second revision no. 121-nfpa 855-2018 [ global comment ] · second revision no. 173-nfpa 855-2018 [...

Second Revision No. 121-NFPA 855-2018 [ Global Comment ]

Replace the use of "energy capacity", "maximum energy rating", "maximum rating", and "maximum ratedenergy"

With:

“Maximum Stored Energy”

Where used to refer to the amount of energy stored in an ESS system.

Examples:

Table 1.3

Section 3.3.13

4.1.4.1(3)

Section 4.2.5

Table 4.4.2

Table 4.4.3

Table 4.4.4

Table 4.5.7

Section 4.6.2

Section 4.8

Table 4.8

Section 4.8.4

Section 17.6

Submitter Information Verification

Committee: ESS-AAA

Submittal Date: Thu Aug 23 13:21:56 EDT 2018

Committee Statement

Committee Statement: Several terms for the maximum energy rating have been changed to be more consistent.

Response Message: SR-121-NFPA 855-2018

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...

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Second Revision No. 173-NFPA 855-2018 [ Global Comment ]

The committee would like to add a new Annex F titled, Fire and Building Codes -- A Short History onStationary Storage Battery Systems. See attached.

Supplemental Information

File Name Description Approved

NFPA_855_History_Annex_FINAL.docx For staff use

855_Global_SR-173_Annex_F--NEW.docx For ballot


Committee: ESS-AAA

Submittal Date: Sun Sep 30 11:36:34 EDT 2018

Committee Statement

Committee Statement: This new Annex provides details as to how NFPA 855 came to be.



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Annex F Fire and Building Codes — A Short History on Stationary Storage Battery Systems

This annex is not a part of the requirements of this NFPA document but is included for informational purposes only.

F.1 General. The National Fire Protection Association’s (NFPA) development of NFPA 855, Standard for the Installation of Stationary Energy Storage Systems, is not the first effort to address the safety of energy storage systems. Energy storage technologies have long been addressed by NFPA 70, National Electrical Code (NEC), along with building and fire codes under the topic stationary storage battery systems.

More focused treatment of battery systems began with the 1997 edition of the ICC Uniform Fire Code (UFC). Before that various standards and model codes provided safety requirements that addressed batteries both as primary sources of electrical energy and for emergency backup power. Because of the amount of acid electrolyte in lead-acid batteries, when viewed in the aggregate and individually, they were being regulated for the hazardous material properties of the electrolyte, which then triggered more stringent high-hazard occupancy construction and protection requirements. As a result, the telecommunications industry sought a change to the UFC that addressed the operating hazards associated with batteries in their facilities without triggering the more stringent building and fire code requirements.

This treatment of battery systems in building and fire codes based upon the chemistry and amount of electrolytes was uniform across the three legacy model codes produced by the Building Officials and Code Administrators International, International Conference of Building Officials, and Southern Building Code Congress International that existed prior to their merger and the creation of the International Code Council series of model codes completed in 2000.

F.2 Historical Development of Codes. F.2.1 1997 Uniform Fire Code. Section 6401 of the 1997 edition of the Uniform Fire Code, based on approved modifications to the 1994 edition, contained the following requirements for stationary lead-acid battery systems:

SECTION 6401 SCOPE. Stationary lead-acid battery systems having a liquid capacity of more than 100 gallons (378.5 L) used for facility

standby power, emergency power or uninterrupted power supplies shall be in accordance with Article 64. Stationary lead-acid battery systems with individual lead-acid batteries exceeding 20 gallons (75.7 L) each shall also comply with Article 80. [UFC, 1997]

The requirements addressed were as follows:

(1) Safety venting

(2) Occupancy separation

(3) Spill control

(4) Neutralization

(5) Ventilation

(6) Signs

(7) Seismic protection

(8) Smoke detection

Note that the scope was not open ended. The individual battery limitation was set at 20 gallons and exceeding that amount per battery still triggered the more extensive hazardous material provisions in the UFC.

The topics addressed were based upon normal operation. Overcharging, thermal runaway, or other abnormal operational conditions were not considered, if in fact they were even recognized safety concerns at the time.

F.2.2 2000 International Code Council Codes. The targeted regulation of stationary lead-acid battery systems that began with the 1997 Uniform Fire Code was carried forward as the three legacy model code organizations merged as the International Code Council and completed work on the development of, among others, the 2000 International Fire Code and 2000 International Building Code. The topics covered were as follows:

(1) Safety venting

(2) Room design and construction

(3) Spill control and neutralization

(4) Ventilation

(5) Signs


(7) Smoke detection

The threshold for application was reduced to 50 gal, and the 20 gal per battery limitation was eliminated compared to the 1997 UFC. In addition, the International Building Code classified the battery storage as incidental use areas and added an exemption from the high-hazard use classification.

The purpose of the requirements was to provide for relief for certain battery system applications from being designated a high-hazard occupancy due to the amount of hazardous materials that were contained within the batteries. In practice, if a stationary lead-acid battery system satisfies these requirements then the facility containing those batteries is not regulated as a hazardous material occupancy and would not be designated a high-hazard use. That said, if the hazardous material maximum allowable quantities (MAQ) relative to the amount of electrolyte was exceeded then the battery system would result in a hazardous material classification.

The requirements for stationary lead-acid battery systems were brought into the 2000 International Fire Code as Section 608 with the topics listed in F.2.2 addressed. For room design and construction, the user was pointed to the 2000 International Building Code where the battery systems were identified as an incidental use area and required to be separated from the remainder of the occupancy by fire resistance rated assemblies.

As with the 1997 UFC, the topics addressed were based upon normal operation. Overcharging, thermal runaway, or other abnormal operating conditions were not considered or recognized at the time.

F.2.3 2003 International Code Council Codes and NFPA 1, Fire Code. In Section 608 of the 2003 International Fire Code, the scope of lead-acid battery systems was changed to lead-acid battery systems using vented (flooded) lead-acid batteries. A new Section 609 was added to the IFC covering valve-regulated lead-acid battery systems and contained similar language. The requirements in the 2003 International Building Code remained the same applying to lead-acid batteries generally.

Section 608 vented (flooded) lead-acid batteries covered the following:

(1) Safety venting



(4) Ventilation

(5) Signs


(7) Smoke detection

Section 609 valve-regulated lead-acid battery systems covered the following:

(1) Safety venting

(2) Thermal runaway



(5) Ventilation

(6) Cabinet ventilation

(7) Signs


(9) Smoke detection

It should be noted that NFPA 1, Fire Code, did not have any requirements for stationary storage battery systems in the 2000 edition. The requirements were added to the 2003 edition of NFPA 1 from the same source used for the 2000 edition of the International Fire Code, the Uniform Fire Code, along with the added coverage of valve-regulated lead-acid batteries. The NFPA 1, Fire Code, battery storage provisions then remained unchanged until the 2009 edition.

F.2.4 2006 International Code Council Codes and NFPA 1, Fire Code. In the 2006 edition of the International Fire Code (IFC), Section 608 was rewritten to cover the following:

(1) Flooded lead-acid batteries

(2) Flooded nickel-cadmium (Ni-Cad) batteries

(3) Valve-regulated lead-acid (VRLA) batteries

(4) Lithium-ion batteries

This edition of the IFC signaled a recognition for and the introduction of new chemistries such as nickel-cadmium and lithium-ion batteries.

The same general topics were covered in the revisions to the 2003 IFC that were implemented as the 2006 IFC, including the need for a separate room or space created in accordance with the building code. That said, beyond the separate room, only the IFC signage, seismic protection, and smoke detection requirements applied to the lithium-ion batteries. Figure F.2.4 provides the overview of the 2006 IFC provisions.

Figure F.2.4 2006 International Fire Code Battery Requirements. (Source: 2006 International Fire Code.)

There were no changes made between the 2003 and the 2006 edition of NFPA 1, Fire Code. As such, it continued to apply only to the flooded lead-acid and valve-regulated lead-acid batteries.

F.2.5 2009 International Code Council Codes and NFPA 1, Fire Code. The 2009 edition of NFPA 1, Fire Code, contained new provisions that added lithium-ion and nickel-cadmium technologies, and both NFPA 1(see Table F.2.5) and the IFC (see Figure F.2.5) contained new

provisions that added lithium metal polymer batteries to the list of regulated battery technologies. The key difference in treatment between lithium-ion batteries and lithium metal polymer batteries was the requirement for thermal runaway protection for lithium metal polymer batteries. It should be noted that although Table 52.1 of the 2009 edition of NFPA 1 indicates no thermal runaway requirement for lithium-ion batteries, the technical language in 52.3.2 indicates thermal runaway was required for lithium-ion as well.

Thermal Runaway. VRLA and lithium-ion and lithium metal polymer battery systems shall be provided with a listed device or other approved method to preclude, detect, and control thermal runaway. [1:52.3.2, 2009]

A change to the International Building Code (IBC) unrelated to battery storage systems limited all incidental uses, the classification the IBC applies to battery systems, to no more than 10 percent of the area of the floor of the building they are located on.

Table F.2.5 Battery Requirements

Requirement

Nonrecombinant Batteries

Recombinant Batteries Other

Flooded Lead-Acid

Flooded Nickel-

Cadmium (Ni-Cd)

Valve-Regulated Lead–Acid

(VRLA)

Lithium-Ion

Lithium Metal

Polymer

Safety caps Venting caps

Venting caps

Self-resealing flame-arresting caps No caps No caps

Thermal runaway management

Not required

Not required Required

Not required Required

Spill control Required Required Not required Not required

Not required

Neutralization Required Required Required Not required

Not required

Ventilation Required Required Required Not required

Not required

Signage Required Required Required Required Required

Requirement

Nonrecombinant Batteries

Recombinant Batteries Other

Flooded Lead-Acid

Flooded Nickel-

Cadmium (Ni-Cd)

Valve-Regulated Lead–Acid

(VRLA)

Lithium-Ion

Lithium Metal

Polymer

Seismic control Required Required Required Required Required

Fire detection Required Required Required Required Required

[1:Table 52.1, 2009]

Figure F.2.5 2009 International Fire Code Battery Requirements. (Source: 2009 International Fire Code.)

F.2.6 2012 and 2015 International Code Council Codes and NFPA 1, Fire Code. Between the 2009 and 2012 editions of the fire codes, there were insignificant changes made to the requirements associated with battery systems. Between the 2012 and 2015 editions no changes were made. Essentially the 2009 and 2015 editions were the same with respect to battery systems.

F.2.7 2018 International Code Council Codes and NFPA 1, Fire Code. Recognizing the development of new battery technologies and the evolution of battery storage into a more robust and wider energy

storage industry in relation to the requirements in the various fire and building codes, the International Code Council’s Fire Code Action Committee created an Energy Storage Systems Work Group (ESS WG). The work of the ESS WG resulted in a new chapter being approved for inclusion in the 2018 International Fire Code — Chapter 12, Energy Systems — into which all the key energy-storage-related requirements (including batteries) were moved including the following:

(1) Emergency and stand-by power systems

(2) Solar photovoltaic power systems

(3) Stationary fuel cell power systems

(4) Electrical energy storage systems

As part of this work the requirements of the former stationary storage battery systems chapter took on the broader application of electrical energy storage systems and addressed the following topics:

(1) Battery storage system threshold quantities

(2) Construction documents

(3) Hazard mitigation analysis

(4) Fault condition

(5) Thermal runaway

(6) Seismic and structural design

(7) Vehicle impact protection

(8) Combustible storage

(9) Testing, maintenance, and repair

(10) Location and construction

(11) Stationary battery arrays

(12) Outdoor installations

(13) Maximum allowable quantities

(14) Storage batteries and equipment

(15) Fire-extinguishing and detection systems

(16) Specific battery-type requirements

(17) Capacitor energy storage systems

A major change within this work of the IFC was the introduction of array (unit) spacing as follows:

1206.2.8.3 Stationary battery arrays. Storage batteries, prepackaged stationary storage battery systems and preengineered stationary storage battery systems shall be segregated into stationary battery arrays not exceeding 50 kWh (180 megajoules) each. Each stationary battery array shall be spaced not less than 3 feet (914 mm) from other stationary battery arrays and from walls in the storage room or area. The storage arrangements shall comply with Chapter 10. [IFC, 2018]

This is intended to restrict the amount of energy in arrays (units) and requires a larger footprint for an energy storage system installation due to the 3 ft separation requirement. Exceptions were provided that eliminate lead-acid and nickel-cadmium storage batteries from this limitation, allow listed prepackaged units to have a 250 kWh threshold for separation, and elimination of the limits based upon large-scale fire testing as follows:

Exceptions:

(1) Lead acid and nickel cadmium storage battery arrays.

(2) Listed preengineered stationary storage battery systems and prepackaged stationary storage battery systems shall not exceed 250 kWh (900 megajoules) each.

(3) 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.

[IFC, 2018]

The IFC relies upon 1- or 2-hour fire-resistant construction to separate systems from the remainder of the building and an assessment that that level of protection can contain the fire impacts within the room or space where a system is installed. A large-scale fire test is needed to document such containment.

The other significant change between the 2015 and 2018 IFC editions was the specification of a maximum allowable battery quantity (see Figure F.2.7). Figure F.2.7 2018 International Fire Code Maximum Allowable Battery Quantities. (Source: 2018 International Fire Code.)

This was the first time there was an upper limit applied to the amount of energy allowed to be stored in an energy storage system located in a room or space. As with the spacing limitations, there was an exception that could be applied based upon large-scale fire testing as follows:

Exception: Where approved by the fire code official, areas containing stationary storage batteries that exceed the amounts in Table 1206.2.9 shall be treated as incidental use areas and not Group H occupancies based on a hazardous mitigation analysis in accordance with Section 1206.2.3 and large-scale fire and fault condition testing conducted or witnessed and reported by an approved testing laboratory. [IFC, 2018]

Along with the provisions in the 2018 IFC, energy storage language was added to the 2018 International Residential Code for the first time. In summary, the new language in the International Residential Code required energy storage systems to be listed and precluded them from being installed within the habitable space of a dwelling unit.

The 2018 NFPA 1, Fire Code, Chapter 52 contained modifications to the 2015 edition that were very similar to all of the new requirements introduced to the 2018 IFC.

F.2.8 2021 International Code Council Code Development and 2019 NFPA 855, Standard for the Installation of Stationary Energy Storage Systems. While the code revision process was being completed for the 2018 editions of the IFC and NFPA 1, NFPA developed the new standard

NFPA 855, Standard for the Installation of Stationary Energy Storage Systems. The work of the NFPA 855 technical committee closely tracked and utilized the 2018 language added to the fire codes along with the language from NFPA 853, Standard for the Installation of Stationary Fuel Cell Power Systems, for the initial NFPA 855 draft document.

With the adoption and availability of the 2018 editions of the codes, a broader audience was reached that generated additional input to the NFPA 855 committee on the impact of the requirements and questions on how to apply them in differing circumstances such as follows:

(1) Roof installs

(2) Open parking garage installs

(3) Remote installations

(4) Dedicated ESS buildings

(5) Array (unit) spacing threshold

(6) Maximum allowable quantity impact

(7) Incidental use 10 percent of floor area limitation

(8) Appropriate requirements based upon technology

(9) Deflagration prevention/venting

(10) Suppression system selection

(11) Fire detection method and where required

Going into the NFPA 855 First Draft process, language improvements were coordinated with work in progress on the proposals for the 2021 editions of the International Fire Code, International Building Code, and the International Residential Code.

Key areas addressed by the current proposals approved by the ICC Fire Code Action Committee and the Fire Code Committee at the proposal hearings for the 2021 edition code change process were as follows:

(1) Permits, operational as well as installation

(2) Large-scale fire test reliance on new UL 9540A

(3) Fire remediation actions and personnel

(4) Commissioning

(5) Decommissioning

(6) Operation and maintenance

(7) Repairs, retrofits, and replacements

(8) Reused and repurposed equipment

(9) Toxic and highly toxic gases

(10) Security of installations

(11) Occupied work centers

(12) Walk-in units

(13) Size and separation threshold reduction

(14) Maximum allowable quantities as simply a testing trigger

(15) Remote installations

(16) Dedicated-use buildings designated as an F-1 Group use

(17) Non-dedicated-use buildings

(18) Elimination of incidental use 10 percent of floor area restriction and H Group designation

(19) Explosion control

(20) Outdoor installations

(21) Rooftop installations

(22) Open parking garage installations

(23) Mobile ESS equipment and operations

Though some of the new language is more conservative, such as the threshold before large-scale fire testing and the requirement for explosion protection for lithium-ion energy storage systems, other proposed changes provide relief from some requirements such as dedicated-use buildings, remote locations, and rooftop and open parking garage installations.

The most restrictive requirements were maintained to address when an energy storage system is installed within a mixed-use occupancy building and it is important to contain an event for life safety and property protection.

The changes proposed for the 2021 I-Codes, and coordinated with the 2019 NFPA 855 development process, are significantly different from the 2018 provisions because of industry participation. The initial language of the 2018 editions of the fire codes and the draft of NFPA

855 are intended to obtain an acceptable level of safety recognizing how challenging and dynamic events from batteries and energy storage systems can be, whether the system instigates an issue or is a casualty of outside events. Those who verify code compliance and others working on the code language have maintained an open view, and where industry has provided data on different technologies and/or on documented safety practices, or a reduction in exposure hazards, there has been a willingness to modify the requirements in recognition of the new information and data.

F.3 NFPA Fire Protection Research Foundation. There are a few research projects involving the NFPA Fire Protection Research Foundation, Factory Mutual, and Sandia National Laboratories and the Pacific Northwest National Laboratory on behalf of the DOE Office of Electricity Energy Storage Program, and others that have provided background and understanding for those involved in the code writing process. There are numerous other sources for information, however, the following sources are those best known to many of those involved in the code development process:

(1) NFPA — firefighter safety in battery energy storage system fires see http://www.nfpa.org/News-and-Research/Resources/Fire-Protection-Research-Foundation/Current-projects/Fire-Fighter-Safety-in-Battery-Energy-Storage-System-Fires

(2) NFPA — lithium-ion batteries hazard and use assessment see the following:

(a) “Lithium Ion Batteries Hazard and Use Assessment”

(b) “Lithium Ion Batteries Hazard and Use Assessment — Phase IIB — Flammability Characterization of Li-ion Batteries for Storage Protection”

(c) “Lithium Ion Batteries Hazard and Use Assessment — Phase III”

(3) DNV GL — considerations for energy storage systems fire safety see https://www.dnvgl.com/publications/considerations-for-energy-storage-systems-fire-safety-89415

(4) Sandia National Laboratory – energy storage see http://energy.sandia.gov/energy/ssrei/energy-storage/

When industry joined the code-development process, they successfully used additional data specific to their products and operations to bring validity and functionality to proposed code language. The increased industry participation will be a benefit moving forward.

Second Revision No. 4-NFPA 855-2018 [ Global Input ]

Global Input CI-109

.Chapter 14 [former 16] Storage of Used or Off Specification Batteries.

See attached word file.



Used_Batteries-Global_Input-CI-109.1531354563672_1_.docx

proposed changes--For staff use

Used_Batteries-Global_Input-CI-109.1531354522250_1_.pdf

Proposed changes as a PDF--For staff use

855_Global_SR-4_Chapter_14.docx For ballot


Committee:

Submittal Date: Tue Jul 24 18:06:11 EDT 2018

Committee Statement

CommitteeStatement:

Subsequent to submittal and posting including a matching proposal to the International Fire Code,industry members were reached out to for review and comment. The Rechargeable BatteryAssociation (PRBA http://www.prba.org/) became actively involved including creation of their owncode committee. The industry identified that as proposed the language would prohibit, (shut down),many battery collection and recycling efforts currently in place including those required by law.

Since the same language was submitted o ICC and the time line was shorter for preparation, thebattery industry code committee to worked with the ICC FCAC work group to come up with languagethat would provide the necessary level of protection that recognized existing industry initiatives. Asresult a number of modifications were developed, reviewed and supported first by the work group,then by the FCAC and have been submitted as a public comment to the ICC process. The suggestedchanges here provide for an acceptable level of protection and parallel the suggested changes to theIFC for consistency across the various codes and standards.

The first suggested modification is to add a definition for "off specification batteries and cells" toclarify that the intent is to apply the requirements to those batteries or cells that do not pass qualitycontrol testing during the manufacturing process and are stored for recycling or destruction.

Section 16.1 has been modified to clarify application of the requirements; include all types ofbatteries, and to add two exceptions to application of the new requirements. The first exceptionrecognizes a state of charge of 30% or less as an acceptable safety level. This level of energy isrecognized by the FAA for shipping of batteries and there is extensive data and testing informationavailable. The second exception recognizes the use of laboratory testing to determine appropriatesprinkler density levels confirming fire event confinement, a concept already embraced for theinstallation of energy storage systems.

Section 16.2 has been modified to clarify that it applies to gathering activities. This is typically a boxlocated in any occupancy where the public and/or employees deposit used batteries, including fromhome. They batteries are of mixed chemistry and typically in the smaller formats such as used forcameras, wireless phones, remotes, etc. The distance between collection containers has beenmodified to recognize that in some cases a clear space can be maintained, but that in others thespace may have other combustible commodities located there such as in a retail establishment andin those cases the distance has been doubled since the intent is eliminate propagation from


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collection box to collection box.

Section 16.3 has been modified to recognize that there are a number of occupancies wherein largerformat used batteries may be stored. The square footage limitation of 100 square feet has beenenlarged to 200 square feet to recognize added space is necessary for storing large format batteriessuch as those for EVs. Three additional recognized methods of protected storage have been addedwith the same 200 square foot limitation to add options for facilities to apply. And a fifth option wasadded to simply go to the higher level protection found in Section 16.4 for indoor storage.

Section 16.4 has been modified to simply apply to "indoor storage" of amounts greater than thatpermitted by Sections 16.2 or 16.3. Whether or not it is a mixed use is covered by the NFPA 5000 soreference to mixed uses was deleted. The section was clarified to apply only to lithium batteries orcells (-ion or metal) and the occupancy designation was clarified as “Industrial, High Hazard”. Thesquare foot limitation was eliminated based upon the occupancy designation and the followingrequired protection levels that are to be provided for. The remaining changes were format/editorial innature.

Section 16.5 was deleted as no longer necessary due to the reformatting of Section 16.4. Thoserequirements now apply whether the indoor storage is in a dedicated building or a mixed-usebuilding.

