HomeMy WebLinkAbout11 Draft BESS Emergency Response Plan_052626 n e>4.ea m p
Jerry Smith Energy
Storage System
Emergency Response Plan
Table of Contents
Tableof Contents..........................................................................................................................................2
1 Introduction............................................................................................................................................4
1.1 Scope and Purpose.....................................................................................................................4
1.2 Timeframe....................................................................................................................................4
1.3 Activation .....................................................................................................................................4
1.4 Agency Jurisdiction......................................................................................................................4
1.5 Operations and Maintenance (O&M)...........................................................................................4
1.6 ERP Update Process...................................................................................................................4
2 Definitions and Acronyms .....................................................................................................................5
2.1 Definitions....................................................................................................................................5
2.2 Acronyms.....................................................................................................................................6
3 General Site Information .......................................................................................................................9
3.1 Owner/Operator Information........................................................................................................9
3.2 Site Overview...............................................................................................................................9
3.3 Site Design...................................................................................................................................9
3.4 Fire Department Access and Staging Area...............................................................................11
3.5 Site Security Perimeter..............................................................................................................11
3.6 Site Access................................................................................................................................11
3.7 Equipment access .....................................................................................................................11
3.8 Water supply..............................................................................................................................12
3.9 Lock Box Access .......................................................................................................................12
3.10 Nearby Exposures.....................................................................................................................12
3.11 Site Maintenance.......................................................................................................................12
3.12 BESS Product Information.........................................................................................................12
3.12.1 BESS Product Features........................................................................................................13
3.12.1.1 Battery Management System (BMS).....................................................................................13
3.12.1.2 Customer Interface Bay.........................................................................................................13
3.12.1.3 Thermal Management System ..............................................................................................14
3.12.1.4 Site Controller and Monitoring...............................................................................................14
3.12.1.5 Electrical Fault Protection Devices........................................................................................14
3.13 Fire Protection Systems.............................................................................................................15
3.13.1.1 Explosion Control System.....................................................................................................15
3.14 Emergency Shutoffs ..................................................................................................................16
3.15 Fire Detection ............................................................................................................................16
3.15.1.1 UL 9540A Thermal Runaway Test Data ...............................................................................16
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3.16 Emergency Contacts .................................................................................................................18
3.17 Fire Responder Contact Information .........................................................................................18
3.18 Other Contact Information .........................................................................................................18
3.19 Roles and Responsibilities.........................................................................................................19
4 Battery Management System (BMS) ..................................................................................................23
4.1 Alarm Matrix...............................................................................................................................23
5 Hazards...............................................................................................................................................25
5.1 Thermal runaway.......................................................................................................................25
5.2 Fire and Re-ignition ...................................................................................................................26
5.3 Explosion ...................................................................................................................................26
5.4 Electrical Shock.........................................................................................................................27
5.5 Arc Flash....................................................................................................................................27
5.6 Toxic Smoke and Gas Emission................................................................................................27
5.7 Additional Hazards and Considerations ....................................................................................28
6 Notification Matrix................................................................................................................................28
7 Emergency Response Considerations................................................................................................28
7.1 Emergency Contacts .................................................................................................................28
7.2 Equipment and Personnel Protective Equipment(PPE)...........................................................28
7.3 APIE (Analyze, Plan, Implement, and Evaluate) Framework....................................................28
7.4 Scene Size-up—Command and Control...................................................................................29
7.5 Determine Fire Protection Approach .........................................................................................30
7.6 Incident Monitoring and Evaluation ...........................................................................................30
8 Response Tactics................................................................................................................................30
8.1 Explosion Incident......................................................................................................................30
8.2 Fire Incident...............................................................................................................................31
8.3 Thermal Runaway or Off-Gassing Incident ...............................................................................32
8.4 Alarm Incident............................................................................................................................33
8.5 External Fire/Thermal Exposure Incident................................................................................33
8.6 External Impact Incident............................................................................................................33
9 Post Incident Operations.....................................................................................................................33
10 Training and Exercises........................................................................................................................33
11 Revision Tracking................................................................................................................................35
Disclaimer: This drafted Emergency Response Plan (ERP) is provided for information and guidance
purposes only and establishes a suggested format.
