Codes and Standards for ESS Relevance and Importance David R. Conover Pacific Northwest National Laboratory Support from DOE Office of Electricity Delivery & Energy Reliability Energy Storage Program IEEE PES January 23, 2018

Purpose and Expected Outcome Reinforce the relevance and continuing importance of ESS safety-related codes and standards (C/S) development and adoption in fostering successful expansion of energy storage technology development and deployment. Expected Outcome An understanding of the value of C/S and the foundation that exists through past and current efforts that will support future efforts.

Energy Storage Safety Goal Achieving desired growth of ESS in the built environment that is minimally affected by safety-related incidents because of the availability of codes and standards that…. support ESS technology form a basis for communication and understanding foster the installation and use of ESS are founded on robust research and field data are supported by all relevant stakeholders are widely adopted and understood can be easily updated as warranted OR

Challenges Associated with ESS Development and Deployment The ever increasing number of ESS technologies and applications and ability of relevant stakeholders to ‘keep up’ Codes and standards provide a vehicle to uniformly document and validate ESS safety but can be in need of updating and enhancement Research and data to define what is and is not safe are needed to develop appropriate codes and standards All interested and affected parties may not recognize the importance of codes and standards or if they do may be reluctant to participate or collaborate with others When codes and standards are available they may not be adopted and applied in a timely manner Ensuring all stakeholders have the necessary training and resources to document, validate and ensure compliance Talk off the bullets. Tee this up as something that occurs over time. Once there was no energy storage and no issues or need for codes/standards. Then electricity and the need for safety and the National Electrical Code was initially developed. The rest is history and now we are seeing more ESS types, chemistries, applications, etc. etc. in new and existing buildings and of new as well as rebuilt technology. So the challenges are the increasing depth and breadth of ESS, C/S are dynamic BUT they flow after (not before technology), you need research, data and information to answer questions so you can formulate C/S etc. We have an infrastructure and many SDOs to work on this but it needs all stakeholders to participate (some choose to not and others are just not aware of things until they have an issue) and then even at that it takes time to adopt and implement those C/S. NOTE that I added the last bullet after ERICA. I think this is one additional key point to make – even if updated and adopted if people do not know about C/S or what they require, etc. then we have not completely closed the loop so to speak.

Addressing the Challenges - ESS Safety Roadmap

A Value Proposition Investment in ESS development and deployment (Y-axis) over time (X-axis) Updated/current C/S provide a basis to uniformly document and validate ESS safety in a timely manner ESS proponents can make an investment to be involved (or not) with C/S development A – active participation B – track efforts of others C – no involvement This simply puts getting from A to B in a time/$$ context. Best case you are engaged and invest some of the RD&D $$ on C/S and related research etc. and that investment (likely 1% of the total RD&D budget) pays off because C/S are available and adopted that provide the ‘road’ to get from A to B. Not making that investment but tracking efforts of others (e.g. being a free rider) means the road to B is a little more challenging and you eventually get to B – but miss the value provided in scenario A in the chart. Not taking any initiative in this area is in a way ‘flying blind’ where eventually you may get to B but way too late or worse are painted into a corner and find there is no way to bring the product to market because of the need to re-design or re-apply because something related to safety and C/S was missed (because there was no activity as in scenario A or B). NOTE I added a new 4th big bullet to close the loop – the message is a little investment early on then pays dividends as ESS starts to go to market (or in the case of B or C is challenged in getting to the market more than A who made an up front investment). If you want to highlight a case in point mention the change in residential codes a while back from a minimum 42 in. to 44 in. clear width for basement egress windows. One mfgr was not paying attention and kept making 42 in. models and ended up with a warehouse full that did not meet the new code. The choice made will affect how successfully ESS can be deployed which in turn affects the ROI associated with ESS development

Codes and Standards Outcomes New and updated C/S are adopted and become the minimum safety metric affecting the timely acceptance of ESS. New and updated guidelines, protocols, best practices, etc. augment minimum C/S Guides, checklists, and educational materials supporting C/S facilitate the ease with which ESS can be approved and implemented.

The Big Picture Many US and global entities that oversee the development of model codes and standards (C/S) C/S collectively form the basis for a cohesive and integrated set of criteria that govern the design, construction, commissioning, operation, maintenance, renovation and demolition of the built environment Standards have specific purposes and scopes and are available for adoption directly, in other standards and/or model codes Model codes adopt standards and in that adoption provide administrative criteria that will influence application of the standard Model codes can be adopted voluntarily, mandated or adopted on a conditional basis as can standards Those adopting model codes or standards can and do amend them Guides, guidelines, protocols, best practices, recommended practices etc. provide additional guidance and can be pre-cursors to C/S There are a myriad of US and global customers, users, and adopters of and objectives and reasons for standards A particular standard may appear to stand alone but in reality it cannot if it is to be used to its full potential Standards are part of a larger body of criteria that in the aggregate govern all aspects of our built environment Standards must be written to be deployable within the US and global codes, standards and conformity assessment environment or they cannot support the collective needs of all involved with the built environment Reduce to bullet points