Section 16.6 (now Section 16.5) was modified to only apply to lithium batteries and cells (-ion ormetal); eliminate the cubic foot limitation, simplify the exposure hazard listing and to modify thedistance between piles to match realistic distances already embraced by codes and standards.

ResponseMessage:

SR-4-NFPA 855-2018

Public Comment No. 749-NFPA 855-2018 [Global Input]


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Global SR-4 3.3.17 Off-Specification Battery or Cell. A cell or battery that has been tested during the manufacturing quality control process and found not to be within the manufacturer's designed set of criteria for its intended use. Chapter 14 Thermal Energy Storage Systems (Reserved)Storage of Used or Off-Specification Batteries 14.1 Used Batteries or Cells. Areas associated with the collection or storage of used or off-specification batteries or cells shall comply with this chapter.

14.1.1

The following areas shall be exempt from the requirements of this chapter:

(1) Areas within a facility that are operated in accordance with procedures that provide for the state of charge of the lithium-ion batteries and cells to be 30 percent or less

(2) Areas where fire and fault condition testing conducted or witnessed and reported by an approved testing laboratory is provided showing that a fire involving the batteries in storage will be limited to the design area of an automatic sprinkler system installed in accordance with NFPA 13 and will not adversely impact occupant egress from the building or adversely impact adjacent stored materials or the building structure

14.1.2

The procedures and test report specified in 14.1.1 shall be provided to the AHJ for review and approval.

14.2 Collection Locations. All areas located indoors in any occupancy where used batteries are collected from employees or the public shall be provided with open-top noncombustible containers or containers approved for battery collection activities.

14.2.1

Containers shall not exceed 1 ft3 (0.03 m3) in size.

14.2.2

Containers shall have a minimum of 3 ft (0.9 m) of open space from other battery collection containers and combustible materials and shall be located a minimum of 5 ft (1.5 m) from exits from the room, space, or building.

14.2.3

Where combustible materials are located within the space between collection containers, the containers shall be spaced a minimum 10 ft (3 m) apart.

14.3 Mercantile, Vehicle Repair, Aircraft Repair, and Laboratory Occupancy Battery Collection and Storage Locations. 14.3.1 General. 14.3.1.1

Batteries collected and stored at mercantile, vehicle repair, aircraft repair, or laboratory occupancies other than those in collection containers complying with 14.2.1 shall be stored in accordance with one or more of the following methods provided for in 14.3.2.1 through 14.3.2.5.

14.3.1.2

Battery terminals shall be protected either through battery design methods or a protective packaging method to prevent short circuit of the battery.

14.3.2 Storage Methods. 14.3.2.1 Rooms or Spaces Not Exceeding 200 ft2 (18.58 m2). Batteries shall be permitted to be stored in rooms or spaces not exceeding 200 ft2 (18.58 m2) in gross floor area.

14.3.2.1.1

The rooms or spaces shall be separated from the remainder of the building areas by fire barriers with a 2-hour fire resistance rating and with horizontal assemblies with a 2-hour fire resistance rating constructed in accordance with the local building code.

14.3.2.1.2

The room or space shall be protected by a radiant-energy detection system installed in accordance with NFPA 72 and shall be protected by an automatic sprinkler system designed and installed in accordance with NFPA 13.

14.3.2.2 Prefabricated Portable Buildings or Containers Not Exceeding 200 ft2 (18.58 m2). Batteries shall be permitted to be stored in approved prefabricated portable buildings or containers not exceeding 200 ft2 (18.58 m2) in gross floor area that are constructed with 2-hour fire resistance ratings and provided with radiant-energy detection system installed in accordance with NFPA 72 and an approved automatic fire suppression system installed in accordance with NFPA 13.

14.3.2.3 Metal Drums. Batteries shall be permitted to be stored in metal drums with batteries separated from each other by vermiculite or other approved material or in containers approved for battery collection and storage activities.

14.3.2.3.1

Each area containing such metal drums or approved containers shall not exceed 200 ft2 (18.58 m2) in area and shall be separated from other battery storage areas by a minimum of 10 ft (3 m).

14.3.2.3.2

The collection and storage area shall be protected by a radiant-energy detection system installed in accordance with NFPA 72.

14.3.2.4 Containers Approved for Transportation. Batteries shall be permitted to be stored in containers approved for use in transportation that will prevent an event from propagating beyond the container.

14.3.2.4.1

Each area containing the approved transportation containers shall not exceed 200 ft2 (18.58 m2) in area and shall be separated from other battery storage areas by a minimum of 10 ft (3 m).

14.3.2.4.2

The storage area shall be protected by a radiant-energy detection system installed in accordance with NFPA 72.

14.3.2.5 Indoor Storage Areas. Batteries shall be permitted to be stored in indoor storage areas meeting the provisions of Section 14.4.

14.4 Indoor Storage. 14.4.1 General. 14.4.1.1

Indoor storage involving used or off-specification lithium-ion or lithium metal batteries or cells not meeting the limitations of Sections 14.2 or 14.3 shall be classified as an industrial high-hazard occupancy and shall comply with Section 14.4.

14.4.1.2

The battery or cell storage shall be in rooms or spaces separated from other areas by fire barriers with a 3-hour fire resistance rating and horizontal assemblies with a 3-hour fire resistance rating constructed in accordance with the local building code.

14.4.1.3

Batteries and cells shall not be located within 10 ft (3 m) of exits from the room or space in which they are stored.

14.4.2 Prevention and Mitigation. A plan that provides for the prevention of fire incidents and includes early detection mitigation measures shall be provided to the AHJ for review and approval.

14.4.3 Fire Detection. The room or space shall be protected by a radiant-energy detection system installed in accordance with NFPA 72.

14.4.4 Fire Suppression. 14.4.4.1

The building the battery storage is located in shall be provided with an automatic fire suppression system installed in accordance with NFPA 13.

14.4.4.2

The battery or cell storage room or space shall be protected by a water spray automatic suppression system installed in accordance with NFPA 15.

14.4.5 Explosion Protection. Explosion protection shall be installed in accordance with NFPA 68 or NFPA 69.

14.5 Outdoor Storage Location. 14.5.1

Outdoor storage locations shall comply with the following:

(1) Individual pile sizes shall be limited to 200 ft2 (18.58 m2) in area separated from other piles by 10 ft (3 m).

(2) Piles located outdoors shall be separated by a minimum 20 ft (6.1 m) from the following exposures:

(a) Lot lines

(b) Public ways

(c) Buildings

(d) Other storage

(e) Hazardous materials

(f) Other exposure hazards

14.5.2

Clearances shall be permitted to be reduced to 3 ft (0.9 m) when a 3-hour freestanding fire barrier, suitable for exterior use, and extending 15 ft (1.5 m) above and extending 15 ft (1.5 m) beyond the physical boundary of the pile is provided to protect the exposure.

Second Revision No. 5-NFPA 855-2018 [ Global Input ]

In mutliple tables throughout the document, rated energy is calculated by:aFor ESS units rated in amp-hrs, kWh equals rated voltage times amp-hr rating divided by 1000.

This should be maximum rated voltage, not a nominal or operating voltage.

For Tables 1.3 and 4.8, make the following change: aFor ESS units rated in amp-hrs, kWh equalsmaximum rated voltage times amp-hr rating divided by 1000.


Committee:


Committee Statement

CommitteeStatement:

This wording could be abused to use nominal voltage instead of maximum voltage, which is theintent. To demonstrate the issue with this, for Li Ion NCM batteries, nominal voltage is ~3.75V, whilemaximum voltage is 4.2V. For LFP it is ~3.3V versus 3.6V. This is a difference of or over 10% andwould allow additional energy beyond the intent to be installed.

ResponseMessage:

SR-5-NFPA 855-2018

Public Comment No. 804-NFPA 855-2018 [Global Input]


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Second Revision No. 133-NFPA 855-2018 [ Detail ]

Change title of 4.4 from "Installations" to "Location."


Committee: ESS-AAA


Committee Statement

Committee Statement: Editorial clarification


Public Comment No. 97-NFPA 855-2018 [Section No. 4.4]


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Add new section 1.3.3

1.3.3

Mobile ESS deployed at an electric utility substation or generation facility for 90 days or lessshall not add to the threshold values in Table 1.3 for the stationary ESS installation if both ofthe following conditions apply:

(1) The mobile ESS complies with Section 4.5.

(2) The mobile ESS is only being used during periods in which facility’s stationary ESS isbeing tested, repaired, retrofitted, or replaced.


Committee: ESS-AAA

Submittal Date: Fri Sep 28 13:30:59 EDT 2018

Committee Statement

CommitteeStatement:

This exception for temporary mobile ESS being used to supplement utilities while they are underrepair is to allow utilities to repair their ESS without having to include the mobile ESS which mightpush the total capacity into the threshold covered by this standard.

ResponseMessage:

SR-168-NFPA 855-2018


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4.11.2.1.1*

Sprinkler systems shall be permitted to use an alternate density based on large-scale firetesting in accordance with 4.1.5.

A.4.11.2.1.1

UL 9540A Installation Level Test, Method 1, provides the data needed to determine ifautomatic sprinkler design densities can be changed. Equivalent test standards, as permittedin 4.1.5, might provide comparable data.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This change allows room for equivalent test methods to UL 9540A. Currently the committee isnot aware of any such testing. This also retains the previous requirement of permitting differentdensities based on testing.

ResponseMessage:

SR-169-NFPA 855-2018


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Add new sections:

4.13.5

Normally unoccupied, remote stand-alone telecommunications structures with a gross floorarea of less than 1500 ft2 (139 m2) with lead-acid and nickel-cadmium battery systems lessthan 50 V ac, 60 V dc that are in telecommunications facilities for installationsof communications equipment under the exclusive control of communications utilities andlocated outdoors or in building spaces used exclusively for such installations that are incompliance with NFPA 76 shall not be required to have a fire water supply.

4.13.6*

Lead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2,used for dc power for control of substations and control or safe shutdown of generatingstations under the exclusive control of the electric utility, and located outdoors or in buildingspaces used exclusively for such installations shall not be required to have a fire water supply.

A.4.13.6

This is in line with the scope of the 90.2(B)(5) of NFPA 70 and applies to lead-acid or nickel-cadmium batteries.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Carve outs have been made to recognize the different hazards associated with specific usesof ESS in certain installations.

ResponseMessage:

SR-170-NFPA 855-2018

Public Comment No. 119-NFPA 855-2018 [New Section after 4.13]


Public Comment No. 994-NFPA 855-2018 [Section No. 4.13.3]

Public Comment No. 656-NFPA 855-2018 [New Section after 4.13.3]



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6.1.1

ESS shall be evaluated and confirmed for proper operation and confirmed by the system owneror their designated agent in accordance with a commissioning plan prepared in accordancewith 6.1.1.1 , 6.1.1.2, and 6.1.1.2 6.1.2 and 6.1.3 .

6.1.1.1

Lead-acid and nickel-cadmium battery systems less than 50 V ac, 60 V dc that are intelecommunications facilities for installations of communications equipment underthe exclusive control of communications utilities and located outdoors or in buildingspaces or walk-in units used exclusively for such installations that are incompliance with NFPA 76 shall be permitted to have a commissioning plan incompliance with recognized industry practices in lieu of complying with 6.1.2 and6.1.3.

6.1.1.2*

Lead-acid and nickel-cadmium battery systems that are designed in accordancewith IEEE C2, used for dc power for control of substations and control or safeshutdown of generating stations under the exclusive control of the electric utilities,and located in building spaces or walk-in units used exclusively for suchinstallations shall be permitted to have a commissioning plan in compliance withapplicable governmental laws and regulations in lieu of developing a commissioningplan in accordance with 6.1.2 and 6.1.3.

A.6.1.1.2

The North American Electric Reliability Corporation (NERC) and Federal EnergyRegulatory Commission (FERC) are two examples of entities that have, or aredeveloping, commissioning requirements for electric utilities ESS installations thatform the basis for governmental laws and regulations.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Utilities need to comply with similar federal regulations and so this will allow them to follow thoseregulations in place of some aspects of NFPA 855 for certain batteries. This also is correctingreferences.

ResponseMessage:

SR-171-NFPA 855-2018


Public Comment No. 905-NFPA 855-2018 [New Section after 6.1.6.3]



Public Comment No. 357-NFPA 855-2018 [Chapter 6]



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Public Comment No. 38-NFPA 855-2018 [Section No. 6.1.1 [Excluding any Sub-Sections]]









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4.11.2 Sprinkler System.

Where required automatic fire suppression and control is provided using automatic sprinklersystems they shall be installed in accordance with one of the following: Sprinkler systemsshall be installed in accordance with NFPA 13 or equivalent.

(1) NFPA 13 with a minimum density of 0.3 gpm/ft2 (12.2 mm/min) based over the areaof the room or 2500 ft2 (230 m2) design area, whichever is smaller

(2) NFPA 13 with a minimum density based on large-scale fire testing in accordance withSection 4.5

4.11.2.1

NFPA 13 with Sprinkler systems shall be designed using a minimum density of 0.3 gpm/ft2

(12.2 mm/min) based over the area of the room or 2500 ft2 (230 m2) design area, whicheveris smaller.


Committee: ESS-AAA

Submittal Date: Sun Sep 30 12:12:50 EDT 2018

Committee Statement

CommitteeStatement:

Equivalent to NFPA 13 is now permitted to make NFPA 855 more internationally accepted.When using other international sprinkler installation standards, the design density will beconsistent.

ResponseMessage:

SR-174-NFPA 855-2018

Public Comment No. 527-NFPA 855-2018 [Sections 4.11.2.1, 4.11.2.2]


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4.1.2.3 Manuals.

An operations and maintenance manual shall be provided to both the ESS owner or theirauthorized agent and system operator before the system is put into operation and includesthe following:

(1) Submittal data stating the ESS size and selected options for each component of thesystem

(2) Manufacturer’s operation manuals and maintenance manuals for the entire ESS or foreach component of the system requiring maintenance that clearly identify the requiredroutine maintenance actions

(3) Contact information for a contracted service agency orresponsible in-house personnel

(4) A narrative of how the ESS and its components and controls are intended to operate,including recommended operational set points

(5) A service record log form that lists the schedule for all required servicingservice andmaintenance actions andwith space for logging such actions that can be completedover timeand retained on site

A.4.1.2.3(3)

The term personnel can refer to a call center, an individual, or department that hasresponsibility for the operation and maintenance of the ESS.


Committee: ESS-AAA

Submittal Date: Mon Oct 01 17:12:57 EDT 2018

Committee Statement

CommitteeStatement:

Comma added for clarity.

"Retained on site" was removed because this is what should be included in the maintenancemanual, how maintenance is done is in another section (Chapter 7)

Annex was added to clarify that personnel can refer to a call center as well as an individual.

Logs are not specified to be paper copies so they can be digital.

ResponseMessage:

SR-175-NFPA 855-2018

Public Comment No. 176-NFPA 855-2018 [Section No. 4.1.2.3 [Excluding any Sub-Sections]]

Public Comment No. 378-NFPA 855-2018 [Section No. 4.1.2.3]




*Name and address of


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4.4.3.9* Hazardous Atmospheres.

The system ESS shall not be located inside or in a manner where it could be affected by potentially hazardous

atmospheres in a classified area as defined in NFPA 70 or IEEE C2 unless listed and approved for thespecific installation.

A.4.4.3.9

Classified areas might contain hazardous and flammable atmospheres that could damage an ESS installation. ESSinstallations might also provide an ignition source for these atmospheres unless properly listed. See NFPA 70, IEEEC2, NFPA 497 , or NFPA 499 for more information.


Committee:

Submittal Date: Fri Jan 11 13:21:44 EST 2019

Committee Statement

CommitteeStatement:

ESS installations should not be placed in classified areas due to possible damage to the ESSbut also because the ESS installation could provide an ignition source for a flammableatmosphere.

ResponseMessage:

SR-177-NFPA 855-2019



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Add new section:

4.2.3.4

Changing out or retrofitting existing lead-acid battery systems with other lead-acid batterysystems in uninterruptable power supplies listed and labeled in accordance with UL 1778 andutilized for standby power applications shall be considered repairs where there is no increasein system size or capacity greater than 10 percent from the original design.


Committee: ESS-AAA

Submittal Date: Tue Aug 21 16:32:16 EDT 2018

Committee Statement

Committee Statement: This exception is added to allign with the carve outs for the utility and telecom industry.



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***New Section after 4.2.1.2***

4.2.1.3

Lead-acid battery systems in uninterruptable power supplies listed and labeled in accordancewith UL 1778 and utilized for standby power applications shall not be required to be listed inaccordance with UL 9540.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Batteries being used for standby power applications have a different hazard than ESS that isbeing charged and discharged continuously.

ResponseMessage:

SR-73-NFPA 855-2018




16 of 186 1/22/2019, 3:28 PM


*** New Section After 4.6.6***

4.6.7

Subsections 4.6.2 and 4.6.3 shall not apply to lead-acid battery systems in uninterruptablepower supplies listed and labeled in accordance with UL 1778, utilized for standby powerapplications, which is limited to not more than 10 percent of the floor area on the floor onwhich the ESS is located.


Committee: ESS-AAA

Submittal Date: Wed Aug 22 08:10:15 EDT 2018

Committee Statement

CommitteeStatement:

The proposed revisions are incomplete and create conflicts within 4.6. Eliminates parameters.The solution can be added here with new language at right or is in the table 9.2.

ResponseMessage:

SR-74-NFPA 855-2018



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Add new annex to 4.9 Exhaust Ventilation.

A.4.9

This section addresses hazards associated with the release of flammable gases from ESSduring normal charging, discharging, and use conditions. Similar requirements have been infire codes for many years primarily to address off-gassing of hydrogen from stationary ventedlead-acid battery systems but not limited to that technology.

This section is not intended to provide protection against the release of flammable gasesduring abnormal charging or thermal runaway conditions. Those conditions are addressed inSection 4.12. In addition, this section does not regulate ventilation of toxic and highly toxicgases, which are regulated by 4.1.1.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This new annex material help differentiate exhaust ventilation vs explosion control measuresin different sections of the standard.

ResponseMessage:

SR-76-NFPA 855-2018


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Second Revision No. 42-NFPA 855-2018 [ Section No. 1.2 ]

1.2 Purpose.

This standard provides the minimum requirements for minimizing mitigating the hazards associated withESS.


Committee:


Committee Statement

CommitteeStatement:

the term mitigating is more appropriate here because the term minimize is already used earlierin the sentence. This is mostly a grammatical change.

ResponseMessage:

SR-42-NFPA 855-2018







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Second Revision No. 19-NFPA 855-2018 [ Section No. 1.3 [Excluding any Sub-Sections]

]

This standard applies to ESS exceeding the values shown in Table 1.3.

Table 1.3 Threshold Quantities

ESS Technology Aggregate

Capacitya

kWh MJ

Battery ESS

Lead-acid, all types 70 252

Nickel-cadmium (Ni-Cd) including Ni-Cad, Ni-MH, and Ni-Znb 70 252

Lithium-ion, all types 20 72

Sodium,all typesnickel chloride 20c 72c

Flow batteriesbc 20 72

Other battery technologies 10 36

Batteries in residential occupanciesone- and two-family dwellings and townhouseunits

1 3.6

Capacitor ESS

Capacitors, all typesElectrochemical double layer capacitorsd 3 10.8

Other ESS

All other ESS 70 252

aFor ESS units rated in amp-hrs, kWh equals maximum rated voltage times multiplied by amp-hr ratingdivided by 1000.

b Nickel battery technologies include nickel cadmium (Ni-Cad), nickel metal hydride (Ni-MH), and nickelzinc (Ni-Zn).

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

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

d Capacitors used for power factor correction, filtering, and reactive power flow are exempt.



855_Section_1.3_on_PC_174_FINAL.docxThis contains the changes the committee voted on. For staff use

855_Section_1.3_on_PC_174_FINAL.docxThis has been updated to exclude a new 1.3.3 because that is now addressed in a ballotable detail. This is the version that should be used. For staff use


Committee:

Submittal Date: Wed Jul 25 10:28:05 EDT 2018

Committee Statement


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CommitteeStatement:

The Technical Committee makes changes to allign this table with the categories in chapter 6.They also add information to clarify that certain applications of batteries are outside of the scopeof this document.

ResponseMessage:

SR-19-NFPA 855-2018

Public Comment No. 104-NFPA 855-2018 [Section No. 1.3 [Excluding any Sub-Sections]]






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1.4 Retroactivity.

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

1.4.1

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

1.4.1

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

1.4.2*

In those cases where the authority having jurisdiction (AHJ) determines that an existing situation presentsan unacceptable degree of risk, the AHJ shall be permitted to apply retroactively any portions of thisstandard deemed appropriate.

A.1.4.2

In order to help determine if an existing ESS installation presents an unacceptable risk and thatretroactivity should apply, the AHJ can request a hazard mitigation analysis be submitted by the ownerin accordance with 4.1.4 .

Based on the hazardous mitigation analysis, the AHJ can apply retroactively any portions of thisstandard deemed appropriate to mitigate any hazards that could be identified in the risk assessmentas unacceptable.


Committee:


Committee Statement

CommitteeStatement:

Sections 1.4 and 1.4.1 did not add clarity as to how or when the standard should be appliedretroactively.






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Second Revision No. 3-NFPA 855-2018 [ Section No. 2.3.6 ]

2.3.7 UL Publications.

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

UL 263, Standard for Fire Tests of Building Construction and Materials, 2018.

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 UseWith Distributed Energy Resources, 2016.

UL 1778, Uninterruptible Power Systems , 2014, revised 2017.

UL 1973, Standard for Batteries for Use in Light Electric Rail (LER) Applications and StationaryApplications, 2016.

UL 1974, Evaluation for Repurposing Batteries, 2018 edition .

UL 2436, Outline of Investigation for Spill Containment for Stationary Lead Acid Battery Systems ,2006.

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

UL 9540A, Test Method for Evaluating Thermal Runaway Fire Propagation in Battery Energy StorageSystems, 2017 2018 .


Committee:


Committee Statement

Committee Statement: Referencing the newest edition of UL 9540A





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Second Revision No. 162-NFPA 855-2018 [ New Section after 3.3.1 ]

3.3.3 Battery Management System (BMS).

A system that monitors, controls, and optimizes performance of an individual or multiple battery modulesin an energy storage system and has the ability to control the disconnection of the module(s) from thesystem in the event of abnormal conditions. This system can be completely independent of the ESMS.