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The ERP requires regular updates with sufficient detail to enable personnel to implement necessary
emergency procedures without question or delay to ensure the continuity of operations.
Introduction
1 .1 Scope and Purpose
This Emergency Response Plan (ERP)or Emergency Operations Plan (EOP) has been developed
for the Jerry Smith Battery Energy Storage System (BESS) located at 339 Jerry Smith Rd.,
Lansing, NY 14882. The purpose of this document is to provide guidance and pertinent information
regarding the roles, responsibilities, and chain of communication and command of the System
Owner/Operator, Property Owner, Emergency Responders, and other required Subject Matter
Experts (SMEs)for preparing for, and safely responding to, a fire, explosion, or other battery-
related incident requiring a public safety response at the energy storage facility.
The Operations and Maintenance (O&M) Manager for the project is an employee of Nexamp. "On-
site personnel' include all individuals on the facility property who are direct employees of the
Owner/Operator or affiliated contractors. The Owner/Operator and contractors are similarly
responsible for establishing and maintaining contractor-specific Emergency Management Plans
and reporting procedures that will work in conjunction with the overall energy storage facility plan.
Life safety shall be the highest priority during any event type associated with this energy
storage facility.
1 .2 Timeframe
This ERP covers the timeframe beginning at the final approval of the Lansing Fire Department to
the beginning of decommissioning and removal of the energy storage system.
1 .3 Activation
This ERP shall be activated during any emergency response to energy storage facility-related
incident on site.
1 .4 Agency Jurisdiction
This plan has been strictly developed for the Lansing Fire Department and does not cover multi-
agency response.
1 .5 Operations and Maintenance (O&M)
Operations and maintenance procedures for the energy storage facility and associated equipment
are outside the scope of this document. Procedures for inspection and testing of associated
alarms, interlocks, and controls are provided in the O&M plan.
Please refer to manufacturer Operations and Maintenance (O&M) manuals for all associated
equipment and protocols related to the site prior to beginning any maintenance work on this
facility.
1 .6 ERP Update Process
Dates for draft issuance, revisions and final issuance of this ERP are provided in Section 11 of the
document.
A review of this emergency response plan shall be conducted and documented:
• at minimum on an annual basis; or
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• if there is a change in design, construction, operation, or maintenance that affects
emergency response planning.
Ensure all relevant stakeholders receive a complete copy of this Emergency Response Plan.
Plan retirement will coincide with decommissioning of the facility. All decommissioning procedures
shall be performed by trained and knowledgeable persons in alignment with the Decommissioning
Plan provided for this installation. Decommissioning shall be performed under the supervision of
the System Owner/Operator and manufacturer.
2 Definitions and Acronyms
2.1 Definitions
Approved—Acceptable to the authority having jurisdiction
Battery—A single cell or a group of cells connected electrically in series, in parallel, or a combination of
both.
Battery cell -The basic electrochemical unit, characterized by an anode and a cathode, used to receive,
store, and deliver electrical energy.
Battery management system (BMS) -A system that monitors and controls performance of an energy
storage system and can have the ability to disconnect the energy storage unit from the system in the
event abnormal or hazardous conditions are detected.
Battery module—A subset of battery cells, connected in series, parallel, or a combination of both, with
some amount of monitoring and passive disconnect capabilities
Battery rack—A subset of interconnected modules, typically in series, which typically includes
switchgear, BMS, and active disconnect capabilities
Certifications— In this context, certifications address primarily Underwriters Laboratory standards,
including UL (Underwriters Laboratories) 1642, UL 1973, UL 1741, and UL 9540. Also, UL 9540A testing
will be included in this context.
Deflagration—Combustion event which propagates through explosive gases released by batteries
during abnormal failure events at subsonic speeds. In this context, deflagration risk may be managed
through a variety of mitigative measures, such as vent design, exhaust, or suppression systems.
Electrical Event- Internal short circuit due to internal cell defects, overvoltage charging or a defect on
internal resistance.
Energy storage system - One or more devices, assembled, capable of storing energy to supply
electrical energy at a future time. Battery energy storages system is called a BESS (Battery Energy
Storage System).
Energy Storage Management System (ESMS) -A system that monitors, controls, and optimizes the
performance of an energy storage system and can control the disconnection of the energy storage
system in the event of abnormal conditions.
