Energy Storage Comes of Age
Over the last two months, my colleague Davion Hill, DNV GL’s leader for energy storage in the Americas, penned a pair of great pieces detailing the growing pains experienced by the energy storage industry (Read them here: Dear Energy Storage Market: It’s Time to Grow Up! and The Importance of Addressing Safety in the Battery Industry). I attempted a similar feat this time last year, congratulating the industry on its maturity and highlighting that with maturity comes a requirement to comply with the same codes and standards as other industries.
As I worked on the piece here and there over a couple of months, I found that with NFPA 855, UL 9540 (and now 9540A), the IFC and other codes—not to mention the continued changes in best practice and stakeholder education—that the industry was continuing to change on an almost weekly basis, frequently outdating or invalidating my work from the past weeks and months. Clearly, the industry was more prepubescent, and perhaps angsty, teen than fully matured adult.
It is now time for our butterfly to leave its cocoon and join the rest of the world. As NFPA 855 heads into it’s second—and potentially final—public comment period before approval, the meat of its content is clear and only minor details remain to be ironed out. UL has finally released their long awaited large-scale testing scope, 9540A. Though not an entirely perfect document, but one much needed as a starting point for defining the large-scale testing that is now required and will help inform future codes. In the meantime, the IFC, NFPA 1 and NFPA 70 (the NEC), now contain language which could be enforced as a standard of care by the more progressive Authorities having Jurisdiction (AHJs) even without adoption by their respective states.
While industry best practice continues to evolve and align with coming codes, it is essential that both the battery manufacturing, integration and development side, as well as the fire service and code enforcement side come together and fill in the knowledge gaps that remain. This is necessary so that energy storage may exist in the world no different, or more complicated, than any other similar technology. In November, I had an opportunity to speak on coming codes and regulations to a group at an NY-BEST meeting. I made a pair of pleas to the industry and stakeholders present, as I have at several other previous conferences: be transparent and be involved.
Real data vs. data gaps
To date, the industry has, for the most part, developed two kinds of data: real data that they keep close to the chest but discuss qualitatively and with a degree of reverence typically reserved for mythical creatures; and data gaps which come from intentional burying of one’s head in the sand. No one can blame them for this, and there are reasons for both. To energy storage professionals and experts, some of the results of safety testing may appear scary. Torch like behavior, self-ignition and reignition, and explosion risks seem like the kind of thing that no rational person would ever want to face.
Why share this data when it may reflect negatively on yourself, the industry, or worse, open yourself to liability? However, the fire service are not normal humans, they are some of the finest, bravest men and women amongst us and they deal with dangerous realities every day. While DNV GL testing shows that energy storage systems may pose a unique combination of threats, none of the threats in and of themselves is unique or unknown to the fire service. The proverbial cat is out of the bag and these risks are now known anyway. Failing to be transparent about this has thus led to a degree of mistrust and reservation towards energy storage. This fear is now manifesting itself in the form of exceptionally conservative requirements in coming codes, requirements that can only be exempted by testing and data sharing.
As for the second type of data, the data gap or nonexistent data, the days of the energy storage “wild west” are over. It is simply no longer acceptable to plead ignorance to safety requirements. Just as the automotive, aviation, maritime, or medical industries could never plead ignorance as a defense to a dangerous failure, energy storage manufacturers and developers may not plead ignorance to safety or mislead code officials as to the safety of their system. Any manufacturer designing a system where ventilation, exhaust, fire suppression and detection, or overall safety are not as key as the battery management system (BMS) and cell selection may do themselves and their colleagues a favor by reconsidering their entire approach and what their ignorance may mean to the industry as a whole.
What can the industry do?
Once we have achieved transparency, or rather in parallel, to reaching this goal, get involved. While NFPA and fire code action committees may be difficult to join as members, they may allow for guest speakers. Certainly, the local fire departments and AHJs in places where your systems are installed would like to hear more about them, especially if they were not involved in permitting or are unaware your system is even there. Publish your data or work with fire fighter training organizations like the NFPA to ensure that the training materials provided to fire fighters are up to date and provide input and feedback to codes when the opportunities arise.
As I mentioned, NFPA 855 will be out for its second round of public comment soon. It is no secret Tesla, LG, and other large manufacturers and developers are on the committee, but are you? Do they represent you and are your systems identical enough to be governed by rules written by them? In general, the entire industry has been represented fairly, but while the industry suffers no shortage of meaningless gimmicks, some systems truly pose different risks and counter measures and may be worthy of an edit in the codes. However, such comments must be supported by data, the case made succinctly and the requested change be clear.
Finally, involvement only helps if it is honest, fact based, and provided with context. The lack of transparency to date has been countered by heavy-handed discussion of worst case scenarios. Within certain circles, the prevailing mindset seems to be that most large scale-energy storage systems will fail in ways similar to the Hindenburg long before they ever reach their regular end of life; and as such, fires and explosions across the nation will be common with these systems. While this is far from the case, a lack of transparency and context have again allowed the safety conversation to separate from reality.
When the only conversations have included gimmicks, perceived but otherwise fictional safety barriers, and worst case scenarios, the industry will never get to the point of sensible regulation it needs to truly prosper, and expensive testing and analysis will remain the norm. Conversations should include barriers of safety, functionality of the BMS, integration of fire suppression and exhaust, emergency action plans, contacts and monitoring support and end of life/disposal plans. A conversation about how your cells don’t go into thermal runaway helps no one while a conversation about the thermal resistance of your chemistry coupled with active monitoring of all cell temperatures and voltages and the integration of your BMS into the fire control system raises the bar to your level and affords the industry an opportunity to again control the conversation.
How DNV GL is helping the industry
Over the next few months, DNV GL will release additional blogs and papers detailing the state of the industry regarding safety and testing, including what we can do to help as well as what you can do to help too. DNV GL has avoided prescribing solutions to these issues in the past, with the idea that the industry is full of smart people who will no doubt innovate amazing solutions when their talents are turned towards these issues. In closing, I will leave you with the summary of one of Davion’s articles about the importance of safety culture from Paul O’Neill’s time at Alcoa:
“When safety is part of the daily conversation, when it is honest, and when it is everyone’s responsibility and no one is above it, there may be growing pains, but in the end the rewards will be more than worth it for all.”