Committee: ESS-AAA

Submittal Date: Mon Sep 10 15:46:04 EDT 2018

Committee Statement

Committee Statement: A definition to help clarify the use of the term in the standard.





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Second Revision No. 154-NFPA 855-2018 [ Section No. 3.3.2.1 ]

3.3.2.1* Flow Battery.

A type of storage battery that includes chemical components dissolved in liquids where the liquid flowsthrough a reaction zone and stored chemical energy is converted to electrical energy .


Committee: ESS-AAA


Committee Statement

Committee Statement: The current definition misses the important part where the electricity comes out.





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3.3.7* Electrochemical Double Layer Capacitor (EDLC).

A capacitor that has liquid electrolyte (e.g., acetonitrile) and electrodes with a highly porous surface thatincreases the surface area for holding charge resulting in much larger capacitance and energy density.

A.3.3.7 Electrochemical Double Layer Capacitor (EDLC).

These capacitors can also be referred to as ultra-capacitors, super capacitors, double layer capacitors,electrochemical capacitors, and so forth.


Committee: ESS-AAA

Submittal Date: Wed Sep 05 09:52:27 EDT 2018

Committee Statement

Committee Statement: Definition added because of this terms use in chapter 10



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3.3.6 Electric Utilities.

All enterprises engaged in the production and/or distribution of electricity for public use including thosethat are typically designated or recognized by governmental law or regulation by public service/utilitycommissions and that install, operate, and maintain electric supply such as generation, transmission, ordistribution systems.


Committee:


Committee Statement

Committee Statement: This definition adds clarity as to what this standard defines as an Electric Utility.








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3.3.7* Electrochemical Energy Storage System.

An energy storage system that utilizes electrochemical storage devices as the means for energystorage.

A.3.3.5 Electrochemical Energy Storage System.

Batteries are an example of a type of electrochemical energy storage system.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The committee moved and altered this definition to help with the organization of the documentand to clarify what the committee intended for this terms.

ResponseMessage:

SR-156-NFPA 855-2018


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3.3.8* Energy Storage Management System (ESMS).

A system that monitors, controls, and controls optimizes the performance of an energy storage systemand can have has the ability to disconnect control the disconnection of the energy storage unit from thesystem in the event of abnormal or hazardous conditions are detected .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This definition has been changed to coordinate with the definition for battery managementsystems.




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Second Revision No. 155-NFPA 855-2018 [ Section No. 3.3.7 [Excluding any Sub-

Sections] ]

One or more devices, assembled together, capable of storing energy in order to supply electrical energy ata future time to the local power loads, to the utility grid, or for grid support .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Deleted definition for electrochemical in section 3.3.5. Combined under 3.3.7 and clarified andadded definition of Electromechanical.

ResponseMessage:

SR-155-NFPA 855-2018










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3.3.9.1 Capacitor Energy Storage System.

A rechargeable An electrical energy storage system consisting of capacitors, chargers, controls, andassociated equipment using capacitors as a storage media .

3.3.9.1.1* Electrochemical Energy Storage System.

An energy storage system that converts and stores chemical energy to electrical energy and vice versa.

A.3.3.9.1.1 Electrochemical Energy Storage System.

The electrochemical energy is related to fuel cells, photoelectrochemical cells, and systems such asbatteries.

3.3.9.1.2* Mechanical Energy Storage System.

An energy storage system that converts and stores mechanical energy to electrical energy and viceversa.

A.3.3.9.1.2 Mechanical Energy Storage System.

The mechanical energy is related to fly wheels, pump storage, compressed air systems, and systemssuch as reservoirs, pressure vessels, or magnets.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This change helps simplify the definition and allow it to be generally used while the EDLCdefinition dives deeper.

ResponseMessage:

SR-158-NFPA 855-2018









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3.3.9.3 Energy Storage System Dedicated-Use Building.

A building constructed on-site that is only used for energy storage, energy generation, and other orelectrical grid-related operations.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

the and was changed to or to be more inclusive of buildings that can be considereddedicated use buildings.




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3.3.13 Large-Scale Fire Testing.

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


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

"Energy storage system units" is undefined and this clarifies that a representative ESS isbeing tested and not an entire system

ResponseMessage:

SR-152-NFPA 855-2018






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3.3.16 Off-Gassing.

The event in which the cell case vents due to a rise in internal pressure of the cell.


Committee: ESS-AAA


Committee Statement

Committee Statement: The term Off-gassing is used throughout the document and should be defined.








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3.3.18 Open Parking Garage.

A 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.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Unless there is some significance of the word "private" in "private motor vehicles," the wordshould be removed.

ResponseMessage:

SR-153-NFPA 855-2018



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3.3.20 Thermal Runaway.

The condition when an electrochemical cell increases its temperature through self-heating in anuncontrollable fashion and progresses when the cell’s heat generation is at a higher rate than it candissipate, potentially leading to off-gassing, fire, or explosion, and gassing .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The term has been applies to other types of technologies and not just Li-ion. Should beconsistent thru document as an recognized event

ResponseMessage:

SR-97-NFPA 855-2018



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4.1.1* General ESS Gas Release .

ESS shall not release toxic or highly toxic gas creating conditions in excess of the permissible exposurelimit (PEL) in the room or space in which they are located during normal charging, discharging, and use.


Committee: ESS-AAA

Submittal Date: Fri Oct 19 11:53:52 EDT 2018

Committee Statement

CommitteeStatement:

The heading has been changed to allow users to more quickly understand what is coveredin this section.



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Second Revision No. 130-NFPA 855-2018 [ New Section after 4.1.2.1.1 ]

4.1.2.1.2

Plans and specifications associated with energy storage systems owned and operated by utilities as acomponent of the electric grid that are considered critical infrastructure documents, in accordance withthe provisions of North American Electric Reliability Corporation and other applicable governmental lawsand regulations shall be made available to the AHJ for viewing based on the requirements of theapplicable governmental laws and regulations.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Certain plans and specifications should not be publicly available because of security concernsinvolved with critical infrastructure of an area.

ResponseMessage:

SR-130-NFPA 855-2018

Public Comment No. 243-NFPA 855-2018 [Section No. 4.1.3.2.1.3]


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Second Revision No. 99-NFPA 855-2018 [ Section No. 4.1.2.1.1 ]

4.1.2.1.1

The plans and specifications associated with an ESS and its intended installation, replacement orrenewal, commissioning, and use shall be submitted to the AHJ for approval and shall include thefollowing:

(1) Location and layout diagram of the room or area in which the ESS is to be installed

(2) Details on hourly fire-resistant-rated assemblies provided or relied upon in relation to the ESS

(3) The quantities and types of ESS units

(4) Manufacturer's specifications, ratings, and listings of ESS

(5) Description of energy storage management systems and their operation

(6) Location and content of required signage

(7) Details on fire suppression, smoke or fire detection, gas detection, thermal management, ventilation,exhaust, and deflagration venting systems, if provided

(8) Support arrangement associated with the installation, including any required seismic support


Committee: ESS-AAA


Committee Statement

Committee Statement: If gas detection is part of the system it should be in the plans and specification.


Public Comment No. 402-NFPA 855-2018 [Section No. 4.1.2.1.1]



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4.1.2.2 Building Owner.

The construction documents described in this section shall be provided to the building owner or theowner’s authorized agent prior to the system being put in service.


Committee:

Submittal Date: Fri Aug 10 13:50:29 EDT 2018

Committee Statement

Committee Statement: Relocating section for readability.



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4.1.2.1.3 Supplemental Information.

Supplemental information necessary to verify compliance with this standard shall include the followingitems and other relevant data, as appropriate, to the type of ESS and its intended installation Thefollowing test data, evaluation information, and calculations shall be provided in addition to the plans andspecifications in 4.1.2.1.1 where required elsewhere in this standard :

(1) Large-scale fire testing test data in accordance with 4.1.5

Reports associated with system or component testing or listing

Failure modes and effects analyses

(2) Hazard mitigation analyses analysis in accordance with 4.1.4

(3) Calculations or modeling data to determine compliance with NFPA 68 and NFPA 69 in accordancewith Section 4.12

(4) Worksheets Other test data, evaluation information, or calculations as required elsewhere in thisstandard

Compliance forms

Manufacturer literature

4.1.2.1.4

If modeling data is provided, validation of the modeling results shall also be included.


Committee:

Submittal Date: Wed Jul 25 19:13:16 EDT 2018

Committee Statement

CommitteeStatement:

Information on calculations and modeling is useful tot he end user of this document. This sectionwas changed to only require test data, evaluation information or calculations to be provided withthe plans and specifications where it is specifically required elsewhere in this standard.

ResponseMessage:

SR-20-NFPA 855-2018




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4.1.2.3.1

The operations and maintenance manual shall be prepared prior to final approval of the ESS and beretained at an on-site location where readily accessible to personnel responsible for the ESS.


Committee:

Submittal Date: Thu Jul 26 10:27:14 EDT 2018

Committee Statement

CommitteeStatement:

Utilities may not always keep O&M manuals on site. They don't hold up well long term under siteconditions. They are normally retained at a maintenance crew headquarters or in electronicformat such a crew laptops.

ResponseMessage:

SR-21-NFPA 855-2018






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4.1.2.4 Commissioning Plan.

A commissioning plan meeting the provisions of Chapter 6 shall be provided to the building owner or theirdesignated authorized agent and a copy of the commissioning plan shall be provided to the AHJ.


Committee:


Committee Statement

Committee Statement: Simplify and remove the second Shall.





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4.1.3.1* General.

Emergency planning and training shall be provided by the owner of the ESS or theirdesignated authorized representative so that ESS facility staff operations and maintenance personneland emergency responders can effectively address foreseeable hazards associated with the on-sitesystems.


Committee:


Committee Statement

Committee Statement: Terminology changed to be more consistent







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Second Revision No. 25-NFPA 855-2018 [ Section No. 4.1.3.2 [Excluding any Sub-

Sections] ]

An emergency operations plan and associated training shall be established, maintained, and conducted byESS facility staff operations and maintenance personnel .


Committee:


Committee Statement

CommitteeStatement:

ESS facilites are un-manned and typically do not have permanent staff, operations andmaintenace personnel would be the responders.

ResponseMessage:

SR-25-NFPA 855-2018






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Second Revision No. 26-NFPA 855-2018 [ Section No. 4.1.3.2.1.1 ]

4.1.3.2.1.1

An emergency operations plan shall be readily available at an approved on-site location for use by facilitystaff operations and maintenance personnel .

4.1.3.2.1.2

For normally occupied facilities, the emergency operations plan shall be on site.


Committee:


Committee Statement

CommitteeStatement:

ESS facilites are un-manned and typically do not have permanent staff, operations andmaintenace personnel would be the responders.

ResponseMessage:

SR-26-NFPA 855-2018





46 of 186 1/22/2019, 3:28 PM


4.1.3.2.1.3

The plan shall be updated when conditions that affect the response considerations and procedureschange.


Committee:


Committee Statement

CommitteeStatement:

As written, this section is too vague. The changing conditions need to be limited to thoseaffecting the plan.




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Second Revision No. 131-NFPA 855-2018 [ New Section after 4.1.3.2.1.3 ]

4.1.3.2.1.5

The emergency operations plan in 4.1.3.2.1 shall not be required for electric utility facilities under theexclusive control of the electric utility located outdoors or in building spaces used exclusively for suchinstallations.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Utilities have their own emergency operation plans for their facilities that comply withgovernmental requirements.

ResponseMessage:

SR-131-NFPA 855-2018



Public Comment No. 623-NFPA 855-2018 [New Section after 4.1.3.2.1.3]


48 of 186 1/22/2019, 3:28 PM


4.1.3.2.1.4

The emergency operations plan shall include the following:

(1) Procedures for safe shutdown, de-energizing, or isolation of equipment and systems underemergency conditions to reduce the risk of fire, electric shock, and personal injuries, and for safestart-up following cessation of emergency conditions

(2) Procedures for inspection and testing of associated alarms, interlocks, and controls

(3)

(4)

(5) Response considerations similar to a safety data sheet (SDS) that will address response safetyconcerns and extinguishment when an SDS is not required

(6) Procedures for dealing with ESS equipment damaged in a fire or other emergency event, includingmaintaining contact information for personnel qualified to safely remove damaged ESS equipmentfrom the facility

(7) Other procedures as determined necessary by the AHJ to provide for the safety of occupants andemergency responders

(8) Procedures and schedules for conducting drills of these procedures


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

I think we want procedures to contact personnel, not procedures to maintain contact withpersonnel, which is something different.

ResponseMessage:

SR-132-NFPA 855-2018


* Procedures to be followed in response to notifications from the energy storage management system(ESMS), when provided, that could signify potentially dangerous conditions, including shutting downequipment, summoning service and repair personnel, and providing agreed upon notification to firedepartment personnel for off-normal potentially hazardous conditions

* Emergency procedures to be followed in case of fire, explosion, release of liquids or vapors, damageto critical moving parts, or other potentially dangerous conditions Procedures can include soundingthe alarm, notifying the fire department, evacuating personnel, de-energizing equipment, andcontrolling and extinguishing the fire.

A.4.1.3.2.1.4(4)

Procedures can include sounding the alarm, notifying the fire department, evacuating personnel,de-energizing equipment, and controlling and extinguishing the fire.


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4.1.3.2.2.1

Personnel responsible for the ESS operation, use, maintenance, repair, servicing, and response of theESS shall be trained in the procedures included in the emergency operations plan in 4.1.3.2.1.


Committee:


Committee Statement

CommitteeStatement:

Delete "use". People who use the ESS could be the general public. Training those whooperate, maintain, repair, service and respond is sufficient. "Use" is not needed.

ResponseMessage:

SR-28-NFPA 855-2018



50 of 186 1/22/2019, 3:28 PM


Sections] ]

The analysis shall evaluate the consequences of the following failure modes and others deemednecessary by the AHJ:

(1) Thermal runaway condition in a single module, or array, or unit

(2) Failure of an energy storage management system

(3) Failure of a required ventilation or exhaust system

Voltage surges on the primary electric supply

Short circuits on the load side of the ESS

(4) Failure of a required smoke detection, fire detection, fire suppression, or gas detection system


Committee:


Committee Statement

CommitteeStatement:

The large-scale fire testing definition uses the term "unit". The thermal runaway evaluation shouldutilize the same terminology if possible.

In addition to being very vague (what size surges? what wave shape? Duration?) the effects ofvoltage surges and shorts are product characteristics that should be addressed in the listing. Theyneed not be addressed at installation.

ResponseMessage:

SR-29-NFPA 855-2018




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4.1.4.3

The AHJ shall be permitted to approve the hazardous mitigation analysis as documentation of the safetyof the ESS installation provided the consequences of the analysis demonstrate the following:

(1) Fires or explosions will be contained within unoccupied ESS rooms for the minimum duration of thefire resistance rating specified in 4.3.6.

(2) Suitable deflagration protection is provided where required.

(3) Fires and explosions in ESS cabinets in occupied work centers allow occupants to safely evacuatein fire conditions .

(4) Toxic and highly toxic gases released during normal charging, discharging, and operation will notexceed the PEL in the area where the ESS is contained.

(5) Toxic and highly toxic gases released during fires and other fault conditions will not reachconcentrations in excess of immediately dangerous to life or health (IDLH) level in the building oradjacent means of egress routes during the time deemed necessary to evacuate from that area.

(6) Flammable gases released during charging, discharging, and normal operation will not exceed 25percent of the LFL.


Committee:


Committee Statement

CommitteeStatement:

The HMA must be reviewed and approved by the AHJ. In item 1, explosions cannot be onlycontained/mitigated with listed passive fire ratings. Item 3, work centers are not defined and limitthe application of occupant safety requirements.

ResponseMessage:

SR-30-NFPA 855-2018



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4.1.4.5*

Construction, equipment, and systems that are required for the ESS to comply with the hazardousmitigation analysis shall be installed, tested, and maintained in accordance with nationally recognizedstandards and specified design parameters this standard and the manufacturer's instructions .


Committee:


Committee Statement

CommitteeStatement:

"nationally recognized standards and specified design standards" is not specific and is opento inconsistent interpretation for maintenance

ResponseMessage:

SR-31-NFPA 855-2018



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4.1.5 Large-Scale Fire Test.

4.1.5.1*

Where required elsewhere in this standard, large-scale fire testing in accordance with 4.1.5 shall beconducted on a representative battery ESS in accordance with UL 9540A or equivalent test standard .

A.4.1.5.1

A UL 9540A test, or equivalent, methodology should evaluate the fire characteristics of an ESS thatundergoes thermal runaway, such as might occur due to a fault, physical damage, or exposure hazard.The data generated by the large-scale fire testing is intended to be used by manufacturers, systemdesigners, and AHJs to determine the fire and explosion protection required for an ESS installation.

4.1.5.2

The testing shall be conducted or witnessed and reported by an approved testing laboratory and showthat a fire involving one battery ESS unit will not propagate to an adjacent unit.

4.1.5.3

Where installed within buildings, the fire during the test shall be contained within the room or enclosedarea for a duration equal to the fire resistance rating of the room separation specified in Table 4.3.6 .

4.1.5.4*

The test report shall be provided to the AHJ for review and approval.

A.4.1.5.4

The test report will provide nonproprietary information that, among other things, describes the size andenergy capacity rating of the unit being tested, model numbers of the modules and ESS units,orientation of ESS in the test facility, and proximity of the ESS unit under test to adjacent ESS, walls,and monitoring sensors. The test report also includes a complete set of test results andmeasurements.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

“Battery ESS unit” is not a defined term, and the requirement should apply to all ESStechnologies as required. UL 9540A addresses many types of ESS.

ResponseMessage:

SR-54-NFPA 855-2018








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4.1.6.3

Combustible materials in occupied work centers shall not be stored within 3 ft (914 mm) of ESSequipment. and shall comply with Section 10.18 of NFPA 1 or other applicable fire codes.

4.1.6.4

Combustible materials in occupied work centers shall comply with Section 10.18 of NFPA 1 or otherapplicable fire codes.


Committee:


Committee Statement

CommitteeStatement:

Remove second "Shall" in statement - other option to create new line 4.1.6.x Combustiblematerials in occupied work centers shall comply with section 10.18 of NAPA A or other applicablefire codes.

ResponseMessage:

SR-32-NFPA 855-2018





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4.1.6.5

Section Subsection 4.1.6 4.13 shall not apply to dwelling units.


Committee:


Committee Statement

Committee Statement: The reference to 4.13 Water Supply seems out of place. The edits correct this.




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Second Revision No. 44-NFPA 855-2018 [ New Section after 4.2.1.1 ]

4.2.1.2*

Lead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2, used fordc power for control of substations and control or safe shutdown of generating stations under theexclusive control of the electric utility, and located outdoors or in building spaces used exclusively forsuch installations shall not be required to be listed in accordance with UL 9540.

A.4.2.1.2

This subsection is in line with the scope of 90.2(B)(5) of NFPA 70 and applies to lead-acid or nickel-cadmium batteries.


Committee:


Committee Statement

CommitteeStatement:

Lead-acid and nickel-cadmium battery systems designed in accordance with IEEE C2 and used forDC power for control of substations and control / safe shutdown of generating stations under theexclusive control of the electric utility located outdoors or in building spaces used exclusively forsuch installations are needed to ensure power is distributed to the electrical grid and have federaloversight.

ResponseMessage:

SR-44-NFPA 855-2018












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4.2.3.1

Retrofitting of ESS shall comply with the following:

An installation permit shall be obtained in accordance with local codes.

(1) ESS units such as batteries, battery Battery systems and modules, and capacitors capacitorsystems and modules shall be listed in accordance with UL 1973.

(2) Battery management and other monitoring systems shall be connected and installed in accordancewith the manufacturer’s instructions.

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

(4) Retrofits shall be documented in the maintenance, testing, and events log required in 4.1.2.3.


Committee:


Committee Statement

CommitteeStatement:

Guidance on permits is not included elsewhere in the draft, with the exception of permits for mobileESS installations in section 4.5.3. The need to comply with local codes is implicit. If a retrofit maytrigger a permit per local codes, this guidance should be moved to the appendix. Otherwise, all ofthe ESS activities that could require a permit should be delineated in the appropriate sections on thestandard.

Battery systems and modules wouldn't be listed to 1989.

ResponseMessage:

SR-34-NFPA 855-2018



59 of 186 1/22/2019, 3:28 PM


4.2.3.3*

Changing out or retrofitting existing lead-acid or nickel-cadmium battery systems with other lead-acid ornickel-cadmium battery systems that are designed in accordance with IEEE C2, used for dc power forcontrol of substations and control or safe shutdown of generating stations under the exclusive control ofthe electric utility, and located outdoors or in building spaces used exclusively for such installations shallbe considered repairs when there is no increase in system size or capacity greater than 10 percent fromthe original design.

A.4.2.3.3

This subsection is in line with the scope of 90.2(B)(5) of NFPA 70 and applies to lead-acid or nickel-cadmium batteries.


Committee:


Committee Statement

CommitteeStatement:

Lead-acid and nickel-cadmium battery systems designed in accordance with IEEE C2 and used forDC power for control of substations and control / safe shutdown of generating stations under theexclusive control of the electric utility located outdoors or in building spaces used exclusively forsuch installations are needed to ensure power is distributed to the electrical grid and have federaloversight. This is in line with the scope of the National Electrical Code section 90.2(B)(5) and appliesto Lead Acid or Nickel Cadmium batteries.

ResponseMessage:

SR-45-NFPA 855-2018










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4.2.3.2

Changing out or retrofitting existing lead-acid or nickel-cadmium battery systems with other lead-acid ornickel-cadmium battery systems less than 50 V ac, 60 V dc in telecommunications facilities forinstallations of communications equipment under the exclusive control of communications utilities locatedoutdoors or in building spaces used exclusively for such installations that are in compliance with NFPA 76shall be considered repairs when there is no increase in system size or capacity greater than 10 percentfrom the original design .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This change was made to provide consistency between the exception for electric utilities andthe telecommunications industry.

ResponseMessage:

SR-70-NFPA 855-2018


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4.2.7.2

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


Committee:


Committee Statement

CommitteeStatement:

The terms pre-engineered or pre-packaged have been deleted from the draft. The documentsimply considers ESS.