Fire Command Center-The principal attended or unattended room or area where the status of the
detection, alarm communications, control systems, and other emergency systems is displayed and from
which the system(s) can be manually controlled.
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Incident Action Plan (IAP) — IAP formally documents incident goals/control objectives, operation period
objectives, and the response strategy defined by incident command during response planning.
Inverter—A piece of electrical equipment which converts DC (Direct Current) energy of the batteries into
AC (Alternating Current) energy of the grid and vice versa
Monitoring Company—alerted in the event of activation of Nexamp' s aspirating smoke detection (ASD)
system.
Mechanical Failures - Physical damage to a cell which may have occurred during the manufacturing or
installation process, as well as damage caused by vibration or expansion.
Off-gassing—Gases released by batteries during abnormal events prior to thermal runaway
Subject matter expert (SME)—One or more parties who have skills and knowledge related to the
operation of the electrical equipment and installations and has received safety training to recognize and
avoid the hazards involved. These parties will be responsible for communication during failures with
facility personnel, system operators, and emergency personnel. The SME will be qualified in workplace
and electrical safety in local jurisdiction of the system.
Thermal Event-A chemical process where self-heating in a battery exceeds the rate of cooling causing
high internal temperatures, melting, off-gassing/venting, and in some cases, fire, or explosion. Thermal,
mechanical, and electrical abuse can lead to thermal runaway; internal short circuit from manufacturing
defects; or the development of metallic dendrites that form an internal short over time. Lithium-ion
batteries undergoing thermal runaway can vent their internal contents in the form of gas. Without proper
ventilation a combination of gases can build up in an enclosed space. The Lower Explosive Limit(LEL)
for this mixture can vary. Oxygen starvation fire suppression in lithium-ion battery systems is not
recommended. Smoke can be toxic and smoke from batteries is no exception. Use of a positive pressure
breathing apparatus is recommended whenever responding to battery system fires.
Thermal runaway -The condition when an electrochemical cell increases its temperature through self-
heating in an uncontrollable fashion and progresses when the cell's heat generation is at a higher rate
than can dissipate leading to fire, explosion, and gassing.
2.2 Acronyms
Abbreviation Description
Acronym
AR Arc-Rated
BESS/ESS Battery Energy Storage System—the complete facility including bidirectional inverter(s),step-
up transformer(s), protection devices, HVAC system(s)and control systems.
BMS Battery Management System—the electronic control system that manages the battery
installation, maintaining operation within safe limits and monitoring and reporting status to the
PPC (Power Plant Controller).
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Abbreviation Description
Acronym
DAS Data Acquisition System (synonymous with SCADA)
E-Stop/EPO Emergency Stop/ Emergency Power Off
ERP Emergency Response Plan
EMS Energy Management System—The system running the PPC and providing an HMI
for the user interface
FACP Fire Alarm Control Panel
FDC Fire Department Connection
FSS Fire Suppression System
HVAC Heating,Ventilation,Air Conditioning system
IC Incident Commander
ICS Incident Command System
kW Kilowatt(s)
kWh Kilowatt-hour(s)
LFL/LEL Lower Flammability Limit/ Lower Explosive Limit
MW Megawatt(s)
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Abbreviation
Acronym
MWh Megawatt-hour(s)
O&M Operations and Maintenance
SCBA Self-Contained Breathing Apparatus
SDS Safety Data Sheets—a document that contains information on the potential hazards(health,
fire, reactivity and environmental)and how to work safely with the chemical product.
PCs Power Conversion System—Includes bidirectional inverter and integrated control system
PPC Power Plant Controller—The main BESS computer that provides user interaction for all
available systems via the EMS HMI.
SCADA Supervisory Control and Data Acquisition—Control system architecture that provides an
interface for monitoring and issuing commands to the BESS via the RTUs (Remote
Telemetry Unit).
SME Subject Matter Expert
SOC State of Charge—The percent level of charge of the batteries relative to their capacity.
SOH State of Health—The percent merit of condition of the batteries relative to ideal conditions.
Will decrease overtime with use.
