is vacant or intended exclusively for routing ductwork, cables, conduits, piping, and similar services and is rarelyaccessed. In such spaces, it is often difficult or impossible to fully comply with the egress requirements of Chapter 7 of NFPA101 . Where portions of such spaces are routinely visited for storage, maintenance, testing, or inspection, that portion isexcluded from this definition, but the remainder of the space might be considered a normally unoccupied building serviceequipment support area. Storage and fuel-fired equipment would not be expected to be permitted in these locations. Roofs arenot considered to be normally unoccupied building service equipment support areas. [ 101 , 2018]


This definition is for a term that is never used in the standard and should be removed.





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A.3.3.9 Normally Unoccupied Building Service Equipment Support Area.

Normally unoccupied building service support areas are often found in attics, crawl spaces, chases, and interstitial areas wherethe space is vacant or intended exclusively for routing ductwork, cables, conduits, piping, and similar services and is rarelyaccessed. In such spaces, it is often difficult or impossible to fully comply with the egress requirements of Chapter 7 of NFPA101 . Where portions of such spaces are routinely visited for storage, maintenance, testing, or inspection, that portion isexcluded from this definition, but the remainder of the space might be considered a normally unoccupied building serviceequipment support area. Storage and fuel-fired equipment would not be expected to be permitted in these locations. Roofs arenot considered to be normally unoccupied building service equipment support areas. [ 101 , 2018]


See related submission on the definition of Normally Unoccupied Building Service Equipment Support Area. This term is not used in the body of the standard.




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Public Input No. 559-NFPA 855-2017 [ Section No. A.4.1 ]

A.4.1

Chapter 4 requirements are intended to be applicable to all ESS technologies. However, it is recognized that hazards andmitigation requirements differ among the various ESS technologies covered by Chapter 5 Chapter 9 through Chapter 12 17 .This section allows requirements in those chapters to supplement or supersede the general requirements of Chapter 4.


Editorial to align the text with the contents of the standard.




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A.4.2.1

It is envisioned that equipment provided will be either pre-engineered ESS or prepackaged ESS, both of which are to be listedin accordance with UL 9540. ESS that are not listed in accordance with UL 9540 should be documented and verified asmeeting the provisions of this standard using the equivalency requirements in Section 1.5, where technical documentationprovided shows the ESS that is proposed results in a system that is no less safe than a system meeting the construction andperformance requirements of UL 9540.

In specific instances, this standard will not require equipment such as lead-acid batteries to be listed. If nonlisted equipment isto be evaluated for compliance with UL 9540, the evaluation and documentation should be provided as part of a fieldevaluation conducted by an approved third-party certification organization.


The last line seems to give direction to something that is not part of the standard: How to evaluated nonlisted equipment. If this line is germane to the standard, please put it in another location so the reader is not misled into thinking it is expected that non-listed Pb-acid batteries will be evaluated for compliance with UL 9540 through some field evaluation conducted by an approved third-party certification organization. I don't see a need for this level of review of Pb-acid batteries.




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A.4.2.1

It is envisioned that equipment provided will be either pre-engineered ESS or prepackaged ESS, both of which are to be listedwhere components arelisted in accordance with UL 9540, 1741, or1973 . ESS that are not listed in accordance with these UL9540 standards should be documented and verified as meeting the provisions of this standard using the equivalencyrequirements in Section 1.5, where technical documentation provided shows the ESS that is proposed results in a system thatis no less safe than a system meeting the construction and performance requirements of UL 9540.

In specific instances, this standard will not require equipment such as lead-acid batteries to be listed. If nonlisted equipment isto be evaluated for compliance with UL 9540, the evaluation and documentation should be provided as part of a field evaluationconducted by an approved third-party certification organization.


Removes reference to pre-packaged as that product does not exist.





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A.4.3.2

Adequate working space is vital for electrical safety related work practices. NFPA 70, Article 110, provides working spacerequirements for electrical equipment. NECA 416 is another installation standard that provides guidelines for working spacerequirements.NFPA 70 Article 706 is also an allowable standard.


Inclusion of a more specific standard to ESS.




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Public Input No. 562-NFPA 855-2017 [ Section No. A.4.3.6.4 ]

A.4.3.6.4

ESS installed in residential garages in garages serving one- or two-family dwelling or townhouses should not be installed in alocation where a motor vehicle being parked in the garage could come in contact with the ESS. Protection can be provided byapproved barriers, by locating the ESS upon a 6 in. (152.4 mm) high platform located to the side of the garage, by locating theESS components at a level above the potential impact height, or by recessing the ESS to one side of the space where thegarage door is not the full width of the garage.


See proposed revision to text in the standard related to the use of the term residential. I believe the intent is to address only garages serving houses if you will. The term residential includes houses but it can also include multi-family buildings as well as hotels; each of which can have larger garages.




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Public Input No. 397-NFPA 855-2017 [ Section No. A.4.8.2.1.2 ]

A.4.8.2.1.2

Gaseous agent fire suppression systems can be used to protect ESS fires in either of the following two ways:

(1) Total flooding systems are used where there is a permanent enclosure around the fire hazard that is adequate to enablethe design concentration to be built up and to be maintained for the period of time required to ensure the complete andpermanent extinguishment of a fire for the specific combustible materials involved. For total flooding systems, potentialleakage sources should be included in the gaseous agent design quantities, which should include leakage throughventilation dampers. Usually ventilation dampers are either gravity actuated (i.e., close when the ventilation fansautomatically shut down upon gaseous agent discharge) or pressure actuated (i.e., close by means of counterweight and apressure-operated latch that is activated by the gaseous agent). Leakage from the interface between the enclosure wallsand the foundation should also be taken into consideration. For ESS enclosures where the normal temperature of theenclosure exceeds 200°F (93°C) or is below 0°F (−18°C), gaseous agent levels should be adjusted as required by theappropriate NFPA standard or the manufacturer’s instruction manual.

(2) Local application systems are used for the extinguishment of surface fires of combustible gases, liquids, or solids, wherethe fire hazard is not enclosed or where the enclosure does not conform to the requirements for a total flooding system.For local application systems, it is imperative that the entire fire hazard be protected. The hazard area should include allareas that are subject to spillage, leakage, splashing, condensation, and so forth, and are of combustible materials thatmight extend a fire outside the protected area or lead a fire into the protected area. This type of hazard could necessitatedikes, drains, or trenches to contain any combustible material leakage. When multiple ESS equipment fire hazards are inan area such that they are interposing, provisions should be made to ensure that the hazards can be protectedsimultaneously, which could involve subdividing the hazards into sections and providing independent protection to eachsection.

To reduce potential downtime, gaseous agent fire suppression systems should generally be designed to have the capacity tosupply two full discharges to avoid having to keep the ESS shut down until the gaseous agent reservoir can be replenished,particularly after a minor fire or accidental discharge. Two full discharges should use 90 percent of the total gaseous agentreservoir capacity as an optimum design; however, up to 95 percent is acceptable. For applications where ambienttemperatures are above the normal operating conditions of the gaseous agent reservoir, a shelter with ventilation openings oran equivalent alternative should be used. Where ambient temperatures are below the normal operating conditions of thegaseous agent reservoir, reservoir heaters (such as immersion heaters) and instrument line heaters should be used or, whereapplicable, the reservoir can be superpressurized with nitrogen to maintain the required flows and pressures in a low-temperature environment. Warning signs and safety instructions are required on some types of gaseous agent systems. Theuser should refer to the appropriate NFPA standards for those systems for detailed requirements.


Reducing downtime is a commercial decision between the customer and manufacturer and does not impact safety.




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Public Input No. 296-NFPA 855-2017 [ Section No. A.4.8.2.1.2.1 ]

A.4.8.2.1.2.1

Where total flooding gaseous systems are used, the ESS enclosure should be arranged for minimum leakage by automaticshutdown of fans and automatic closing of doors, ventilation dampers, and other openings. During operation of an ESS, thereis a need for substantial amounts of cooling and ventilation air. This air Residual air flow will not stop immediately upon ESSfan shutdown and should be considered in the extinguishing system design.


In many cases, ESS operation does not require substantial amounts of cooling and ventilation air. This is not the case for telecommunications and data center where the cooling load of the battery plant is actually very low. The sentence is misleading and should be removed.




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A.4.8.4.2 1

This requirement targets rooms, enclosures, and containers, not ESS in cabinets installed outdoors. During abnormalconditions such as a fire, when the ESS is off gassing, a mixture of flammable gases such as CO, H2, ethylene, methane,

benzene, HF, HCl, and HCN is produced, which presents a deflagration hazard when confined within a room, enclosure, orcontainer. The deflagration prevention measures are covered in Chapter 8 of NFPA 69. The design of the exhaust system mustbe able to maintain the combustible concentration in the room, enclosure, or container at or below 25 percent of the LFL of themixture of gases given off. The design is based upon the emission rate of the mixture of gases obtained by actual testing of theESS.

The emission rate of the mixture of gases and Lower Flammability Limit (LFL) of the mixture shall be measured when aninternal fire condition is created within a single module in the initiating cabinet or container as in UL 9540A (proposed).

The alternative deflagration protection method is to provide deflagration venting in accordance with NFPA 68. The explosionanalysis is conducted with the total volume of the room, enclosure, or container being filled with the mixture of gases generatedby the fire. The analysis shall show that the structural members of the room are not compromised.For containers and cabinetsthe top shall open to direct fire or an explosion upwards. The composition of the mixture of gases involved in a fire should beobtained by actual testing. When deflagration vents are installed on an enclosure or a container, walkways, egress paths, fireaccess roads, and other access paths intended to be utilized by first responders should be taken into consideration in locatingthe vents.


Link A4.8.4.1 to corresponding section 4.8.4.1

The proposed UL 9540A will prescribe methods to measure and document the emission rate and LFL of the mixture of gasses from an internal fire condition.

When conducting an explosion analysis, identifying the failure of the structural members of the room is the objective of the analysis.

For containers and cabinets, directing fire and/or explosions upward to protect first responders in the direct vicinity of the affected ESS is the objective.




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A.4.8.4.3

This requirement targets rooms, enclosures, and containers, not ESS in cabinets installed outdoors. During abnormalconditions such as a fire, when the flooded lead-acid or VRLA batteries will be off gassing, there will be a mixture of flammable,of corrosive , and toxic gases, such as SO2, H 2 , CO, propane, and HCl. Upon detection, increased exhaust must be

designed in accordance with the requirements of Chapter 8 of NFPA 69. The combustible concentration must be maintained ator below 25 percent of the LFL of the mixture of gases given off. The emission rate of the mixture of gases is obtained byactual testing.