ResponseMessage:

SR-35-NFPA 855-2018



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4.2.9.5*

Lead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2, used fordc power for control of substations and control or safe shutdown of generating stations under theexclusive control of the electric utility, and located outdoors or in building spaces used exclusively forsuch installations shall not be required to comply with 4.2.9.1 through 4.2.9.3 .

A.4.2.9.5

This is in line with the scope of 90.2(B)(5) of NFPA 70 and applies to lead-acid or nickel-cadmiumbatteries.


Committee:


Committee Statement

CommitteeStatement:

The committee has created new requirements to permit Utilities to not comply with certainsections to align with the requirements of the national electrical code as well as to allow utilities touse certain technology for infrastructural resilience and safety.

ResponseMessage:

SR-47-NFPA 855-2018









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4.2.10 Reused and Repurposed Equipment.

4.2.10.1

Storage batteries previously used in other applications, such as electric vehicle propulsion, shall not bepermitted provided unless the equipment is repurposed by a UL 1974 compliant battery repurposingcompany when reused in ESS applications and the system complies with 4.2.1.

4.2.10.2

Materials, equipment, and devices shall not be reused or reinstalled unless such elements have beenreconditioned, tested, and placed in good and proper working condition and approved.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Reused and re-purposed equipment includes more than just the battery and this SR tries toaddress that.





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4.3.2* Working Space.

At a minimum, ESS equipment shall be located provided with working space in accordance with NFPA70or IEEE C2, as appropriate, for operation, inspection, troubleshooting, maintenance, or replacement.


Committee:


Committee Statement

CommitteeStatement:

Utilities are following the applicable ANSI/IEEE standards. Utility substations are exempt fromNFPA 70 and follow IEEE C2 for work space requirements.

ResponseMessage:

SR-36-NFPA 855-2018










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4.3.5.2*

The signage required in 4.3.5.1 shall be in compliance with ANSI Z535 and shall include the followinginformation as shown in Figure 4.3.5.2:

(1) Labeled “Energy Storage Systems” with symbol of lightning bolt in a triangle

(2) Type of technology associated with the ESS

(3) Special hazards associated as identified in Chapters 5 9 through Chapter 14 15 .

(4) Type of suppression system installed in the area of the ESS

(5) Emergency contact information

Figure 4.3.5.2 Example of ESS Signage.


Committee:


Committee Statement

Committee Statement: This aligns the image with the text





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4.3.5.3

A permanent plaque or directory denoting the location of all electric power source disconnecting means onor in the premises shall be installed at each service equipment location and at the location(s) of thesystem disconnect(s) for all energy sources capable of being interconnected.

4.3.5.3.1

Energy storage located on property that is under the exclusive control of utilities, secured from publicaccess, and in accordance with 90.2 B(5) of NFPA 70 shall not be required to comply with 4.3.5.3 .

4.3.5.3.2

Energy storage located in a dedicated-use building that is under the exclusive control oftelecommunication utilities and secured from public access shall not be required to comply with4.3.5.3 .


Committee:


Committee Statement

CommitteeStatement:

Utilities have a special security need for their disconnect to not be labeled due to risk ofvandalism and terrorist activities.

ResponseMessage:

SR-37-NFPA 855-2018








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4.3.6 Separation.

Rooms or spaces containing ESS in other than high hazard occupancies shall be separated from otherareas of the building in accordance with Table 4.3.6 by fire barriers with a minimum 2-hour fire resistancerating and horizontal assemblies with a minimum 2-hour fire resistance rating, constructed in accordancewith the local building code .

Table 4.3.6 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


Committee:


Committee Statement

CommitteeStatement:

The heat potential fire event and the hrr it produces is not occupancy based. From a fire protectionstandpoint it make no sense to provide for a differing fire-resistance rating, i.e., reduced to I hour forother occupancies. This change will also provide for consistency with changes submitted to theInternational Building Code and International Fire Code that has been approved by the IFCCommittee.

ResponseMessage:

SR-39-NFPA 855-2018



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4.3.7.1

All ESS shall be located or protected to prevent physical damage from impact where such risks areidentified .


Committee:


Committee Statement

CommitteeStatement:

Not all ESS need protection from physical damage such as impact, because someenvironments do not present such risks. The protection should be based on identified threats.

ResponseMessage:

SR-40-NFPA 855-2018



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4.3.7.3*

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 .

(2) Posts shall be filled with concrete.

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

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

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

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


Committee:


Committee Statement

Committee Statement: Style question - Shall used twice in same directive.




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4.3.9 Elevation.

ESS shall be located only on floors that can be accessed by external fire department laddering capabilitiesunless a higher location is approved by the AHJ .

4.3.9.1 Belowgrade Installations.

4.3.9.1.1

ESS installations where the floor level is below the finished floor of the lowest level of exit dischargeshall not be permitted unless the location is approved by the AHJ.

4.3.9.1.2

The ESS shall not be located inside an electrical room.

4.3.9.1.3

The ESS shall be accessible to emergency responders without traversing through an electrical room.

4.3.9.1.4

When approved by the AHJ, ESS installations in underground vaults constructed in accordance withPart III of Article 450 of NFPA 70 shall be permitted.

4.3.9.2

When approved by the AHJ, ESS installations on rooftops of buildings that do not obstruct firedepartment rooftop operations shall be permitted.

4.3.9.3

The requirements in 4.3.9 shall not apply to the following:

(1) Lead-acid and nickel-cadmium battery systems less than 50 V ac, 60 V dc in telecommunicationsfacilities for installations of communications equipment under the exclusive control ofcommunications utilities and located outdoors or in building spaces used exclusively for suchinstallations that are in compliance with NFPA 76

(2)

(3) Lead-acid battery systems in uninterruptable power supplies listed and labeled in accordance withUL 1778, utilized for standby power applications, which is limited to not more than 10 percent ofthe floor area on the floor on which the ESS is located

4.3.9.4

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

4.3.9.5

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

4.3.9.6

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

* Lead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2,used for dc power for control of substations and control or safe shutdown of generating stationsunder the exclusive control of the electric utility, and located outdoors or in building spaces usedexclusively for such installations

A.4.3.9.3(2)

This is in line with the scope of 90.2(B)(5) of NFPA 70 and applies to lead-acid or nickel-cadmium batteries.


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Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The committee has changed this section to no longer have a height limitation but rather leave it upto the local fire departments laddering capabilities, which the old limitation was based on anyway.The committee also elaborated on below grade installation requirements.

ResponseMessage:

SR-164-NFPA 855-2018

Public Comment No. 645-NFPA 855-2018 [New Section after 4.4.2.4.4]








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Sections] ]

Indoor ESS installations shall comply with this section and as detailed in Table 4.4.2.

Table 4.4.2 Indoor ESS Installations

Compliance RequiredDedicated-Use

BuildingsaNon-Dedicated-Use

Buildingsb Reference

Administrative Yes Yes Chapters 1–3

General Yes YesSections4.1–4.3

Size and separation Yesc Yes Section 4.6

Maximum rated energyMaximumstored energy

No Yes Section 4.8

Elevation Yes Yes 4.4.2.44.3.9

Separation NA Yes 4.3.6

Smoke and fire detection Yesd Yes Section 4.10

Fire control and suppression Yesc Yes Section 4.11

Water supply Yesc Yes Section 4.13

Signage Yes Yes 4.3.5

Occupied work centers Not allowed Yes Section 4.7

Technology-specific protection Yes YesChapters9–1613

NA: Not applicable.

aSee 4.4.2.1.

bSee 4.4.2.2.

cWhere approved by the AHJ, the fire control and suppression systems, the size and separationrequirements, and the water supply are permitted to be omitted in dedicated-use buildings located morethan 100 ft (30.5 m) from buildings, lot lines that can be built upon , public ways, stored combustiblematerials, hazardous materials, high-piled stock, and other exposure hazards not associated with electricalgrid infrastructure.

dWhen approved, alarm signals are not required to be transmitted to an approved location when local firealarm annunciation is provided and trained personnel are always present.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Correcting Reference and lot lines that can not be built upon do not pose the same exposurerisk as those that can be built upon.

ResponseMessage:

SR-72-NFPA 855-2018




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4.4.2.3 Dwelling Units and Sleeping Units.

4.4.2.3.1

Stationary ESS shall not be installed in sleeping units rooms or in habitable spaces living areas ofdwelling units unless specifically allowed in Chapters 9 through 17 13 .

4.4.2.3.2

Portable ESS regulated by this standard shall be permitted to be used in sleeping units rooms and inhabitable spaces of dwelling units provided they are listed and are used in accordance with the terms oftheir listing .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The modification is to match the broader restriction concerning "living areas" found inSection 17.5.2.





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4.4.2.4 Elevation.

ESS shall be located only on floors that can be accessed by external fire department ladderingcapabilities unless a higher location is approved by the AHJ.

4.4.2.4.1

Installations where the floor level is below the finished floor of the lowest level of exit discharge shall notpermitted unless the location is approved by the AHJ.

4.4.2.4.2

When approved, installations on rooftops of buildings that do not obstruct fire department rooftopoperations shall be permitted.

4.4.2.4.3

When approved, installations in underground vaults constructed in accordance with NFPA 70 , Article450, Part III, shall be permitted.

4.4.2.4.4

The requirements in 4.4.2 do not apply to lead-acid and nickel-cadmium battery systems less than 50V ac, 60 V dc in telecommunications facilities for installations of communications equipment under theexclusive control of communications utilities located outdoors or in building spaces used exclusively forsuch installations that are in compliance with NFPA 76 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

There was two section that gave requirements on the elevation. They have been blendedtogether and are now in section 4.3.9

ResponseMessage:

SR-165-NFPA 855-2018


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4.4.3.1 Classification.

Outdoor ESS installations shall be classified as follows:

(1) Remote locations. Remote outdoor locations include ESS located more than 100 ft (30.5 m) frombuildings, lot lines that can be built upon , public ways, stored combustible materials, hazardousmaterials, high-piled stock, and other exposure hazards not associated with electrical gridinfrastructure.

(2) Locations near exposures. Locations near exposures include all outdoor ESS locations that do notcomply with remote outdoor location requirements.


Committee: ESS-AAA


Committee Statement

Committee Statement: lot lines that can't be built upon do not need to be considered an exposure.









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4.4.3.2.1

Outdoor walk-in containers or enclosures housing ESS shall not exceed 53 ft × 8.5 ft × 9.5 ft high (16.2 m× 2.6 m × 2.9 m), not including HVAC and other equipment .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The length and height stated are common measurements for high cube ISO containers, theadjustment of the width from 8ft to 8.5 ft brings the width in line with the common width dimensionfor the high cube container. This has also been changed to allow HVAC and other equipment to beattached to the exterior without expanding the footprint.

ResponseMessage:

SR-136-NFPA 855-2018




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Sections] ]

ESS located outdoors shall be separated by a minimum 10 ft (3048 mm) from the following exposures:

(1) Lot lines

(2) Public ways

(3) Buildings

(4) Stored combustible materials

(5) Hazardous materials

(6) High-piled stock

(7) Other exposure hazards not associated with electrical grid infrastructure


Committee: ESS-AAA


Committee Statement

Committee Statement: Statement was inconsistent with other application of grid infrastructure and separation.




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4.4.3.3.2

Clearances to buildings shall be permitted to be reduced to 3 ft (914 mm) where noncombustible exteriorwalls with no openings or combustible overhangs are provided on the wall adjacent to the ESS. The andthe fire resistance rating of the exterior wall shall comply complies with the fire resistance requirements inTable 4.4.3 4.3.6 .


Committee: ESS-AAA


Committee Statement

Committee Statement: Correcting incorrect reference and removing multiple requirements in one section.




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4.4.3.3.3

Clearances to buildings shall be permitted to be reduced to 3 ft (914 mm) where the enclosure of the ESSis constructed of noncombustible materials and it has been demonstrated that a fire within the enclosurewill not ignite combustible materials outside the enclosure based on large-scale fire testing complying with4.1.5.

4.4.3.3.4

Where approved, clearances to exposures other than buildings shall be permitted to be reduced to 3 ft(914 mm) where large-scale fire testing of the ESS in accordance with 4.1.5 demonstrates that a firewithin the ESS enclosure will not generate radiant heat flux sufficient to ignite stored materials orotherwise threaten the exposure.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The standard already requires noncombustible enclosures so redundant language was removed.Acceptance criteria has been more clearly defined. The addition of 4.4.3.3.4 was based on theAHJ approval and proper testing requirements.

ResponseMessage:

SR-56-NFPA 855-2018

Public Comment No. 522-NFPA 855-2018 [Sections 4.4.3.3.3, 4.4.3.3.4]


81 of 186 1/22/2019, 3:28 PM


4.4.3.3.5

Clearances to buildings and exposures shall be permitted to be reduced to 3 ft (914 mm) where theenclosure of the ESS has a 2-hour fire resistance rating established in accordance with ASTM E119 or UL263.


Committee: ESS-AAA


Committee Statement

Committee Statement: clearences should be applied to exposures as well as buildings.



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4.4.3.4.2

Where approved by the AHJ, clearances to means of egress shall be permitted to be reduced to 3 ft(914 mm) where large-scale fire testing in accordance with 4.1.5 demonstrates that a fire within theESS will not adversely impact the means of egress.


Committee: ESS-AAA


Committee Statement

Committee Statement: This adds clarification to distances from means of egress in addition to other exposures.



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4.4.3.4.3

The AHJ shall be authorized to approve smaller separation distances if large-scale fire and faultcondition testing complying with 4.1.5 is provided that shows that a fire involving the ESS will notadversely impact occupant egress.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This section has been deleted because it is repeating the same requirements as stated in4.4.3.4.2.




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4.4.3.5.1

Where an ESS includes an outer enclosure, the unit shall only be entered for inspection, maintenance,and repair of energy storage units and ancillary equipment, and shall not be occupied for other purposes.


Committee: ESS-AAA


Committee Statement

Committee Statement: Style issue remove second shall to separate line.




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4.4.3.10 Exterior Wall Installations.

4.4.3.10.1

ESS shall be permitted to be installed outdoors on exterior walls of buildings when all of the followingconditions are met:

(1) The maximum stored energy of individual ESS units shall not exceed 20 kWh (72 MJ).

(2) The ESS shall comply with applicable requirements in Chapter 4 .

(3) The ESS shall be installed in accordance with the manufacturer's instructions and their listing.

(4) Individual ESS units shall be separated from each other by at least 3 ft (914 mm).

(5) The ESS shall be separated from doors, windows, operable openings into buildings, or HVACinlets by at least 5 ft (1524 mm).

4.4.3.10.2

Where approved by the AHJ, smaller separation distances in items (4) and (5) shall be permitted basedon large scale fire testing in accordance with 4.1.5 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This addition provides requirements for a common installation of smaller energy ESS unitsoccurring now on buildings of various occupancies. The parameters of allowing for exterior wallinstallations at various occupancies are consistent for what is allowed for one- and two-familydwellings. This addition will provide for consistency with new language added to the IFC.

ResponseMessage:

SR-140-NFPA 855-2018



86 of 186 1/22/2019, 3:28 PM


Sections] ]

Rooftop and open parking garage ESS installations shall comply with this section and as detailed in Table4.4.4.

Table 4.4.4 Rooftop and Open Parking Garage ESS Installations

Compliance Required Rooftopsa*Open Parking

Garagesb†Reference

Administrative Yes Yes Chapters 1–3

General Yes Yes Sections 4.1–4.3

Maximum size Yes Yes 4.4.3.2

Means of egress separation Yes Yes 4.4.3.4

Walk-in units Yes Yes 4.4.3.5

Enclosures Yes Yes 4.4.3.7

Clearance to exposures Yes Yes 4.4.4.2

Fire suppression and control Yes Yes Section 4.11

Rooftop installations Yes No 4.4.4.4

Open parking garages No Yes 4.4.4.5

Size and separation Yes Yes Section 4.6

Maximum rated energyMaximum storedenergy

Yes Yes Section 4.8

Elevation Yes Yes 4.3.9

Smoke and Firefire detection Yes Yes Section 4.10

Signage Yes Yes 4.3.5

Occupied work centers Not allowed Not allowed Section 4.7

Open rack installations Not allowed Not allowed 4.3.11

Technology-specific protection Yes YesChapters9–1613

NA: Not applicable.

a * See 4.4.4.1(1).

b † See 4.4.4.1(2).


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Other Tables state Smoke and Fire detection. Section 4.10 titled Smoke and Fire Detection.Change for consistency.

ResponseMessage:

SR-141-NFPA 855-2018



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4.4.4.2.2

Clearances are shall be permitted to be reduced to 3 ft (914 mm) under the following conditions:

(1) Where a 1-hour freestanding fire barrier, suitable for exterior use, and extending 5 ft (1.5 m) aboveand extending 5 ft (1.5 m) beyond the physical boundary of the ESS installation is provided to protectthe exposure

(2) Where the weatherproof ESS enclosure is constructed of noncombustible materials and it has beendemonstrated that a fire within the enclosure will not ignite combustible materials outside theenclosure based on large-scale fire testing complying with Section 4.1.5 4.6


Committee: ESS-AAA


Committee Statement

Committee Statement: The reference should be 4.1.5 and not 4.6.






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4.4.4.3.1

ESS located in walk-in enclosures on rooftops or in open parking garages shall be provided withautomatic fire control and suppression systems within the ESS enclosure in accordance with Section4.11 4.8 .


Committee: ESS-AAA


Committee Statement

Committee Statement: 4.11 covers fire suppression for walk-in enclosures.





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4.4.4.3.3

When approved by the AHJ, ESS shall be permitted to be installed in open parking garages without theprotection of an automatic fire control and suppression system where large-scale fire and fault conditiontesting conducted in accordance with 4.1.5 indicates that an ESS fire does not present an exposurehazard to parked vehicles or compromise the means of egress.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

"Fault Condition" was removed to be consistent with the definitions section and the rest ofthe document.



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4.4.4.5 Open Parking Garages.

ESS and associated equipment that are located in open parking garages shall comply with all of thefollowing:

(1) ESS shall not be located within 50 ft (25 15 .3 m) of air inlets for building HVAC systems. Thisdistance shall be When approved, this distance is permitted to be reduced to 25 ft (7620 mm 7.6 m )if the automatic fire alarm system monitoring the radiant energy-sensing detectors de-energizes theventilation system connected to the air intakes upon detection of fire.

(2) ESS shall not be located within 25 ft (7620 mm 7.6 m ) of exits leading from the attached buildingwhen located on a covered level of the parking structure not directly open to the sky above. Whenapproved, the separation distance is permitted to be reduced to 10 ft (2048 mm 3 m ) based on large-scale fire and fault condition testing conducted in accordance with 4.1.5.

(3) Means of egress separation shall comply with 4.4.3.4.

(4) A radiant energy-sensing fire detection system complying with Section 4.10 shall be provided toprotect the ESS.

(5) An approved fence with a locked gate or other approved barrier shall be provided to keep the generalpublic at least 5 ft (1024 mm 1.5 m ) from the outer enclosure of the ESS.


Committee: ESS-AAA


Committee Statement

Committee Statement: Multiple shall statements in the same section has been corrected.




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4.5.1.1

Mobile ESS used to temporarily provide power to lead-acid and nickel-cadmium battery systems thatare designed in accordance with IEEE C2, used for dc power for control of substations and control orsafe shutdown of generating stations under the exclusive control of the electric utility, and locatedoutdoors or in building spaces used exclusively for such installations shall not be required to complywith 4.5.1 .


Committee: ESS-AAA


Committee Statement

Committee Statement: Utilities may have to deploy large ESS to help the infrastructure of an area.







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4.5.2.1

Mobile ESS used to temporarily provide power to lead-acid and nickel-cadmium battery systems thatare designed in accordance with IEEE C2, used for dc power for control of substations and control orsafe shutdown of generating stations under the exclusive control of the electric utility, and locatedoutdoors or in building spaces used exclusively for such installations shall not be required to complywith 4.5.2 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Utilities may have to deploy ESS on a temporary basis to support electrical infrastructure onan emergency basis.

ResponseMessage:

SR-124-NFPA 855-2018


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4.5.4 Deployment Documents.

The following information shall be provided to the AHJ with any locally required operational permitapplications for mobile ESS deployments:

(1) Relevant information for the mobile ESS equipment and protection measures in the constructiondocuments required by 4.1.2

(2) Location and layout diagram of the area in which the mobile ESS is to be deployed, including a scalediagram of all nearby exposures

(3) Location and content of signage, including no smoking signs

(4) Description of fencing to be provided around the ESS, including locking methods

(5) Details on fire suppression, smoke and automatic fire detection, system monitoring, thermalmanagement, exhaust ventilation, and explosion control, if provided

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

(7) Description of the temporary wiring, including connection methods, conductor type and size, andcircuit overcurrent protection to be provided

(8) Description of how fire suppression system connections to water supplies or extinguishing agents areto be provided

(9) Contact information for personnel who are responsible for maintaining and servicing the equipmentand responding to emergencies


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The signage requirements found in Section 4.3.5.1 refer to ESS specific signage. There is norequirement for no smoking signs and they should not be included here. As written there is noguidance where such signs belong.

ResponseMessage:

SR-122-NFPA 855-2018



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Sections] ]

Deployed mobile ESS equipment and operations shall comply with this section and Table 4.5.7.

Table 4.5.7 Mobile Energy Storage Systems (ESS)

Compliance Required Deploymenta Reference

Administrative Yes Chapters 1–3

General Yes Sections 4.1–4.3

Size and separation Yesb Section 4.6

Maximum rated energyMaximum stored energy Yes Section 4.8

Fire and smoke detection Yesc Section 4.10

Fire control and suppression Yesd,e Section 4.11

Maximum size Yes 4.4.3.2

Vegetation control Yes 4.4.3.6

Means of egress separation Yes 4.4.3.4

Technology-specific protection Yes Chapters 9–1613

aSee 4.5.2.

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

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

dSee 4.5.7.2.

e Only required for walk-in units.


Committee: ESS-AAA


Committee Statement

Committee Statement: The intent is to apply these requirements to walk in units only.





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4.5.7.3 Duration.

Mobile ESS deployments that provide power for durations longer than 30 days shall comply with 4.5.6 .

4.5.7.3.1

Mobile ESS deployments that provide power for durations longer than 30 days shall comply with 4.5.6.

4.5.7.3.2

Mobile ESS deployments in excess of 30 days, for emergencies, shall not be required to comply with4.5.6 , with AHJ approval.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The intent of this section is to treat mobile deployments of duration longer thAn 30 days, aspermanent installations. Also, the reference may be incorrect (seems circular).

