3RCNY 608-01 Outdoor Stationary Storage Battery Systems

Proposed Rules: Closed to Comments (View Public Comments Received:25)

Agency:
Comment By: 
Thursday, May 30, 2019

Statement of Basis and Purpose of Proposed Rule

 

The Fire Department proposes this rule to establish standards, requirements and procedures for the design, installation, operation and maintenance of outdoor stationary storage battery systems that use various types of new energy storage technologies, including lithium-ion, flow, nickel-cadmium and nickel metal hydride batteries.  The proposed rule would not govern indoor battery installations.

 

Background and Purpose

 

In April 2018, a working group coordinated by the City University of New York and the New York State Energy Research and Development Agency, in which the Fire Department participated, issued the first comprehensive set of guidelines for installing outdoor lithium-ion energy storage systems in New York City, to create a pathway for safe widespread use of lithium-ion stationary storage battery systems.  This proposed rule would implement the working group’s guidelines through fully-developed design and installation requirements and emergency management procedures for outdoor stationary storage battery systems.

 

This proposed rule also seeks to address the fire safety concerns associated with new battery technologies by setting testing standards and establishing an equipment approval process for manufacturers.  Establishing testing standards, and in particular, requiring full-scale testing of battery system components and pre-engineered products, will enable manufacturers to identify fire safety issues and eliminate them or engineer mitigating measures in the design.  The evaluation of the performance of battery system components or products in this manner will also allow the Fire Department to eliminate or expedite its approval process for specific installations.  Equipment approvals will allow developers and installers to select products that are already approved for New York City use, with or without conditions or limitations.

 

Evolution of Battery Use and Technology

Stationary storage battery systems are commonly used in office buildings and other commercial buildings to provide emergency or standby power for life safety systems, or uninterruptible power for business operations.  The storage batteries commonly used for these applications are lead-acid batteries similar to those found in automobiles, the science and safety of which is well-understood.

 

The movement to replace fossil fuels with alternative energy sources to address global environmental concerns has prompted the rapid development of new energy storage technologies. In recent years, new storage battery technology has been developed for large-scale power uses, such as storing power for general building use.  The batteries can be charged overnight or during other low-demand periods, and provide building power during the daytime.  Additionally, stationary storage batteries can be used to store power generated by rooftop solar panel installations and other local, small-scale energy generating systems.  The power generated by these systems, when not needed on site, can supply power to the public utility’s power grid.

 

Because of their energy density (high-energy generation considering the battery’s size and weight), lithium-ion batteries are increasingly being used in a wide range of applications, including consumer products.  However, lithium-ion batteries are subject to thermal runaway, which occurs when the heat generated by a malfunctioning energy cell or module causes others to fail, potentially generating intense fires and fires that reignite after being extinguished.  Various highly-publicized incidents have illustrated the fire safety concerns associated with lithium-ion batteries.  In addition to lithium-ion, the new stationary storage battery technology includes nickel-cadmium, nickel metal hydride and flow batteries.  This rule would apply to these technologies as well.

 

Testing and Listing Standards

 

The Fire Department has been actively engaged for several years in the development of appropriate standards for stationary storage battery systems. Working with national standard-making organizations, nationally-recognized testing laboratories and Federal, State and City agencies, the Fire Department has advocated for the testing of new technologies that would enable the Fire Department and other regulatory agencies to fairly assess, in a scientific manner, any potential hazards associated with the new technologies.

 

The proposed rule requires the use of the current edition of the Underwriters Laboratories Test Method 9540A for full-scale testing, but the Fire Department is aware that these testing standards, like the technologies themselves, are still in development. The proposed rule acknowledges the evolving standards by specifying the latest listing and testing standards, but authorizing the Fire Department to accept later editions or other standards that address the Fire Department’s fire safety concerns.  Also under development is a new listing standard that will be used to establish listings with installation conditions based on test data.  The proposed rule anticipates that when such listing standard is developed, and approved by the Fire Department and the Department of Buildings, it will replace the existing listing and testing standards and the Fire Department’s equipment approval process, and supersede required separation distances to the extent addressed in the new listing.

 

The Fire Department specifically invites public comment, including technical comment, about the full-scale testing standard and other standards adopted in this proposed rule.

 

Proposed Regulatory Requirements

 

The proposed rule would regulate outdoor stationary storage battery systems based on their technology and size.  Table 1 establishes proposed thresholds for small, medium or large outdoor stationary storage battery systems. The size of the stationary storage battery system is based on the energy storage/generating capacity of such system, as rated by the manufacturer, and includes any and all storage battery units operating as a single system.

 

Table 2 lists the compliance requirements in the proposed rule and indicates, in a readily accessible format, the requirements applicable to each size, and in some cases type, of battery system.

 

The fire safety regulations in the proposed rule include the following requirements:

 

·        Permits.  The proposed rule would require a Fire Department permit for medium and large outdoor stationary storage battery systems.  Operational permits ensure that the Fire Department and its firefighting force are aware of the location of the stationary storage battery systems and can conduct periodic inspections as the Fire Department determines appropriate.

 

·        Supervision.  The proposed rule would require that all outdoor stationary storage battery systems be under the general supervision of a trained and knowledgeable person holding a Fire Department Certificate of Fitness.  The Fire Department anticipates that installers or other persons associated with the design or installation of the stationary storage battery system would be the persons qualified to supervise such systems.

 

A Certificate of Fitness requirement would help ensure that installers and other businesses involved in stationary storage battery systems – who may be new to New York City – are familiar with New York City regulatory requirements, and the Certificate of Fitness holder can serve as a point of contact with the Fire Department.  The proposed rule would require the Certificate of Fitness holder to assist the Fire Department in any emergency involving or affecting the stationary storage battery system that the Certificate of Fitness holder supervises, including responding to the incident location in a timely manner to confirm that the stationary storage battery system is in good working order, or to mitigate the condition and decommission the stationary storage battery system.  The proposed rule anticipates that the required emergency management plan would be developed by manufacturers, installers and, in some cases, property owners, to address how such situations would be handled.