UICS Unified Incident Command System
UFL/ UEL Upper Flammability Limit/Upper Explosive Limit
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3 General Site Information
3.1 Owner/Operator Information
The owner of the BESS is Jerry Smith Storage, which is an LLC of Nexamp. The Operator of the
BESS is Nexamp. Nexamp is a vertically integrated Independent Power Producer(IPP) based in
Boston that has constructed, owns, and operates 200+ MWh of energy storage across
Massachusetts and New York. Nexamp also operates over a 1GW of solar across the United
States, and continues to develop and construct a multi-GW pipeline of energy storage and solar
projects across the U.S.
More information about Nexamp can be found here: https://www.nexamp.com/
3.2 Site Overview
The Jerry Smith Energy Storage facility is located at 339 Jerry Smith Rd., Lansing, NY 14882. The
Jerry Smith Energy Storage facility consists of Six (6) Megapack 2XL with a nameplate capacity of
979.2 kW/3,916.8 kWh (4-hour duration). Four(4) Megapack 2XL are rated at 850 kW/ 3,916.8
kWh and Two (2) Megapack 2XL are rated at 800 kW/3,916.8 kWh for a total operating BESS
capacity of 5,000 kW/23,500.8 kWh.
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Figure 1 Site Layout
3.3 Site Design
The BESS is located toward the center portion of the property, slightly to the east, as shown in
Figure 2. The BESS is southwest and connected to an access road that provides fire apparatus
access.
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Figure 2 BESS Location-zoomed out
The BESS is connected to an access road that provides fire apparatus access as seen below in
Figure 3.
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Figure 3 BESS Layout-zoomed in
In the event of an emergency, all site personnel, visitors, Nexamp, and emergency response
personnel (including the fire department) should remain outside the 1 ON radius seen below. In
the event of an emergency, the neighboring property owners should be notified of the event and
provided updates throughout the duration of the event.
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— --- -----------
Figure 4- 100 ft radius
Electrical equipment including metering enclosures, transformers, Data Acquisitions System
cabinets are located within the BESS area, with at least a 10 ft setback between the BESS unit,
the equipment, and the access road.
The BESS enclosure is installed on a concrete pad, elevated above the flood plain with the
surrounding area noted as gravel. The gravel will extend to the access road and between the
BESS area.
3.4 Fire Department Access and Staging Area
An entrance point is located on the northeast end of the property. Staging areas are recommended
to be conducted on the access road just at the entrance gate of the site facility outside the 100ft
radius. Staging areas should be based on the IC and their initial size-up. The staging area is
not finalized and will be decided upon by the Fire Department in future discussions with Nexamp.
The Fire Department should not attempt to enter the site fence line unless there is a clear
threat to life safety.
Figure 5 Fire Department Access and Staging Area— To be Updated
3.5 Site Security Perimeter
The site is enclosed with a locked gate as the primary entrance to the facility and is surrounded by
a fence. The BESS units are each individually locked. As noted above, the Fire Department should
not attempt to enter the BESS area unless there is a clear threat to life safety.
3.6 Site Access
The site is enclosed within protective steel fencing with a 10-ft gated entrance located at the
northern side of the site. As noted above, the Fire Department should not attempt to enter the site
fence unless there is a clear threat to life safety.
3.7 33Equipment access
The Tesla Megapack enclosures are only accessible for maintenance purposes via cabinet-style
enclosure doors and cannot be physically entered by personnel at any time.
The Fire Department should not attempt to open the enclosure doors at any time.
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3.8 Water supply
Primary water source to be confirmed with Fire Department.
3.9 Lock Box Access
A lock box openable by a standard key (Fire Department approved) containing a physical copy of
the EPRP, operational permits, O&M logs, product manuals, etc., is provided at the site entrance
shown in Figure 3.
3.10 Nearby Exposures
The following nearby exposures are in the immediate area, as shown in Figure 1 above.
1. Residences to the North and Northwest
a. Location: —300- 600 ft from BESS
b. Construction: To be identified
2. Existing PV Array to the East, South, and West
a. Location: —50- 500 ft from BESS (portion to the West closest section of PV array)
b. Construction: Steel and PV modules
3.11 Site Maintenance
The facility's interior access roads shall be maintained to guarantee accessibility to the site by
emergency personnel, especially during inclement weather. Nexamp shall ensure snow removal,
landscaping, and other ongoing upkeep activities are in place prior to construction.