ResponseMessage:

SR-126-NFPA 855-2018



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4.5.7.5.1.1

Required separation distances shall be permitted to be reduced in accordance with 4.4.3.3.1 through4.4.3.3.4 .


Committee: ESS-AAA


Committee Statement

Committee Statement: Separation distances should be able to be reduced based on fire protection measures.





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4.5.7.6.1

Temporary wiring for electrical power connections shall comply with NFPA 70 or equivalent code .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The section as written conflicts with the NESC. Recommend adding the applicableinstallation standard.




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4.5.7.8 Fencing.

An approved fence with a locked gate or other approved barrier shall be provided to keep the generalpublic at least 5 ft (1024 mm) from the outer enclosure of a deployed mobile ESS.

4.5.7.8.1

An approved fence with a locked gate or other approved barrier shall be provided to keep the generalpublic at least 5 ft (1024 mm) from the outer enclosure of a deployed mobile ESS.

4.5.7.8.2

A mobile ESS that is locked to prevent access by unauthorized persons shall be accepted as meeting4.5.7.8 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

If a mobile piece of equipment is deployed, it is almost certainly going to be provided to serve atemporary need. To require a permanent fence around a temporary piece of equipment isunreasonable and unnecessary if the equipment is designed to be safe to be operated without afence, as demonstrated by a 3rd party listing.

ResponseMessage:

SR-129-NFPA 855-2018



99 of 186 1/22/2019, 3:28 PM


Global SR-121

4.6.2

ESS shall be comprised of groups with a maximum energy capacitymaximum stored energy of 25050kWh each.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The size has been reduced to 50 kWh for consistency with changes to the IFC and based upon thehrr exhibited by lower energy amounts when subjected to large scale fire testing. The impact isnegligible since large scale fire testing is required for lower levels anyway to generate data fordeflagration prevention and correct fire protection levels.

ResponseMessage:

SR-75-NFPA 855-2018




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4.6.6*

Subsections 4.6.2 and 4.6.3 shall not apply to lead-acid and nickel-cadmium battery systemsdesigned in accordance with IEEE C2 and used for dc power for control of substations and control orsafe shutdown of generating stations under the exclusive control of the electric utility.

A.4.6.6



Committee:


Committee Statement

CommitteeStatement:

The committee is permitting a "carve out" for certain applications of specific batteries used foressential operations in areas under the control of an electric utility. This is inline with the scope ofNFPA 70.

ResponseMessage:

SR-49-NFPA 855-2018

Public Comment No. 535-NFPA 855-2018 [Section No. A.4.6]



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Second Revision No. 50-NFPA 855-2018 [ Section No. 4.8 [Excluding any Sub-Sections]

]

ESS in the following locations shall comply with Section 4.8 as follows:

(1) Fire areas within non-dedicated-use buildings containing ESS as described in 4.4.2.2 shall not exceedthe maximum rated energy maximum stored energy values in Table 4.8 except as permitted by 4.8.1.

(2) Outdoor ESS installations in locations near exposures as described in 4.4.3.1(2) shall not exceed themaximum rated energy maximum stored energy values in Table 4.8 except as permitted by4.8.2 4.8.3 .

(3) ESS installations in open parking garages and on rooftops of buildings as described in 4.4.4.1 shallnot exceed the maximum rated energy maximum stored energy values in Table 4.8 except aspermitted by 4.8.2 4.8.3 .

(4) Mobile ESS equipment as covered by Section 4.5 shall not exceed the maximum ratedenergy maximum stored energy values in Table 4.8 except as permitted by 4.8.2 4.8.3 .

Table 4.8 Maximum Rated ESS EnergyMaximum Stored Energy

ESS Type Maximum Rated EnergyMaximum Stored Energy*a (kWh)

Lead-acid batteries, all typesb 600Unlimited

Nickel-cadmium batteriesb 600Unlimited

Lithium-ion batteries, all types 600

Sodium nickel chloride batteries, all types 600

Flow batteries†c 600

Other battery technologies 200

Storage Capacitorscapacitors 20

* aFor batteries and capacitors rated ratings in amp-hrs, kWh should equal maximum rated voltagetimes multiplied by amp-hr rating divided by 1000.

b Quantities are unlimited in the telecommunication buildings complying with NFPA 76.

b Nickel battery technologies include nickel cadmium (Ni-Cad), nickel metal hydride (Ni-MH), and nickelzinc (Ni-Zn).

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


Committee:


Committee Statement

CommitteeStatement:

The Committee created a "carve out" for electric utilities for specific types of batteries that areneeded for the safe shutdown of power generation equipment. This is in line with the scope ofNFPA 70. References corrected. Capacitors aren't rated in amp-hours.

ResponseMessage:

SR-50-NFPA 855-2018





102 of 186 1/22/2019, 3:28 PM






103 of 186 1/22/2019, 3:28 PM


4.8.3

Where more than one ESS technology is present within a fire area, the fire protection systems shall bedesigned to protect the greatest hazard.


Committee: ESS-AAA


Committee Statement

Committee Statement: improve the flow of the document


Public Comment No. 134-NFPA 855-2018 [Sections 4.8.2, 4.8.3]


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4.8.2

Where approved by the AHJ, outdoor ESS installations, ESS installations in open parking garages and onrooftops of buildings, and mobile ESS equipment that exceed the amounts in Table 4.8 shall be permittedbased on a hazardous mitigation analysis in accordance with Section 4.16 4.1.4 and large-scale fire andfault condition testing complying in accordance with 4.1.5.


Committee: ESS-AAA


Committee Statement

Committee Statement: corrected reference and removed fault condition testing for consistency.



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4.8.4

Where a single fire areas area within buildings and other installations contain building or walk-in unitcontains a combination of energy systems covered in Table 4.8, the total aggregate quantities maximumstored energy per fire area shall be determined based on the sum of percentages of each type divided bythe maximum rated stored energy of each type.


Committee: ESS-AAA


Committee Statement

Committee Statement: cleaned up language to clarify



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4.9.1 General.

Where required by Table 9.2 or elsewhere in this standard, exhaust ventilation shall be provided forrooms, enclosures, walk-in containers units , and cabinets in accordance with 4.9.2 or 4.9.3.


Committee: ESS-AAA


Committee Statement

Committee Statement: Walk in units is a defined term.



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4.9.2* Exhaust Ventilation by Design.

The ventilation system shall be designed to limit the maximum concentration of flammable gas to 25percent of the lower flammable limit (LFL) of the total volume of the room, walk-in unit, enclosure,container, or cabinet during the worst-case event of simultaneous “boost” charging of all the batteries, inaccordance with nationally recognized standards.

A.4.9.2

See IEEE 1635/ASHRAE 21 which covers the ventilation of stationary battery systems utilizing vented(flooded) lead-acid, valve-regulated lead-acid (VRLA), and nickel-cadmium (Ni-Cad) batteries.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Annex material to add relevant reference standards and to categorize the ventilation moreclearly.




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4.9.3 Mechanical Exhaust Ventilation.

4.9.3.1

Mechanical exhaust ventilation shall be provided at a rate of not less than 1 ft3/min/ft2 (5.1 L/sec/m2) offloor area of the room, walk-in unit, enclosure, container, or cabinet.

4.9.3.1.1

The mechanical exhaust ventilation shall be either continuous or be activated by a gas detection systemin accordance with 4.9.3.4 4.9.3.2 .

4.9.3.1.2

Required mechanical exhaust ventilation systems shall be installed in accordance with the manufacturer’sinstallation instructions and local building, mechanical, and fire codes.

4.9.3.1.3

Required mechanical exhaust ventilation systems shall be supervised by an approved central station,proprietary, or remote station service in accordance with NFPA 72 or shall initiate an audible and visualsignal at an approved, constantly attended on-site location.

4.9.3.2

Where required by 4.9.3 4.9.3.1.1 , rooms, walk-in units, enclosures, walk-in containers, and cabinetscontaining ESS shall be protected by an approved continuous gas detection system that complies with thefollowing:

(1) The gas detection system shall be designed to activate the mechanical exhaust ventilation systemwhen the level of flammable gas detected in the room, walk-in unit, enclosure, container, and cabinetexceeds 25 percent of the LFL.

(2) The mechanical exhaust ventilation system shall remain on until the flammable gas detected is lessthan 25 percent of the LFL.

(3) The gas detection system shall be provided with a minimum of 2 hours of standby power.

(4) Failure of the gas detection system shall annunciate a trouble signal at an approved central station,proprietary, or remote station service or when approved at a constantly attended on-site inaccordance with NFPA 72 or at an approved, constantly attended location.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This change is clarifying the different approaches between exhaust ventilation by design andmechanical exhaust ventilation.

ResponseMessage:

SR-79-NFPA 855-2018





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4.10.3*

Lead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2, used fordc power for control of substations and control or safe shutdown of generating stations under theexclusive control of the electric utility, and located outdoors or in building spaces used exclusively forsuch installations shall be allowed to use the process control system to monitor the smoke detectorsrequired in 4.10.1 .

A.4.10.3



Committee:


Committee Statement

CommitteeStatement:

The Technical Committee created a "carve out" for the electric utilities utilizing a specifictechnology that needs to comply with an IEEE standard and that is critical to the safe shutdown oftheir systems. This is in line with the scope of NFPA 70.

ResponseMessage:

SR-51-NFPA 855-2018








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4.10.2*

Normally unoccupied, remote stand-alone telecommunications structures with a gross floor area of less

than 1500 ft2 (139 m2) utilizing lead-acid battery technology, or nickel-cadmium battery technology, ornickel-metal hydride battery technology shall not be required to have the detection required in 4.10.1.

A.4.10.2

This requirement is intended to address small, normally unoccupied structures in remote locations,such as repeater stations, which are not adjacent to other important buildings or structures. It is notintended to apply to structures in an urban or suburban setting. The AHJ determines which structuresare considered to be remote. The hardship of installing and maintaining smoke detection in thesesmall, remote structures, along with heating and cooling to maintain the smoke detectors within listingspecifications, is a reason for this exclusion.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Removed Nickel Metal Hydride for consistency with other exceptions. The annex noteprovides explanation of the intent of how to apply this section.

ResponseMessage:

SR-80-NFPA 855-2018


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4.11.1*

Where required elsewhere in this standard, fire control and suppression for rooms or areas withinbuildings and outdoor walk-in units containing ESS shall be provided in accordance with this section.

A.4.11.1

Fire control and suppression is only required to protect ESS when so specified elsewhere in thestandard, such as Table 4.4.2 , Table 4.4.3 , and Table 4.4.4 .

The fire control and suppression systems requirements in this section are intended to provideprotection in ESS rooms and outdoor walk-in units containing ESS. The protection serves the followingtwo purposes:

(1) Protect the building and nearby exposures from a fire initiating in the ESS

(2) Provide protection for ESS from an external exposure fire that impinges on the ESS

A phased approach to suppression can help mitigate failure points and limit fire impacts that canpotentially lead to thermal runaway or other more severe fire conditions.

Thermal Runaway . While non-water-based fire suppression has been shown to be effective atsuppressing Class B and Class C fires in ESS enclosures, current suppression agents, both waterbased and non-water based, are probably not going to be able to stop thermal runaway. No publishedcase studies, test reports, or data generated to date indicate otherwise. The current protectionconcepts in this standard, including size and separation, maximum rated energy, and elevation, aredesigned to try and keep a thermal runaway event from propagating from one ESS unit to another,contain a fire within a room or outdoor walk-in unit, and not allow it to compromise exposures.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Annex material was added to provide clarification as to the protection scheme requiredwithin this standard.



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Second Revision No. 100-NFPA 855-2018 [ Sections 4.11.2.1, 4.11.2.2 ]

4.11.3 Alternate Automatic Fire Control and Suppression Systems.

4.11.3.1*

Where other fixed Other automatic fire control and suppression systems are used to provide requiredprotection, they shall be permitted based on reports issued as a result of large-scale fire testing asprovided in accordance with 4.11.2 4.1.5 .

A.4.11.3.1

UL 9540A Installation Level Test, Method 2, provides the data needed to determine if other fixed firecontrol and suppression systems are suitable for the application. Equivalent test standards, aspermitted in 4.1.5 , can provide comparable data.

4.11.3.1.1*

Foam fire suppression systems shall be designed to provide a foam blanket or foam submergence untilit can be demonstrated that the ESS has cooled to below the temperature that can cause thermalrunaway and below the autoignition temperature of combustible material present.

A.4.11.2.1.1

Fire suppression system discharge durations should be held as long as the hazards of thermalrunaway and autoignition of combustible material present exist.

When foam suppression systems are used, full discharge tests should be completed to determine if

the ESS will be submerged. Fencing with a maximum opening of 2 in. 2 (1300 mm 2 ) or otherbarriers should be used when openings in the protected ESS enclosure are present.

4.11.3.1.1 Gaseous Agent Fire Suppression Systems.

4.11.3.1.1.1

Total flooding gaseous agent systems shall be designed based on the following factors including but notlimited to:

The agent concentrations required for the specific combustible materials involved

The specific configuration of the equipment and enclosure

4.11.3.1.1.2*

Total flooding gaseous suppression systems shall be designed to maintain the design concentrationwithin the enclosure for a time to ensure that the fire is extinguished and that temperatures of the ESShave cooled to below the autoignition temperature of combustible material present and the temperaturethat can cause thermal runaway as defined in the emergency operations plan.

A.4.11.2.1.2.2

Fire suppression system design concentrations and discharge durations should be held as long as thehazards of hot ESS components above the autoignition temperature and thermal runaway exist. Themanufacturer should be consulted for applicable ESS cooldown times. It is recommended that theminimum discharge time be no less than twice the time demonstrated to achieve fire extinguishmentand component cooldown for the suppressant used. Where design concentrations cannot bemaintained effectively, an alternative system should be provided.

4.11.3.1.1.2

An operating device shall be available in an approved location such that fire services can begin exhaustprior to hold time expiration if deemed necessary.


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4.11.3.1.1.3*

Local application gaseous agent suppression systems shall be designed to operate for a time sufficientto ensure that the fire is extinguished and that temperatures of the ESS have cooled to below theautoignition temperature of combustible material present and the temperature at which thermal runawaycan occur.

A.4.11.2.1.2.4

Fire suppression system discharge durations should be held as long as the hazards of temperaturesabove the autoignition temperature and the temperature at which thermal runaway can occur. Themanufacturer should be consulted for applicable ESS cooldown times. Information on fire tests thatdemonstrate the extinguishment time for an ESS should also be considered in determining theminimum discharge time. It is recommended that the minimum discharge time be no less than twicethe time demonstrated to achieve fire extinguishment for the suppressant used. An extendeddischarge time is necessary to prevent potential fire reignition due to smoldering and heat soak.

4.11.3.1.2

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

4.11.3.1.3*

Water mist suppression systems shall be designed and installed in accordance with their listing for thespecific hazards and protection objectives specified in the listing.

A.4.11.2.1.4

Water mist fire suppression systems need to be designed specifically for use with the size andconfiguration of the specific ESS installation or enclosure being protected. Currently there is nogeneric design method recognized for water mist systems. System features such as nozzle spacing,flow rate, drop size distribution, cone angle, and other characteristics need to be determined for eachmanufacturer’s system through large-scale fire testing in accordance with Section to obtain a listing foreach specific application and must be designed, installed, and tested in accordance with NFPA 750 .

4.11.3.2*

Where other fixed The automatic fire control and suppression systems are used, they shall comply withthe following standards, or their equivalent, as appropriate:

(1) NFPA 12

(2) NFPA 15

(3) NFPA 750

(4) NFPA 2001

(5) NFPA 2010


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A.4.11.3.2


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Gaseous Agents. Gaseous agent fire suppression systems can be used to protect ESS fires in either ofthe following two ways:

(1) Total flooding systems are used where there is a permanent enclosure around the fire hazard thatis adequate to enable the design concentration to be built up and to be maintained for the period oftime required to ensure the complete and permanent extinguishment of a fire for the specificcombustible materials involved. For total flooding systems, potential leakage sources should beincluded in the gaseous agent design quantities, which should include leakage through ventilationdampers. Usually ventilation dampers are either gravity actuated (i.e., close when the ventilationfans automatically shut down upon gaseous agent discharge) or pressure actuated (i.e., close bymeans of counterweight and a pressure-operated latch that is activated by the gaseous agent).Leakage from the interface between the enclosure walls and the foundation should also be takeninto consideration. For ESS enclosures where the normal temperature of the enclosure exceeds200°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, where the fire hazard is not enclosed or where the enclosure does not conform tothe requirements for a total flooding system. For local application systems, it is imperative that theentire fire hazard be protected. The hazard area should include all areas that are subject tospillage, 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 ofhazard could necessitate dikes, drains, or trenches to contain any combustible material leakage.When multiple ESS equipment fire hazards are in an area such that they are interposing,provisions should be made to ensure that the hazards can be protected simultaneously, whichcould involve subdividing the hazards into sections and providing independent protection to eachsection.

Total flooding and local application gaseous agent systems should be designed based on factorsincluding but not limited to the following:

(1) Agent concentrations required for the specific combustible materials involved including buildingsystems and battery electrolytes, whichever are higher

(2) Design concentration for the electrolyte determined by a cup burner test of the appropriate batteryelectrolyte

(3) Specific configuration of the equipment and enclosure

(4) Design maintains the design concentration within the enclosure for a time to ensure that the fire isextinguished and that the enclosure temperatures of the ESS have has cooled to below theautoignition temperature of combustible material present and below the enclosure temperature thatcan cause thermal runaway as defined in the emergency operations plan

(5) Suppression systems’ inability to cool the internal battery temperature once thermal runaway hasstarted

To reduce potential downtime, gaseous agent fire suppression systems should generally be designed tohave the capacity to supply two full discharges to avoid having to keep the ESS shut down until thegaseous agent reservoir can be replenished, particularly after a minor fire or accidental discharge. Twofull discharges should use 90 percent of the total gaseous agent reservoir capacity as an optimumdesign; however, up to 95 percent is acceptable. For applications where ambient temperatures areabove the normal operating conditions of the gaseous agent reservoir, a shelter with ventilationopenings or an equivalent alternative should be used. Where ambient temperatures are below thenormal operating conditions of the gaseous agent reservoir, reservoir heaters (such as immersionheaters) and instrument line heaters should be used or, where applicable, the reservoir can besuperpressurized with nitrogen to maintain the required flows and pressures in a low-temperatureenvironment. Warning signs and safety instructions are required on some types of gaseous agentsystems. The user should refer to the appropriate NFPA standards for those systems for detailedrequirements.

Where total flooding gaseous systems are used, the ESS enclosure should be arranged for minimumleakage by automatic shutdown of fans and automatic closing of doors, ventilation dampers, and otheropenings. During operation of an ESS, there could be a need for substantial amounts of cooling andventilation air. This air flow will not stop immediately upon ESS shutdown and should be considered inthe extinguishing system design. Also, continuous mixing per 5.3.6 of NFPA 2001 can be consideredas it can help cooling, improve mixing, and improve dispersion of agent in to the battery rack.

If gas levels should continue to increase during a fire event an operating device should be available inan approved location such that fire services can begin exhaust prior to hold time expiration if deemed


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necessary.

Suppression systems can extinguish a fire but will not stop thermal runaway or off gassing if the cellsare damaged, creating a potential explosive environment. Similar to a natural gas fire, if gas is allowedto accumulate, a more hazardous condition can develop. There might be times that venting is morecritical than suppression. If the gas detection system continues to see increasing levels of combustiblegas or toxic gases during suppression, venting might be required through either a direct tie to the gasdetection system or a manual operation to begin venting. The suppression systems might not havereached their hold times yet and agent might be vented. Even if the fire has been extinguished andhold times have been met, the gas detection system should still be monitored in case of anysubsequent events. Venting might be required a later point as well.

Water Mist . Water mist fire suppression systems need to be designed specifically for use with the sizeand configuration of the specific ESS installation or enclosure being protected. Currently there is nogeneric design method recognized for water mist systems. System features such as nozzle spacing,flow rate, drop size distribution, cone angle, and other characteristics need to be determined for eachmanufacturer’s system through large-scale fire testing in accordance with Section 4.1.5 to obtain alisting for each specific application and must be designed, installed, and tested in accordance withNFPA 750.

Discharge Duration. Fire suppression system discharge durations should be held as long as thehazards of temperatures above the autoignition temperature and the temperature at which thermalrunaway can occur. The manufacturer should be consulted for applicable ESS cooldown times.Information on fire tests that demonstrate the extinguishment time for an ESS should also beconsidered in determining the minimum discharge time. It is recommended that the minimum dischargetime be no less than twice the time demonstrated to achieve fire extinguishment for the suppressantused. An extended discharge time is necessary to prevent potential fire reignition due to smoldering andheat soak. Where design concentrations cannot be maintained effectively, an alternative system shouldbe provided.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The fire protection requirements were simplified to allows for equivalent standards to be used inthe event this standard is used internationally. The language was also cleaned up to clarify thatautomatic sprinkler systems are required unless testing shows that other fire suppression systemsor other water densities can control the potential fire.

ResponseMessage:

SR-100-NFPA 855-2018


Public Comment No. 346-NFPA 855-2018 [Section No. A.4.11.2.1.2.1]


Public Comment No. 345-NFPA 855-2018 [New Section after A.4.11.2.1.2.2]








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4.11.5

Lead-acid battery systems in uninterruptable power supplies listed and labeled in accordance with UL1778, utilized for standby power applications, which is limited to not more than 10 percent of the floorarea on the floor on which the ESS is located, shall not be required to have a fire suppression systeminstalled.


Committee: ESS-AAA

Submittal Date: Tue Sep 25 10:58:46 EDT 2018

Committee Statement

CommitteeStatement:

This section was added to recognize that lead acid batteries are a technology that has beensafety implemented for a number of years and that there are already requirements for these.

ResponseMessage:

SR-166-NFPA 855-2018


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4.11.6*

Lead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2, used fordc power for control of substations and control or safe shutdown of generating stations under theexclusive control of the electric utility, and located outdoors or in building spaces used exclusively forsuch installations shall not be required to have a fire suppression system installed.

A.4.11.6



Committee:


Committee Statement

CommitteeStatement:

The committee created this carve out so that the electric utilities can safety shutdown theirgenerating technology when using a specific technology that is already covered by another IEEEstandard. This exception is in line with the National Electrical Code.

