2023 White Paper

The Evolution of Battery Energy Storage

Safety Codes and Standards

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 1 OVERVIEW
The U.S. energy storage market is growing rapidly, with
4.8 gigawatts of deployments in 2022 and a forecast of
75 gigawatts of additional deployments between 2023
and 2027 across all market segments,1 with approximately
95% of current projects using Li ion battery technology.2
Incidents involving fire or explosion are quite rare, with the
EPRI Battery Energy Storage System (BESS) Failure Event
Database3 showing a total of 16 U.S. incidents since early
2019. Nevertheless, failures of Li ion batteries in other
TABLE OF CONTENTS
markets, most prominently fires involving unqualified and
1 OVERVIEW............................................................. 2
unregulated hoverboards, e-bikes, and e-scooters,4 have
2 HAZARDS ASSOCIATED WITH BATTERY SYSTEMS....3
raised public awareness of Li ion battery failures to such an
3 HISTORICAL INCIDENTS AND CODES AND extent that local opposition has caused the cancellation of
STANDARDS DEVELOPMENT................................... 3
some BESS projects.5
3.1 ESS Incidents as a Driver for Codes and
Standards Development.................................. 3 Statistically, the increase in ESS deployments means that
3.2 Electrical Code................................................ 4 there will be an inevitable increase in the number of failure
3.3 Fire Codes and NFPA 855................................. 4
incidents. That said, the evolution in codes and standards
3.4 Qualification Standards for Battery ESS........... 5
regulating these systems, as well as evolving battery system
3.5 Fire and Explosion Testing............................... 5
designs and strategies for hazard mitigation and emergency
3.6 Personnel Safety............................................. 5
response, are working to minimize the severity of these
3.7 Transportation................................................. 6
3.8 Environmental Standards................................ 6 events and to limit their consequences.
3.9 Evolution of Codes and Standards................... 6 This report provides a historical overview of BESS incidents,
4 STANDARDS-DRIVEN ESS DESIGN AND the resulting evolution of North American codes and stan-
INSTALLATION........................................................ 7
dards, their influence on ESS installations. Environmental
4.1 Overview......................................................... 7 safety is also discussed as an essential element in the future
4.2 Waivers Approved by the AHJ......................... 7
decommissioning of these systems. The lessons learned
4.3 Location.......................................................... 8
with Li ion ESS provide a framework for assessing the
4.4 Size and Separation......................................... 8
hazards and safety management associated with emerging
4.5 Smoke, Fire, and Gas Detection....................... 8
4.6 Explosion Control............................................ 8 storage technologies, although existing test methods may
4.7 Firefighting Philosophy.................................... 9 not address new failure modes that may emerge.
4.8 Pre-Incident Planning.................................... 10
5 DECOMMISSIONING............................................. 10
5.1 Decommissioning Plan.................................. 10
5.2 Transportation Considerations...................... 10
5.3 Decommissioning Safety............................... 10
1 U.S. Energy Storage Monitor, Q1 2023 full report and 2022 Year in
6 ASSESSING THE HAZARDS AND SAFETY Review, Wood Mackenzie Power & Renewables/American Clean
MANAGEMENT OF NEW TECHNOLOGIES............. 11 Power Association, https://www.woodmac.com/industry/power-and-
renewables/us-energy-storage-monitor/.
6.1 Evaluating Emerging Technologies................. 11 2 DNV Energy Transition Outlook 2022, https://www.dnv.com/energy-
7 REFERENCES......................................................... 12 transition-outlook
3 https://storagewiki.epri.com/index.php/BESS_Failure_Event_Data-
8 ACRONYMS AND ABBREVIATIONS........................ 12 base.
4 https://www.npr.org/2023/03/11/1162732820/e-bike-scooter-lithi-
9 ACKNOWLEDGMENTS........................................ 13 um-ion-battery-fires.
5 https://www.energy-storage.news/local-opposition-leads-to-bess-
project-cancellations-in-north-america-report/.

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2 HAZARDS ASSOCIATED WITH 3 HISTORICAL INCIDENTS AND
BATTERY SYSTEMS CODES AND STANDARDS
Hazards related to stationary batteries can be broadly clas- DEVELOPMENT
sified as: electrical, such as electrical abuse, shock, and
3.1 ESS Incidents as a Driver for Codes
arc flash; chemical, such as spills and toxic emissions; and
and Standards Development
thermal, such as fires and explosions. Li ion systems present
Early ESS deployments were not regulated by specific
all these hazards, except spills.
building electrical, fire, and product qualification codes and
The main concern with Li ion batteries is the risk of thermal standards but by more generic or less application-relevant
runaway,6 leading to venting of flammable and/or toxic requirements. For example, Underwriters Laboratories (UL)
gases and the possibility of fire or explosion. These hazards standards for portable consumer cells and battery packs
are the main driver for development of codes and stan- were applied to much larger ESS batteries, but these did not
dards relating to these battery systems. adequately address the particular hazards of larger station-
ary units. The codes and standards landscape started to
Differing chemistries have varying propensities and inten-
change after a series of 23 fires, mostly occurring in the pe-
sities of thermal runaway. While some Li ion chemistries,
riod of June 2018 to January 2019, at South Korean energy
such as lithium iron phosphate (LFP), have more favorable
storage facilities. A five-month investigation by an expert
safety characteristics (e.g., longer time under duress before
panel under the Ministry of Trade, Industry and Energy,
thermal runaway is initiated; lower maximum temperatures
published in June 2019, identified ‘four causes of accidents
during runaway) than the current prevalent chemistries in
such as insufficient battery protection system and poor
electric vehicles, such as lithium nickel-manganese-cobalt
operating environment management.’9
oxide (NMC)and lithium nickel-cobalt-aluminum oxide
(NCA), none of them is intrinsically safe. All contain flam- Figure 1 shows the distribution of BESS events by year from
mable electrolytes and can exhibit propagating thermal the EPRI BESS Failure Event Database.10 The spike in 2018
runaway. For more information on lithium ion chemistries and 2019 is from the South Korean fires.
and associated safety considerations, refer to EPRI’s White
Paper on this topic (3002025283).7