3.12 BESS Product Information
The BESS Technology/Product incorporated into the design of this project is the Tesla Megapack
2XL (MP2XL). The Megapack 2XL is a pre-engineered and integrated energy storage unit that
utilizes Lithium-ion batteries to store and discharge power/energy. More specifically, the batteries
use lithium Iron Phosphate (LFP) battery cell chemistry where battery cells are configured into
battery modules, which are then integrated into battery racks that are housed in the
enclosure/container as shown in Figure 6. The Megapack 2XL is offered is various configurations
of varying power/energy capacities.
The MP2XL arrives at the site fully assembled needing just the alternate current (AC)connection
and communications cable to be connected on site. The MP2XL is approximately 28.9 ft in length,
5.4ft deep, and 9.2ft in height. The MP2XL is intended for outdoor installations, ground-mounted to
a foundation or base strong enough to support the weight of the equipment and anchor loads
(including concrete pads, grade beams, etc.). The thermal roof(part of the thermal management
system) is enclosed within an IP20 enclosure that sits above the battery module bays. The lithium-
ion batteries are housed inside an IP66 steel enclosure (battery module bay)that provides
protection against particles and water ingress.
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1. Individually fused battery modules(active and passive)-externally serviceable
2. Touch-safe Customer Interface Bay
3. Externally serviceable inverter bay
4. Non-walk-in IP66 enclosure,with internal and external thermal insulation and deflagration mitigation
5. Thermal roof with overpressure vents
Figure 4 Tesla Megapack 2XL Overview
Megapack 2XL is listed to the following standards by OSHA-recognized Nationally Recognized Testing
Laboratories:
• UL 1642 (cell-level certification)
• UL 1973 and IEC 62619 (battery module-level certification)
• UL 9540, IEC 62933-5-2, IEC 62109-1 (System-level certification)
• UL 1741, CSA C22.2 #107.1 (power electronics)
• UL 1998 and IEC 60730 Annex H (functional safety of software)
• IEC 61000-6-2, and EN 55011 (EMC)
• UN 38.3 (transportation, self-certified)
• IEEE 693 (seismic safety)
• UL 9540A(large-scale fire testing): Tested the cell, module, and unit level
The Megapack 2XL is designed to comply with major installation codes for energy storage systems,
including NFPA 855, IFC 2018 and 2021, and NEC 2020. The Megapack 2XL has been reviewed and
validated by an Independent Engineer, both at the product level and for the results of large-scale fire testing.
3.12.1 BESS Product Features
3.12.1 .1 Battery Management System (BMS)
See Section 4.
3.12.1 .2 Customer Interface Bay
The Customer Interface Bay (CIB) is a user-accessible area designed for operation and service.
The CIB includes the main AC breaker, a status panel and controller area network (CAN)
interface for service personnel, customer input/output (1/0)terminals, and the keylock switch (a
"Lock Out/Tag Out" switch), which shuts down the AC bus to permit MP2XL maintenance by
service personnel.
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3.12.1 .3 Thermal Management System
The thermal management system (TMS) provides suitable operating temperature for the MP2XL.
The thermal bay and thermal rood house the components of the TMS. The TMS contains a
closed-loop liquid cooling system that circulates a 50/50 mixture of ethylene glycol and water
throughout the battery modules and power electronics to maintain an optimum battery operating
temperature. The TMS works autonomously and does not require user feedback or controls to
turn the system on when needed or to adjust temperature settings. The thermal cabinet includes
pumps that circulate the liquid coolant through the MP2XL, an in-line heater that can warm the
coolant and a compressor that maintains control for the cabinet. The thermal roof, located above
the battery bays within its own IP20 enclosure, provides a ventilation airspace for the MP2XL. It
contains fans and radiators that cool the ethylene glycol-water resolution. Cool air enters the
thermal roof through the grates on the front of the MP2XL. The cool air then passes over the
radiators, absorbing heat, and then is exhausted out of the top of the thermal roof via fans.