The alternative deflagration protection method is to provide deflagration venting in accordance with NFPA 68. The explosionanalysis is conducted with the total volume of the room, enclosure, or container being filled with the mixture of gases generatedby the fire. The composition of the mixture of gases involved in a fire should be obtained by actual testing. When deflagrationvents are installed on an enclosure or a container, walkways, egress paths, fire access roads, and other access paths intendedto be utilized by first responders should be taken into consideration in locating the vents.


It is not clear to me that high levels of combustible gasses are given off during fires of flooded Pb-acid or VRLA batteries. Low levels of Hydrogen under certain use conditions, are given off. Toxic and corrosive gasses are released in a fire event. But I am not aware of combustible gasses released during a fire. If there is testing to show this is a problem, I would like to have it reviewed before the standard is released with the proposed language.




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A.4.8.4.3

This requirement targets rooms, enclosures, and containers, not ESS in cabinets installed outdoors. During abnormalconditions such as a fire, when the flooded lead-acid or VRLA batteries will be off gassing, there will be a mixture of flammable,corrosive, and toxic gases, such as SO2, H2, CO, propane, and HCl. Upon detection, increased exhaust must be designed in

accordance with the requirements of Chapter 8 of NFPA 69. The combustible concentration must be maintained at or below 25percent of the LFL of the mixture of gases given off. The emission rate of the mixture of gases is obtained by actual testing.Theemission rate of the mixture of gases and Lower Flammability Limit (LFL) of the mixture shall be measured when an internalfire condition is created within a single module in the initiating cabinet or container as in UL 9540A (proposed).

The alternative deflagration protection method is to provide deflagration venting in accordance with NFPA 68. The explosionanalysis is conducted with the total volume of the room, enclosure, or container being filled with the mixture of gases generatedby the fire.The analysis shall show that the structural members of the room are not compromised. For containers and cabinetsthe top shall open to direct fire or an explosion upwards. The composition of the mixture of gases involved in a fire should beobtained by actual testing. When deflagration vents are installed on an enclosure or a container, walkways, egress paths, fireaccess roads, and other access paths intended to be utilized by first responders should be taken into consideration in locatingthe vents.


The proposed UL 9540A will prescribe methods to measure and document the emission rate and LFL of the mixture of gasses from an internal fire condition.

When conducting an explosion analysis, identifying the failure of the structural members of the room is the objective of the analysis.

For containers and cabinets, directing fire and/or explosions upward to protect first responders in the direct vicinity of the affected ESS is the objective.




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Public Input No. 301-NFPA 855-2017 [ Section No. A.4.11 ]

A.4.11

Signage provides important information for fire fighters and emergency responders who respond to a fire or other incident in abuilding or facility in which ESS is contained. Being able to quickly understand the following is critical to maintain their safety:

(1) The presence and location of multiple disconnects that can be used to de-energize and isolate portions of the electricalsystem

(2) The location of ESS rooms and areas and the types of ESS within the room or area

(3) Significant hazards associated with the ESS technology present

The intent of this standard is to allow flexibility in the exact wording used on required signage so conflicts are not created withother codes and standards.

Some jurisdictions can choose to supplement these required markings with NFPA 704 hazard identification system markings orthe fire fighter safety building marking system described in Annex E of NFPA 1. However, the hazards for some ESStechnologies are may have hazards not clearly categorized in the hazard ranking system, or present no hazards .


The proposed wording is inflammatory and implies there are more hazards outside of the 704 nomenclature. I am not sure this is the case.




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A.4.14.2

Occupiable ESS are installations where personnel can enter the enclosure or container housing the system or systemcomponents for any reason reasons other than service and maintenance . This includes does not include ESS enclosed withinan outer enclosure similar to an ISO shipping container and where personnel can partially enter into the outer enclosure toperform these activities, which are normally unoccupied and not considered an occupied work center .


Enclosures and ISO containers housing energy storage systems should not be considered occupiable ESS, occupied work centers or buildings, since they are normally unoccupied. This definition would contradict the vast majority of current installations around the world.




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A.4.14.2

Occupiable ESS are installations where personnel can enter the enclosure or container housing the system or systemcomponents for any reason. This includes ESS enclosed within an outer enclosure similar to an ISO shipping container andwhere personnel can partially fully enter as part of normal operations into the outer enclosure to perform these activities. Thepresence of a Normally Unnocupied Building Service Equipment Support Area does not make an enclosure Occuipiable if itwould not otherwise be considered as such.


The term “partially enter” here is too vague - does this include an enclosure that you can put your hand inside? We suggest replacing this with “fully enter” and we agree that enclosures which are fully entered as part of normal operations should comply with egress and other relevant provisions of the building code. In the case of Utility-scale installations, access is restricted to authorized and trained personnel who adhere to strict safety protocols when accessing the ESS.




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A.4.14.2

. Occupiable ESS are installations where personnel can enter the enclosure or container housing the system or systemcomponents for any reason. This includes ESS enclosed within an outer enclosure similar to an ISO shipping container andwhere personnel can partially enter into the outer enclosure to perform these activities. are intended to enter for normaloperation


There is no clear definition on what partial entry would be for applicability of this clause. Most of the ISO shipping containers are installed in remote location and not meant to be typically Occupiable.




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A.4.14.2

Occupiable ESS are installations where personnel can enter the enclosure or container housing the system or systemcomponents for any reason. This includes ESS enclosed within an outer enclosure similar to an ISO shipping container and butnot where trained personnel can familiar with the equipment only partially enter into the outer enclosure to perform theseactivities.


for equipment installed outdoors in a noncombustible container or enclosure and where a trained service person is the only person that may enter, the designation as "occupiable" means it is subject to the same requirements as an ESS installed indoors. Clearly the risk to both people and property is reduced in the outdoor installation.





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Public Input No. 589-NFPA 855-2017 [ New Section after A.6.4.2 ]

A 6.4 Existing Systems

After an ESS is commissioned and put into operation it becomes an existing system. There may come a time whenthat existing system is altered, repositioned, repaired,added to, renovated, renewed or in some way modified beyondsimple sevice or replacement of in kind parts and components. When any of those activities are conducted on thesystem there is no documentation or verification that the system will properly operate (e.g. the originalcommissioning plan and commissioning report would not necessarily support the system since it was modified insome way by one or more of these activities). That necessitates the resultant system be commissioned again. Whilethe term recommissioning might be used in this case that term can also be used to describe the conduct (again) of aninititial commissioning activity on a new system where that initial commissioning process failed and was redone. With respect to an existing system that has been modified in some way the intent of the standard is simply tocommission the system again in accordace with the commissining requirements in Section 6.1.


To provide additional insight into the commissioning requirements for existing systems.




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A.6.4.2

Listed software or hardware changes are not considered system renewals.


Changes that do not affect the system's listed certifications as documented in Section 4.2.1 should not be required to undergo recommissioning since these changes do not affect the listing, and thus should not have material impact on the safety of the system. If changes do impact listing certifications, then recommissioning may be necessary. Requiring recommissioning due to system changes is unnecessary since this is covered by existing standards, such as UL9540.




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A.6.4.2

Listed software changes are considered system renewals, but do not require permitting .


According to section E.1.1 Application and this section which classifies software change as a renewal, permits should be secured from and issued by the authority having jurisdiction for a software change. This seems overly burdensome.

Furthermore, renewals are not defined, nor are renovation, alteration, nor repair. Some distinction between these should be made so the standard is clear.




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A.8.1.1

Considerations that should be included in the decommissioning plan would include but not be limited to the following:

(1) An identification of all energy sources (batteries, connected batteries in other enclosures or structures), inverters [akapower conversion systems (PCS)], dc bus precharge power supplies, UPS, support equipment with batteries, and ac or dcauxiliary power equipment and distribution systems

(2) Information about PPE and requirements for use as needed (site dependent), noting that each electrical equipment cabinetshould already have shock and arc flash warning labels applied as per NFPA 70E

(3) A notification that the ESS should be discharged to its safe state of charge (SOC) for transport, for example, less than 30percent state of charge (SOC) for lithium-ion

(4) Assurance that during the decommissioning process, critical support equipment such as, but not limited to, fire detectionand suppression equipment, emergency lighting, electrical circuits to facilitate decommissioning, and so forth, remainoperational to the extent possible

(5) A warning not to disconnect any ESS grounding until all energy sources are isolated and locked out

(6) A notification to disconnect and shut down all batteries and support or auxiliary equipment associated with the system or itscomponent parts

(7) Isolation of all energy sources, starting with those with highest fault energy, by isolating the ac point of interconnection,then isolating strings, then isolating the individual battery modules

(8) The need to mechanically uninstall battery trays and place them into original or equivalent packing materials or protectterminals

(9) Assurance that the materials are properly classified and packaged based on regulations governing the classification beforeremoving material from the site (e.g., requirement that shipments on public roads comply with DOT regulations, includingUN/DOT 38.3-tested packing for Li-ion batteries and UN2800 for VRLA nonspillable batteries)

(10) The need to remove batteries from other equipment associated with the system as part of decommissioning and prior toremoval


Recommendation of 30 percent state of charge (SOC) is not, as far as I can tell, universal. It is true for Lithium-ion, but maybe not for Pb-acid or other technologies.




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Public Input No. 331-NFPA 855-2017 [ Section No. B.2.4 ]

B.2.4

Electrical hazards for persons working with ESS where they might come in contact with energized parts greater than 50 V Vac

or 100Vdc and exposed to arcing of electric energy with an incident energy level of 1.2 cal/cm2 (5 J/cm2) (potential to causesecond-degree burns on skin), are electrical shock and arc flash as identified in NFPA 70E. Electrical hazards to emergencyresponders from ESS that have been exposed to fire or other emergency incidents need to be addressed, including thepotential for arc faults and shock hazards due to shorting from damaged parts and water. Since first responders are not trainedelectrical workers and might not have appropriate PPE for direct contact with live parts or arc flash incidents, acceptable levelsof voltage and incident energy need to be reduced from that allowed for trained workers with suitable PPE.


The 50V limit should be clarified as being for ac circuits. A dc value should also be included.