One prominent event involving a Li ion battery was an

explosion at the McMicken BESS in Surprise, Arizona, in
which four firefighters were injured.8 In that case, there was
ongoing propagation of thermal runaway in the absence of
flame, allowing flammable gases to build up in the contain-
er above the upper flammable limit (UFL). When firefight-
ers opened the door, oxygen was allowed to enter, and the
explosion occurred. Mitigating the risk of such explosions is
a major discussion point in the ongoing evolution of codes
and standards and in ESS system designs (see Section 4.6). Figure 1. BESS failures by year (EPRI BESS Failure Event Database)

While the number of incidents (excluding the South Korean

fires) showed a sixfold increase from two events in 2017
to 12 in 2022, Figure 2 indicates that US energy storage
deployments increased by 18 times over the same period.
6 The Difference Between Thermal Runaway and Ignition of a Lithium Note that the events involving facilities over 50 MWh in
ion Battery. EPRI, Palo Alto, CA: 2022. 3002025283.
7 Safety Implications of Lithium Ion Chemistries. EPRI, Palo Alto, CA: 9 MOTIE Report, “Announcement of ESS accident cause investigation
2023. 3002028522. results and safety reinforcement measures,” June 2019.
8 Arizona ESS Explosion Investigation and Line of Duty Injury Reports 10 https://storagewiki.epri.com/index.php/BESS_Failure_Event_Data-
Now Available. base.

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3 | EPRI White Paper November 2023
2021 and 2022, are indicative of the overall facility size, and 2017 and quickly updated to the fourth edition in late 2019.
not the number of units or modules involved in the event. The standard was opened for preliminary review in Decem-
For example, the 2022 fire in a Tesla Megapack at the ber 2022 and the technical committee is addressing a total
182.5 MW/730 MWh facility in Moss Landing, California, of 36 proposed changes in preparation for release of the
involved the loss of just one out of 256 units installed there. fifth edition.

3.2 Electrical Code

NFPA 70, National Electrical Code (NEC) covers ESS electri-
cal safety for both design and installation. ESS are classi-
fied in the NEC as ‘Special Conditions’ in Chapter 7 of the
document, with Article 706 applying to all ESS having a
capacity greater than 1 kWh. (Stationary standby batteries
are covered by Article 480.) One notable requirement in
Figure 2. U.S. energy storage deployments across all market Article 706.20 is for provisions for ‘diffusion and ventilation
segments, 2017–202211
of any possible gases… to prevent the accumulation of an
While the statistical sample size of failures is quite small, it explosive mixtures.’ This requirement seems to apply to Li
is reasonable to conclude that the rate of ESS incidents nor- ion vent gases but is inconsistent with explosion control
malized to capacity or number of facilities has decreased provisions in the 2023 edition of NFPA 855 and the 2021
in recent years, and that is due to increased awareness of International Fire Code, as discussed in Section 3.3.
the hazards and risks of specific design features as well as
development and application of mitigation opportunities 3.3 Fire Codes and NFPA 855
for those risks. Many actions were driven voluntarily or pro- The two model fire codes are the International Fire Code
actively by concerned entities well in advance of the codes (IFC), published by the International Code Council, and
and standards evolution. The subsequent progression of NFPA 1, Fire Code. For these model codes to be enforce-
codes and standards has led to more widespread adoption able, they must be adopted, in whole or in part, by states or
and enforcement of mitigations. For example, the quali- local jurisdictions. The adoption process generally results in
fication standard for ESS batteries, UL 1973, Standard for a lag in implementation.
Batteries for Use in Stationary and Motive Auxiliary Power
Chapter 52 of NFPA 1 provides high-level requirements
Applications (see Section 3.4), started life in 2013 with the
for ESS but mostly refers to NFPA 855, Standard for the
title, ‘Batteries for Use in Light Electric Rail (LER) Applica-
Installation of Stationary Energy Storage Systems. The 855
tions and Stationary Applications.’ That first edition and the
Standard is effectively elevated to code status since its
subsequent 2018 revision allowed the use of cells compli-
provisions are mandated by NFPA 1. With a similar scope
ant with UL 1642, Standard for Lithium Batteries, without
to NFPA 1, the IFC includes ESS-related content in Section
further testing and evaluation, despite the fact that UL 1642
1207 that is largely harmonized with NFPA 855.
is focused primarily on small consumer cells. The third edi-
tion of UL 1973, published in 2022, now contains a full suite Some key areas of difference between IFC Section 1207 and
of Li ion cell qualification requirements in normative annex NFPA 855 include the following:
E and no longer refers to UL 1642. • The IFC does not include the provision in 4.4.1 (5) of
NFPA 855, where an AHJ can require an HMA for ‘exist-
In the same way, lessons learned from real-world incidents
ing lithium-ion ESS systems that are not UL 9540 listed’,
have informed the evolution of UL 9540A, Standard for Test
effectively making some requirements retroactive.
Method for Evaluating Thermal Runaway Fire Propagation
• NFPA 855 grants extensive exceptions to lead-acid and
in Battery Energy Storage Systems, first published in late
Ni-Cd standby batteries. In the IFC, those exceptions
11 U.S. Energy Storage Monitor, Q1 2023 full report and 2022 Year in are only available to batteries installed in facilities
Review, Wood Mackenzie Power & Renewables/American Clean under the exclusive control of communications utilities
Power Association, https://www.woodmac.com/industry/power-and-
renewables/us-energy-storage-monitor/. and operating at less than 60 VDC.