3.12.1 .4 Site Controller and Monitoring
Beyond the built-in safeguards of the BMS described in Section 5, the MP2XL is supported by a
Tesla Local Operations Center(LOC). The MP2XL has 24/7 remote monitoring by Tesla's LOC,
but also Nexamp' s Network Operating Center(NOC) located in Lawrence, MA. The 24/7 remote
monitoring is accompanied by 24/7 diagnostics and troubleshooting capabilities, without needing
a technician on site. All faults are transmitted to the LOC and NOC, alerting Tesla and the
Operator abnormal conditions that may require corrective action, either through remote means or
an in-person field service. This communication link is accomplished via the Tesla Site Controller
(TSC). The TSC provides the single point of interface for the Utility, network operator, and/or the
System Owner/Operator's SCADA systems to control and monitor the entire energy storage
facility.
3.12.1 .5 Electrical Fault Protection Devices
The MP2XL has several passive and active safety control mechanisms installed within the battery
module circuit and distribution circuit that would be available to interrupt a fault condition. At a
high level, these electrical fault protection features include:
• Battery module overcurrent protection: The battery modules contain DC single-use
fusible links mounted directly on the battery modules. These fuses are one-time only use
safety devices that can interrupt the flow of an overcurrent in the battery module during
an off-normal electrical event.
• Inverter DC protection: The inverter modules, which are installed at each of the battery
modules, are equipped with a high-speed pyrotechnic fuse that can isolate the battery
module passively or actively during an off-normal event.
• Inverter AC protection: In addition, each inverter module is equipped with its own AC
contactor and AC fuses should an off-normal electrical event occur at the inverter module
on the AC side of the circuit.
• Ground fault protection: Finally, the MP2XL is also provided with a DC ground fault
detection system. It measures insulation resistance prior to operation and looks for
excessive leakage current during operation. Additionally, the MP2XL also contains an AC
circuit breaker, with ground-fault trip settings, which is installed within the CIB to provide
distribution system protection
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3.13 Fire Protection Systems
3.13.1 .1 Explosion Control System
The MP2XL includes an explosion control system to mitigate the risk of an uncontrolled
deflagration. The system includes pressure-sensitive vents (overpressure vents), and sparkers
installed throughout the battery module bay. The sparkers are designed to ignite flammable
gases exceedingly early in a thermal runaway event before they accumulate within the enclosure
and become an explosion hazard. They are installed at a variety of locations and heights
throughout the battery module bays to ensure the flammable gases released during thermal
runaway quickly meet an ignition source. Note, this explosion control system is the same
approach that Tesla has utilized in previous versions of the Megapack (Megapack 1 and
Megapack 2)and is not a new concept. It has been extensively validated through installation level
testing for these previous Megapack versions as well as the MP2XL and its performance has
been demonstrated in the field during thermal events involving Megapacks.
The overpressure vents are installed in the roof of the sealed battery bay's IP66 enclosure, as
shown in Figure 7. When activated, the overpressure vents open into the enclosed thermal roof,
ensuring that the release of the overpressure vents does not create a projectile hazard. In
addition, since they are installed in between the battery module bays and the thermal roof, the
overpressure vents are not exposed to the environment, which means they are protected from the
elements, such as falling tree limbs or snow, which could impact their functionality.
IP20 Thermal Roof
Overpressure
Vents
,'2' N
IP66 Battery Bay
Figure 5 MP2XL Overpressure vent overview
Once opened, the overpressure vents permit gases, products of combustion, and flames to safely
exhaust through the roof of the MP2XL during a thermal event. By designing this natural
ventilation flow path, flammable gases are not permitted to accumulate within the MP2XL cabinet,
reducing the risk of a deflagration or explosion that could compromise the cabinet's integrity, push
open the front doors, or expel projectiles from the cabinet. In addition, the ventilation path creates
a controlled fire condition, should one occur, out the top of the MP2XL cabinet. By maintaining the
MP2XL cabinet's integrity, keeping all the doors shut during a fire event, reducing the risk of
projectiles, and creating a controlled path for flames to exit the top of the MP2XL cabinet, the
likelihood of a thermal event having an impact on life safety, site personnel or first responders, is
reduced. In addition, by maintaining these features, the likelihood of a fire propagating to adjacent
MP2XL cabinets, electrical equipment, or other exposures is also reduced.