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B.2.4

Electrical hazards for persons working with ESS where they might come in contact with energized parts greater than 50 V ac

and 100 V dc and exposed to arcing of electric energy with an incident energy level of 1.2 cal/cm2 (5 J/cm2) (potential to causesecond-degree burns on skin), are electrical shock and arc flash as identified in NFPA 70E. Electrical hazards to emergencyresponders from ESS that have been exposed to fire or other emergency incidents need to be addressed, including thepotential for arc faults and shock hazards due to shorting from damaged parts and water. Since first responders are not trainedelectrical workers and might not have appropriate PPE for direct contact with live parts or arc flash incidents, acceptable levelsof voltage and incident energy need to be reduced from that allowed for trained workers with suitable PPE.


The data is clear that dc voltages below 100 volts are as safe or safer than 50 volts ac in terms of electric shock.



Public Input No. 501-NFPA 855-2017 [Section No. 4.5.1] related




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B.3.2 Chemical Hazards.

Under normal operating conditions, the potential exists for exposure to hazardous materials by workers in contact with thesystem for maintenance, repair, and replacement of systems. OHSA and NIOSH have guidelines on exposures to hazardousmaterials, including limits for workers that have the potential for exposure during normal operation maintenance, and so forth.

Examples of chemical hazards are as follows:

(1) Examples of liquid hazards are as follows:

(2) Corrosive electrolytes: Batteries with electrolytes in the range of pH ≤2 or ≥11.5 are considered corrosive (

acid

(a) acidic or caustic). This is an issue with systems with these electrolytes, where there can be a situation of leaks orspills during maintenance or normal operation. There should be measures for spill containment, and workers shouldhave appropriate safe work procedures protective clothing to work around systems with these corrosive liquids.

(b) Toxic liquids: The potential exists for exposure to toxic liquids during normal operating, servicing, and maintenance ofsome systems. Guidance for worker exposure to toxic liquids can be found in OSHA hazardous materials guidelines.Workers in contact with these systems need to be aware of potential hazards and have appropriate procedures andequipment/PPE to avoid these hazards.

(3) Oxidizers: The potential exists for oxidizers to be present within the ESS. An oxidizer will increase the flammabilitypotential of other materials. NFPA 400, Annex G, provides information on tests to classify an oxidizer material andidentifies known oxidizing materials under their classifications. NFPA 400, Annex G, also provides guidance on safetymeasures to use when there are significant exposed quantities of known oxidizers, which can occur during normalmaintenance conditions of certain ESS technologies that contain them.

(4) Gases — Toxic gases: The potential exists for exposure to toxic gases under normal conditions of maintenance andservice of some ESS systems. OSHA and NIOSH provide guidance for exposures, including permissible exposure limits(PEL), recommended exposure limits (REL) for exposure during an 8- or 10-hour workday, ceiling limits, which are theupper limit of a safe exposure, and IDLH, which represents concentrations that are immediately dangerous to life andhealth.

(5) Solids: Water-reactive and toxic metals that might be contained in some battery technologies typically are not exposedduring routine maintenance and servicing of these systems but can present issues under abnormal conditions. Batteriescontaining these hazardous materials should be marked with the NFPA 704 diamond hazard symbols.


Revised for consistency between "acidic" and "caustic".




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B.3.2 Chemical Hazards.

Under normal operating conditions, the potential exists for exposure to hazardous materials by workers in contact with thesystem for maintenance, repair, and replacement of systems. OHSA and NIOSH have guidelines on exposures to hazardousmaterials, including limits for workers that have the potential for exposure during normal operation maintenance, and so forth.

Examples of chemical hazards are as follows:

(1) Examples of liquid hazards are as follows:

(2) Corrosive electrolytes: Batteries with electrolytes in the range of pH ≤2 or ≥11.5 are considered corrosive (acid orcaustic). This is an issue with systems with these electrolytes, where there can be a situation of accidental leaks orspills during maintenance or

normal

(a) operation. There should be measures for spill

containment

(a) control , and workers should have appropriate safe work procedures protective clothing to work around systems withthese corrosive liquids.

(b) Toxic liquids: The potential exists for exposure to toxic liquids during normal operating, servicing, and maintenance ofsome systems. Guidance for worker exposure to toxic liquids can be found in OSHA hazardous materials guidelines.Workers in contact with these systems need to be aware of potential hazards and have appropriate procedures andequipment/PPE to avoid these hazards.

(3) Oxidizers: The potential exists for oxidizers to be present within the ESS. An oxidizer will increase the flammabilitypotential of other materials. NFPA 400, Annex G, provides information on tests to classify an oxidizer material andidentifies known oxidizing materials under their classifications. NFPA 400, Annex G, also provides guidance on safetymeasures to use when there are significant exposed quantities of known oxidizers, which can occur during normalmaintenance conditions of certain ESS technologies that contain them.

(4) Gases — Toxic gases: The potential exists for exposure to toxic gases under normal conditions of maintenance andservice of some ESS systems. OSHA and NIOSH provide guidance for exposures, including permissible exposure limits(PEL), recommended exposure limits (REL) for exposure during an 8- or 10-hour workday, ceiling limits, which are theupper limit of a safe exposure, and IDLH, which represents concentrations that are immediately dangerous to life andhealth.

(5) Solids: Water-reactive and toxic metals that might be contained in some battery technologies typically are not exposedduring routine maintenance and servicing of these systems but can present issues under abnormal conditions. Batteriescontaining these hazardous materials should be marked with the NFPA 704 diamond hazard symbols.


Leak are accidental, they are not part of normal operation as indicated in the original text. Also spill control is required per the codes and standards, spill containment is not.




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B.3.3 Electrical Hazards.

Under normal operating conditions some battery systems might have electrical hazards that need to be addressed as part ofoperation and maintenance. Electrical hazards that can occur during normal operating conditions follow:

(1) Electrical shock: ESS with voltages above 50 V ac or 100 V dc (per NFPA 70E limits for electrical shock) can posehazards to trained workers who might come in contact with live parts during operation and servicing of the systems. It isnecessary that appropriate labeling and procedures and protective equipment are utilized by workers when servicing thesesystems.

(2) Arc flash: ESS that have an incident energy level greater than 23.8 ft-lb/in.2 (5 J/cm2) should have the arc flashboundaries calculated, identified through markings, and proper procedures and equipment in place to prevent worker injuryfrom arc flash during normal operation and servicing.

(3) Stranded or stored energy hazards: Energy that can be accumulated and reserved for future use, generally in the form ofelectricity, is stranded or stored energy. An example of a stranded or stored energy hazard is worker exposure to ESS thatare not discharged sufficiently or ESS that are damaged and where the potential exists for electric shock and arc flashissues. For normal operating conditions, sites housing commercial and industrial battery ESS should maintain onsiteinstructions for isolation of hazardous voltage and energy for maintenance and for discharging batteries for safereplacement and disposal. Residential and smaller commercial systems should have information provided and access totrained technicians to perform these duties to ensure that stranded and stored energy do not represent a hazard undernormal operating conditions.


The data is clear that dc voltages below 100 volts are as safe or safer than 50 volts ac in terms of electric shock.




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B.4.1 Fire Hazards.

Fire hazards can include the following:

(1) Combustible/flammable concentrations due to overheating and venting of flammable gases near sources of ignition canoccur during emergency/abnormal conditions. If concentrations of vented gases such as hydrogen or hydrocarbons aresufficient to create combustible/flammable concentrations in the presence of hot parts, there will be ignition resulting ineither a fire or an explosion. All batteries, with the exception of hermetically sealed types such as sodium beta , havemeans to relieve internal pressure when overheated to prevent explosions of the battery cell from overpressurization.

(2) There can be fires due to overheating of electrical parts under abnormal conditions such as short circuits.


hydrogen is not the only vented gas. Most Li-ion batteries today have ethylene carbonate electrolyte solvents and the vented gases are CO and hydrocarbon variants. this is important for LEL and flammability considerations. Hydrogen is a minor concentration gas during venting of Li-ion batteries. Lastly, naming of a battery type (sodium beta) is unnecessary and because this isn't even a commercial battery today, it doesn't need to be named out of all of the others.




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Public Input No. 512-NFPA 855-2017 [ Section No. B.5.1 [Excluding any Sub-Sections] ]

A flow battery is an energy storage component similar to a fuel cell that stores its active materials in the form of two electrolytesexternal to the reactor interface. When in use, the electrolytes are transferred between reactor and storage tanks. Twocommercially available flow battery technologies are zinc bromine and vanadium redox. Zinc bromine flow batteries have zinc atthe negative electrode and bromide at the positive electrode with an aqueous solution containing zinc bromide and othercompounds contained in two separate reservoirs. During charging, energy is stored as zinc metal within the cell andpolybromide in the cathode reservoir. During discharge, the zinc is oxidized to zinc oxide and the bromine is reduced tobromide. Vanadium redox flow batteries contain vanadium salts in various stages of oxidation in a sulfuric acid electrolyte.Charging and discharging the battery changes the oxidation state of the vanadium in the electrolyte solutions.



Conventional_Flow_Compare.pdf Comparison to conventional flow batteries


Revise language to more broadly define zinc bromide batteries



Public Input No. 504-NFPA 855-2017 [Section No. 3.3.1.1] Similar definition update




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A flow battery is an energy storage component similar to a fuel cell that stores its active materials in the form oftwo electrolytes external to the reactor interface. When in use, the electrolytes are transferred between reactorand storage tanks. Two commercially available flow battery technologies are zinc bromine and vanadium redox.Zinc bromine flow batteries have zinc at the negative electrode and bromide at the positive electrode with anaqueous solution containing zinc bromide and other compounds contained in two separate reservoirs. Duringcharging, energy is stored as zinc metal within the cell and polybromide in the cathode reservoir. Duringdischarge, the zinc is oxidized to zinc oxide and the bromine is reduced to bromide. Vanadium redox flowbatteries contain vanadium salts in various stages of oxidation in a sulfuric acid electrolyte. Charging anddischarging the battery changes the oxidation state of the vanadium in the electrolyte solutions.



Conventional_Flow_Compare.pdf Comparison to conventional flow batteries ✓


Revise language to more broadly define zinc bromide batteries



Public Input No. 504-NFPA 855-2017 [Section No. 3.3.1.1] Similar definition update




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Copyright Assignment

I, Mark Collins, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this PublicInput (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights,including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Ihereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Mark Collins, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C...