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4 | EPRI White Paper November 2023
An important requirement in NFPA 855 (also in the IFC) is While the focus of this document is on North American
for explosion control. Li ion batteries are exempted from standards, there are several international standards with
the requirements for exhaust ventilation under normal similar scopes. The following is a partial listing of applicable
operation but are required to provide either explosion pre- IEC standards:
vention in accordance with NFPA 69, Standard on Explosion • IEC 63056, Secondary cells and batteries containing
Prevention Systems, or deflagration venting in accordance alkaline or other non-acid electrolytes – Safety require-
with NFPA 68, Standard on Explosion Protection by Defla- ments for secondary lithium cells and batteries for use
gration Venting. This either/or approach seems to conflict in electrical energy storage systems.
with the ventilation provisions in the NEC (see Section 3.2) • IEC 62485-5, Safety requirements for secondary batter-
and is discussed in more detail in Section 4.6. ies and battery installations – Part 5: Safe operation of
stationary lithium ion batteries.
3.4 Qualification Standards for • IEC 62933-5-2, Electrical energy storage (EES) systems
Battery ESS – Part 5-2: Safety requirements for grid-integrated EES
U.S. fire and electrical codes require that energy storage systems – Electrochemical-based systems.
systems be listed, meaning the product must be tested by a
• IEC 62281, Safety of primary and secondary lithium
Nationally Recognized Testing Laboratory (a private-sector
cells and batteries during transport.
organization recognized by the Occupational Safety and
Health Administration) and certified to meet consensus- 3.5 Fire and Explosion Testing
based test standards. For ESS, the standard is UL 9540, Fire and explosion testing to UL 9540A is mandated by the
Standard for Energy Storage Systems and Equipment. fire codes. UL 9540A is a test method with no stated pass/
fail criteria, so it is not a qualification standard. However,
UL 9540 covers the complete ESS, including battery system,
favorable test results under this standard are important for
power conversion system (PCS), and energy storage man-
securing approval by the authority having jurisdiction (AHJ)
agement system (ESMS). Each of these components must
for the proposed ESS layout (see Section 4.2).
be qualified to its own standard:
• UL 1973, Standard for Batteries for Use in Stationary and 3.6 Personnel Safety
Motive Auxiliary Power Applications. In addition, the Most requirements for personnel electrical safety are
BMS is qualified to UL 991, Standard for Tests for Safety- covered in NFPA 70E, Standard for Electrical Safety in the
Related Controls Employing Solid-State Devices, and UL Workplace, while installations under the exclusive control
1998, Standard for Software in Programmable Compo-
of an electric utility are largely covered by IEEE C2, National
nents. BMS design and construction is covered by CSA/
Electrical Safety Code (NESC). In the area of shock hazards,
ANSI C22.2 No. 340:23, Battery Management Systems.
NEC Article 706.15 requires battery circuits exceeding 240 V
• UL 1741, Standard for Inverters, Converters, Controllers
to have provisions for disconnection into segments not ex-
and Interconnection System Equipment for Use with
ceeding 240 V DC nominal for maintenance purposes, while
Distributed Energy Resources.
NFPA 70E Article 320.3 requires personal protective equip-
• As with the BMS, the ESMS is qualified to UL 991 and
ment (PPE) for batteries or segments over 100 V DC. Provi-
UL 1998.
sions to meet segmentation requirements include interlocks
UL Solutions certifies BESS equipment under two product that open contactors when enclosure doors are opened,
categories: segmentation with multipole disconnects, and insulation of
• FTBW, referring to complete ESS and equipment current-carrying components. NFPA 70E Article 130.4 also
• FTBL, referring to energy storage equipment DC subas- requires a shock risk assessment to be performed.
semblies.
There is growing understanding regarding DC arc-flash
Note that an FTBL listing would most likely not be consid- hazards. NFPA 70E Article 130.5 requires an arc-flash risk
ered sufficient certification, as the complete ESS would not assessment to be performed. Historically, arc flash as a
be UL certified. concept first appeared in NFPA 70E in 1995, and in 2002