The overpressure vents themselves are passive and are not actuated or controlled by another
device. They are designed to release during an overpressure event, such as the rapid ignition of
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flammable gases by a sparker. The number and total area of overpressure vents were sized
following the guidance of NFPA 68 with a safety factor of two times the enclosure's strength,
including the front doors. Tesla developed the overpressure vents and sparker system because
the direct application of NFPA 68 or NFPA 69 is not suitable for the MP2XL cabinet, which does
not have large volumes of open-air space. This engineered approach is permitted by NFPA 855
§9.6.5.6.4 provided it is validated by installation-level fire and explosion testing and an
engineering evaluation, which Tesla has performed.
3.14 Emergency Shutoffs
Emergency shutoff is provided at multiple levels, though the Fire Department should not engage
with E-Stops, as BESS shutdown may adversely affect the electrical grid.
The Fire Department should not engage with E-Stops, as BESS shutdown may adversely
affect the electrical grid. Any interaction with E-Stops should only be initiated in
coordination with Nexamp, and other SMEs as is deemed necessary.
Automatic E-Stop
Automatic shutdown is provided at different levels for the Tesla Megapack battery modules,
depending on the type of failure:
• For major faults within battery module(s)—such overtemperature, overcharge, or
ground fault—the failed module(s)will be isolated by DC-DC converters,
disconnects, and/or DC fuses, and an alarm will be generated. This may not result in
complete shutdown of the system.
• If a large propagating thermal runaway occurs, the faulted Megapack is isolated by
opening its AC contactors and over temperature loss faults will be sent to the service
team.
Enclosure-Level E-Stop
Each Megapack unit is equipped with an AC circuit breaker located within the Megapack
Customer Interface Bay door and is to be used only by authorized maintenance or operations
personnel.
In the event of a battery-related failure,the Fire Department should not approach any
battery enclosures or engage with any enclosure E-Stops.
3.15 Fire Detection
The MP2XL does not have an internal fire detection system or one that is integral to its
design/construction.
3.15.1 .1 UL 9540A Thermal Runaway Test Data
Figure 68, Figure 79, and Figure 8provide an overview of the Cell and Module Level results of the
UL 9540A testing conducted on MP2XL. Unit and installation overviews are provided in the
Hazard Mitigation Analysis (HMA)that has been submitted to the Lansing Fire Department.
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Average cell surface temperature at gas venting 1740C
Average Cott surface temperature at thermal runaway 2390C
Coll vent gas volume released 93.3 L
LFL, °,c volume in air at the ambient temperature 7.15%
LFL, volume in air at the venting temperature 6.05%
Burning Velocity(S.) 90.0 Cm/s
Maximum pressure(P.,..) 98.46 psig
Figure 6 UL 9540A Cell Level Testing:Key Flammability Characteristics
Gas Name Chernicat Structure %Measured Component UFL
Carbon Monoxide CO 10.881 10.9
Carbon Dioxide CO2 27.107 N/A
Hydrogen H2 50.148 4.0
Methane CH4 6.428 4.4
Acetylene C2H2 O.264 2.3
Ethylene C2H4 3.283 2.4
Ethane C2H6 1.100 2.4
Propene C3HC 0.379 1.8
Propane C3H8 0.125 1.7
C4(Total) 0.190 N/A
CS(Total) 0.027 N/A
C6(Total) 0.005 N/A
Benzene C6H6 0.002 1.2
Toluene C7H8 0.002 1.0
Dimethyl Carbonate C3H603 0.055 N/A
Ethyl Methyl Carbonate C4H803 0.004 N/A
Total 100
Figure 7 UL 9540A Cell Level Testing: Cell Vent Gas Composition (Excluding Oxygen and Nitrogen)
17
r
Carbon Monoxide CO 205
Carbon Dioxide CO2 6721
Methane CH4 68.8
Acetylene C2H2 17.1
Ethene C2H4 Not Detected
Ethane C2H6 Not Detected
Propane C3H8 Not Detected
Butane C3H4 Not Detected
Pentane C3H6 Not Detected
Benzene C6H6 9.0
Hexane C7H14 Not Detected
Hydrofluoric Acid HF Not Detected
Hydrogen Chloride HCL Not Detected
Hydrogen Cyanide HCN Not Detected
Hydrogen H2 446
Total Hydrocarbons (Propane Equivalent) 247
Figure 8 UL 9540A Module Level Testing:Product of Combustion
3.16 Emergency Contacts
• Local Fire Department: Lansing Fire Department
o Address: 80 Ridge Rd, Lansing, NY 14882
o Emergency: 9-1-1 (if dialing locally from BESS location)
• Local Hospital: TBD with Fire Department