ResponseMessage:

SR-52-NFPA 855-2018












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4.11.4

Lead-acid and nickel-cadmium battery systems less than 50 V ac, 60 V dc that are in telecommunicationsfacilities for installations of communications equipment under the exclusive control of communicationsutilities and located outdoors or in building spaces used exclusively for such installations that are incompliance with NFPA 76 shall not be required to have a fire suppression system installed.


Committee: ESS-AAA


Committee Statement

Committee Statement: renumbered section to be consistent with the rest of the section



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4.11.7

When approved by the AHJ, ESS shall be permitted to be installed in open parking garages without theprotection of an automatic fire suppression system where full-scale fire and fault condition testingdocuments the system does not present an exposure hazard to parked vehicles when installed inaccordance with manufacturer’s instructions and this standard.

4.11.8

When approved by the AHJ, ESS shall be permitted to be installed in dedicated-use buildings withoutthe protection of an automatic fire control and suppression system where large-scale fire testingconducted in accordance with 4.1.5 documents that an ESS fire does not compromise the means ofegress and does not present an exposure hazard to buildings, lot lines, public ways, stored combustiblematerials, hazardous materials, high-piled stock, and other exposure hazards not associated withelectrical grid infrastructure.

4.11.9

When approved by the AHJ, ESS shall be permitted to be installed in outdoor walk-in enclosures withoutthe protection of an automatic fire control and suppression system where large-scale fire testingconducted in accordance with 4.1.5 documents that an ESS fire does not compromise the means ofegress and does not present an exposure hazard in accordance with 4.4.3.3 and 4.4.3.4 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Language was intended to mirror that of 4.11.3, so that dedicated use buildings and outdoor walk-in enclosures can address fire hazards in the same manner as parking garages. There was a gap inthe proposed wording, in that it did not appropriately capture exposures, and did not explicitlyrequire documentation be provided to the AHJ. This updated language is more complete.

Proposes a path to using large scale fire testing to demonstrate that fire suppression is notnecessary if a fire does not present a hazard.

ResponseMessage:

SR-101-NFPA 855-2018



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4.12* Explosion Control.

Hazardous exhaust and Where required elsewhere in this standard, explosion prevention or deflagrationventing shall be provided in accordance with this section.

A.4.12

During failure conditions such as thermal runaway, fire, and abnormal faults, some ESS, in particularelectrochemical batteries and capacitors, begin off-gassing flammable and toxic gases, which caninclude mixtures of CO, H2, ethylene, methane, benzene, HF, HCl, and HCN. Among other things,these gases present an explosion hazard that needs to be mitigated. Explosion control is provided tomitigate this hazard.

Both the exhaust ventilation requirements of Section 4.9 and the explosion control requirements ofSection 4.12 are designed to mitigate hazards associated with the release of flammable gases inbattery rooms and walk-in units. The difference is that exhaust ventilation is intended to provideprotection for flammable gases released during normal charging and discharging of battery systemssince some electrochemical ESS technologies such as vented lead-acid batteries release hydrogenwhen charging.

In comparison, the Section 4.12 provisions are designed to provide protection for electrochemicalESS during an abnormal condition, such as thermal runaway, which can be instigated by overcharging,short circuiting, and overheating technologies such as lithium-ion batteries, which incidentally do notrelease detectable amounts of flammable gas during normal charging and discharging, but which canrelease significant quantities of flammable gas during a thermal event.

4.12.1*

Lithium-ion technology ESS installed within a room, enclosure, or container shall be provided withdeflagration prevention by combustible concentration reduction measures in accordance with NFPA 69or shall be provided with deflagration venting in accordance with NFPA 68 . ESS installed within a room,building, or walk-in unit shall be provided with one of the following:

(1) Explosion prevention systems designed, installed, operated, maintained, and tested in accordancewith NFPA 69

(2) Deflagration venting installed and maintained in accordance with NFPA 68


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A.4.12.1

This requirement targets rooms, enclosures, and containers, not ESS in cabinets installed outdoors.During abnormal conditions such as a fire, when the ESS is off gassing, a mixture of flammable gasessuch as CO, H 2 , ethylene, methane, benzene, HF, HCl, and HCN is produced, which presents adeflagration hazard when confined within a room, enclosure, or container. The deflagration preventionmeasures are covered in Chapter 8 of NFPA 69 . The design of the exhaust system must be able tomaintain the combustible concentration in the room, enclosure, or container at or below 25 percent ofthe LFL of the mixture of gases given off. The design is based upon the emission rate of the mixture ofgases obtained by actual testing of the ESS buildings, and walk-in units, not ESS in cabinets installedindoors or outdoors or in open parking garages .

The alternative deflagration protection method is to provide deflagration venting in accordance withNFPA 68 . The explosion analysis is conducted with the total volume of the room, enclosure, orcontainer being filled with the mixture of gases generated by the fire. The composition of the mixtureof gases involved in a fire should be obtained by actual testing. When deflagration vents are installedon an enclosure or a container, walkways, egress paths, fire access roads, and other access pathsintended to be utilized by first responders should be taken into consideration in locating the vents.

NFPA 68 applies to the design, location, installation, maintenance, and use of devices and systemsthat vent the combustion gases and pressures resulting from a deflagration within an enclosure so thatstructural and mechanical damage is minimized, and provides criteria for design, installation, andmaintenance of deflagration vents and associated components.

NFPA 69 applies to the design, installation, operation, maintenance, and testing of systems for theprevention of explosions in enclosures that contain flammable concentrations of flammable gases,vapors, mists, dusts, or hybrid mixtures by means of the following methods:

(1) Control of oxidant concentration

(2) Control of combustible concentration

(3) Pre-deflagration detection and control of ignition sources

(4) Explosion suppression

(5) Active isolation

(6) Passive isolation

(7) Deflagration pressure containment

(8) Passive explosion suppression

Data on flammable gas composition and release rates, such as that included in UL 9540A large-scalefire testing, provide the information needed to design effective explosion control systems.

4.12.2

Deflagration Explosion prevention and deflagration venting shall not be required when documentation ispresented that the system discharge where approved by the AHJ based on large-scale fire testing inaccordance with 4.1.5 that demonstrates that flammable gas concentrations in the room, building, orwalk-in unit cannot exceed 25 percent of the lower explosive limit (LEL) anywhere in the room, enclosure,or container. LFL in locations where the gas is likely to accumulate.

4.12.3*

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


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A.4.12.3

This requirement targets rooms, enclosures, and containers, not ESS in cabinets installed outdoors.During abnormal conditions such as a fire, when the flooded lead-acid or VRLA batteries will be offgassing, there will be a mixture of flammable, corrosive, and toxic gases, such as SO 2 , H 2 , CO,propane, and HCl. Upon detection, increased exhaust must be designed in accordance with therequirements of Chapter 8 of NFPA 69 . The combustible concentration must be maintained at orbelow 25 percent of the LFL of the mixture of gases given off. The emission rate of the mixture ofgases is obtained by actual testing.

The alternative deflagration protection method is to provide deflagration venting in accordance withNFPA 68 . The explosion analysis is conducted with the total volume of the room, enclosure, orcontainer being filled with the mixture of gases generated by the fire. The composition of the mixture ofgases involved in a fire should be obtained by actual testing. When deflagration vents are installed onan enclosure or a container, walkways, egress paths, fire access roads, and other access pathsintended to be utilized by first responders should be taken into consideration in locating the vents.

4.12.3.1

Deflagration prevention and deflagration venting shall not be required when documentation is presentedthat the system discharge cannot exceed 25 percent of the lower explosive limit (LEL) anywhere in theroom, enclosure, or container.

4.12.3.2

Lead-acid and nickel-cadmium battery systems less than 50 V ac, 60 V dc in telecommunicationsfacilities for installations of communications equipment under the exclusive control of communicationsutilities located outdoors or in building spaces used exclusively for such installations that are incompliance with NFPA 76 shall be exempt from the requirements in Section 4.12 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This section has been simplified to rely more on NFPA 68 & 69 requirements for deflagration andexplosion protection since those committees has more expertise on the subject. Annex materialwas added to help clarify the intent of the requirements.

ResponseMessage:

SR-96-NFPA 855-2018

Public Comment No. 8-NFPA 855-2018 [Section No. A.4.12.3]









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4.13.1*

Sites Where required elsewhere in this standard, sites where nonmechanical ESS are installed shall beprovided with a permanent source of water for fire protection.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The section needs a statement that helps coordinate with the tables for indoor and outdoorinstallations.




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4.13.3

Fire hydrants in accordance with NFPA 24 Accessible fire hydrants shall be provided for site ESSinstallations where a public or private water supply is available.

4.13.4

Fire hydrants installed on private fire service mains shall be installed in accordance with NFPA 24 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

NFPA 24 does not apply to public fire mains and the language was changed to allow users totake advantage of public fire hydrants.

ResponseMessage:

SR-120-NFPA 855-2018


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Second Revision No. 151-NFPA 855-2018 [ New Section after 5.1 ]

5.1.1

Lead-acid and nickel-cadmium battery systems less than 50 V ac, 60 V dc that are intelecommunications facilities for installations of communications equipment under the exclusive controlof communications utilities and located outdoors or in building spaces used exclusively for suchinstallations that are in compliance with NFPA 76 shall not be required to comply with Sections 5.1and 5.2 .

5.1.2

Lead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2, used fordc power for control of substations and control or safe shutdown of generating stations under theexclusive control of the electric utility, and located outdoors or in building spaces used exclusively forsuch installations shall not be required to comply with Sections 5.1 and 5.2 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The committee acknowledges that the telecom and electric utility industries have their ownregulations that they need to follow and the committee waived these requirements because of theexisting regulations.

ResponseMessage:

SR-151-NFPA 855-2018











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5.3.7 Water.

Where the ESS requires water to operate, it shall be provided through a connection to an on-site watersupply in accordance with ICC IPC (International Plumbing Code), IAPMO UPC (Uniform Plumbing Code),or local regulations, or through a self-contained water source.


Committee: ESS-AAA


Committee Statement

Committee Statement: Header is missing from draft text.





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5.4 Communication Systems.

Engineered and field-constructed ESS shall have appropriate communication interconnections betweenthe ESS components and site-located systems, which will allow for necessary for safe operation of thesystem and in accordance with the product listing, manufacturer’s installation instructions, and thisdocument safe operation of the system .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The added text expands on the concept of appropriate interconnections which is vague. Thedistinction between engineered and field-constructed is not used elsewhere in the text and is notnecessary for the requirement.

ResponseMessage:

SR-114-NFPA 855-2018




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5.5* Notification.

Notifications shall be present per the requirements of NFPA 70 , 706.7(D).

A.5.5

Installations of communications equipment under the exclusive control of utilities located outdoors or inbuildings used exclusively for such installations are outside the scope of NFPA 70 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The notification requirements in this section pertain to the ESS disconnect and are alreadyprovided in section 5.2.

ResponseMessage:

SR-115-NFPA 855-2018






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5.5 Mechanical Support Systems.

All connections to and from a self-contained prepackaged an ESS or the components of a pre-engineered an ESS to required plumbing, fire alarm, detection, or control circuits or tomechanical ventilation systems shall be in accordance with nationally recognized standards applicable tothose systems, listed equipment manufacturer’s instructions, listings, and the applicable provisions ofChapters 5 4 and Chapter 6 5 .

5.5.1

All connections to and from a self-contained prepackaged ESS or the components of a pre-engineeredESS to required plumbing, fire alarm, detection, or control circuits or to mechanical systems shall be inaccordance with nationally recognized standards applicable to those systems, listed equipmentinstructions, and the applicable provisions of Chapter 5 and Chapter 6 .

5.5.1

All connections to, from, and within engineered and field-constructed ESS to required plumbing, firealarm, detection, or control circuits or to mechanical systems shall be in accordance with the listedequipment instructions and applicable provisions of Chapter 5 and Chapter 6 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This section addresses the necessary support equipment associated with the operation of anESS. Stored energy mechanisms for circuit breakers are covered by the product listing standardand outside the scope of this section.

ResponseMessage:

SR-116-NFPA 855-2018




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5.7 Emergency and Standby Systems.

All energy storage–based emergency and standby systems shall comply with NFPA 111 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The scope of NFPA 111 is very limited and does not apply to optional standby power systems, solarsystems, wind-stored energy systems and other types of standby systems. To make a blanketstatement that all standby systems must comply with NFPA 111 adds confusion. The text should beremoved or revised if it is valuable to the 855 draft. Also it is not clear why this reference is inChapter 5.

I am on the NFPA 111 Technical Committee, but do not represent the TC in this instance.

ResponseMessage:

SR-117-NFPA 855-2018





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Second Revision No. 82-NFPA 855-2018 [ Sections 6.1.1.1, 6.1.1.2 ]

6.1.4

The system installer or commissioning agent shall prepare a written commissioning plan that provides adescription of the means and methods necessary to document and verify that the system and itsassociated controls and safety systems, as required by this standard, are in proper working condition.

6.1.5

The commissioning plan shall include, but not be limited to, the following information:

(1) An overview of the commissioning process developed specifically for the ESS to be installed andnarrative description of the activities to be conducted

(2) Roles and responsibilities for all those involved in the planning, design, commissioning construction,installation, or operation of the system(s)

(3) Means and methods whereby the commissioning plan will be made available during theimplementation of the ESS project(s)

(4) Plans and specifications necessary to understand the installation and operation of the ESS and allassociated operational controls and safety systems

(5) A detailed description of each activity to be conducted during the commissioning process, who willperform 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 operationalcontrols and safety systems

(7) Testing for any required fire detection or suppression and thermal management, ventilation, orexhaust systems associated with the installation and verification of proper operation of the safetycontrols

(8) Guidelines and format for a commissioning checklist and relevant operational testing forms andnecessary commissioning logs and progress reports

(9) Means and methods whereby facility 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 toincidents involving the each system

(11) A decommissioning plan meeting the provisions of Section 8.1 that covers the removal of the systemfrom service and from the facility in which it is located and information on disposal of materialsassociated with the each ESS


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

the commissioning plan should not be limited to the Landry list of items here but couldinclude other information as well.

ResponseMessage:

SR-82-NFPA 855-2018







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6.1.2

System commissioning shall be conducted in accordance with 6.1.2.16.1.2.1 and 6.1.2.26.1.2.2 after theinstallation is complete but prior to final inspection and approval.

6.1.2.1

ESS shall be evaluated for their proper operation by the system installer or commissioning agent inaccordance with the commissioning plan developed under 6.1.1 and a commissioning report documentingthe commissioning process in accordance with 6.1.66.1.6 .

6.1.2.2

The commissioning results in accordance with 6.1.36.1.3 shall be provided by the system installerto installer or commissioning agent to the system(s) owner and the AHJ prior to final inspection andapproval.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Commissioning need not be performed by the installer. Per 6.1.1.1 a commissioning agentcan be used.




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6.1.3.1

A commissioning report shall be prepared by the system installer or commissioning agent and shallsummarize the commissioning process and the operation of the system and associated operationalcontrols and safety systems.


Committee: ESS-AAA


Committee Statement

Committee Statement: Commissioning agent can complete the report in addition to the installer.




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Second Revision No. 85-NFPA 855-2018 [ Sections 6.1.4, 6.1.5 ]

15.4 Commissioning.

15.4.1

ESS installed in one- and two-family homes shall be permitted to be commissioned family dwellings andtownhouse units shall be commissioned as follows:

(1) Verify that the system is installed in accordance with the approved plans and manufacturer’sinstructions and is operating properly

(2) Provide a copy of the manufacturer’s installation, operation, and maintenance instructions providedwith the listed system

(3) Provide training on the proper operation and maintenance of the system to the system owner

(4) Provide a label on the installed system containing the contact information for the qualifiedmaintenance and service providers

15.4.2

Where the system is installed in a one- or two-family dwelling or townhouse unit that is owned by thebuilder and has yet to be sold, commissioning shall be conducted as outlined in Section 15.46.1.4 , andthe builder shall then transfer the required information in Section 15.46.1.4 to the home owner when theproperty is sold.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Other suggested revisions have been provided to address how OTFDs and townhouse units arecovered in the standard. Currently since these buildings have to meet only Chapter 17 then it seemsmore appropriate for these provisions to be located in Chapter 17 and modified to apply to townhouseunits as well. That is the intent of this provision - since one using the standard right now in beingdirected to Chapter 17 would not likely read this provision. Commissioning of these buildings isimportant and these provisions should be added to Chapter 17. If other changes I have suggested in1.3 are accepted (e.g. allow these structures to meet either Chapters 4 to 9 or Chapter 17) then thistext can also remain in Chapter 6, but should be modified to also apply to townhouse units.

ResponseMessage:

SR-85-NFPA 855-2018

Public Comment No. 55-NFPA 855-2018 [Sections 6.1.4, 6.1.5]


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7.1.2

The operation and maintenance documentation 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, when applicable:

(a) Energy storage management systems (ESMS)

(b) Fire protection equipment and systems

(c) Spill control and neutralization systems

(d) Exhaust and ventilation equipment and systems

(e) Gas detection systems

(f) Other required safety equipment and systems

(4) Response considerations similar to a safety data sheet (SDS) that will address response safetyconcerns and extinguishment when an SDS is not required

(5) An indication of which changes would necessitate re-permitting

(6)


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This line refers to equipment changes, not status changes. See suggested language toright.





* A notification that An instruction that equipment or system changes to the system installation arerequired to be recorded by updating any engineering documentation


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7.1.3 SDS for Hazardous Materials.

7.1.3.1

Copies of SDS for hazardous materials contained in the ESS shall be posted within sight of thedisconnecting means of any ESS or at a location approved by the AHJ.

7.1.3.2

For ESS located outdoors, a means shall be provided to protect the SDS from the weather.


Committee: ESS-AAA


Committee Statement

Committee Statement: A necessary level of protection when located outdoors.




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7.1.1 Electric Utilities Under NERC Jurisdiction.

7.1.1.1

Electric utilities under NERC jurisdiction shall comply with NERC PRC-005 requirements.

7.1.1.2

Electric utilities under NERC jurisdiction shall not be required to follow manufacturer’s instructions forlead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2, used fordc power for control of substations and control or safe shutdown of generating stations under theexclusive control of the electric utility, and located outdoors or in building spaces used exclusively forsuch installations.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Electric systems operators have extensive experience with the maintaining and operating FLAbattery systems. Many of the practices exceed the manufactures requirements and other are lessstringent based on experience. An example of less stringent would be checking the electrolyte levelevery 3 month where a utility might check it every 6 months

ResponseMessage:

SR-172-NFPA 855-2018

















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7.1.6.1

For normally occupied facilities, the operations record shall be on site.

7.1.6.2

The operations record shall be permitted to be made available electronically.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This recognizes that as technology advances storing electronic records are secure andmore likely.






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7.2.4

Maintenance documentation shall be revised to include information record information on any repair,renewal, or renovation made to the ESS .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Revision usually implies changes to a document issue under a documentation control plan toreflect changes to the procedure or content. It seems what we are asking for is for a record to bemade. This should not be considered a document revision. The record should be restricted to theESS and not other characteristics of the facility.

ResponseMessage:

SR-107-NFPA 855-2018



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7.2.5.3

Records Training records of training site operations and maintenance personnel shall be retained andaccessible to the AHJ , indicating the training taken, the name(s) of those taking the training, and thetraining date of the training .


Committee: ESS-AAA


Committee Statement

Committee Statement: This refers to the site staff and the accessible refers to AHJ review. .




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8.1 Decommissioning Plan.

Prior to decommissioning, the owner of an ESS or their designated agent(s) shall prepare a writtendecommissioning plan complying with 8.1.3 that provides the organization, documentation requirements,and methods and tools necessary to indicate how the safety systems as required by this standard and theESS and its components will be decommissioned and the ESS removed from the site.

8.1.1

Lead-acid and nickel-cadmium battery systems less than 50 V ac, 60 V dc that are intelecommunications facilities for installations of communications equipment under the exclusive controlof communications utilities and located outdoors or in building spaces or walk-in units used exclusivelyfor such installations that are in compliance with NFPA 76 shall be permitted to have adecommissioning plan in compliance with recognized industry practices in lieu of complying with 8.1.3 .

8.1.2*

Lead-acid and nickel-cadmium battery systems that are designed in accordance with IEEE C2, used fordc power for control of substations and control or safe shutdown of generating stations under theexclusive control of the electric utilities, and located in building spaces or walk-in units used exclusivelyfor such installations shall be permitted to have a decommissioning plan in compliance with applicablegovernmental laws and regulations in lieu of complying with 8.1.3 .

A.8.1.2

The North American Electric Reliability Corporation (NERC) and Federal Energy RegulatoryCommission (FERC) are two examples of entities that have, or might be developing, decommissioningrequirements of ESS installations for electric utilities that form the basis for governmental laws andregulations.

8.1.3*

The decommissioning plan shall include the following information:

(1) An overview of the decommissioning process developed specifically for the ESS that are to bedecommissioned

(2) Roles and responsibilities for all those involved in the decommissioning of the ESS and their removalfrom the site

(3) Means and methods whereby the decommissioning plan will be made available at a point in timecorresponding to the decision to decommission the ESS

(4) Plans and specifications necessary to understand the ESS and all associated operational controlsand safety systems, as built, operated, and maintained

(5) A detailed description of each activity to be conducted during the decommissioning process and whowill perform that activity and at what point in time

(6) Procedures to be used in documenting the ESS and all associated operational controls and safetysystems that have been decommissioned

(7) Guidelines and format for a decommissioning checklist and relevant operational testing forms andnecessary decommissioning 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 limited to structural elements, building penetrations, means of egress, and requiredfire detection and suppression systems, will be protected during decommissioning and confirmed asbeing acceptable after the system is removed


Committee: ESS-AAA


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Committee Statement

CommitteeStatement:

These changes were made to recognize that other industry practices and governmental laws andregulations exist that many Utilities in the United States have to comply with. The committeeacknowledges that if these technologies are regulated by the government that it could overrulecertain parts of NFPA 855.

ResponseMessage:

SR-147-NFPA 855-2018






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9.1.1*

The requirements of this chapter shall apply to installations of electrochemical ESS.

A.9.1.1

Annex B includes information on general hazards associated with ESS. Section B.5 provides adescription of commercially available battery technologies and the hazards associated with them.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

A new annex section was created to remind users that helpful information is located inAnnex B



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9.2 General.

Electrochemical ESS shall comply with the applicable sections of Chapters 4 and 9 as specified in Table9.2.