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5 | EPRI White Paper November 2023
IEEE Std 1584, IEEE Guide for Performing Arc-Flash Hazard automatically with sprinklers or manually by firefighters,
Calculations12 was first published. However, all content at can result in contaminated runoff 17 that may require re-
that time was focused on AC arc flash, and it was not until mediation. Such problems are avoided with the ‘let-it-burn’
2007 that a study of DC arc-flash testing was published.13 philosophy (see Section 4.7).
This and other contemporaneous work formed the basis of
a DC arc-flash calculation method in Annex D of the 2012 3.9 Evolution of Codes and Standards
edition of NFPA 70E, and that method is mostly unchanged Codes and standards will continue to evolve in response
in the 2021 edition. More recent studies have shed new to lessons learned in the field. The model codes are on
light on the dynamic behavior of DC arcs, indicating that a three-year update cycle, with new revisions of the fire
current guidance is dated, and that arc interruption oc- codes due in 2024 and the NEC in 2026. NFPA standards are
curs earlier than predicted.14 This new understanding will revised and updated every three to five years. In the case of
inform a revised calculation method and an increase in the NFPA 855, the process to generate the revision for the 2026
threshold voltage to 150 V in the next revision of NFPA 70E, version is already underway, with 19 task groups addressing
expected later in 2023. different areas, including topics such as toxic emissions, fire
protection, and explosion issues. Among other revisions, it
NFPA 70E also includes a useful flow chart in Annex F.7
is expected that explosion control that relies solely on def-
addressing multiple battery hazards and their requirements
lagration venting will no longer be permitted. Furthermore,
for PPE.
there is a proposal to prohibit the use of clean agent or
aerosol fire suppression systems unless fire and explosion
3.7 Transportation
testing can demonstrate that use of such systems does not
Regulation of the transportation of Li ion batteries has also
present a deflagration hazard. See Sections 4.6 and 4.7 for
changed in response to incidents, such as the 2010 crash of
additional discussion on these topics. Note that submission
a UPS Boeing 747 aircraft caused by a fire involving lithium
of a recommendation by a task group does not guarantee
batteries that were not declared as hazardous materials.15
that a proposed change will be adopted in the next revision.
Such incidents have resulted in progressively more stringent
However, it will spur discussion among experts in the field
limitations, including banning of transportation of these
on the appropriateness and robustness of the suggestion
batteries on passenger aircraft. The latest regulations are
and potential outstanding knowledge gaps.
described in the DOT publication, ‘Lithium Battery Guide for
Shippers, A Compliance Tool for All Modes of Transporta- As discussed in Section 3.6, the recent studies and new un-
tion, Revised June 2023.’16 Additionally, transportation of derstanding related to dc arc-flash hazards are expected to
decommissioned batteries is discussed in Section 5.2. result in a new calculation method in the 2024 revision to
NFPA 70E. It is also expected that systems operating below
3.8 Environmental Standards 150 V will be exempted from requirements for Arc Flash
Li ion cells are hermetically sealed, with no emissions PPE (versus 100 V in the 2021 edition).
in normal operation. As such, environmental standards
UL standards are revised on an as-needed basis. Some
relating to air pollution or water contamination do not
standards are stable and not in need of regular revision; for
apply. Using water to suppress battery fires, applied either
example, UL 991 for safety-related controls was last revised
12 IEEE Std 1584, IEEE Guide for Performing Arc-Flash Hazard Calcula- in 2004. Other standards may be updated rapidly, with UL
tions, https://standards.ieee.org/. 9540A being a good example. That document was first pub-
13 C. Keyes and C. Maurice, “DC Arc Hazard Assessment Phase II,” Kinec-
trics, Toronto, ON, Canada, Rep. K012623-RA-0001-R00, Jul. 7, 2007. lished in November 2017, with revisions published in January
14 L. Gordon, “Modeling DC Arc Physics and Applications for DC Arc 2018, June 2018, and November 2019. The revision process
Flash Risk Assessment,” IEEE Industry Applications Society Electrical
Safety Workshop 2023, https://electricalsafetyworkshop.com/. for UL 9540A is again underway, with preliminary review of
15 United Parcel Service Flight 6, N571UP, Federal Aviation Administra- some 36 proposed changes completed in January 2023.
tion Lessons Learned, https://www.faa.gov/lessons_learned/trans-
port_airplane/accidents/N571UP. 17 Quant, M., Willstrand, O., Mallin, T., Hynynen, J., Ecotoxicity Evalu-
16 https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2023-07/ ation of Fire-Extinguishing Water from Large-Scale Battery and
Lithium%20Battery%20Guide.pdf. Battery Electric Vehicle Fire Tests. Environ. Sci. Technol. https://doi.
org/10.1021/acs.est.2c08581.

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One likely change to UL 9540A is to force ignition of vent When referring to fire codes, this section focuses on the
gases. There is inconsistency as to whether ignition occurs requirements of NFPA 855. As discussed in Section 3.3, the
during testing, and there have been instances when a sys- ESS-related content of the IFC is largely harmonized with
tem completed UL 9540A testing without ignition but was NFPA 855.
involved in a fire in an installation. Forcing ignition will give
a better understanding of the fire propagation hazard for a 4.2 Waivers Approved by the AHJ
battery design. Certain requirements of NFPA 855 may be waived based
on evaluation of results from a hazard mitigation analy-
With the recent publication of CSA/ANSI C22.2 No. 340:23,
sis (HMA) and on fire and explosion testing to UL 9540A
Battery Management Systems, referenced in Section 3.4, it
or equivalent, subject to approval by the AHJ. The HMA
seems likely that the next revision to UL 1973 will include
includes a failure modes and effects analysis (FMEA) and is
this new BMS standard as a normative reference.
a requirement of product listing. An AHJ can also require an
HMA for an existing installation that is not listed to UL 9540
4 STANDARDS-DRIVEN ESS
and can require safety modifications (retrofits) to be made.
DESIGN AND INSTALLATION
Some specific requirements that may be waived include:
4.1 Overview • Maximum stored energy (see Section 4.4)
Figure 3 indicates compliance requirements for a typical
• Size and separation of ESS groups (see Section 4.4)
ESS project. Fire codes require that the ESS be listed to UL
• Fire control and suppression systems for remote instal-
9540, which in turn requires that the subsystems be quali-
lations (see Section 4.7)
fied to their relevant standards as indicated in Section 3.4.
Most battery systems are also required to undergo fire and • Permanent source of water for firefighting (see
explosion testing to UL 9540A as described in Section 3.5. Section 4.7)
The overall installation is governed by the electrical and
fire codes as discussed in Sections 3.2 and 3.3, respectively,
and interconnection requirements are set by IEEE Std 1547
at the distribution level or IEEE Std 2800 for transmission-
connected facilities.

