An emergency response plan (ERP) is intended to provide guidance to personnel and responders on how to proceed safely and effectively in the case of a fire or events leading up to it.
Emergency response is a critical facet of battery energy storage system (BESS) safety, particularly with respect to systems relying on lithium-ion chemistries, which have an inherent fire risk. It is the responsibility of the BESS project owner to ensure that appropriate safeguards and procedures are in place to minimize the risk of fire and its impact to human life, property, and the environment. As such, first and foremost, the safety of all BESS site personnel and local first responders needs to be ensured. An emergency response plan (ERP) is intended to provide guidance to personnel and responders on how to proceed safely and effectively in the case of a fire or events leading up to it.
With the release of National Fire Protection Association (NPFA) 855 “Standard for the Installation of Stationary Energy Storage Systems” in 2020, authorities having jurisdiction (AHJs) and offtakers are actively seeking to align with the guidelines therein. NFPA 855 requires an ERP for BESS installations. Consequently, submission of an ERP is increasingly becoming a requirement of the BESS project permitting process. The Alberta Utility Commission in Canada, for example, in its AUC Rule 007 (BF16-18) recently included the following requirements for grid-connected energy storage applications:
- confirm that it has or will have a corporate or site-specific ERP for the construction and operation of the proposed battery facility—and if it is a corporate response plan, why it decided not to develop a site-specific one
- summarize the site-specific risks (in construction and operations) that have been identified to date, the emergency mitigation measures that have been identified, and the site monitoring and communication protocols that will be put into place
- confirm that local responders and authorities have been contacted or notified regarding the ERP, describe requirements or feedback received, and how the applicant intends to address those matters.
To some degree, this planning requirement is the same as those required for other, non-battery technologies, but Li-ion battery technologies must account for such technology-specific issues as thermal runaway and managing off-gas. New York State was a pioneer in researching lithium battery safety standards. For example, the New York State Energy Research and Development Authority (NYSERDA) has created the Battery Energy Storage System Guidebook for local governments—the document lays out the requirements for an emergency operations plan.
In addition, there are several other industry standards and guidelines that have been developed to address the need for emergency planning and response. One notable standard is NFPA 1620, regarding pre-incident planning. However, NFPA is carrying out an Emergency Response and Responder Safety Consolidation Project that will incorporate NFPA 1620 with NFPA 1600 and 1616 to create a new consolidated standard NFPA 1660. The new consolidated standard will address community risk assessment, pre-incident planning, mass evacuation, sheltering, and re-entry programs.
The consolidation plan for those Emergency Response & Responder Safety (ERRS) standards pertains to all NFPA ERRS standards, including various guides and best practices. The goal of consolidation, to be finalized in 2025, is to improve the ERRS standards development process. The consolidation effort focuses on standards that address operational concerns, professional qualifications for responders, and personal protective equipment. This effort will help owners and developers of BESS avoid conflicting information from one standard to the next, thereby making planning more efficient and effective.
In 2018, the U.S.-based Energy Storage Association (ESA), with input from DNV and other industry experts, began to develop an Energy Storage Corporate Responsibility Initiative (CRI), which launched in March 2019. The purpose was to get industry leaders to sign a pledge “to engage in a good-faith effort to optimize performance, minimize risk and serve as an exemplary corporate citizen in the manufacturing, deployment, implementation and operation of energy storage projects across the United States.” As of August 2020, 57 companies in the energy storage industry (including DNV) are signatories to the pledge. Under the CRI, ESA and the signatories created an example ERP, a resource that site owners and operators could borrow from as they develop robust response plans to suit the specifics of their own sites. This document is intended to be adapted as needed to be appropriate to the conditions, environment, staffing, structure, technologies, and setup of a given site.
With increasing regulatory requirements and changing standards, BESS owners and operators need to focus on their site-specific ERPs, either developing or retooling them. DNV can help. As the leading energy storage advisory firm, DNV performs fire safety testing and develops protocols across battery types and brands, and can provide third-party assurance that your ERP is designed to mitigate the greatest risk for your BESS to keep your operations safe and compliant.