1 Code Compliance for Stationary Battery Systems Code

1 Code Compliance for Stationary Battery Systems Code Enforcement Implications

Major Fire/Building Codes that Include Stationary Battery Regulations New Battery Section in 2018 Edition New Battery Section in 2018 Edition 2021 Battery Section Already Drafted! FCAC New! NFPA 855 1st DRAFT DONE 2nd DRAFT

3 Driver for Fire Code Battery Section Changes Unknown (or unfamiliar with) hazards with new technology battery systems. New deployment applications such as micro-grids – Density of energy storage in residential complexes and high rise buildings!

4 Traditional lead-acid and ni-cd These proven technologies also face increased regulations. along with the new technologies – Ventilation, thermal runaway .

5 Parallel Code Development Tracks NFPA-855-2020 NFPA-1 2021 Process Stage First Draft Process Stage Process Step Date Pre-First Draft Technical Committee Meeting 30-31- 2018 May First Draft Public Input Closing Date 27-Jun 2018 First Draft Report Posting Date 27-Feb 2019 Second Draft Motions Committee Report (NITMAM) Year Public Comment Closing Date 8-May 2019 Second Draft Report Posting Date 22-Jan 2020 NITMAM Closing Date 19-Feb 2020 Second Draft Motions Committee Report (NITMAM) Process Step First Draft Posting and Technical Committee Ballot Final Date for Receipt of Technical Committee First Draft Ballot Final Date for Receipt of Technical Committee First Draft Ballot - Recirculated First Draft Report Posting Date for Public Comment Public Comment Closing Date Second Draft Technical Committee Meeting Second Draft Report Posting and Technical Committee Ballot Final Date Receipt of Technical Committee Ballot Posting of Second Draft Second Draft Meeting Second Draft Ballot Post Second Draft for NITMAM Review NITMAM Closing Date Posting of NITMAM CAM Appeal Closing Date for Consent Standards Appeal Closing Date for Standards with CAMS Date Year 24-Jan 2018 IFC-2021 Process Step Date Year Deadline for CDP Access Online 12-Jan Receipt of Code Change Proposals 2018 Web Posting of Proposed Changes to the I-Codes 28-Feb 2018 2018 2018 Committee Action Hearing (CAH) in Columbus Ohio 15-Apr 25-Apr 2018 10-Oct 2018 2018 24-Oct 2018 Committee Action Committee 15-May Online Vote for CAH Floor Motions TBD TBD TBD TBD TBD TBD Web Posting of Report of CAH 30-May 2018 Deadline for CDP Access Public 16-Jul Comments for CAH Report 2018 Web Posting of Public Comment Agenda 2018 7-Feb 2018 14-Feb 2018 11-Apr 2018 20-Jun 15-Aug 3-Jan 31-Jan 3-Apr 2019 2019 2019 18-Apr 2019 10-Jul 2019 31-Aug Public Comment Hearing (PCH) 24-Oct 31-Oct 2018 Online Government Consensus 15-Nov Vote 2018 Web Posting of Final Action TBD 30-Nov

Code Meeting Schedule Code Title Current Edition Next Edition NFPA-1 Fire Code 2018 2021 IFC International Fire Code 2018 NFPA-855 Energy Storage Standard New “New “ 2021 (2021 input was due 12-January 2018) 2020 (First Draft Posting Jan 24, 2018) NFPA-70 National Electrical Code 2017 NFPA-101 Life Safety Code 2015 2020 (First Draft Posting July 6, 2018) 2021 IBC International Building Code 2018 2021 IMC International Mechanical Code 2018 2021 NFPA110/111 Standard on Stored Electrical Energy Emergency and Standby Power Systems 2016 2019 (Jan 24, 2018 Second Draft Posting, Feb 21, 2018 NITMAM deadline)

Public Participation ICC: http://www.iccsafe.org/ (to provide public input use link for code development process access from the ICC site: https://cdpaccess.com/login) NFPA: http://www.nfpa.org/codes-and-standards -Formal Pubic Input – 1st or 2nd Draft -Technical Committee member proposals -NITMAM Process

8 Other Required Regulations EPA EPCRA (related to sulfuric acid - EHS) EPCRA Sections Thresholds DOT Criteria 302 - Emergency TPQ 1,000 lbs. Planning Notification OSHA CFR 1926.441 304 - Emergency RQ 1,000 lbs. – a1-a7, b1 – b3 Release Notification 311 - MSDS Reporting 312 - Chemical Inventory Reporting (i.e. Tier II) TPQ 500 lbs. TPQ 500 lbs.