Figure 3. Codes and standards compliance for a typical ESS project

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7 | EPRI White Paper November 2023
4.3 Location 4.6 Explosion Control
NFPA 855 classifies ESS locations as follows: Explosions represent the greatest danger to first responders
• Indoor, ESS dedicated-use building in an ESS incident. As was stated in Section 3.3, NFPA 855
requires either explosion prevention (NFPA 69) or deflagra-
• Indoor, Non-dedicated-use building
tion venting (NFPA 68). There is increasing consensus that
• Outdoor, 100 ft. or less from exposures
designs relying only on deflagration venting can present
• Outdoor (remote), more than 100 ft. from exposures a serious risk to personnel. If multiple cells vent without
There are some additional outdoor classifications, including flame, gas levels within the enclosure can accumulate
rooftops, parking garages, and mobile installations, which above the UFL, where no combustion is possible. This con-
are not discussed in this document. dition can remain completely stable until firefighters open
a door, when oxygen from the outside air will mix with the
Regulation of these facilities is the least stringent for out-
vent gas and an explosion could occur.
door remote installations and for dedicated-use buildings
located more than 100 ft from exposures, and the most System designers are increasingly implementing explosion-
stringent for non-dedicated-use indoor installations. prevention strategies. In many cases, ventilation panels are
opened automatically when vent gas is detected, and fans
4.4 Size and Separation are actuated to draw in outside air to achieve rapid dilution
NFPA 855 includes limits for maximum stored energy, en- of the gas mixture. Such designs are not without chal-
ergy per group, and separation between groups. For Li ion lenges since panel opening must be fail-safe and fans must
batteries, the maximum energy is 600 kWh and groups are be securely powered for at least two hours. Furthermore,
limited to 50 kWh. Groups are required to be separated by with the trend to large LFP cells (280 ampere-hours is now
3 ft. from each other and from walls (except from walls of a standard size, and some are producing larger cells), and
outdoor units). These limitations may be exceeded subject the trend to energy-dense enclosure designs, the volume
to AHJ approval (see Section 4.2). Remote outdoor units of flammable gases relative to the free air volume in the
or dedicated-use buildings that are more than 100 ft. from enclosure may make it impossible to meet the requirement
exposures are not subject to these limitations. of NFPA 69 to maintain combustible concentration at or
below 25% of the lower flammability limit (LFL) (or at or
4.5 Smoke, Fire, and Gas Detection below 60% of the LFL where continuously monitored and
NFPA 855 requires ESS to be equipped with a smoke detec-
controlled with safety interlocks).
tion or radiant energy-sensing system. Additional guidance
is provided in informative Annex G, where speed of sensing While the vent gas from all Li ion cells contains a substantial
is emphasized, due to the short time in which Li ion safety amount of hydrogen, the mixture of different flammable
events can develop. Early detection of an incident can be ac- constituents and the diluting effect of carbon dioxide raises
complished by detecting vent gases, including carbon monox- the LFL above that of hydrogen alone. One study18 esti-
ide, carbon dioxide, hydrogen, and flammable hydrocarbons. mates the LFL of vent gas from NMC cells to be between
7.6% and 9.0%, and from LFP cells to be between 8.6% and
Where gas detection is used to activate a combustible gas
10.0%. Sturk et al 19 provided a figure for total gas volume
concentration reduction system (for compliance with NFPA
from LFP cells of 42 L/kg, so a 280 Ah cell weighing ap-
69 as discussed in Section 4.6), the detectors must be se-
proximately 5.4 kg might produce 227 L of vented gas. For
curely powered in standby mode for a minimum of 24 hours,
the lower end of the estimated LFL range, 25% of the LFL
followed by 2 hours in alarm.

18 A. Baird, E. Archibald, K. Marr, O. Ezekoye, “Explosion hazards from

lithium-ion battery vent gas,” Journal of Power Sources, Volume 446,
2020, 227257, ISSN 0378-7753, https://doi.org/10.1016/j.jpow-
sour.2019.227257.
19 D. Sturk, L. Rosell, P. Blomqvist, A. Ahlberg Tidblad, “Analysis of Li ion
Battery Gases Vented in an Inert Atmosphere Thermal Test Chamber,”
Batteries 2019, 5(3), 61; https://doi.org/10.3390/batteries5030061.