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Lead acid batteries have lead dioxide as the active material of their positive electrode and metallic lead as the negativeelectrode with a 1.28 specific gravity sulfuric acid solution electrolyte. During discharge, both positive and negative electrodesare converted to lead sulfate. There are two basic categories of lead-acid batteries:

(1) Vented lead-acid batteries, also called wet cell or flooded lead-acid batteries

(2) Valve-regulated lead-acid (VRLA) batteries, sometimes referred to as starved electrolyte or maintenance-free batteries

Vented lead-acid batteries require ongoing maintenance of the electrolyte, and the contents of the battery are open to theatmosphere through a vent/flame arrester assembly. VRLA batteries are generally sealed to the atmosphere and contain avalve that can open when pressure builds up in the battery and then close again. The electrolyte in VRLA batteries isimmobilized either through use of a gel electrolyte or through absorption of the electrolyte in a porous AGM separator. Lead acidbattery construction consists of an internal electrode plate built into the monobloc battery housing.


Some Pb-acid batteries use a lower specific gravity solution: 1.195 for example. No need to be so specific.




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Lead acid batteries have lead dioxide as the active material of their positive electrode and metallic lead as the negativeelectrode with a 1.28 specific gravity dilute sulfuric acid solution electrolyte. During discharge, both positive and negativeelectrodes are converted to lead sulfate. There are two basic categories of lead-acid batteries:

(1) Vented lead-acid batteries, also called wet cell or flooded lead-acid batteries

(2) Valve-regulated lead-acid (VRLA) batteries, sometimes referred to as starved electrolyte or maintenance-free batteries

Vented lead-acid batteries require ongoing maintenance of the electrolyte typically require periodic water additions , and thecontents of the battery are open to the atmosphere through a vent/flame arrester assembly. VRLA batteries are generally sealedto the atmosphere and contain a valve that can open when pressure builds up in the battery and then close again. Theelectrolyte in VRLA batteries is immobilized either through use of a gel electrolyte or through absorption of the electrolyte in aporous AGM separator. Lead acid battery construction consists of an internal electrode plate built into the monobloc batteryhousing.


The specific gravity of lead-acid batteries varies depending on the design of the cell and typically ranges from 1.210 - 1.350. The important fact for this section is that it is dilute sulfuric acid. The electrolyte does not need maintenance, however periodic water additions are typically necessary. The last sentence does not make sense.




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Public Input No. 226-NFPA 855-2017 [ Section No. B.5.2.1 ]

B.5.2.1 Vented Lead-Acid Batteries.

Hazard considerations for vented lead-acid batteries under normal operating conditions are as follows:

(1) Fire hazards: There is the potential for concentrations of hydrogen from vented lead-acid batteries if the area where thebatteries are located is not properly ventilated. However, this should be taken care of if the installation complies with thecodes.

(2) Chemical hazards: There is the potential for contact with the sulfuric acid electrolyte because these batteries requiremaintenance and are open to the atmosphere. Workers near these batteries need to use proper PPE and take care toprevent exposure to acid when working around the batteries. These systems should be provided with spill control andneutralization per codes.

(3) Electrical hazards: There are electrical hazards associated with routine maintenance of these batteries if they have are athazardous voltage and energy levels.

(4) Stranded or stored energy hazards: There can be the potential for stored or stored energy hazards during maintenance ifthe batteries cannot be isolated for maintenance or replacement of batteries.

(5) Physical hazards: Not applicable.

Hazard considerations for vented lead-acid batteries under emergency/abnormal conditions are as follows:

(1) Fire hazards: There is the potential for concentrations of hydrogen from vented lead-acid batteries due to overheating fromabnormal conditions if the area where the batteries are located is not properly ventilated. Another area that can createproblems during abnormal conditions is the potential for shorting of high current circuits.

(2) Chemical hazards: There is the potential for contact with the corrosive sulfuric acid electrolyte during abnormal conditions,should acids leak or bubble out through openings that might be created if spill containment is not present or sufficient tocontain large quantities of leaked electrolyte . First responders, in emergency situations, need to be aware of potential acidspills that can occur and take appropriate caution around these batteries.

(3) Electrical hazards: Electrical hazards might be present under abnormal conditions if the system is at hazardous voltageand energy levels.

(4) Stranded or stored energy hazards: There can be the potential for stored or stranded energy hazards if batteries aresubject to abnormal conditions.

(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazards under abnormalconditions if accessible parts are overheating or if there is exposure to moving hazardous parts such as fans or exposedpump parts where guards may be missing.


The codes require spill control, not spill containment. Containment, even when present, does not prevent potential contact as the wording implies. We have seen accidents where working in the vicinity of containment has damaged batteries and caused spills of electrolyte. Spill control is sufficient and preferred.




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(2) Chemical hazards: There is the potential for contact with the sulfuric acid electrolyte because these batteries requiremaintenance and are open to the atmosphere. Workers near these batteries need to use proper PPE and take care toprevent exposure to acid when working around the batteries. These systems should be provided with spill control andneutralization per codes.


(4) Stranded or stored energy hazards: There can be the potential for stored or stored energy hazards during maintenance ifthe batteries cannot be isolated for maintenance or replacement of batteries.




(2) Chemical hazards: There is the potential for contact with the corrosive sulfuric acid electrolyte during abnormal conditions,should acids leak or bubble out through openings that might be created if spill containment is not present or sufficient tocontain large quantities of leaked electrolyte. First responders, in emergency situations, need to be aware of potential acidspills that can occur and take appropriate caution around these batteries.



(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazards under abnormalconditions if accessible parts are overheating or if there is exposure to moving hazardous parts such as fans or exposedpump parts where guards may be missing .


The wording is very general, and should be refined. Pb acid batteries normally don't have fans. Any items with a guard removed can be dangerous.




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(2) Chemical hazards: There is the potential for contact with the sulfuric acid electrolyte because these batteries requiremaintenance and are open to the atmosphere. Workers near these batteries but is only a risk when workers are handlingelectrolyte. Workers handling electrolyte need to use proper PPE and take care to prevent exposure to acid whenworking around the batteries . These systems should be provided with spill control and neutralization per codes.


(4) Stranded or stored energy hazards: There can be the potential for stored or stored energy hazards during maintenance ifthe batteries cannot be isolated for maintenance or replacement of batteries .

(5) Physical hazards: Not applicable There are lifting hazards due to the weight of the battery which are only an issue duringinstallation, replacement or removal .



(2) Chemical hazards: There is the potential for contact with the corrosive sulfuric acid electrolyte during abnormal conditions,should acids leak or bubble out through openings that might be created if spill containment is not present or sufficient tocontain large quantities of leaked electrolyte . First responders, in emergency situations, need to be aware of potential acidspills that can occur and take appropriate caution around these batteries.



(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazards under abnormalconditions if accessible parts are overheating or if there is exposure to moving hazardous parts such as fans or exposedpump parts where guards may be missing.


The electrolyte hazard is only an issue if the worker is handling electrolyte. See NFPA 70EA lead-acid battery cannot be turned off so the voltage/energy hazard is always present. It does not matter if you isolate the battery from the system.There are physical hazards when any cell is moved.It does not matter if spill containment is present or not, if the cell is leaking workers are exposed to the electrolyte.The physical hazard as written in the second part does not make sense with respect to lead-acid batteries.



Public Input No. 545-NFPA 855-2017 [Section No. B.5.2.2]




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B.5.2.2 Valve-Regulated Lead-Acid Batteries (VRLA).

Hazard considerations for VRLA batteries under normal operating conditions are as follows;

(1) Fire hazards: There should be no combustible gas generation under normal operating conditions if batteries are operatedas intended to prevent overheating and thermal runaway conditions.

(2) Chemical hazards: These batteries are starved electrolyte types, so there should be no issue with exposure to corrosiveelectrolyte under normal operating conditions.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazards during maintenanceif the batteries cannot be isolated for maintenance or replacement of batteries.


Hazard considerations for VRLA batteries under emergency/abnormal conditions are as follows:

(1) Fire hazards: There is the potential for off-gassing of hydrogen under abnormal conditions when batteries overheat. Thiscan present a potential fire hazard due to combustible concentrations. There can be the potential for thermal runaway if thebatteries are not maintained at appropriate operating parameters. Also, there can be fire hazards due to short-circuitingabnormal conditions.

(2) Chemical hazards: Although these batteries contain corrosive electrolyte, they do not have as much free electrolyte thatcould result in spill hazards similar to vented types. There might be some bubbling of electrolyte or potential for someleakage under abnormal conditions, if battery cases crack or leak.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazards if the batteries areexposed to abnormal conditions that first responders might be exposed to. Damaged batteries might contain stored energythat can be a hazard during disposal if care is not taken.

(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazards under abnormalconditions if accessible parts are overheating or if there is exposure to moving hazards parts such as fans where guardsmight be missing .


The wording is very general, and should be refined. Pb acid batteries normally don't have fans. Any items with a guard removed can be dangerous.




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B.5.2.2 Valve-Regulated Lead-Acid Batteries (VRLA).

Hazard considerations for VRLA batteries under normal operating conditions are as follows;

(1) Fire hazards: There should be no combustible gas generation under normal operating conditions if batteries are operatedas intended to prevent overheating and thermal runaway conditions. is the potential for concentrations of hydrogen fromvented lead-acid batteries if the area where the batteries are located is not properly ventilated. However, this should betaken care of if the installation complies with the codes.

(2) Chemical hazards: These batteries are starved electrolyte types, so there should be no issue with exposure to corrosiveelectrolyte under normal operating conditions.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazards during maintenanceif the batteries cannot be isolated for maintenance or replacement of batteries .

(5) Physical hazards: Not applicable There are lifting hazards due to the weight of the battery which are only an issue duringinstallation, replacement or removal .

Hazard considerations for VRLA batteries under emergency/abnormal conditions are as follows:

(1) Fire hazards: There is the potential for off-gassing of hydrogen under abnormal conditions when batteries overheat. Thiscan present a potential fire hazard due to combustible concentrations. There can be the potential for thermal runaway if thebatteries are not maintained at appropriate operating parameters. Also, there can be fire hazards due to short-circuitingabnormal conditions.

(2) Chemical hazards: Although these batteries contain corrosive electrolyte, they do not have as much free electrolyte thatcould result in spill hazards similar to vented types. There might be some bubbling of electrolyte or potential for someleakage under abnormal conditions, if battery cases crack or leak.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazards if the batteries areexposed to abnormal conditions that first responders might be exposed to. Damaged batteries might contain stored energythat can be a hazard during disposal if care is not taken.

(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazards under abnormalconditions if accessible parts are overheating or if there is exposure to moving hazards parts such as fans where guardsmight be missing.


There is a potential hazard for hydrogen and some ventilation is required in all cases. A lead-acid battery cannot be turned off so the voltage/energy hazard is always present. It does not matter if you isolate the battery from the system.There are physical hazards when any cell is moved.The physical hazard as written in the second part does not make sense with respect to lead-acid batteries.