 

Certificates of Fitness are obtained by studying the online study materials applicable to the particular certificate and submitting to administration of a computerized examination at Fire Department Headquarters.  Test results are immediately available, and if a passing score is achieved, the certificate is issued on the spot.  The fee for most Certificates of Fitness is $25 for a 3-year period.

 

The Fire Department specifically invites public comment as to how outdoor stationary storage battery systems are likely to be managed, maintained and monitored once installed, and the category of persons who would be best qualified and available to provide the assistance that the Fire Department may require in the event a seriously malfunctioning stationary storage battery system necessitates a Fire Department response.

 

·        Multiple battery systems.  The proposed rule would require Fire Department review of multiple outdoor stationary storage battery systems on a single premises to ensure that the fire safety requirements for larger stationary storage battery systems are not being circumvented by a number of smaller systems.

 

·        Mobile battery systems. Stationary storage battery systems are typically fixed, not portable.  However, stationary storage battery systems can be mounted on trailers and towed to locations, in the same way as air compressors, diesel-fueled emergency generators, and other mobile power and heating trailers.  The proposed rule would allow mobile stationary storage battery systems and make appropriate adjustments in the approval and permitting process.

 

·        Installation approvals.  It is anticipated that only large stationary storage battery systems will require site-specific installation approvals.  The proposed rule sets forth the information that will be required for such applications, including any related Department of Buildings applications, Fire Department equipment approvals for stationary storage battery units or components, and site plans.

 

·        Commissioning/decommissioning.  The proposed rule would require that outdoor stationary storage battery systems be installed (commissioned) or removed (decommissioned) only by trained and knowledgeable persons holding a Fire Department Certificate of Fitness.  The Fire Department anticipates that these will be the same businesses and individuals who will be responsible for maintaining the system once installed and who will be required to obtain a Certificate of Fitness.

 

The proposed rule would require notification to the Fire Department in connection with the commissioning and decommissioning of these outdoor stationary storage battery systems, so Fire Department firefighters or other representatives can, if they wish, familiarize themselves with these installations.  The removal of any stationary storage battery system experiencing abnormal temperatures or gas emission readings as a result of physical damage, exposure to fire or other cause of failure, would have to be coordinated with the Hazardous Materials Unit of the Fire Department’s Bureau of Operations.

 

·        Design and installation requirements.  The proposed rule sets forth general design and installation requirements, including Fire Department access and water supply, and separation distances from streets, building openings, overhead power lines, infrastructure and other sensitive locations.  The proposed rule would authorize the Fire Department to reduce separation distances if the full-scale testing results show minimal hazards, or increase them if there are hazards that have not been addressed by the manufacturer in engineering of the stationary storage battery system.

 

The Fire Department anticipates that medium and large outdoor stationary storage battery systems will be housed in containers and other enclosures.  Malfunctioning stationary storage battery systems can generate flammable gases and the enclosures in which they are housed could allow these gases to collect and reach dangerous levels.  Accordingly, the proposed rule would require that the enclosures be designed with fire and gas detection systems and other fire protection systems, explosion protection and a manual exhaust system for firefighter use.

 

The Fire Department specifically invites public comment on the design and installation requirements for enclosures, and whether the rule needs to address the design and installation of other products developed for outdoor stationary storage battery systems.

 

·        Rooftop installations.  The proposed rule allows the installation of stationary storage battery systems on building rooftops, but includes requirements designed to address the fire safety concerns associated with rooftop installations.

 

·        Remote monitoring and reporting.  The Fire Department understands that all outdoor stationary storage battery systems will be designed with a battery management system (BMS) that will be remotely monitored on a 24/7 basis.  The proposed rule would require such remote monitoring to ensure timely notifications to the Fire Department, Certificate of Fitness holder and manufacturer of the battery if the stationary storage battery system exhibits abnormal behavior indicative of a serious malfunction.

 

The Fire Department specifically invites public comment on the business arrangements among the manufacturer, installer and property owner with respect to the monitoring of battery management systems and management of emergencies affecting outdoor stationary storage battery systems.

 

·        Emergency management plan and technical assistance.  The proposed rule would require that the property owner, manufacturer and/or installer develop an emergency management plan or protocol that includes procedures for notifications, technical assistance and response to the incident location in the event of an emergency involving or affecting an outdoor stationary storage battery system.

 

·        Signage.  The proposed rule would require detailed signage indicating the type of stationary storage battery system, providing emergency contact information, and other information at the fire department (hose) connection, public utility connection or other conspicuous location.  The signage must also indicate whether the battery system is connected to a public utility power grid, such that its shut-down could have widespread or power grid impacts.

 

·        Maintenance.  The proposed rule would require an annual inspection of the outdoor stationary storage battery system by the Certificate of Fitness holder.  The proposed rule also clarifies that the replacement of battery components with different battery technologies or chemistries would constitute an alteration of the system that must be submitted for Fire Department review and approval in accordance with the requirements of the proposed rule.

 

·        Recordkeeping.  The proposed rule would require that records of the installation, maintenance and removal of the outdoor stationary storage battery system and associated equipment must be maintained by the Certificate of Fitness holder and/or the property owner.

Public Hearing
Subject: 

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Public Hearing Date: 
Thursday, May 30, 2019 -
11:00am to 1:45pm
Contact: 

No contact

Location: 
FDNY Headquarters Auditorium
9 Metrotech Center
Brooklyn, NY 11201