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is 2.2%, so assuming perfect mixing, the free air volume again, there is no explicit statement regarding non-walk-in
would have to be greater than about 10,500 L to comply battery enclosures. It is expected that this ambiguity will
with NFPA 69. Of course, the air volume around the gas be resolved in the next revision of NFPA 855, expected for
plume from the cell would exceed the LFL, but NFPA 69 release in 2026.
does not consider such dynamic effects.
In the early days of Li ion deployments, all ESS Li ion battery
If compliance with NFPA 69 is not possible and an NFPA systems were equipped with FSS. Over the years, it became
68-only solution is too risky, an acceptable compromise more widely recognized that extinguishing a fire without
would be a combination approach, with ventilation panels being certain to stop ongoing exothermic reactions and
opening to allow vent gases to be exhausted, plus deflagra- potential propagation could create an explosion risk. The
tion panels for additional protection in case an explosion risk of ongoing reactions can be seen in the numerous inci-
occurs before the gas has sufficiently dissipated. While gas dents with EVs, where firefighters use tens of thousands of
exhaust can be accomplished more quickly with fans, the gallons of water to extinguish a fire, only to have it reignite
combination approach may not require secure powering, hours, days, or even weeks later.
thus simplifying the design. This hybrid approach is allow-
This realization has driven a new ‘let it burn’ philosophy, in
able under fire codes and has been adopted in some recent
which an ESS battery fire is allowed to burn out in a con-
ESS designs. The deflagration panels would meet the NFPA
trolled manner while protecting adjacent exposures. This
68 alternative, thus complying with the letter of the code,
philosophy has several advantages:
while the ventilation will (eventually) provide explosion
prevention for better firefighter safety. • Issues with stranded energy and reignition are avoided.
• Flammable gases are consumed as they are released,
At least one ESS integrator has adopted an approach in
eliminating the risk of explosion.
which a sparking device is used to ignite vent gases before
• By not using firefighting water on the fire itself,
they can reach an explosive level. This can be an effective
contaminated run-off is avoided.
strategy if oxygen supply is sufficient to support ongoing
However, allowing BESS fires to burn out results in a com-
combustion. Combustion initiated by the sparking device
bustion plume that will travel downwind until it disperses.
necessarily means that the gas concentration has exceeded
This may result in temporary shelter-in-place or evacuation
the LFL, so this device must be implemented as part of
advisories for the local community. While laboratory testing
a hybrid approach, either with a ventilation system that
identifies toxic compounds that are released by burning Li
would meet NFPA 69 in most circumstances, or deflagration
ion batteries, these may be consumed internally, combust-
venting in accordance with NFPA 68.
ed, or may react to form other non‐toxic compounds before
Ventilation and deflagration panels should be located on being released to the environment. In recent events where
the roof of the battery enclosure and should direct flames batteries have burned in this fashion, fire services have an-
away from personnel standing in front of the unit. Where nounced that nearby air-quality monitoring has shown the
ventilation panels must be mounted on the sides of en- air quality to be at safe levels.
closure, they should be as high as possible and fitted with
Consuming flammable gases requires a supply of oxygen,
deflectors to protect nearby personnel.
so this approach is compatible with the ventilation strategy
4.7 Firefighting Philosophy for explosion control described in Section 4.6. Adoption of
NFPA 855 mandates fire control and suppression for ‘build- this firefighting philosophy has spurred a move to smaller,
ings’ and ‘outdoor walk-in units.’ The requirement appears modular enclosures that can be shipped fully assembled,
not to apply to outdoor enclosures that cannot be entered, which minimizes installation costs and allows fire losses
but such units are not explicitly exempted. There is a provi- to be reduced. An important aspect of the design of these
sion for fire suppression systems (FSS) to be omitted from systems is substantial insulation that allows enclosures
ESS in remote locations, subject to approval by the AHJ, but to be closely spaced while preventing propagation of fire
between units.

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As discussed in Section 3.7, there is a proposal to modify moving an energy storage system from service that has been
NFPA 855 to prohibit the use of clean agent or aerosol fire damaged by a fire or other event’ (emphasis added). This
suppression systems unless UL 9540A testing can demon- planning for removal of a damaged ESS unit, with updates as
strate that use of such systems does not present a deflagra- needed to accommodate new technologies and techniques
tion hazard. This proposal, if adopted, is consistent with the for handling and recycling, would be a prudent addition to
‘let it burn’ strategy. the decommissioning plan for a facility in any jurisdiction.