9 Examples of characteristics – Lead Acid (hydrogen, sulfuric acid, thermal runaway) are understood by first responders – Lithium, Sodium, NiMH, Flow technologies Flammability – AND cell to cell propagation Electrolyte (corrosivity, reactivity, toxicity) Best suppression system (water reactive?) Material incompatibility issues from spills, venting, or products of combustion – Mixed systems are a particular concern

2018 IFC and NFPA-1 Threshold Quantities Figure 1. Battery Capacity Threshold Covered by Codes Technology Capacity Threshold (kilowatt hours) Lead Acid (all types) 70 KWh (252 Mega joules) Nickel Cadmium (Ni-Cd) 70 KWh (252 Mega joules) Lithium (all types) 20 KWh (72 Mega joules) Sodium (all types) 20 KWh (72 Mega joules) Flow Batteries 20 KWh (72 Mega joules) Other Battery Technologies 10 KWh (36 Mega joules) NFPA-855 Threshold 1 KWh for Residential Battery !!! Kilowatt-hours for a single string (array): rated amp-hours (at an 8-hour rate) multiplied by the battery string voltage and divided by 1000. As an example of a system that is covered by the code, the photograph below shows strings of VLA batteries that are rated at approximately 4000 amp-hours. So even a single string would be subject to the codes. 48V x 4000 amp-hours / 1000 192 KWh.

2018 Stationary Battery Section Changes – New table outlining the kW-Hours for different technologies subject to the code – Maximum allowable quantities (MAQ) – Maximum array (string) sizing – Required physical separation distances – Location parameters within buildings (and outside) – Hazard mitigation analysis criteria – Energy management systems – Automatic charger disconnect – Signage criteria – Ventilation & gas detection – Operational Permit added to IFC

Maximum Allowable Quantities (MAQ) Maximum Allowable Quantities for different types of batteries are defined in IFC chapter 12 and NFPA-1 chapter 52. For the 2018 editions, both codes plan to be harmonized with the values shown in Figure 3. If a user or site exceeds or is planned to exceed these maximum allowable quantities, the facility will need to be classified as a high hazard occupancy and be subjected to increased physical and operational criteria as described in the occupancy sections of the IFC/IBC or NFPA-1. The high hazard designation has consequences in allowed uses for the building, fire protection measures, and construction. Figure 3. IFC and NFPA-1 MAXIMUM ALLOWABLE QUANTITIES (MAQ) MAXIMUM ALLOWABLE Quantities a GROUP H OCCUPANCY Lead acid, all types Nickel cadmium (Ni-Cd) unlimited Not Applicable unlimited Not Applicable Lithium, all types 600 KW-h Group H-2 Sodium, all types Flow batteries b 600 KW-h 600 KW-h Group H-2 Group H-2 Other battery technologies 200 KW-h Group H-2 c BATTERY TECHNOLOGY a. a. For batteries rated in Amp-Hours, Watt-hours (KWh) shall equal rated battery voltage times the Amp-hour rating divided by 1000 a. b. Shall include vanadium, zinc-bromine, polysulfide-bromide, and other flowing electrolyte type technologies a. c. Shall be a Group H-4 occupancy if the fire code official determines that a fire or thermal runaway involving the battery technology does not represent a significant fire hazard

Maximum Array (String) Size Storage batteries, prepackaged stationary storage battery systems and preengineered stationary storage battery systems are required to be segregated into stationary battery arrays (strings) not exceeding 50 KWh (180 Mega joules) each. Exceptions include: Lead acid and nickel cadmium storage battery arrays Listed pre-engineered stationary storage battery systems and prepackaged stationary storage battery systems shall not exceed 250 KWh (900 Mega joules) each The fire code official is authorized to approve listed pre-engineered and prepackaged battery arrays with larger capacities or smaller battery array spacing if large scale fire and fault condition testing conducted or witnessed and reported by an approved testing laboratory is provided showing that a fire involving one array will not propagate to an adjacent array, and be contained within the room for a duration equal to the fire resistance rating of the room separation specified in Table 509 of the International Building Code

Location Restrictions A new addition to both NFPA-1 Chapter 52 and IFC Section 1206 imposes a restriction prohibiting a battery installation more than 75 feet above street level fire department vehicle access. Additionally, battery spaces cannot be placed more than 30 feet below the lowest finish floor access point. An exception is planned for lead-acid and nickelcadmium batteries to this criterion, however it is the prerogative of local AHJ on whether to grant these exceptions. While some exemptions may be in place in the codes to allow certain installations, this restriction could have an impact especially if other types of batteries are placed with equipment in higher floor data centers.