Table 9.2 Electrochemical ESS Technology-Specific Requirements

ComplianceRequired

Battery Technology OtherElectrochemicalESS and Battery

Technologiesb a

ReferenceLead-Acid

Ni-Cd or Ni-

mH Nickel aLithium-

IonFlow

SodiumNickel

Chloride

Exhaustventilation

Yes Yesc No Yes No Yes Section 4.9

Spill control Yesb d Yesb d No Yes No Yes Section 4.14

Neutralization Yesb d Yesb d No Yes No Yes4.1.5 Section

4.15

Safety caps Yes Yes No No No Yes Section 9.4

Thermalrunaway Yese Yes Yesc f No Yes f Yesc f Section 9.3

Explosioncontrol Yesd g No Yes g Yes No Yes Yes Section 4.12

Size andseparation

Yes Yes Yes Yes Yes Yes Section 4.6

a Nickel battery technologies covered in this column include nickel cadmium (Ni-Cad), nickel metalhydride (Ni-MH), and nickel zinc (Ni-Zn).

a b The protection in this column is Not not required if documentation acceptable to the AHJ, including ahazard mitigation analysis complying with Section 4.15 4.1.4 , provides justification that the protection isnot necessary based on the technology used.

c Exhaust ventilation is not required for nickel metal hydride batteries.

b d Applicable only to vented- (i.e., flooded-) type nickel-cadmium and lead-acid batteries.

e Thermal runaway protection is not required for vented (e.g., flooded) lead-acid batteries.

c f The thermal runaway protection is permitted to be part of a battery management system that has beenevaluated with the battery as part of the evaluation to UL 1973 or UL 9540.

g Explosion control is not required for the following:

d (1) Not required for lead Lead -acid and nickel-cadmium battery systems less than 50 V ac, 60 V dc intelecommunications facilities for installations of communications equipment under the exclusive control ofcommunications utilities located outdoors or in building spaces or walk-in units used exclusively for suchinstallations that are in compliance with NFPA 76

(2) Lead-acid and nickel-cadmium battery systems designed in accordance with IEEE C2 and used for dcpower for control of substations and control or safe shutdown of generating stations under the exclusivecontrol of the electric utility located in building spaces or walk-in units used exclusively for suchinstallations

(3) Lead-acid battery systems in uninterruptable power supplies listed and labeled in accordance with UL1778, utilized for standby power applications, and housed in a single cabinet in a single fire area inbuildings or walk-in units



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Table_9.2_Changes.docxChanges to Table 9.2 that the committee voted on and passed at the meeting are attached. For staff use


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The committee made several changes to the 9.2 table. The committee added a column for SodiumNickel Chloride to acknowledge that spill control, neutralization and exhaust is not needed for thattechnology. The Ni-cad and Ni-mH column was changed to Nickel and an annex note was added toclarify that this is intended to cover nickel zinc as well as the previous two chemistrys. Referenceswere corrected and incident reports have shown Nickel type batteries have an explosion hazard sothat was addressed in the table. Carve outs for the UPS and Utility industries were added forconsistency with chapter 4.

ResponseMessage:

SR-146-NFPA 855-2018



















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Second Revision No. 167-NFPA 855-2018 [ Chapter 10 [Title Only] ]

Capacitors Energy Storage Systems


Committee: ESS-AAA


Committee Statement

Committee Statement: This change aligns the Chapter 10 title chapter with the definitions in Chapter 3.



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10.1.4*

This chapter shall not apply to capacitors and capacitor equipment for electric utilities and industrialfacilities used in applications such as flexible ac transmission (FACTS) devices, filter capacitor banks,power factor correction, and stand-alone capacitor banks for voltage correction and stabilization.

A.10.1.4

Capacitors used for utility applications that are not included in this chapter for capacitor ESS aretypically technologies that have metallized film electrodes with a polymer film (polypropylene) andaromatic hydrocarbon fluid dielectric and are referred to as metallized film capacitors or all filmcapacitors.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

revised wording to address utility applications capacitors and include annex note regardingtechnologies.








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10.2 Protection Features.

Capacitor ESS installations shall comply with the technology-specific requirements applicable sections ofChapters 4 and 10 specified in Table 10.2.

Table 10.2 Capacitor Electrochemical Double Layer Capacitor (EDLC) ESS Technology-SpecificRequirements

Compliance Required Capacitor EDLC Energy Storage* Reference

Exhaust ventilation Yes Section 4.9

Spill control Yes Section 4.14

Neutralization Yes 4.1.5 4.15

Thermal runaway† Yes Section 10.3

Safety caps Yes Section 10.4

Explosion control Yes Section 4.12

*Not required if documentation acceptable to the AHJ, including a hazard mitigation analysis complyingwith Section 4.15, provides justification that the protection is not necessary based on the capacitortechnology used.

†The thermal runaway protection is permitted to be part of an ESS management system that has beenevaluated with the capacitor as part of the evaluation to UL 1973 or UL 9540.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Revised table title to address specific ESS capacitor technology used for ESSapplications.




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10.4 Safety Caps.

Where required by Table 10.2, vented batteries vented capacitors used in ESS shall be provided withflame-arresting safety caps.


Committee: ESS-AAA


Committee Statement

Committee Statement: Replace batteries with capacitors for this chapter.





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Second Revision No. 110-NFPA 855-2018 [ Chapter 11 ]

Chapter 11 Fuel Cell Energy Storage Systems

11.1 Installation and Maintenance.

11.1.1

Stationary fuel cell ESS shall comply with the following requirements of Chapter 4:

(1) Charge controllers (see 4.2.7)

(2) Inverters and converters (see 4.2.8)

(3) Energy storage management system (ESMS) (see 4.2.9)

(4) Impact protection (see 4.3.7)

(5) Smoke and fire detection (see Section 4.10)

(6) Fire control and suppression (see Section 4.11)

(7) Water supply (see Section 4.13)

(8) Signage (see Section 4.3.5)

(9) Combustible storage (see Section 4.1.6)

(10) Hazard mitigation analysis (see Section 4.1.4)

(11) Emergency planning and training (see Section 4.1.3)

(12) Construction documents (see Section 4.1.2)

11.1.2

Non-hydrogen-fueled stationary fuel cell ESS shall be installed and maintained in accordance with NFPA70, NFPA 853, the manufacturer’s instructions, and the equipment listing.

11.1.3

Hydrogen-fueled stationary fuel cell ESS shall be installed and maintained in accordance with NFPA 2,NFPA 70, NFPA 853, the manufacturer's instructions, and the equipment listing.

11.2 Fuel-Cell-Powered Vehicle Use.

11.2.1

The temporary use of the dwelling unit owner's or occupant’s fuel-cell-powered vehicle to power thedwelling in a one- and two-family dwelling or townhouse unit while parked in an attached or detachedgarage or outside shall only be required to comply with the vehicle manufacturer's instructions andNFPA 70 .

11.2.2

The temporary use of the dwelling unit owner's or occupant's fuel-cell-powered vehicle to power thedwelling in a one- and two-family dwelling or townhouse unit while parked in an attached or detachedgarage or outside shall not be for more than 30 days.


Committee: ESS-AAA


Committee Statement

Committee Statement: This section is intended to provide consistency with Section 17.12 Electric Vehicle Use




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14-deleted Pumped Hydro (Reserved)-DELETED


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

"NFPA 855 was initiated to address the concerns of emergency responders, AHJ’s, facility managers,and others regarding integration of specific energy storage systems into the urban environment.Specifically, the concern was with electrochemical energy or battery storage systems. The currentdraft of NFPA 855 goes significantly beyond this charter. While the sections currently underdevelopment do address Chemical Energy (Battery) Storage Systems, subsequent Chapters areincluded (reserved) that are planned to address other mechanical energy storage technologies. Someof these are specifically within the domain of NFPA 850 and NFPA 853 (e.g., hydroelectric, fuel cell,etc.). Others when applied in utility scale are similar to facilities covered by NFPA 850. Note that thetechnology/application chapters as currently written in the draft of NFPA 855 are centered on batteriesand would be misapplied and confusing if an attempt is made to apply these to other types of ESS.

Pumped storage hydroelectric facilities are simple derivations of hydroelectric facilities that areaddressed by NFPA 850. Hydroelectric facilities are not unknown hazards to emergency respondersor the public and are typically remotely located for obvious reasons, especially pumped storagehydroelectric facilities due to the upper impoundment requirements. The upper impoundmentcomprises the “energy storage” and does not present further hazard beyond that typical tohydroelectric facilities. The remainder of the facility is an electric generating station adequatelyaddressed by NFPA 850. Additional requirements are not necessary.

Similarly, fuel cell technologies are addressed by NFPA 853. Fuel cell energy storage systems aresimply derivations of fuel cell systems. Since fuel cell energy storage systems involve additionalequipment for generation and collection of hydrogen or other gases, these aspects of these systemswould be adequately covered by NFPA standards applicable to those gases (e.g., NFPA 2, NFPA 55,etc.). If gaps are identified, those standards should be updated. The NFPA 850/853 Committee hasthe technical expertise to address any emerging technologies involving fuel cells.

NFPA 855 also has other “reserved” chapters that address electric generation technologies that arebased on various mechanical energy storage systems (fly wheels, compressed gas, etc.). Thesefacilities are electric generating facilities, the output is from a generator. They do not present a new,different or abstract hazard to emergency responders or the public. Small scale applications would beeasily protected using existing guidance typical to other forms equipment in mechanical or machineryrooms. These types of technologies applied on a large utility scale would most likely be remotelylocated. On the large utility scale, they involve machines that have similar hazards to those alreadypresented by other more conventional forms of electric power generation that are addressed in NFPA850. Again, the technical expertise for hazards associated with large machinery typical toconventional electric power generation appropriately resides in the NFPA 850 Committee.Conventional forms of power generation and those evolving technologies with hazards similar toconventional forms of power generation should be addressed by the NFPA 850/853 Committee.Significant revision to NFPA 850 would not be necessary to address these technologies.

I urge the NFPA 855 committee to limit NFPA 855’s scope to electro chemical, capacitor and superconducting magnet energy storage systems, especially those that are built into the urbanenvironment. Remotely located utility scale electrochemical energy storage should not be mandatedfor protection typical to that located in a high rise apartment building. This more defined scope wouldallow the committee to remain focused on the immediate concern presented to the emergencyresponders that are responding to such facilities where the public may be impacted."


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ResponseMessage:

SR-111-NFPA 855-2018







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15-deleted Compressed Air Energy Storage Systems (Reserved)-DELETED


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

NFPA 855 was initiated to address the concerns of emergency responders, AHJ’s, facility managers,and others regarding integration of specific energy storage systems into the urban environment.Specifically, the concern was with electrochemical energy or battery storage systems. The currentdraft of NFPA 855 goes significantly beyond this charter. While the sections currently underdevelopment do address Chemical Energy (Battery) Storage Systems, subsequent Chapters that areincluded (reserved) that are planned to address other mechanical energy storage technologies. Thesechapters should be deleted. Some of these are specifically within the domain of NFPA 850 and NFPA853 (e.g., hydroelectric, fuel cell, compressed air and flywheel etc.). Others when applied in utilityscale are similar to facilities covered by NFPA 850. Note that the technology/application chapters ascurrently written in the draft of NFPA 855 are centered on batteries and would be misapplied andconfusing if an attempt is made to apply these to other types power generation facilities.

NFPA 855 “reserved” chapters that address electric generation technologies that are based onvarious mechanical energy storage systems (fly wheels, compressed gas, etc.) should be deletedfrom the scope of NFPA 855. These facilities are electric generating facilities; the output is from agenerator. They do not present a new, different or abstract hazard to emergency responders or thepublic. Small scale applications would be easily protected using existing guidance typical to otherforms of equipment in mechanical or machinery rooms. These types of technologies applied on alarge utility scale would most likely be remotely located. On the large utility scale, they involvemachines that have similar hazards to those already presented by other more conventional forms ofelectric power generation that are addressed in NFPA 850. Again, the technical expertise for hazardsassociated with large machinery typical to conventional electric power generation appropriatelyresides in the NFPA 850 Committee. Conventional forms of power generation and those evolvingtechnologies with hazards similar to conventional forms of power generation should be addressed bythe NFPA 850/853 Committee. Significant revision to NFPA 850 would not be necessary to addressthese technologies.

I urge the NFPA 855 committee to limit NFPA 855’s scope to electro chemical, capacitor and superconducting magnet energy storage systems, especially those that are built into the urbanenvironment.

ResponseMessage:

SR-112-NFPA 855-2018




Public Comment No. 46-NFPA 855-2018 [Chapter 15 [Title Only]]


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15.1* General.

ESS installed in installations associated with one- or two-family dwellings or in townhouse units shallcomply with the requirements of this chapter.

A.15.1 Dwelling.

Any detached building, or any part of a townhouse structure that is separated from the remainder ofthe townhouse structure with fire resistance rated assemblies in accordance with local building code,that contains no more than two dwelling units intended to be used, rented, leased, let, or hired out tobe occupied or that are occupied for habitation purposes. [ 13D: 3.3.3]


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The definition of Dwelling will help users better understand and apply the requirements herein.Other word change on mandatory langue is editorial.

ResponseMessage:

SR-86-NFPA 855-2018

Public Comment No. 340-NFPA 855-2018 [Chapter 17 [Title Only]]





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15.2 Equipment Listings.

Global SR-121

15.2.1

ESS 1 kWh or greater in energy capacitymaximum stored energy shall be listed and labeled forresidential use in accordance with UL 9540.

15.2.2

ESS listed and labeled solely for utility or commercial use shall not be used for residential applications.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Per UL 9540 40.4, energy storage systems are only marked “for residential use” when they arelimited to installations only in those locations, in other words it is a restrictive marking. Some UL9540 listed energy storage systems may have no such restrictions, and can safely be used in anyapplication – residential, commercial, or other. Their use within the capabilities of their certificationshould not be artificially limited.

ResponseMessage:

SR-90-NFPA 855-2018



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15.5 ESS Spacing.

Individual ESS units shall be separated from each other by a minimum of 3 ft (914 mm) unless smallerseparation distances are documented to be adequate as approved by the AHJ, based on large-scale firetesting complying with 4.1.5.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Evaluation and Certification to the UL 9540 and UL 9540A standards should be the determiningfactor in regards to product spacing requirements. Not all ESS present a hazard needing mitigationthrough spacing. “Documented to be adequate” is vague and unenforceable, whereas certificationto a safety standard provides clarity.

ResponseMessage:

SR-91-NFPA 855-2018



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15.6.1

ESS shall only be permitted to be located in accordance with installed in the following locations :

(1) In attached garages separated from the dwelling unit living area and sleeping units in accordancewith the local building code

(2) In detached garages and detached accessory structures

(3) Outdoors on exterior walls or on the ground located a minimum of 3 ft (914 mm) from doors andwindows

(4) In enclosed utility closets and storage or utility spaces

15.6.1.1

If the room or space where the ESS is to be installed is not finished, the walls and ceiling of the room orspace shall be protected with not less than 5 ⁄8 in. Type X gypsum board.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

To ensure the location is not within any living areas of the home and that any location usedhas been enclosed with protection.

ResponseMessage:

SR-92-NFPA 855-2018





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15.7.2

ESS installations of more than 80 kWh with an aggregate energy rating exceeding that allowed by15.6.1 shall comply with Chapters 4 through 9.


Committee: ESS-AAA


Committee Statement

Committee Statement: Referencing table 17.6.1 helps keep consistency though the chapter.





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15.7.3*

The use of an electric-powered vehicle to power the dwelling while parked shall comply with Section15.1317.12 .

A.15.7.3

The batteries on electric vehicles should not be included in the aggregate energy capacity limitations in15.6.1 .


Committee: ESS-AAA


Committee Statement

Committee Statement: Energy capacity limitations do not apply to temporary vehicle additions.




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15.9.1

Rooms, Interconnected smoke alarms shall be installed throughout the dwelling, including in rooms,attached garages, and areas in which ESS are installed shall be protected by smoke alarms incompliance with local building code.


Committee: ESS-AAA


Committee Statement

Committee Statement: Interconnected smoke alarms are necessary for early warning.



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15.11 Exhaust Ventilation.

Indoor installations of ESS that include batteries that produce hydrogen or other flammable gases duringcharging shall be provided with ventilation meet the exhaust ventilation requirements in accordance withSection 4.9 4.12 .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

The revision addresses what appears to be an incorrect reference (4.9 Exhaust Ventilation,instead of 4.12 Explosion Control), and clarifies that for many installations mechanical ventilationmay not always be required for environments with sufficient air exchange.

ResponseMessage:

SR-87-NFPA 855-2018



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15.12 Toxic and Highly Toxic Gas.

ESS that have the potential to release toxic or highly toxic gas during charging, discharging, and normaluse conditions shall not be installed within one- or two-family dwellings or in townhouses shall be installedoutdoors .


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Reading Chapter 17, and specifically 17.5, it appears that an ESS cannot be installed inside adwelling unit (e.g. living and sleeping areas) and is limited to exterior walls (which are outside),outside locations and garage and utility shed locations. As stated 17.11 appears to lead the user inthinking that if the stated hazards do not exist then it is OK to install the ESS inside a dwelling unit.The proposed change eliminates potential confusion and provides clearer direction as to where thecovered ESS must be installed (outside - noting that exterior walls are also outside).

ResponseMessage:

SR-88-NFPA 855-2018



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15.13 Electric Vehicle Use.

15.13.1

The temporary use of the dwelling unit owner’s or occupant’s electric-powered vehicle to power thedwelling while parked in an attached or detached garage or outside shall comply with the vehiclemanufacturer’s instructions and NFPA 70.

15.13.2

The temporary use of the dwelling unit owner’s or occupant’s electric-powered vehicle to power thedwelling while parked in an attached or detached garage or outside shall not exceed 30 days.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

This is a clarification. The use was intended to be temporary at a time of need, if used regularlyas a stationary ESS all requirements of this standard need to apply.

ResponseMessage:

SR-89-NFPA 855-2018



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Second Revision No. 1-NFPA 855-2018 [ New Section after A.1.3 ]

A.1.1

Energy generation equipment even if it is tied to the ESS is not covered under this scope. An exampleof this is a solar farm that feeds ESS on the same property. The solar collection and generationequipment is not governed by this standard. NFPA 850 or other relevant standard should be applied forthe design, construction, installation, commissioning, operation, and maintenance of generationfacilities.


Committee:


Committee Statement

CommitteeStatement:

Further clarification is needed in reference to generation vs storage. Additional needed reference toNFPA 850 as a recommended practice. NFPA 850 is a relevant code as these facilities becomelarger, more prevalent and necessary in the future of energy development. The will be tied togeneration facility and property. Facilities are already being proposed and permitted for 300 Mw andup. These are being installed on Utility owned generating plants.

ResponseMessage:

SR-1-NFPA 855-2018

Public Comment No. 188-NFPA 855-2018 [New Section after A.1.3]


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Second Revision No. 68-NFPA 855-2018 [ Section No. A.4.2.1 ]

A.4.2.1

It is envisioned that equipment provided will be either pre-engineered ESS or prepackaged ESS, both ofwhich are to be listed in accordance with UL 9540. ESS that are not listed in accordance with UL 9540should 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 proposedresults in a system that is no less safe than a system meeting the construction and performancerequirements of UL 9540. If nonlisted equipment is to be evaluated for compliance with UL 9540, theevaluation and documentation should be provided as part of a field evaluation conducted by an approvedthird-party certification organization.

In specific instances, this standard will not require equipment such as lead-acid batteries to be listed.


Committee: ESS-AAA


Committee Statement

CommitteeStatement:

Section 4.2.1 now requires listing to UL 9540. The terms pre-engineered ESS and pre-packagedESS are descriptions of ESS left over from prior drafts of NFPA 855 and are no longer used inthe standard.

ResponseMessage:

SR-68-NFPA 855-2018



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Second Revision No. 61-NFPA 855-2018 [ Section No. A.4.6 ]

A.4.6

This section includes requirements designed to keep fires originating in a single energy storage unit fromeasily spreading to adjacent energy storage units or out of the fire area in which the ESS is installed. Thisis done by limiting potential fire size within an individual energy storage unit by limiting the totalkWh energy capacity of individual units. It also reduces the potential of fire originating in one unit fromigniting an adjacent unit, or breaching a fire resistance rated wall through radiant heat transfer by requiringspacing between individual energy storage units, and between units and walls. An option is provided forincreasing individual unit kWh size energy capacity or reducing spacing by successfully passing large-scale fire testing in accordance with Section 4.1.5 4.5 .


Committee: ESS-AAA


Committee Statement

Committee Statement: corrected reference and specified energy capacity not just the units.



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Second Revision No. 6-NFPA 855-2018 [ Chapter B [Title Only] ]

Battery Energy Storage System Hazards


Committee:


Committee Statement

CommitteeStatement:

The annex speaks only to battery hazards, not hazards for all ESS and should be titledaccordingly. Throughout Annex B, the term ESS is used when Battery ESS would be moreappropriate.

ResponseMessage:

SR-6-NFPA 855-2018

Public Comment No. 868-NFPA 855-2018 [Chapter B [Title Only]]


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Second Revision No. 7-NFPA 855-2018 [ Section No. B.2.5 ]

B.2.5

The term stranded or stored energy refers to unknown unquantified hazardous levels of electrical energythat can be contained in all or part of an ESS, including one that has been damaged and/or thought to bedischarged and that represents a hazard to persons in contact with the system, who are unaware of thehazardous energy. Since this hazard represents a potential unknown unquantified electrical hazard, theallowed levels will be different depending on whether it pertains to normal conditions for repair andreplacement by trained workers or for emergency responders dealing with damaged ESS that can stillcontain hazardous energy.


Committee:


Committee Statement

CommitteeStatement:

The committee agrees that the wording could be written better but instead or removing all of itthe committee has changed the term "unknown" to "unquantified"

ResponseMessage:

SR-7-NFPA 855-2018

Public Comment No. 536-NFPA 855-2018 [Section No. B.2.5]


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B.3.2 Chemical Hazards.

Under normal operating conditions, the potential exists for exposure to hazardous materials by workers incontact with the system for maintenance, repair, and replacement of systems. OSHA and NIOSH haveguidelines on exposures to hazardous materials, including limits for workers that have the potential forexposure during normal operation maintenance, and so forth.