Adoption of Codes and Standards Mandatory adoption by Federal, state or local authorities via legislation or regulation Adoption by reference and/or adaptation into model codes Voluntary adoption by non-governmental entities as a component of procurement, insurance, government support/financing, contractor licensing and other reasons Model Codes Mandatory adoption by Federal, state or local legislative or regulatory action by reference, within the legislation, automatic or as warranted Applicable in all areas covered by the action Mandatory maximum/minimum Mandatory minimum with amendment allowed Mandatory only if agency elects to adopt a code Mandatory as a required design specification even if an agency elects to adopt Voluntary adoption through insurance, builder, utility, contractor, etc. action Adoption as a component of a professional ethics and licensing

Scope of Codes and Standards vis-a-vis ESS MACRO MICRO This is one way of looking at ESS in relation to safety and C/S. Using the example of the building we are sitting in we can look at the HVAC system. At the micro level there are components of the HVAC equipment like relays, valves, heat exchangers, refrigerants, etc. Then the next level up is the entire HVAC system itself, then above that the installation of that system in the building and then above that the entire building. There are standards for system components, for entire systems, for the specifics associated with installing the system and then overarching requirements that cover entire facilities (which in part tie what applies to the system and its installation to other things/issues associated with the entire facility).

Key Codes and Standards NFPA 1-2018 (Fire Code) NFPA 70-2017 (National Electrical Code) ICC 2018 IFC ICC 2018 IRC IEEE C2-2017 (National Electric Safety Code) DNVGL-RP-0043 (Safety, Operation and Performance of Grid-connected ESS) NFPA 855-20XX (Standard for the Installation of Stationary Energy Storage Systems) NECA 416-2016 (Recommended Practice for Installing Stored Energy Systems) FM Global Property Loss Prevention Data Sheet # 5-33 January 2017 (Electrical Energy Storage Systems) Just list these out as shown. If you have time to elaborate you can use the information below. Also note we have the webinar slides available and the C/S report each month that tracks these things and keeps folks updated. NFPA 1-2015 (Fire Code). The 2018 edition is finalized. Chapter 52 includes requirements related to ESSs. Public inputs for the 2021 edition are due in mid-2018. NFPA 70-2017 (National Electrical Code). Article 706 applies to ESSs and Article 480 applies to batteries. Proposed changes were due September 7, 2017, and initiate a revision process that will lead to the 2020 edition. 2018 IFC (International Fire Code). Section 1206 covers electrical ESSs. Proposed changes are due January 8, 2018. The code development process, will occur during 2018and result in the 2021 edition of the IFC. 2018 IRC (International Residential Code). A section of the IRC covers ESSs and proposed changes are due January 8, 2018 IEEE C2-2017 (National Electric Safety Code [NESC]). The final date to receive change proposals from the public for revision of the 2017 edition is July 15, 2018. The outcome of the revision process will be the 2022 edition of the NESC. DNVGL-RP-0043, September 2017 (Safety, Operation and Performance of Grid-connected Energy Storage Systems). NFPA 1-2015 (Fire Code). The 2018 edition is finalized. Chapter 52 includes requirements related to ESSs. Public inputs for the 2021 edition are due in mid-2018. DNVGL-RP-0043, September 2017 (Safety, Operation and Performance of Grid-connected Energy Storage Systems). UL 9540 (Energy Storage Systems and Equipment) ASME TES-1 (Safety Standard for Thermal Energy Storage Systems)

Key Codes and Standards IEEE P1679.1 (Guide for the Characterization and Evaluation of Lithium-Based Batteries in Stationary Applications) IEEE P1679.2 (Guide for the Characterization and Evaluation of Sodium-Beta Batteries in Stationary Applications) UL 1973 (Batteries for Use in Light Electric Rail and Stationary Applications) UL 1974 (Evaluation for Repurposing Batteries) UL 810A (Electrochemical Capacitors) Just list these out as shown. Also note we have the webinar slides available and the C/S report each month that tracks these things and keeps folks updated.

Summary and Moving Forward Secure Adoption Foster Compliance Experiences & Data Additional Research Update C/S All stakeholders need to coordinate and collaborate to achieve success You know this well – update, get adopted, etc. etc. Lots to do in providing input to each circle and lots to do in getting output from each circle. If all work together this can be much easier than if stakeholders and interested parties choose to do their own thing. Get them adopted Facilitate documenting and validating compliance Accumulate experiences with ESS design, construction, inspection, commissioning, operation, maintenance, incident response and decommissioning Conduct additional research to get answers to relevant ESS safety questions or issues Update C/S and secure their adoption Go back to step 1

DOE-Office of Electricity Delivery and Energy Reliability Acknowledgement Dr. Imre Gyuk DOE-Office of Electricity Delivery and Energy Reliability

Q/A and Further Information David Conover PNNL david.conover@pnnl.gov https://energystorage.pnnl.gov/ http://www.sandia.gov/energystoragesafety/ PNNL-SA-131213