Public Input No. 542-NFPA 855-2017 [Section No. B.5.2.1] related




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B.5.5.1 Nickel-Cadmium (Ni-Cd) Batteries.

Hazard considerations for Ni-Cd batteries under normal operating conditions are as follows:

(1) Fire hazards: There is the potential for concentrations of hydrogen from vented Ni-Cd batteries if the area where thebatteries are located is not properly ventilated. However, this should be taken care of if the installation complies with thecodes.

(2) Chemical hazards: There is the potential for contact with the corrosive/caustic potassium hydroxide electrolyte becausethese batteries require maintenance and are open to the atmosphere. Workers near these batteries need to use properPPE and take care to prevent exposure to caustic electrolyte when working around the batteries. These systems should beprovided with spill control and neutralization per codes.

(3) Electrical hazards: There are electrical hazards associated with routine maintenance of these batteries if they are athazardous voltage and energy levels.

(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazards during maintenanceif the batteries cannot be isolated for maintenance or replacement.


Hazard considerations for Ni-Cd batteries under emergency/abnormal conditions are as follows:

(1) Fire hazards: There is the potential for concentrations of hydrogen from vented Ni-Cd batteries due to overheating fromabnormal conditions if the area where the batteries are located is not properly ventilated. Another area that might createproblems during abnormal conditions would be the potential for shorting of high-current circuits.

(2) Chemical hazards: There is the potential for contact with the corrosive/caustic potassium hydroxide electrolyte duringabnormal conditions, should electrolyte leak or bubble through openings that might be created if spill containment is notpresent or sufficient to contain large quantities of leaked electrolyte. First responders, in an emergency situation, need tobe aware of potential caustic spills that can occur and take appropriate caution around these batteries. Ni-Cd batteriescontain cadmium, which is toxic and a hazardous waste. Although not exposed under normal conditions, there might bepotential for cadmium in vapors of burning batteries during abnormal conditions.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazards if the batteries areexposed to abnormal conditions where they could still contain hazardous levels of energy. Damaged batteries mightcontain stored energy that can be a hazard during disposal if care is not taken.

(5) Physical hazards: Depending on the design of the system, the The potential exists for physical hazards under abnormalconditions if accessible parts are overheating or if there is exposure to moving hazardous parts such as fans whereguards might be missing .


The wording is very general, and should be refined. Nickel-cadmium batteries normally don't have fans. Any items with a guard removed can be dangerous.




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B.5.5.1 Nickel-Cadmium (Ni-Cd) Batteries.

Hazard considerations for Ni-Cd batteries under normal operating conditions are as follows:

(1) Fire hazards: There is the potential for concentrations of hydrogen from vented Ni-Cd batteries if the area where thebatteries are located is not properly ventilated. However, this should be taken care of if the installation complies with thecodes.

(2) Chemical hazards: There is the potential for contact with the corrosive/caustic potassium hydroxide electrolyte becausethese batteries require maintenance and are open to the atmosphere. Workers near these batteries need to use properPPE and take care to prevent exposure to caustic electrolyte when working around the batteries. These systems should beprovided with spill control and neutralization per codes.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazards during maintenanceif the batteries cannot be isolated for maintenance or replacement.


Hazard considerations for Ni-Cd batteries under emergency/abnormal conditions are as follows:

(1) Fire hazards: There is the potential for concentrations of hydrogen from vented Ni-Cd batteries due to overheating fromabnormal conditions if the area where the batteries are located is not properly ventilated. Another area that might createproblems during abnormal conditions would be the potential for shorting of high-current circuits.

(2) Chemical hazards: There is the potential for contact with the corrosive/caustic potassium hydroxide electrolyte duringabnormal conditions, should electrolyte leak or bubble through openings that might be created if spill containment is notpresent or sufficient to contain large quantities of leaked electrolyte . First responders, in an emergency situation, need tobe aware of potential caustic spills that can occur and take appropriate caution around these batteries. Ni-Cd batteriescontain cadmium, which is toxic and a hazardous waste. Although not exposed under normal conditions, there might bepotential for cadmium in vapors of burning batteries during abnormal conditions.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazards if the batteries areexposed to abnormal conditions where they could still contain hazardous levels of energy. Damaged batteries mightcontain stored energy that can be a hazard during disposal if care is not taken.

(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazards under abnormalconditions if accessible parts are overheating or if there is exposure to moving hazardous parts such as fans where guardsmight be missing.


Codes require spill control, not spill containment. Containment does not prevent accidental contact. Some spills have been caused by working in close proximity to spill containment barriers.




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B.5.6 Sodium Batteries, Aqueous — General Description.

Aqueous sodium batteries, which are also referred to as sodium ion batteries or saltwater batteries, consist of a manganeseoxide positive electrode, a carbon titanium phosphate composite anode, and a saltwater solution electrolyte, and sodium ionsintercalate between the positive and negative electrode during the charge and discharge operation. These sodium batteriesoperate at ambient temperatures with an optimal range of 23°F to 104°F (–5°C to 40°C).

Hazard considerations for aqueous sodium batteries under normal operating conditions are as follows:

(1) Fire hazards: Not applicable There is the potential for concentrations of hydrogen from all aqueous batteries if the areawhere the batteries are located is not properly ventilated. However, this should be taken care of if the installation complieswith the codes.

(2) Chemical hazards: Not applicable


(4) Stranded or stored energy hazards: The potential exists for stranded or stored energy hazards during maintenance if thebatteries cannot be isolated for maintenance.

(5) Physical hazards: Not applicable

Hazard considerations for aqueous sodium batteries under emergency/abnormal conditions are as follows:

(1) Fire hazards: These systems have aqueous electrolytes, so the potential exists for off-gassing of hydrogen under abnormalconditions. The potential might also exist for fire hazards for high-energy systems that are subject to short circuit or otherabnormal conditions.

(2) Chemical hazards: Not applicable.


(4) Stranded or stored energy hazards: The potential exists for stranded or stored energy hazards if the batteries are exposedto abnormal conditions where they might still contain hazardous levels of energy.

(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazards under abnormalconditions if accessible parts are overheating or if there is exposure to moving hazardous parts such as fans where guardsmight be missing.


Since these are aqueous I suspect they would vent hydrogen in normal use as do flooded lead acid. I inserted analogous wording for group expert consideration and differ to others familiar with this chemistry.




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B.5.7 Sodium Batteries, High-Temperature — General Description.

High-temperature sodium batteries, sometimes referred to a sodium beta batteries or molten salt batteries, are hermeticallysealed batteries with metallic sodium as the negative electrode and a ceramic beta-alumina as the electrolyte. These batteriesoperate at very high temperatures of 518°F to 662°F (270°C to 350°C) so that the active materials are in a molten state and toensure ionic conductivity. There are two types of commercially available high-temperature sodium batteries: sodium sulfur andsodium nickel chloride. Sodium sulfur batteries consist of a sodium negative electrode, a beta-alumina electrolyte, and a sulfurpositive electrode with an operating temperature within a temperature range of 590°F to 698°F (310°C to 370°C). Sodiumnickel chloride batteries consist of a sodium negative electrode, a beta-alumina as the electrolyte, and a positive electrode thatcould consist of nickel, nickel chloride, or sodium chloride with an operating temperature range of 518°F to 662°F (270°C to350°C).

B.5.7.1 Sodium Sulfur (NaS) Batteries.

Hazard considerations for NaS batteries under normal operating conditions are as follows:

(1) Fire hazards: The potential exists for fire hazards if there are latent defects within the cells or design issues with thecontrols that prevent thermal runaway of the cells. Systems need to be evaluated for their ability to prevent propagationdue to these defects.

(2) Chemical hazards: Not applicable. The batteries contain water-reactive sodium, but the systems are hermetically sealed.



(5) Physical hazards: There should be no hazards associated with these batteries if the designs have sufficient insulation toprevent exposure to hot surfaces, because these batteries run at very hot temperatures under normal operating conditions.

Hazard considerations for NaS batteries under emergency/abnormal conditions are as follows:

(1) Fire hazards: These systems might be subject to thermal runaway due to defects within the cells and protection scheme.Large energy systems can result in fires if there are abnormal conditions such as short-circuiting.

(2) Chemical hazards: The potential exists for exposure to hazardous water-reactive materials if the hermetic seals are brokenand sodium is exposed to the atmosphere. PPE is required to address exposure during abnormal conditions.


(4) Stranded or stored energy hazards: The potential exists for stranded or stored energy hazards if the batteries are exposedto abnormal conditions where they might still contain hazardous levels of energy.

(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazards under abnormalconditions if accessible parts are overheating.


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B.5.7.2 Sodium Nickel Chloride Batteries.

Hazard considerations for sodium nickel chloride batteries under normal operating conditions are as follows:


(2) Chemical hazards: Not applicable. Although sodium is water reactive, the systems are hermetically sealed.



(5) Physical hazards: There should be no hazards associated with these batteries if the designs have sufficient insulation toprevent exposure to hot surfaces, because these batteries run at very hot temperatures under normal operating conditions.

Hazard considerations for sodium nickel chloride batteries under emergency/abnormal conditions are as follows:




(4) Stranded or stored energy hazards: The potential exists for stranded or stored energy hazards if the batteries are exposedto abnormal conditions where they could still contain hazardous levels of energy.



very is not necessary. "high temperature" is more precise and more common




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High-temperature sodium batteries, sometimes referred to a sodium beta batteries or molten salt batteries, are hermeticallysealed batteries with metallic sodium as the negative electrode and a ceramic beta-alumina as the electrolyte. These batteriesoperate at very high temperatures of 518°F 500°F to 662°F 698°F (270°C 260°C to 350°C 370°C ) so that the activematerials are in a molten state and to ensure ionic conductivity. There are two types of commercially available high-temperaturesodium batteries: sodium sulfur and sodium nickel chloride. Sodium sulfur batteries consist of a sodium negative electrode, abeta-alumina electrolyte, and a sulfur positive electrode with an operating temperature within a temperature range of 590°F to698°F (310°C to 370°C). Sodium nickel chloride batteries consist of a sodium negative electrode, a beta-alumina as theelectrolyte, and a positive electrode that could consist of nickel, nickel chloride, or sodium chloride with an operatingtemperature range of 518°F 500°F to 662°F (270°C 260°C to 350°C).