Examples of chemical hazards are as follows:

(1) Liquid hazards:

(a) Corrosive electrolytes: Batteries with electrolytes in the range of pH ≤2 or ≥11.5 are consideredcorrosive (acid or caustic). This is an issue with systems with these electrolytes, where there canbe a situation of leaks or spills during maintenance or normal operation. There should bemeasures for spill control, and workers should have appropriate safe work procedures andprotective 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 of some systems. Guidance for worker exposure to toxic liquids can be foundin OSHA hazardous materials guidelines. Workers in contact with these systems need to beaware of potential hazards and have appropriate procedures and equipment/PPE to avoid thesehazards.

(2) Oxidizers: The potential exists for oxidizers to be present within the ESS. An oxidizer will increase theflammability potential of other materials. Annex G in NFPA 400, Annex G, provides information ontests to classify an oxidizer material and identifies known oxidizing materials under theirclassifications. Annex G in NFPA 400, Annex G, also provides guidance on safety measures to usewhen there are significant exposed quantities of known oxidizers, which can occur during normalmaintenance conditions of certain ESS technologies that contain them.

(3) Gases — Toxic gases: The potential exists for exposure to toxic gases under normal conditions ofmaintenance and service of some ESS systems. OSHA and NIOSH provide guidance for exposures,including permissible exposure limits (PEL), recommended exposure limits (REL) for exposure duringan 8- or 10-hour workday, ceiling limits, which are the upper limit of a safe exposure, and IDLH, whichrepresents concentrations that are immediately dangerous to life and health.

(4) Solids: Water-reactive and toxic metals that might be contained in some battery technologies typicallyare not exposed during routine maintenance and servicing of these systems but can present issuesunder abnormal conditions. Batteries containing these hazardous materials should be marked withthe NFPA 704 diamond hazard symbols.


Committee:


Committee Statement

Committee Statement: Missing "and" from the sentence between "work procedures" and "protective clothing."




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B.3.3 Electrical Hazards.

Under normal operating conditions some battery systems might have electrical hazards that need to beaddressed as part of operation and maintenance. Electrical hazards that can occur during normaloperating conditions follow:

(1) Electrical shock: ESS with voltages above 50 V (per NFPA 70E limits for electrical shock) can posehazards to trained workers who might come in contact with live parts during operation and servicingof the systems. It is necessary that appropriate labeling and procedures and protective equipment areutilized by workers when servicing these systems.

(2) Arc flash: ESS that have an incident energy level greater than 23.8 ft-lb/in. 2 1.2 cal/cm 2 (5 J/cm2)should have the arc flash boundaries calculated, identified through markings, and proper proceduresand equipment in place to prevent worker injury from 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 of electricity, is stranded or stored energy. An example of a stranded or storedenergy hazard is worker exposure to ESS that are not discharged sufficiently or ESS that aredamaged and where the potential exists for electric shock and arc flash issues. For normal operatingconditions, sites housing commercial and industrial battery ESS should maintain onsite instructionsfor isolation of hazardous voltage and energy for maintenance and for discharging batteries for safereplacement and disposal. Residential and smaller commercial systems should have informationprovided and access to trained technicians to perform these duties to ensure that stranded and storedenergy do not represent a hazard under normal operating conditions.


Committee:


Committee Statement

CommitteeStatement:

Consistency of energy units between B.2.4 and B.3.2 is suggested. Current draft usescal/cm2 in B.2.4 and ft-lb/in2 in B.3.2.

ResponseMessage:

SR-9-NFPA 855-2018



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B.4.3 Electrical Hazards.

Examples of electrical hazards are as follows:

(1) Electrical shock: Circuits with voltages above 50 V have the potential for electrical shock hazards,because first responders under emergency conditions would not have the training and protectiveequipment that trained electrical workers would have under normal servicing and maintenanceconditions. Information needs to be available for maintenance staff and first responders on how toaddress electrical hazards. In addition, under emergency conditions the potential exists foremergency responder exposure to live parts in contact with conductive fluids such as water and liveparts exposed as a result of abnormal conditions. Manufacturers/installers of battery energy systemsshould define standoff distance and type and angle of water spray for first responders. Emergencyresponse guidelines as outlined in 4.3.5.3 4.1.3.2.1.3 should address the issue of isolation ofhazardous voltages.

(2) Shock, arc flash, and arc blast hazards: First responders are generally not provided with training andproper protection from arc flash, arc blast, and shock hazards, including clothing, gloves, and so forth,so the potential for sufficient energy that will result in a hazardous electrical event occurring during anemergency response exists. Manufacturers should provide emergency response guidance on how toreduce arc flash and blast hazards. See the emergency response guidance in 4.3.5.3 4.1.3.2.1.3 .

(3) Stranded or stored energy hazards: ESS damaged during an emergency incident can presentpotential shock, arc flash, arc blast, and re-ignition hazards. Sites should have access to on-calltrained staff to assist in emergency situations to isolate potential hazard energy and, if necessary, todrain energy to prevent potential re-ignition of some technologies at a later time. For commercial andindustrial installations, there needs to be trained personnel available for emergency response on site.For residential and smaller scale commercial systems, on-call trained personnel need to be madeavailable to assist first responders and address discharging of stored energy in batteries for disposal.

Note: UL research into the issue of potential shock to fire fighters from water spray on PV fires indicatedthat the electric shock hazard due to application of water is dependent on voltage, water conductivity,distance, and spray pattern. For example: (1) A slight adjustment from a solid stream toward a fog pattern(a 10-degree cone angle) reduced measured current below perception level. (2) Salt water should not beused on live electrical equipment. (3) A distance of 20 feet ft (6.1 m) had been determined to reducepotential shock hazard from a 1000 V dc source to a level below 2 mA considered as safe.


Committee:


Committee Statement

Committee Statement: Reference has been changed to the correct section.




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Second Revision No. 11-NFPA 855-2018 [ Section No. B.5.2.2 ]

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 ifbatteries are operated as intended to prevent overheating and thermal runaway conditions.

(2) Chemical hazards: These batteries are starved electrolyte types, so there should be no issue withexposure to corrosive electrolyte under normal operating conditions.

(3) Electrical hazards: There are electrical hazards associated with routine maintenance of thesebatteries if they are at hazardous voltage and energy levels.

(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazardsduring maintenance.

(5) Physical hazards: There are lifting hazards due to the weight of the battery that are only an issueduring installation, 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 whenbatteries overheat. This can present a potential fire hazard due to combustible concentrations. Therecan be the potential for thermal runaway if the batteries are not maintained at appropriate operatingparameters. Also, there can be fire hazards due to short-circuiting abnormal conditions.

(2) Chemical hazards: Although these batteries contain corrosive electrolyte, they do not have as muchfree electrolyte that could result in spill hazards similar to vented types. There might be somebubbling of electrolyte or potential for some leakage under abnormal conditions if battery cases crackor leak.

(3) Electrical hazards: Electrical hazards might be present under abnormal conditions if the system is athazardous voltage and energy levels.

(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazardsif the batteries are exposed subject to abnormal conditions that first responders might be exposed to.Damaged batteries might contain stored energy that can be a hazard during disposal if care is nottaken .

(5) Physical hazards: The potential exists for overheating.


Committee:


Committee Statement

CommitteeStatement:

Making language consistent with that of flooded lead-acid and other types. I don't seejustification for the differing text.

ResponseMessage:

SR-11-NFPA 855-2018

Public Comment No. 889-NFPA 855-2018 [Section No. B.5.2.2]


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B.5.5 Nickel Batteries — General Description.

Nickel batteries for stationary applications are divided into two main technologies: nickel-cadmium (Ni-Cd Cad ) and nickel-metal hydride (NiMH Ni-MH ). There is also a third category that has becomecommercialized, Nickel nickel-zinc (Ni-Zn), which is very similar to Ni-Cad batteries. Nickel- cadmiumbatteries have nickel hydroxide active material for the positive electrode and cadmium for the negativeelectrode with potassium hydroxide solution for the electrolyte. The nickel-cadmium batteries for stationaryapplications can be vented pocket plate or vented sintered-plate batteries that are designed of multiplecells in a monobloc battery similar to a vented lead-acid battery. They also have vents for maintenance ofthe electrolyte. Nickel-cadmium batteries can also be sealed types, such as a fiber nickel-cadmium batterythat is sealed and provided with a pressure relief valve similar to a VRLA battery. Nickel-zinc batteries aresimilar to Nickel-cadmium batteries except the negative electrode is zinc. Nickel- metal hydride batterieshave nickel hydroxide active material for the positive electrode, a metal hydride alloy for the negativeelectrode, and a solution of potassium hydroxide as the electrolyte. Nickel-metal hydride batteries aresealed either a single cell design or a monobloc design with multiple internal cells and are provided withan enclosable valve for relieving pressure similar to a VRLA battery.

B.5.5.1 Nickel-Cadmium (Ni-Cd Cad ) and Nickel-Zinc (Ni-Zn) Batteries.

Hazard considerations for Ni-Cd Cad batteries and Ni-Zn batteries under normal operating conditions areas follows:

(1) Fire hazards: There is the potential for concentrations of hydrogen from vented Ni-Cd Cad and Ni-Znbatteries 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: There is the potential for contact with the corrosive/caustic potassium hydroxideelectrolyte but this is only a risk when workers are handling electrolyte. Workers handling electrolyteneed to use proper PPE. These systems should be provided with spill control and neutralization percodes.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazardsduring maintenance if the batteries cannot be isolated for maintenance or replacement.

(5) Physical hazards: There are lifting hazards due to the weight of the battery that are only an issueduring installation replacement or removal.

Hazard considerations for Ni-Cd Cad and Ni-Zn batteries under emergency/abnormal conditions are asfollows:

(1) Fire hazards: There is the potential for concentrations of hydrogen from vented Ni-Cd batteries Cadand Ni-Zn batteries due to overheating from abnormal conditions if the area where the batteries arelocated is not properly ventilated. Another area that might create problems during abnormalconditions would be the potential for shorting of high-current circuits.

(2) Chemical hazards: There is the potential for contact with the corrosive/caustic potassium hydroxideelectrolyte during abnormal conditions should electrolyte leak. First responders, in an emergencysituation, need to be aware of potential caustic spills that can occur and take appropriate cautionaround these batteries. Ni-Cd Cad batteries contain cadmium, which is toxic and a hazardous waste.Although not exposed under normal conditions, there might be potential for cadmium in vapors ofburning batteries during abnormal conditions.

(3) Electrical hazards: Electrical hazards might be present under abnormal conditions if the system is athazardous voltage and energy levels.

(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazardsif the batteries are exposed to abnormal conditions where they could still contain hazardous levels ofenergy. Damaged batteries might contain stored energy that can be a hazard during disposal if care isnot taken.

(5) Physical hazards: The potential exists for overheating.


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B.5.5.2 Nickel-Metal Hydride (NiMH Ni-MH ) Batteries.

Hazard considerations for NiMH Ni-MH batteries under normal operating conditions are as follows:

(1) Fire hazards: There should be no combustible gas generation under normal operating conditions, ifbatteries are operated as intended to prevent overheating and thermal runaway conditions.

(2) Chemical hazards: These batteries are starved electrolyte types, so there should be no issue withexposure to corrosive electrolyte under normal operating conditions.


(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazardsduring maintenance if the batteries cannot be isolated for maintenance or replacement.

(5) Physical hazards: Not applicable.

Hazard considerations for NiMH Ni-MH batteries under emergency/abnormal conditions are as follows:

(1) Fire hazards: There is the potential for off-gassing of hydrogen under abnormal conditions whenbatteries overheat. This can present a potential fire hazard due to combustible concentrations. Therecan be the potential for thermal runaway if the batteries are not maintained at appropriate operatingparameters. Also, there could be fire hazards due to short-circuiting abnormal conditions.

(2) Chemical hazards: Although these batteries contain corrosive electrolyte, they do not have as muchfree electrolyte that could result in spill hazards similar to vented types. There might be somebubbling of electrolyte or potential for some leakage under abnormal conditions if battery cases crackor leak. Burning NiMH Ni-MH batteries can release toxic vapors, including cobalt oxide fumes, nickeloxide fumes, and so forth.

(3) Electrical hazards: Electrical hazards can be present under abnormal conditions if the system is athazardous voltage and energy levels.

(4) Stranded or stored energy hazards: There can be the potential for stranded or stored energy hazardsif the batteries are exposed to abnormal conditions where they might still contain hazardous levels ofenergy. Damaged batteries might contain stored energy that can be a hazard during disposal if care isnot taken.

(5) Physical hazards: Depending on the design of the system, the potential exists for physical hazardsunder abnormal conditions if accessible parts are overheating or if there is exposure to movinghazardous parts such as fans where guards might be missing.


Committee:


Committee Statement

CommitteeStatement:

Nickel Zinc batteries are commercially available and are very close to Nickel Cadmium batterieswith regard to their technology and associates hazards. They should be added to the informationunder Nickel Cadmium batteries.

ResponseMessage:

SR-12-NFPA 855-2018



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Second Revision No. 13-NFPA 855-2018 [ Section No. C.2 ]

C.2 General.

Battery ESS based on electrochemical technologies represent the majority of ESS being designed andinstalled. The safe operation of electrochemical ESS is critical especially when installed inside occupiedstructures. The primary concerns of the fire service with this type of installation would include theimplications of overheating via internal or external heat source, thermal runaway, potential deflagrationevent in enclosed spaces, and the effective operation of fire detection, suppression, and smoke exhaustsystems. There are additional concerns to be considered when assessing fire fighter responses toelectrochemical ESS.

Handover procedures for potentially damaged systems should be developed for fire departments toensure the timely response of qualified technical representatives to manage safety issues. Theseprocedures would also cover issues such as the removal or recycling of damaged equipment. Anotherprocedural component is the realization that damaged ESS system components could include significantstored or stranded energy with no known method for safe dissipation. Stored or stranded energy could bedefined as energy that remains in a battery after the system has been shut down.


Committee:


Committee Statement

Committee Statement: It's important to list this possibility in the initial information on potential hazards.


Public Comment No. 758-NFPA 855-2018 [Section No. C.2]


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Second Revision No. 63-NFPA 855-2018 [ Section No. C.3 ]

C.3 Suppression Systems.

Some ESS design validations have included pre-engineered inert or clean agent fire suppression systemsfor fire protection. These system installations were often approved without validation based on large-scalefire testing in accordance with Section 4.1.5 4.5 by nationally recognized testing laboratories. Evidence-based data is needed to ensure ESS designers specify appropriate fire protection systems based on thematerial involved and physical design characteristics. Several early research papers from multipleorganizations, including NFPA’s Fire Protection Research Foundation, and third-party engineering groupshave shown that fires involving lithium-ion cells must be cooled to terminate the thermal runaway process.Water is the agent of choice, yet system cabinet design could pose a significant barrier to the efficientapplication of water while simultaneously allowing the free movement of fire and combustion gases.


Committee: ESS-AAA


Committee Statement

Committee Statement: Correcting reference.



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Second Revision No. 14-NFPA 855-2018 [ Section No. C.5.1 ]

C.5.1 Lithium-Ion (Li-ion) Batteries.

Water is considered the preferred agent for suppressing lithium-ion battery fires. Water has superiorcooling capacity, is plentiful (in many areas), and is easy to transport to the seat of the fire. While watermight be the agent of choice, the module/cabinet configuration could make penetration of water difficult forcooling the area of origin, but might still be effective for containment. Water spray has been deemed safeas an agent for use on high-voltage systems. The possibility of current leakage back to the nozzle, andultimately 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 BatteryHazards: A Report on Full-Scale Testing Results. Fire-fighting foams are not considered to be effective forthese chemistries because they lack the ability to cool sufficiently and can conduct electricity. There is alsosome evidence that foams might actually encourage thermal runaway progression by insulating theburning materials and exacerbating heat rise.

Fire-fighting dry chemical powders can eliminate visible flame. However, they also lack the ability to coolburning battery components. Quite often, even if visible flame is removed, the thermal runaway inside thebattery will continue resulting in re-ignition. Carbon dioxide and inert gas suppressing agents will alsoeliminate 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 are tied in with the firedetection 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. In some firesuppression systems, the HVAC recirculates and does not shut down and provides a means of dispersingthe clean agents. Responders must ensure adequate hold time has occurred prior to accessing batteryroom/container. Manufacturer-recommended times should be made clear. These agents might alsoreduce flammability by suppressing oxygen levels, but data has identified that flammable gases willcontinue to be produced due to the continued heating and could create an environment ripe for flashoveror backdraft when oxygen is reintroduced into the system.


Committee:


Committee Statement

CommitteeStatement:

Shutting down the HVAC and individual lithium module fans in closed loop systems may inhibit thecirculation of the clean agent systems to the point of the thermal runaway event which could leadto continued propagation. This could lead to an uncontrollable fire situation.

ResponseMessage:

SR-14-NFPA 855-2018

Public Comment No. 50-NFPA 855-2018 [Section No. C.5.1]


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C.5.2 Lead-Acid, and Flooded Cell Nickel-Cadmium, and Other Aqueous Battery Technologies.

Lead-acid, nickel-cadmium, and other aqueous batteries are a very familiar chemistry to fire fighters.However, though the chemistries employed in ESS are similar to those that would be found in batterybackup systems, they can be expected to be found in much larger arrays. The size of the battery systemis certainly a factor when determining suppressing suppression agent requirements, strategy, and tactics.

Overcharging can lead to overheating and production of hydrogen gas, case swelling, and electrolyteleakage. Large fires can be treated as hazardous materials events.

Water, powders, inert gases, and carbon dioxide are all considered acceptable suppressing suppressionagents for small fires involving lead-acid these batteries. However, if the fire is large, water will be thepreferred agent because of its superior accessibility, portability, and cooling effectiveness.


Committee:


Committee Statement

CommitteeStatement:

Unclear if this sections is meant to cover Nickel-Cadmium. If not, a separate section should beadded for those chemistries as the standard has no current guidelines.

ResponseMessage:

SR-15-NFPA 855-2018



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C.7.3 Suppression Tactics.

As previously mentioned, battery components are often housed in cabinets or other configurations thatcan serve to protect the components and thus limit the ability of fire stream penetration. Fire fightersshould never use piercing nozzles and long penetrating irons. Mechanically damaged cells or puncturingunburned or undamaged cells can result in the immediate ignition of those cells. In addition, internalshorting within the cabinets could create an electrocution risk.

Movement of damaged cells might result in arcing or re-ignition if active material or cells remain in themodules. Modules should not be moved without consultation from qualified personnel.

Ventilation during suppression is critical. Research has shown that Li-ion batteries might continue togenerate flammable gases during and after extinguishing. In addition, testing has shown that duringsprinkler suppression, removal of combustion and flammable gases emitted from the battery significantlyimproves the effectiveness of the suppression.

Testing has shown that electrical current leakage back through hose streams will not be a shock hazardwhen appropriate streams are used and distances maintained. In cases where systems are thoroughlydestroyed and electric potential is shown to be minimal, close range engagement with hoses for thepurpose of drowning modules can be performed to provide more direct cooling.

During post-fire operations, SCBA should continue to be worn by all persons near the damaged ESS,especially when systems are in confined or poorly ventilated spaces or have not been sufficiently cooledyet. Gases, and in particular CO, should be monitored during this period, as dangerous buildups havebeen observed during post-fire testing. If possible, batteries should be monitored for residual heat andtemperature, as re-ignition is a possibility in cells that are not sufficiently cooled.

Care should be taken to secure the area the batteries are located in and ensure that the heat has beenremoved and that the batteries are not at risk of being electrically shorted or mechanically damaged. Thisshould be done at the guidance of a qualified technician. At this point, the fire scene should be handedover to the owner, operator, or responsible party appointed by the site owner.

Though trace amounts of heavy metals such as nickel and cobalt can be deposited from combustion ofthe batteries, these elements are not expected to be present in large quantities or in quantities larger thanany other similar fire. In most instances, water exposed to the batteries shows very mild acidity, with anapproximate pH of 6. Runoff water pH can be monitored during fire-fighting operations but should not posea greater risk than normal fire-fighting run-off.

In unique cases where a system on fire poses little or no risk to the surrounding uninvolved equipment orthe environment, it is can be reasonable to assume a defensive posture and allow the system to burn itselfout. Some typical steps for this approach include the following: local municipal fire fighters responding tothe scene to make sure that the flames do not spread beyond the property perimeter, having ESSoperations personnel arriving at the scene to review the situation and conditions, and then allowing the fireto burn out. This practice would remove stranded energy risks as well as make disposal and post fire-fighting operations simpler. This option should only be considered when no risks are posed to theenvironment and the risk to fire-fighting operations is great or unknown. It is up to the site owner/operatorto communicate with fire services in the event of an emergency to relay vital system information to fireservices.


Committee:


Committee Statement

CommitteeStatement:

I think it is a dangerous assumption to conclude that just because the fire self-extinguished atsome point that all stranded energy risk has been removed. This sentence should be removed.

ResponseMessage:

SR-17-NFPA 855-2018


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Second Revision No. 18-NFPA 855-2018 [ Section No. F.1.2.4 ]

G.1.2.3 IEEE Publications.

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

IEEE 1635/ASHRAE 21, Guide for the Ventilation and Thermal Management of Batteries for StationaryApplications,2012 2018 .

IEEE C2, National Electrical Safety Code , 2017.


Committee:


Committee Statement

CommitteeStatement:

A revised edition of this document was recently approved for publication earlier this year. Note thatI could not find a reference to this document in the text of the standard (it was referenced in theprior draft but it seems in reading the actions taken by the committee that all text referring to thisdocument has been deleted). If that is the case then the reference can be deleted in Annex F.

ResponseMessage:

SR-18-NFPA 855-2018

Public Comment No. 162-NFPA 855-2018 [Section No. F.1.2.4]


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Second Revision No. 178-NFPA 855-2019 [ Section No. G.3 ]

G.3 References for Extracts in Informational Sections.

NFPA 1, Fire Code, 2018 2009 edition.

NFPA 13D , Standard for the Installation of Sprinkler Systems in One- and Two-Family Dwellings andManufactured Homes , 2019 edition.

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


Committee: ESS-AAA

Submittal Date: Wed Jan 16 14:56:00 EST 2019

Committee Statement

CommitteeStatement:

This Second Revision is changing the reference to NFPA 1 from the 2018 edition to the editionthat is actually referenced in the document, which is the 2009 edition.

ResponseMessage:

SR-178-NFPA 855-2019


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