Another NFPA 855 requirement, which may be waived by

5.2 Transportation Considerations
the AHJ for remote locations, is for a permanent source of
Under the Environmental Protection Agency’s Standards for
water for fire protection. Under the ‘let it burn’ strategy,
Universal Waste Management (40 CFR part 273), end-of-
water would be used only for defensive measures to pro-
life batteries are subject to the same level of regulation as
tect nearby exposures.
other hazardous wastes, and must meet the Department of
Transportation’s regulations for hazardous material pack-
4.8 Pre-Incident Planning
aging and transportation. Enclosures that were shipped
NFPA 855 requires an emergency operation plan to be
factory-assembled are already certified for transport, sub-
established, also frequently referred to as an emergency
ject to any special preparation advised by the manufacturer.
response plan (ERP). There are several requirements for the
ESS units in larger containers or other systems that were
ERP, including safe shutdown and isolation of equipment,
assembled on site would have to be disassembled, with
procedures to be followed in case of fire or explosion, and
cell modules transported in approved packaging. Damaged,
contact information for subject matter experts. An impor-
defective, or recalled modules do not meet the hazardous
tant aspect is the ability of first responders to access BMS
waste exemptions of 40 CFR part 273, so additional report-
data, either directly or through a network operations cen-
ing requirements may apply.20 Packaging and transport
ter, so that battery temperature in units adjacent to a fire
requirements for these modules are also more extensive
can be monitored for possible defensive operations.
than for undamaged modules. Packaging may be subject to
Another NFPA 855 requirement is for initial and annual DOT Special Permit requirements, and damaged modules
refresher training for facility staff and first responders. It is are strictly prohibited for transportation by aircraft.21
important to include local firefighters in this training, since
they must be comfortable with firefighting procedures, 5.3 Decommissioning Safety
particularly the ‘let it burn’ strategy. Training firefighters on The decommissioning plan should address all aspects of
site has the added advantage of making them familiar with safety, including preparation for shipment and consider-
site access and equipment layout, allowing them to respond ations for personnel and environmental safety. The battery
more efficiently to an incident. system should generally be discharged to 30% state of
charge (SOC) or below. This provides for safer transporta-
5 DECOMMISSIONING tion, and a SOC above 30% triggers more stringent require-
This section considers the relevant codes and standards and ments for storage under NFPA 855. A consideration for the
safety considerations for ESS decommissioning. Recycling depth of discharge is whether the battery is destined for
and/or disposal are beyond the scope of this document. possible reapplication or recycling. A battery intended for
reapplication should be shipped as close to 30% SOC as pos-
5.1 Decommissioning Plan sible to allow for longer storage periods, while one that will
Both the IFC and NFPA 1 require a written decommissioning be recycled can be discharged to lower (and safer) levels.
plan to be prepared and submitted to the AHJ as part of the
commissioning plan. Section 1207.2.1 of the IFC requires 20 EPA Guidance on Lithium Battery Recycling. May 24, 2023.
the plan to include ‘contingencies for removing an intact https://rcrapublic.epa.gov/files/14957.pdf.
21 Lithium Battery Guide for Shippers. U.S. Department of Transporta-
operational energy storage system from service, and for re- tion. Updated July 6, 2023. https://www.phmsa.dot.gov/training/
hazmat/lithium-battery-guide-shippers.

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10 | EPRI White Paper November 2023
Provisions should be made for powering safety subsystems, batteries, using the ‘bowtie’ approach. ESIC participants are
such as heat, smoke, and gas monitoring, while the decom- currently developing a generic flow-battery HMA.
missioning work is in progress. Since activities may involve
An example of this issue can be seen with valve-regulated
work on battery terminals, procedures should outline steps
lead-acid (VRLA) batteries. VRLA products can experience
for disconnecting and sectionalizing the battery to minimize
their own form of thermal runaway (now sometimes called
arc flash and shock hazards.
thermal walkaway, to distinguish it from the more severe
version with Li ion), in which toxic hydrogen sulfide gas can
6 ASSESSING THE HAZARDS AND
be released. Two factors differentiate VRLA thermal run-
SAFETY MANAGEMENT OF NEW
away from Li ion: first, the heat released is derived from the
TECHNOLOGIES
charger, and the event can be stopped by attenuating the
6.1 Evaluating Emerging Technologies charger output; and second, VRLA batteries become more
As the ESS market expands and the demand for long-dura- susceptible to thermal runaway as they age. If VRLA prod-
tion energy storage grows, it is inevitable that new battery ucts were to be introduced as a new technology today, test-
technologies and other non-battery systems will be offered, ing to UL standards would not address this failure mode,
often with rosy predictions for low cost, improved safety, or since the batteries are not aged before testing, nor are they
other characteristics. It is important for prospective users connected to a charger during thermal runaway testing.
of these systems to understand their aging mechanisms
Another example is Sodium ion (Na-ion). The technology is
and failure modes so that possible hazards and appropri-
expected to be widely deployed in the ESS market. News
ate safety management can be assessed. A framework for
articles have been enthusiastic about the safety of Na-ion,23
this assessment is provided by IEEE Std 1679, IEEE Recom-
going as far as to refer to them as nonflammable.24 It is im-
mended Practice for the Characterization and Evaluation
portant to understand that the term ‘Na-ion’ covers a wide
of Energy Storage Technologies in Stationary Applications.
range of electrochemistries,25 as does Li ion. Most emerging
Additional guidance is provided for certain classes of bat-
products have hard carbon anodes, while there are numer-
tery systems in a series of subsidiary documents. Published
ous materials used for cathodes. Many designs have electro-
guides are for lithium-based batteries (IEEE Std 1679.1),
lytes based on mixtures of organic carbonates, which have
sodium-beta batteries (IEEE Std 1679.2), and projects are
similar flammability characteristics to Li ion electrolytes. The
underway for flow batteries (P1679.3) and alkaline and zinc-
reference to Na-ion batteries being non-flammable is based
based technologies (P1679.4).
on use of ionic liquids, which have lower ionic conductiv-
There is a framework for covering new technologies in ity than conventional organic electrolytes and may not be
existing codes and standards. UL qualification standards are suitable for all applications. As with Li ion chemistry, Na-ion
intended to be as generic as possible, and listing requires cells with organic electrolytes form a solid-electrolyte
an FMEA to be performed and HMA to be submitted. That interphase (SEI) on the surface of the hard carbon anode,
said, the FMEA can only be as thorough as the developer’s and its breakdown can trigger thermal runaway. Indeed, the
understanding of the technology’s aging mechanisms and SEI in Na-ion cells becomes unstable at a lower temperature
failure modes. To the extent that those failure modes are than its Li ion counterpart, although the rate of heat release
different from those of Li ion or other existing battery types, is much lower.26 From the above information, the situation
new test methods may be needed to assess a system de-
sign’s tolerance to those failures. EPRI is actively involved in 23 M. Sawicki, L. Shaw, “Advances and challenges of sodium ion bat-
teries as post lithium ion batteries,” RSC Adv., 2015,5, 53129-53154,
this process through its Energy Storage Integration Council
https://doi.org/10.1039/C5RA08321D.
(ESIC), an industry-wide collaborative. Members of ESIC’s 24 Tech Brew, Sodium-based batteries could solve the lithium crunch.
25 Q. Abbas, M. Mirzaeian, & M. Hunt, (2020). “Materials for sodium-ion
Safety Task Force have developed the ESIC Energy Storage
batteries.” In Reference Module in Materials Science and Materials
Reference Fire Hazard Mitigation Analysis,22 based on Li ion Engineering Elsevier B.V., https://doi.org/10.1016/B978-0-12-803581-
8.12115-0.
26 D. Velumani and A. Bansal, “Thermal Behavior of Lithium- and
22 ESIC Energy Storage Reference Fire Hazard Mitigation Analysis. EPRI, Sodium-Ion Batteries: A Review on Heat Generation, Battery Degrada-
Palo Alto, CA: 2021. 3002023089. tion, Thermal Runway − Perspective and Future Directions,” Energy
Fuels 2022, 36, 14000−14029.