The word "Very" is an unnecessary relative adverb. Corrected operating temperature range to include lower end of Sodium Nickel Chloride and upper end of Sodium Sulfur




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High-temperature sodium batteries, sometimes referred to a sodium beta batteries or molten salt batteries, are hermeticallysealed batteries with metallic sodium as the negative electrode and a ceramic beta-alumina as the electrolyte. These batteriesoperate at very at high temperatures of 518°F to 662°F (270°C 260°C to 350°C) so that the active materials are in a moltenstate and to ensure ionic conductivity. There are two types of commercially available high-temperature sodium batteries: sodiumsulfur and sodium nickel chloride. Sodium sulfur batteries consist of a sodium negative electrode, a beta-alumina electrolyte,and a sulfur positive electrode with an operating temperature within a temperature range of 590°F to 698°F (310°C to 370°C).Sodium nickel chloride batteries consist of a sodium negative electrode, a beta-alumina as the electrolyte, and a positiveelectrode that could consist of nickel, nickel chloride, or sodium chloride with an operating temperature range of 518°F to 662°F(270°C 260°C to 350°C).


High temperature battery is enough, doesn't require other terms like "very"



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(5) Physical hazards: There should be no hazards associated with these batteries if the designs have sufficient insulation toprevent exposure to hot surfaces, because these batteries run at very hot at high temperatures under normal operatingconditions.








"very hot" is an unnecessary relative description, High temperature is more accurate.





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(5) Physical hazards: There should be no hazards associated with these batteries if the designs have sufficient insulation toprevent exposure to hot surfaces, because these batteries run at very hot at high temperatures under normal operatingconditions.








High temperature only is more accurate



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Public Input No. 337-NFPA 855-2017 [ Section No. C.1.1 ]

C.1.1 Emergency Responder Pre-incident Planning.

Emergency planning and training for facility staff and emergency responders is covered in Section 4.16. The fire departmentshould develop have access to a pre-incident plan for responding to fires, explosions, and other emergency conditionsassociated with the ESS installation, and the pre-incident plan should include the following elements:

(1) Understanding A documented review of the procedures included in the facility operation and emergency response plandescribed

(2) Identifying A list of the types of ESS technologies present, the potential hazards associated with the systems, andmethods for responding to fires and incidents associated with the particular ESS

(3) Identifying A list of the location of all electrical disconnects in the building and understanding guidance that electricalenergy stored in ESS equipment cannot always be removed or isolated

(4) Understanding the procedures for shutting down and de-energizing or isolating equipment to reduce the risk of fire, electricshock, and personal injury hazards

(5) Understanding the procedures for dealing with damaged ESS equipment in a post-fire incident, including the following:

Recognizing

(a) Recognition that stranded electrical energy in fire-damaged storage batteries and other ESS has the potential for re-ignition long after initial extinguishment

Contacting

(a) Instruction for contacting personnel qualified to safely remove damaged ESS equipment from the facility (This contactinformation is included in the facility operation and emergency response plan.)


The section seems to give action items to the fires department to develop the plan. Other items in the feature list are edited for readability.




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Public Input No. 338-NFPA 855-2017 [ Section No. C.2 ]

C.2 General.

Battery ESS based on electrochemical technologies represent the majority of ESS being designed and installed. The safeoperation of electrochemical ESS is critical especially when installed inside occupied structures. The primary concerns of thefire service with this type of installation would include the implications of overheating via internal or external heat source,thermal runaway, and the effective operation of fire detection, suppression, and smoke exhaust systems. There are additionalconcerns to be considered when assessing fire-fighter responses to electrochemical ESS.

For example, handover Handover procedures for potentially damaged systems should be developed for fire departments toensure the timely response of qualified technical representatives to manage safety issues. These procedures would also coverissues such as the removal or recycling of damaged equipment. Another procedural component is the realization that damagedESS system components could include significant stored or stranded energy with no known method for safe dissipation. Storedor stranded energy could be defined as energy that remains in a battery after the system has been shut down.


Remove unnecessary wording.




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C.3 Suppression Systems.

Early Some ESS design validation often validations have included pre-engineered inert or clean agent fire suppressionsystems for fire protection. These system installations were often approved without validation based on large-scale fire testingby nationally recognized testing laboratories. Evidence-based data is needed to ensure ESS designers specify appropriate fireprotection systems based on the material involved and physical design characteristics. Several early research papers frommultiple organizations, including NFPA’s Fire Protection Research Foundation, and third-party engineering groups have shownthat fires involving lithium ion cells must be cooled to terminate the thermal runaway process. Water is the agent of choice, yetsystem cabinet design could pose a significant barrier to the efficient application of water while simultaneously allowing the freemovement of fire and combustion gases.


Reworded for historical accuracy. Telecom designs have used ESS for 100 years without suppression, so it may not be suitable to say early design validation included inert or clean agent fire protection.




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C.4.1 Overheated Batteries.

The process of charging/discharging results in heat dissipation from cells. An optimum overall system design should includecascading layers of hardware and software protection, including at the battery cell, module or pod, and rack levels. Should afault occur and overheating of a cell continues, damage could occur resulting in swelling, off-gassing, fire, or explosion.

(1) Proper response to an overheated battery should include the following procedures and steps:

(2) Isolate area of all nonessential personnel.

(3) Review status of both building and ESS alarm system with available data.

(4) Review status of any fire protection system activation.

(5) Perform air monitoring of all connected spaces.

(6) Identify location of overheated battery.

(7) Isolate affected battery, string, or entire system based on extent of damage by opening battery disconnect switches, whereavailable .

(8) Contact person or company responsible for operation and maintenance of system.

(9) Continue temperature monitoring to ensure mitigation of overheating condition.


Not all installations have disconnect switches.




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C.4.2 Fires.

Fires in electrochemical ESS are often a result of a process called thermal runaway. Thermal runaway can simply be defined asthe process in which a battery creates heat but cannot dissipate that heat, resulting in dynamic temperature increase. Initialsigns of thermal runaway might include pressure increase at the cell level, temperature increase, and off-gassing. As theprocess continues, additional signs might include vent gas ignition, exploding cells, projectile release, heat propagation, andflame propagation.

As the failure cascades, responders should also be aware of prepared for toxic and potentially explosive gas release. Thoughlarge-scale testing to determine battery burn outcomes, including toxic gas release calculations, remains incomplete,responders should treat them as highly dangerous and use their full suite of PPE and breathing apparatus when responding.

Proper response to electrochemical ESS fires should include the following procedures and steps:

(1) System isolation and shutdown

(2) Hazard confinement and exposure protection

(3) Fire suppression

(4) Ventilation


Reword for proactive protection as opposed to reactive.




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Public Input No. 395-NFPA 855-2017 [ New Section after C.5 ]

Sodium Nickel Chloride (SMC)

SMC batteries do not pose flammability risks any greater than familar chemistries. This battery chemistry does not producedangerous gasses when in operation and the products are made from non-flammable materials such as steel, ceramic andglass fiber insulation. The energy storage components (the cells) are contained in thermally insulated, mechanicallyrigid containers that isolate these component from the ambient environment which greatly reduces the probability of Thermalor Mechanical abuse. The battery chemisry is intrinsiclly stable, producing stable solids (table salt and aluminum) withoutany out-gassing and with a limited amount of exothermic heat generation in the event of a failure.

Refer to the manufacturers Safety Data Sheet (SDS) for suggested extigushing methods.


Inclusion of SMC batteries in Annex C





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C.5 Suppressing Agent Choice Considerations.

An in-depth understanding of battery failure and suppressing agent properties is essential to the response strategy. There isanecdotal evidence that a number of suppressants could work to suppress burning batteries. However, some perform betterthan others. Battery chemistry plays a significant role in suppressant choice as some suppressants will perform well on a singlechemistry while others might work well on a suite of battery chemistries. Additionally, some suppressants might beinappropriate for certain battery chemistries, and their release could create a more dangerous situation.

When choosing a suppression system, the following should be considered:

(1) Cooling effect

(2) Availability

(3) Portability

(4) Conductivity

(5) Available testing data

(6) Cascading protections

C.5.1 Lithium Ion (Li-ion) Batteries.

Water is considered the preferred agent for suppressing lithium ion battery fires. Water has superior cooling capacity, is plentiful(in many areas), and is easy to transport to the seat of the fire. While water might be the agent of choice, the module/cabinetconfiguration could make penetration of water difficult for cooling the area of origin, but might still be effective for containment.Water spray has been deemed safe as an agent for use on high-voltage systems. The possibility of current leakage back to thenozzle, and ultimately the fire fighter, is insignificant based on testing data published in the Fire Protection ResearchFoundation report Best Practices for Emergency Response to Incidents Involving Electric Vehicles Battery Hazards: A Reporton Full-Scale Testing Results. Fire-fighting foams are not considered to be effective for these chemistries because they lack theability to cool sufficiently and can conduct electricity. There is also some evidence that foams might actually encourage thermalrunaway progression by insulating the burning materials and exaggerating heat rise.

Fire-fighting dry-chemical powders can eliminate visible flame. However, they also lack the ability to cool burning batterycomponents. Quite often, even if visible flame is removed, the thermal runaway inside the battery will continue resulting in re-ignition. CO2 and inert gas suppressing agents will also eliminate visible flame but will likely not provide sufficient cooling to

interrupt the thermal runaway process. ESS with clean agent suppression systems installed have ventilation systems that aretied in with the fire detection and control panel so that the HVAC shuts down and dampers close to ensure the agents havesufficient hold times at the proper concentration levels to be effective suppressants. Responders must ensure adequate holdtime has occurred prior to accessing battery room/container. Manufacturer-recommended times should be made clear. Theseagents might also reduce flammability by suppressing oxygen levels, but data has identified that flammable gasses willcontinue to be produced due to the continued heating and could create an environment ripe for flashover or backdraft whenoxygen is reintroduced into the system.

C.5.2 Lead-Acid and Flooded Cell Battery Technologies.

Lead-acid batteries are a very familiar chemistry to fire fighters. However, though the chemistries employed in ESS are similarto those that would be found in battery backup systems, they can be expected to be found in much larger arrays. The size ofthe battery system is certainly a factor when determining suppressing agent requirements, strategy, and tactics.

Overcharging can lead to overheating and production of hydrogen gas, case swelling, and electrolyte leakage. Large fires canbe treated as hazardous materials events.

Water, powders, inert gases, and CO2 are all considered acceptable suppressing agents for small fires involving lead-acid

batteries. However, if the fire is large water will be the preferred agent because of its superior accessibility, portability, andcooling effectiveness.

C.5.3 Flow Batteries.

