On August 21, the US Environmental Protection Agency (EPA) posted updated guidance for battery energy storage system (BESS) installation and incident response. EPA has added a 3-page Fact Sheet, “Battery Energy Storage Systems: Main Considerations for Safe Installation and Incident Response” to its online compilation of information for “Sustainable Management of Electronics and Batteries.” EPA notes that BESS operations help stabilize electrical grids by providing steady power flow, particularly where there may be interruptions in grid power or fluctuations in production from renewable energy sources. However, EPA also notes that lithium battery fires at some installations (notably at commercial facilities in San Diego and Moss Landing, California) have raised safety concerns in many communities. EPA intends its new guidance to help address these concerns; the remainder of this note summarizes EPA’s new guidance.
What are BESS installations and what safety and response challenges do they present?
The guidance focuses on commercial- and utility-scale battery installations, which can amass thousands of batteries that can store and discharge hundreds of megawatts of electricity. However, many of the practical considerations also apply to facility-scale installations.
Installation considerations
EPA recommends that BESS installations incorporate safety measures designed to minimize the risk of fires. In particular, EPA recommends the following design and siting considerations:
- Comply with state and local siting, zoning, marking, and permitting requirements to ensure site suitability
- Consider BESS units’ design (battery chemistry, manufacturing quality assurance/quality checks, unit design, battery management system analytic capabilities, and system integration) and consult the most recent industry safety standards
- Include remote sensors and monitoring (e.g., infrared, thermal, fire detection).
- Communicate with local first responders to develop emergency response plans for incidents.
Incident response consideration
EPA explains that BESS incidents can present unique challenges for host communities and first responders. These include:- Fire Suppression: Lithium battery fires can be extremely difficult to extinguish and may reignite hours or days later.
- Emissions and health hazards: Battery fires can release harmful gases that pose health risks to first responders and others (anyone still at the facility, and nearby residents).
- Environmental Impact: Proper cleanup and disposal of damaged batteries requires specialized procedures.
Accordingly, EPA recommends that facilities consider the following when developing an incident response plan for BESS:
- Ensure use of Personal Protective Equipment (PPE) including self-contained breathing apparatuses to protect against hazardous air emissions.
- Set an isolation zone depending on the site and numbers of batteries; e.g., for large commercial BESS at least 330 feet.
- Position responders upwind and uphill.
- Evaluate the need for community shelter-in-place or evacuation.
- Direct fire crews to let the fire burn itself out and to use water to prevent the spread of fire to neighboring batteries or other structures (this is current response professional guidance). Research is ongoing into the most effective method of water application to prevent spread.
- Assess hazardous air emissions, which may include hydrogen, carbon monoxide, hydrogen fluoride, hydrogen cyanide, and hydrogen chloride. As an incident extends, air sampling for metals and combustion byproducts of burning plastics may be appropriate.
- Minimize, contain, and/or redirect runoff from water application, to the extent possible.
- Package post-event wastes for transport and disposal after the event, considering Department of Transportation and EPA requirements.
EPA’s guidance also provides links to relevant standards (National Fire Protection Association and Underwriters Laboratory), and a collection of additional information resources.
What happens now?
Siting and response recommendations are evolving rapidly. EPA’s new guidelines provide a useful overview, and are accompanied by links to more detailed standards and practices. Organizations that hae or are considering significant battery energy storage installations should consider this guidance as they prepare for onsite activities.
Self-assessment checklist?
Do any of the organization’s locations include significant battery energy storage?
Does the organization include thorough safety planning in each design, installation, and operation?
Has the organization developed operational and incident response plans for each facility?
Has the organization coordinated with incident response entities (such as local fire department) that would respond to an incident?
Has the organization identified environmental sampling entities that could be called upon during and after incident response?
Where can I go for more information?
- EPA
- “Sustainable management of Electronics and Batteries”
- “Battery Energy Storage Systems: Main Considerations for Safe Installation and Incident Response”
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
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