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11 | EPRI White Paper November 2023
with emerging Na-ion products is much more complex than IFC, International Fire Code
sweeping generalizations in news articles would indicate.
NFPA 1, Fire Code
Following the approach of IEEE Std 1679, details on aging
mechanisms, failure modes, and safety management should NFPA 68, Standard on Explosion Protection by Deflagration
be requested from the manufacturer for the product in Venting
question. It should not be assumed that the safety of one
NFPA 69, Standard on Explosion Prevention Systems
Na-ion product is the same as another.
NFPA 70, National Electrical Code
The failure modes of Na-ion batteries can be reasonably
predicted by their similarity with Li ion technology, and thus NFPA 70E, Standard for Electrical Safety in the Workplace
existing qualification and fire-testing standards should be
NFPA 855, Standard for the Installation of Stationary Energy
adequate to address the hazards of Na-ion battery failure.
Storage Systems
That said, other emerging battery technologies such as flow
batteries may exhibit unique failure modes and resulting UL 991, Standard for Tests for Safety-Related Controls Em-
hazards that may not be fully addressed. Codes and stan- ploying Solid-State Devices
dards organizations will have to remain vigilant and ready
UL 1973, Standard for Batteries for Use in Stationary and
to update these documents as needed.
Motive Auxiliary Power Applications
Revising qualification standards to reflect new failure
UL 1998, Standard for Software in Programmable Components
modes and new test methods will likely not occur until
some years after the first shipments of a new technology. UL 9540, Standard for Energy Storage Systems and Equipment
At the time of preparing this paper, the US Department UL 9540A, Test Method for Evaluating Thermal Runaway
of Energy’s Energy Storage Safety Strategic Plan is being Fire Propagation in Battery Energy Storage Systems
revised, and the safety of new technologies is a major topic
of discussion. It remains to be seen how this topic will be 8 ACRONYMS AND ABBREVIATIONS
addressed moving forward. The following is a list of acronyms and abbreviations used in
this report:
7 REFERENCES
The following is a listing of the codes and standards AHJ authority having jurisdiction
referred to in this document: ANSI American National Standards Institute
CSA/ANSI C22.2 No. 340:23, Battery Management Systems BESS battery energy storage system
IEEE Std 1547, IEEE Standard for Interconnection and In- BMS battery management system
teroperability of Distributed Energy Resources with Associ-
ated Electric Power Systems Interfaces CFR Code of Federal Regulations

IEEE Std 1547.9, IEEE Guide for Using IEEE Std 1547 for CSA Canadian Standards Association
Interconnection of Energy Storage Distributed Energy ERP emergency response plan (emergency operations
Resources with Electric Power Systems plan)
IEEE Std 1679, IEEE Recommended Practice for the Charac- ESIC Energy Storage Integration Council
terization and Evaluation of Energy Storage Technologies in
Stationary Applications ESMS energy storage management system

IEEE Std 2800, IEEE Standard for Interconnection and ESS energy storage system
Interoperability of Inverter-Based Resources (IBRs) Inter- EV electric vehicle
connecting with Associated Transmission Electric Power
Systems FSS fire suppression system

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12 | EPRI White Paper November 2023
HMA hazard mitigation analysis 9 ACKNOWLEDGMENTS
IEEE Institute of Electrical and Electronics Engineers The following organization, under contract to EPRI,
prepared this report:
LEL lower explosive limit
McDowall Advisors LLC
LFL lower flammable limit Phone: 203.435.2546
LFP lithium iron phosphate (cathode material) Email: [email protected]

Li ion lithium ion Principal Investigator

Jim McDowall
Na-ion sodium-ion

NCA lithium nickel-cobalt-aluminum oxide (cathode

material)

NEC National Electrical Code (NFPA 70)

NESC National Electrical Safety Code (IEEE C2)

NFPA National Fire Protection Association

NMC lithium nickel-manganese-cobalt oxide (cathode

material)

PCS power conversion system

PPE personal protective equipment

SEI solid-electrolyte interphase

SOC state of charge

UFL upper flammable limit

UL Underwriters Laboratories

VRLA valve-regulated lead-acid

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13 | EPRI White Paper November 2023
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