Flow batteries do not pose flammability risks like more solid batteries, and the fire load is comparably smaller as most of themass of the system is nonflammable liquid. Though the plastics comprising the balance of the system might pose a fire risk, ingeneral, the system is mostly nonflammable and does not contain many ignition risks beyond the power electronics, which aretypically housed separately. Under certain extreme conditions, such as exposure to significant heat, the system can generateH2, which is likely to be captured in the large tanks and vented in a controlled manner.

The system does pose considerable toxicity risks, as electrolyte is typically composed of hydrochloric acid, sulfuric acid, orsome combination of the two. There is also likely to be a large volume, possibly in excess of thousands of gallons, of electrolytein each containerized system. However, most containers are designed to contain spills.

In the case of zinc bromine (ZnBr) flow batteries, the bromine or hydrobromic acid can pose a significant health risk. Thoughunlikely, the vanadium oxide in vanadium flow batteries might form trace, salt-like deposits, which also pose a significant healthrisk. When dealing with failures involving either type of system, it is recommended to wear PPE, including SCBA, at all times.


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C.5.4 Sodium Sulfur (NaS) Batteries.

Sodium sulfur batteries operate at very high temperatures during normal operation. Though these batteries have become saferover time, there are cases where they have caught fire. NaS fires are very energy dense and cannot, per manufacturerrecommendations, be extinguished with water, which could ultimately make them far worse. Sulfur dioxide (SO2) is generated

during a fire and can damage the human respiratory system. Proper monitoring equipment and tactics should be employed togauge the level of detectable gases.

When NaS batteries are deployed, it is advised that fire services work with owner/operators or system owners to developappropriate standard operating procedures for dealing with NaS emergencies.

C.5.5 Sodium Nickel Chloride.

To be write, missed


A paragraph on sodium nickel chloride is missed



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Public Input No. 342-NFPA 855-2017 [ Section No. C.5 [Excluding any Sub-Sections] ]

An in-depth understanding of battery failure and suppressing agent properties is essential to the response strategy. There isanecdotal evidence that a number of suppressants could work to suppress burning batteries. However, some perform betterthan others. Battery chemistry plays a significant role in suppressant choice as some suppressants will perform well on a singlechemistry while others might work well on a suite of battery chemistries. Additionally, some suppressants might be inappropriatefor certain battery chemistries, and their release could create a more dangerous situation.

When choosing a suppression system, the following should be considered:

(1) Availability

(2) Cooling effect

(3) Availability

(4) Portability

(5) Conductivity

(6) Available testing data

(7) Cascading protections

(8)


Availability should be first consideration. If it is not available, stop considering it.I am not sure how cascading protections fit in. Maybe consider removal from the list or rephrase for clarity.




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C.5.1 Lithium Ion (Li-ion) Batteries.

Water is considered the preferred agent for suppressing lithium ion battery fires. Water has superior cooling capacity, is plentiful(in many areas), and is easy to transport to the seat of the fire. While water might be the agent of choice, the module/cabinetconfiguration could make penetration of water difficult for cooling the area of origin, but might still be effective for containment.Water spray has been deemed safe as an agent for use on high-voltage systems. The possibility of current leakage back to thenozzle, and ultimately the fire fighter, is insignificant based on testing data published in the Fire Protection ResearchFoundation report Best Practices for Emergency Response to Incidents Involving Electric Vehicles Battery Hazards: A Reporton Full-Scale Testing Results. Fire-fighting foams are not considered to be effective for these chemistries because they lack theability to cool sufficiently and can conduct electricity. There is also some evidence that foams might actually encourage thermalrunaway progression by insulating the burning materials and exaggerating exacerbate heat rise.

Fire-fighting dry-chemical powders can eliminate visible flame. However, they also lack the ability to cool burning batterycomponents. Quite often, even if visible flame is removed, the thermal runaway inside the battery will continue resulting in re-ignition. CO2 and inert gas suppressing agents will also eliminate visible flame but will likely not provide sufficient cooling to

interrupt the thermal runaway process. ESS with clean agent suppression systems installed have ventilation systems that aretied in with the fire detection and control panel so that the HVAC shuts down and dampers close to ensure the agents havesufficient hold times at the proper concentration levels to be effective suppressants. Responders must ensure adequate holdtime has occurred prior to accessing battery room/container. Manufacturer-recommended times should be made clear. Theseagents might also reduce flammability by suppressing oxygen levels, but data has identified that flammable gasses willcontinue to be produced due to the continued heating and could create an environment ripe for flashover or backdraft whenoxygen is reintroduced into the system.


I think the better word here is exacerbate.




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C.5.3 Flow Batteries.

Flow batteries do not pose flammability risks like more solid batteries, and the fire load is comparably smaller as most of themass of the system is nonflammable liquid. Though the plastics comprising the balance of the system might pose a fire risk, ingeneral, the system is mostly nonflammable and does not contain many ignition risks beyond the power electronics, which aretypically housed separately. Under certain extreme conditions, such as exposure to significant heat, the system can generateH2, which is likely to be captured in the large tanks and vented in a controlled manner.

The system does pose considerable toxicity risks, as electrolyte is typically composed of hydrochloric acid, sulfuric acid, orsome combination of the two. There is also likely to be a large volume, possibly in excess of Electrolyte capacity can be fromtens of gallons to thousands of gallons, of electrolyte in each containerized system. However, most containers are designed tocontain spills Spill containment is a critical part of a flow batter design .

In the case of zinc bromine (ZnBr) flow batteries, the bromine or hydrobromic acid can pose a significant health risk. Thoughunlikely, the vanadium oxide in vanadium flow batteries might form trace, salt-like deposits, which may also pose a significanthealth risk. When dealing with failures involving either type of system, it is recommended to wear PPE, including SCBA, at alltimes.


Minor text edits to remove subjective statements and provide more accuracy.




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C.5.4 Sodium Sulfur (NaS) Batteries.

Sodium sulfur batteries operate at very high temperatures during normal operation. Though these batteries have become saferover time, there are cases where they have caught fire. NaS fires are very energy dense and cannot, per manufacturerrecommendations, be extinguished with water, which could ultimately make them far worse. Sulfur dioxide (SO2) is generated

during a fire and can damage the human respiratory system. Proper monitoring equipment and tactics should be employed togauge the level of detectable gases during fire events .

When NaS batteries are deployed, it is advised that fire services work with owner/operators or system owners to developappropriate standard operating procedures for dealing with NaS emergencies.


Clarify that the monitoring is required during a fire event as opposed to normal use.




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C.6 Air Monitoring.

Air monitoring should be a priority for responders during and after any ESS emergency. Though the ESS might include an air-monitoring system, it is recommended that the responding fire companies use 4-meter or other gas detection equipment todetermine toxic gas levels. Many fire departments carry single gas CO meters that can be used to offer limited data on thecondition of the ESS environment.

When testing the involved areas, responders should be aware that hydrogen can give an erroneous reading on the CO meterbecause there is a cross-sensitivity with hydrogen. Full PPE and SCBA should always be used , including during overhaul andespecially in confined or poorly ventilated spaces during a fire event .

The battery room or building might employ a fixed inert gas or other oxygen-displacing fire suppression system. Whenactivated, these agents will displace oxygen from the environment in an effort to control flame. This impact on O2 levels can

impact the lower explosive limit (LEL). Begin metering in areas outside the affected BESS room to establish baseline readings.These areas should include floors above and below the BESS, corners, low-lying areas, and areas out of the path ofsmoke/gas travel, including near ventilation points.


The original text could be read to imply that SCBA is needed whenever working on or near the batteries (always be used). I don't think this is the intent. Revised text applies the requirement to fire responses.




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C.7.1 Fire Detection.

Battery management systems are primarily designed to monitor temperatures and voltages of cells and modules. They shouldmay be designed to shut down the affected charging/discharging circuits in the event of out-of-parameter conditions but mightnot be able to determine whether a fire is actually occurring. Fire detection should be designed into ESS whether onboard oras an infrared radiation (IR) system outside the cabinets.


Some systems, such as telecom, may not have a battery management system, so the text should be more general. The desire that fire detection is built into the ESS system is not consistent with earlier part of the standard which specified room detectors per NFPA 72. This part should be removed or edited for consistency.




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C.7.2 Fixed Passive Fire Suppression Control .

Fixed Passive fire suppression control features should be designed to meet the unique challenges of managingelectrochemical ESS fires. Fixed suppression systems Passive fire control features should be designed to limit the cascadingeffects of fire spread. This might include cell to cell (built into the module), module to module (built into the rack/or pack), rack torack (built into the ESS room or container), or even protection from system to system propagation.


The features described are to limit fire spread. They are more accurately called control features as opposed to suppression features, as they contain the fire and prevent spread, but do not extinguish the fire.




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Public Input No. 201-NFPA 855-2017 [ New Section after D.1 ]


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Technical Comparison and Future Potential for ESS.


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It is apparent that there are a wide range of different ESS technologies, and it is highly likely that more will emergein the next 10 to 15 years. Different applications with varying requirements will determine what features are needed,and this makes it difficult to conduct a comprehensive assessment and comparison. Not all ESS are commerciallyavailable in the current ranges for rated power (1 kW to 1 GW) and energy capacity (0.1 kWh to 100 GWh). Most ofthe technologies could be installed or upgraded with even larger power output and energy capacity (at leastdouble), due to the modular design options. Figure D.5(a) shows a very broad and generalized comparison ofstorage technologies and their applications.

Figure D.5(a) Positioning of Energy Storage Technologies. (Source: U.S. Department of Energy, Energy StorageSystem Guide for Compliance with Safety Codes and Standards.)

Some exceptions are PHS and systems with underground storage for H 2 , SNG, and CAES. The energy-to-power

(ETP) ratio adds an additional system characterization factor known as the discharge time [1 sec (short) to severalmonths (long)] as a function of energy density. The higher the power and energy density, the lower the requiredvolume for the system. There are many trade-offs for how each ESS is positioned with respect to performancebased on these properties and best fit for key markets (utility, consumer, and renewable) and the applications withinthem. Figure D.5(b) illustrates which ESS is or could become feasible for what applications, and where furtherresearch, development, and scale-up are necessary.

Figure D.5(b) ESS Feasibility, Future Potential, and Need for Development by 2030. (Source: Fraunhofer ISE.)


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It can be concluded that many different types of ESS will be required to cover all the applications outlined, as no

single superior universal storage technology exists 1 .


This is a suggestion to revise the order of the sections in this Annex.




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Public Input No. 193-NFPA 855-2017 [ Section No. D.1 ]

D.1 Introduction.