Separation Criteria Indoor: 3 ft. from walls, equipment, other obstructions – Exception: Lead acid and nickel cadmium storage battery arrays. The fire code official is authorized to approve listed preengineered and prepackaged battery arrays with larger capacities or smaller battery array spacing if large scale fire and fault condition testing conducted or witnessed and reported by an approved testing laboratory is provided showing that a fire involving one array will not propagate to an adjacent array, and be contained within the room for a duration equal to the fire resistance rating of the room separation specified in Table 509 of the International Building Code. Outdoor: 5 ft. from lot lines, public ways, buildings, stored combustible materials, hazardous materials, high-piled stock, and other exposure hazards. IEEE 480 Separation Is Less Restrictive . for now! NFPA-855 Outdoor 10 FT Separation

Hazard Mitigation Analysis In cases where battery systems exceed the MAQs or in facilities where different battery types or chemistries are collocated within one space, AHJs will likely require risk mitigation and failure mode analysis studies. Evaluate the consequences of the following failure modes: – Thermal runaway condition in a single battery storage rack, module, or array. – Failure of any energy management system. – Failure of any required ventilation system. – Voltage surges on the primary electric supply. – Short circuits on the load side of the stationary battery storage system. – Failure of the smoke detection, fire suppression, or gas detection system. – Spill neutralization not being provided or failure of the secondary containment system.

Energy Management System Monitors and balances cell voltages, current, and temperatures within the manufacturer's specifications. System must transmit an alarm signal to an approved location if potentially hazardous conditions are detected. Definition of energy management system is somewhat broad - BMS integrated with the battery Appropriate alarming parameters and indicators activated and routed to an acceptable alarm management system would be the prerogative of the AHJ.

Gas Detection & Ventilation Where required rooms containing stationary storage battery systems shall be protected by a gas detection system. The gas detection system shall be designed to activate where the level of flammable gas exceeds 25 percent of the lower flammable limit (LFL), or where the level of toxic or highly toxic gas exceeds 1/2 the IDLH. The gas detection system must be designed with the following features; initiation of distinct audible and visible alarms in the battery storage room, transmission of an alarm to an approved location, de-energizing of the battery charger, and activation of the mechanical ventilation system, where the system is interlocked with the gas detection system. – – Need for Gas Detection outlined in 1206.2.12 Specific Battery Type Requirements. Lead-acid and Ni-Cd appear to be exempt. Ventilation – no change to ventilation rates but added other battery technologies to the criteria.

19 Proposed 2021 IFC Additions Standby power for ventilation Operational permits More construction documentation Decommissioning Limit array size to 50 KWh Align with NFPA-855 Residential Battery Code (Chapter 18) More full scale fire testing Listing to UL9540 Larger outdoor separation distances

NFPA-855 New Technical Committee developing a comprehensive energy storage system standard First Meeting Was January 2017 First Draft Posting April 11, 2018 Covers all stationary storage applications – Fire protection – Placement and Siting – Thermal Management & Ventilation – Interconnection – General Battery Requirements

NFPA-111 Standard on Stored Electrical Energy Emergency and Stand-by Power Systems Guidelines for safe deployment and operation of stationary battery systems in stand-by applications. – The emergency power systems that operate at less than 24 volts and/or less than 500 VA are not subjected to these requirements. Not used as basis for existing code enforcement. Industry best practices for power sources, controls, converters, transfer equipment, and accessory equipment including: – Installation – Maintenance – Operation – Testing A sister document NFPA-110 focuses more on generators and associated back-up power.

Summary Newer battery technologies and large quantities of traditional batteries are an area of concern for public safety officials, fire departments, and building inspectors. These concerns have led to increasing regulations and criteria as proposed and developed in the 2018 IFC and 2018 NFPA 1. More changes for 2020 NFPA-855 and 2021 IFC. Battery manufacturers should be aware of the increased interest in requests for test data, fault data, and fire simulation work to satisfy code officials and meet the new code additions. End users should have a thorough understanding of these codes to determine types of technologies that can be readily deployed in existing structures, and installation and design issues for newer installations and facilities. Battery users, manufacturers, and researchers participation in the various code development bodies is encouraged.