ESS can be classified according to the form of energy, and the main categories are mechanical, electrochemical, chemical,electrical, and thermal as depicted in Figure D.1. Hydrogen and synthetic natural gas (SNG) are secondary energy carriersbecause they store energy by way of water electrolysis to produce hydrogen is a secondary energy carrier that is produced,along with oxygen, using water electrolysis . In fuel cells, electricity is produced through the oxidation of a fuel, such ashydrogen . The combined hybrid process and the reduction of oxygen from the air or an alternate oxygen source. The system

comprised of an electrolyzer and a fuel cell is a chemical ESS1.

Figure D.1 Classification of Electrical ESS. (Source: Fraunhofer ISE.)

The purpose of this annex is to provide insight into the types, features, and applications of currently available ESS that have notbeen included in the standard in detail and their deployment status. The technologies of focus include, but are not limited to,pumped hydro storage (PHS), compressed air energy storage (CAES), flywheel energy storage (FES), superconductingmagnet ESS (SMES) and thermal ESS. These technologies can both store and release electrical energy but are not powergeneration systems that require a fuel source to function. These technologies will also be compared to other technologies,including a variety of batteries and capacitors that have been evaluated in detail and fall within the jurisdiction of the standard.The standard recognizes that there are a large variety of ESS technologies, and some will be excluded for a multitude ofreasons, including inapplicability to grid storage, immaturity (commercialization is estimated to require more than 5 years), size,or the requirement that the installation and safety validation needs specialized expertise or conditions that cannot begeneralized as effectively as the more common technologies. Grid ESS technologies range from over 100 GW of installedpumped hydro plants to experimental metal-air batteries and flywheels. Each offers unique advantages in terms of energy,power, lifetime, applicability, technical maturity, and cost. The disadvantages can be equally diverse, from geographic limitations(CAES) to cycle life issues (batteries). Also, grid ESS must deal with location-specific competition from alternative solutionssuch as added transmission , smart grids, and natural gas plants.

Pumped hydro and CAES are mature with well-documented use, so batteries and flywheels are currently the primary focus forenhanced grid-scale safety. For these systems and possibly some others, the associated failure modes for grid-scale powerand energy requirements have not been well-characterized, and this results in much larger uncertainty around the risks andconsequences of failures. This uncertainty around system safety can lead to barriers to adoption and commercializationsuccess but more importantly, the determination of impacts to health and the environment. To address these risks, it isrecommended that efforts be concentrated in the following areas:

(1) Materials science R&D extending into all device components

(2) Engineering controls and system design

(3) Simulation and modeling

(4) System testing and analysis

(5) Commissioning and field system safety protocols

The key modus operandi for using the areas outlined in the preceding list is to develop understanding and confidence byrelating results at one scale to expected outputs at a higher scale. It is important to try and predict the interplay betweencomponents, as well as protecting against unexpected outcomes when multiple failure modes are present at the same time.Extensive research, modeling, and validation testing are required to address these challenges. This warrants building a reliablesafety program by combining hazard analysis approaches with research and commissioning plans. The primary mandate is toidentify, respond to, and mitigate any observed safety events that are critical for the validation of safe ESS.


Provides clarifications and mentions the reduction reaction in fuel cells that occurs with the oxidation reaction. Both the reduction and oxidation reactions should be mentioned.




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Public Input No. 202-NFPA 855-2017 [ Section No. D.5 ]

D.5 Technical Comparison and Future Potential for ESS.

It is apparent that there are a wide range of different ESS technologies, and it is highly likely that more will emerge in the next10 to 15 years. Different applications with varying requirements will determine what features are needed, and this makes itdifficult to conduct a comprehensive assessment and comparison. Not all ESS are commercially available in the current rangesfor rated power (1 kW to 1 GW) and energy capacity (0.1 kWh to 100 GWh). Most of the technologies could be installed orupgraded with even larger power output and energy capacity (at least double), due to the modular design options. FigureD.5(a) shows a very broad and generalized comparison of storage technologies and their applications.

Figure D.5(a) Positioning of Energy Storage Technologies. (Source: U.S. Department of Energy, Energy StorageSystem Guide for Compliance with Safety Codes and Standards.)

Some exceptions are PHS and systems with underground storage for H 2 , SNG, and CAES. The energy-to-power (ETP) ratio

adds an additional system characterization factor known as the discharge time [1 sec (short) to several months (long)] as afunction of energy density. The higher the power and energy density, the lower the required volume for the system. There aremany trade-offs for how each ESS is positioned with respect to performance based on these properties and best fit for keymarkets (utility, consumer, and renewable) and the applications within them. Figure D.5(b) illustrates which ESS is or couldbecome feasible for what applications, and where further research, development, and scale-up are necessary.

Figure D.5(b) ESS Feasibility, Future Potential, and Need for Development by 2030. (Source: Fraunhofer ISE.)

It can be concluded that many different types of ESS will be required to cover all the applications outlined, as no single

superior universal storage technology exists 1 .


This is a suggestion to reorder sections of this Annex.





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Public Input No. 196-NFPA 855-2017 [ Section No. E.1.1 ]

E.1.1 Application.

Permits should be secured from and issued by the authority having jurisdiction for the following:

(1) Installation of new stationary ESS

(2) Additions, alterations, renewals, or renovations to existing stationary ESS (for systems with planned modular additions oraugmentations, permits can be obtained in advance during the time of the original installation permit)

(3) Recommissioning or decommissioning of existing ESS

(4) Placement of mobile ESS

(5) Stationary installations of mobile or portable ESS

(6) A change in the occupancy classification of a building or facility in which a stationary ESS is installed


This provides provisions for planned additions or augmentations.




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E.1.1 Application.

Permits should be secured from and issued by the authority having jurisdiction for the following:

(1) Installation of new stationary ESS

(2) Additions, alterations, renewals, or renovations to existing stationary ESS

(3) Recommissioning or decommissioning of existing ESS

(4) Placement of mobile ESS

(5) Stationary installations of mobile or portable ESS

(6) A change in the occupancy classification of a building or facility in which a stationary ESS is installed

Routine maintenance, repairs or renewals using like for like parts do not require a permit. An example would be replacement ofa damaged battery or group of life batteries with new batteries of the chemistry and capacity.


It is important that routine maintenance not be misconstrued as requiring a permit. The terms additions, alterations, renewals, renovations and repair can be used somewhat interchangeably in normal conversation, and are not clearly defined by the standard. This can lead to a miss-application of the standard. As noted earlier, the text as provided considers software updates a renewal and renewals trigger permits and inspections.




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E.1.2 Content.

Permits should be issued by and in accordance with the procedures of all authorities having jurisdiction and should bear thename and signature of each authority having jurisdiction or their designated representative(s). In addition, the permit shouldindicate the following:

(1) Purpose of the ESS for which the permit is issued

(2) Type of ESS, size, weight broken down by subcomponents or subsystems , type, and amount of any hazardous materials,general arrangement of the system, and extent of work to be performed

(3) Address where the ESS is to be installed and operated

(4) Name and address of the permittee

(5) Permit number and date of issuance

(6) Period of validity of the permit

(7) Inspection requirements


The calculation of volumes of water for suppression or flow rates for ventilation are dependent on the total mass of battery cells, and therefore this metric is critical to the permitting process. Reporting only the entire system weight (without reporting the portion that is only battery cells) will present confusion such that extinguishing or ventilation rates are overestimated based on total system mass.




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Public Input No. 392-NFPA 855-2017 [ Section No. F.1.2.7 ]

F.1.2.7 UL Publications.



UL 2743, Standard for Portable Power Packs, 2016.


UL 1973, Standard for Batteries for Use in Light Electric Rail (LER) Apllications and Stationary Applications, 2016


Include reference to UL 1973





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Public Input No. 195-NFPA 855-2017 [ Section No. F.1.2.8 ]

F.1.2.8 References for Annex D.

1. International Electrochemical Commission (IEC), “Electrical Energy Storage,” White Paper, Geneva/Switzerland, pp. 17–34,December 2011.

2. Rastler, D., “Electricity Energy Storage Technology Option,” Electric Power Research Institute, December 2010.

3. Doetsch, C., “Electrical energy storage from 100 kW – State of the art technologies, fields of use,” 2nd InternationalRenewable Energy Storage Conference, Bonn, Germany, November 2007.

4. Xie, S., and L. S. Wang, “Industry Trends — Issue 9,” China Energy Storage Alliance, January 2012.

5. The ADELE project in Germany uses adiabatic compression, while the SustainX, General Compression, and LightSailprojects in the U.S. use Isothermal compression. See “ADELE — Adiabatic Compressed-Air Energy Storage (CAES) forElectricity Supply,” RWE, www.rwe.com, accessed May 17, 2012; “SustainX's ICAES,” SustainX, www.sustainx.com, accessedMay 17, 2012; “General Compression, Who We Are,” General Compression, www.generalcompression.com, accessed May 17,2012.

6. Nakhamkin, M., “Novel Compressed Air Energy Storage Concepts,” developed by Energy Storage and Power Consultants(ESPC) and presented to EESAT, May 2007.

7. Beacon Power had a Gen 4 product but applied for bankruptcy in 2011, “Azure International energy storage database,”Energy Storage World Markets Report, Beijing, China, March 2012.

8. Inage, Shin-ichi, “Prospects for Large-Scale Energy Storage in Decarbonised Grids,” International Energy Agency, Report,2009.

9. Schossig, P., “Thermal Energy Storage,” 3rd International Renewable Energy Storage Conference, Berlin, Germany,November 2012.

10. Fairley, P., http://spectrum.ieee.org/energy/environment/largest-solar-thermal-storage-plant-to-start-up, Article 2008,Accessed July 2011.

11. Jahnig D. et al., “Thermo-chemical storage for solar space heating in a single-family house,” 10th International Conferenceon Thermal Energy Storage, Ecostock 2006, New Jersey, May/June 2006.

12. Tamme, R., “Development of Storage Systems for SP Plants,” DG TREN – DG RTD Consultative Seminar onConcentrating Solar Power, Brussels, Belgium, June 2006.

13. Bullough, C., “Advanced Adiabatic Compressed Air Energy Storage for the Integration of Wind Energy,” European WindEnergy Conference and Exhibition, London, GB, November 2004.


Suggest using another reference to describe the use of flywheels. The currently listed reference mentions a 4th Generation product and bankruptcy.




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TECHNICAL COMMITTEE ON Energy Storage …...Mostafa Kashe Principal Los Angeles County 900 South...

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