o Address:
o Emergency: 9-1-1 (if dialing locally from BESS location)
• Nexamp Emergency Response Coordinator:
o Sean Banaee, 757-971-7732
• Nexamp Emergency Line - (857)239-0057
3.17 Fire Responder Contact Information
• Local Fire Department: Lansing Fire Department
o Address: 80 Ridge Rd, Lansing, NY 14882
o Emergency: 9-1-1 (if dialing locally from BESS location)
o Non-Emergency: (607) 273-8000
• Local Hospital: To be updated
o Address: To be updated
o Emergency: 9-1-1 (if dialing locally from BESS location)
o Emergency Room: To be updated
o Non-Emergency: To be updated
3.18 Other Contact Information
18
Nexamp Site Contacts
Name Role Phone Number
Nexamp Emergency Call Center 857-239-0057
Jerry Smith Storage BESS Owner 617-431-1440
Sean Banaee Emergency Response 752-971-7732
Coordinator
Mohamed Kassamali BESS SME 516-355-1466
Vendor
Name Role Phone Number
857-239-0057
Nexamp BESS Operator
Back up: 617-431-1440
Tesla BESS Manufacturer 650-681-6060
Chemtrec HAZMAT Remediation 800-424-9300
3.19 Roles and Responsibilities
The following table provides a high-level summary of key stakeholders' responsibilities regarding
emergency preparedness and response.
The BESS Owner and Operator will assist in the implementation of this plan by knowing and
communicating evacuation routes to work during emergency evacuation and reporting the status of
the incident and evacuation to the Lansing Fire Department.
All facility personnel have a responsibility to immediately report any emergencies to the SME
and/or BESS Operator or local emergency responders when appropriate. No delay to report
emergency events that require the local emergency responders.
The SME and designated alternative will be always contactable by telephone; be readily available
to first responders in the event of an emergency. The SME shall be well versed in battery failure
modes and hazards. If SME is not available, a toll-free phone number for first responders to call at
any time shall be provided. Additionally, first responders shall be given operational data on the
system, including the current state of health, system alarm notifications and advice on how to
proceed during an emergency event shall be provided.
19
BESS Owner
Identity Jerry Smith Storage (Nexamp)
Responsibilities Shall coordinate with the Emergency Response Coordinator and/or its contractors with
access to the site, as necessary, for them to perform their duties and obligations.
Emergency . . Coordinator
Identity Sean Banaee (Nexamp)
Responsibilities Shall provide a site-specific Emergency Response Plan for each site that was
developed during the engineering, construction, and commissioning phases of the
projects. The Emergency Response Plan should be submitted to the local fire
department, the BESS Operators, and the BESS Maintenance Contractors prior to
going live. The Emergency Response Coordinator will also be responsible for
introductory training of the ERP, the BESS project site, and introduction amongst all
emergency response stakeholders listed in this table.
Identity Mohamed Kassamali and Nickole Gagne (Nexamp)
20
Responsibilities The BESS SME role consists of at least two people, one of which is the battery
technology expert, and the other being a qualified electrical expert. The two
parties are responsible for communicating with each other, the BESS operator,
and the Local Fire Department. The description of these two parties and their
respective responsibilities are listed below.
Qualified Electrical Expert(Nexamp)
One person employed by the BESS Owner has the skills and knowledge
related to the operation of the electrical equipment and installations and has
received safety training to recognize and avoid the hazards involved. This party
will be qualified in the workplace and electrical safety in local jurisdiction of the
system. This party will be responsible for the following during an emergency or
failure:
- Prepare for and conduct exchange of information with battery
technology experts (BESS SME), Emergency Response Coordinator,
Local Fire Department, and BESS operators
- Communicate proper methods for isolation and shutdown the system
based on available information on the emergency event
- Determine electrical hazards and failures and communicate them to
the Local Fire Department
Battery Technology Expert (Nexamp)
One person employed by the BESS Owner has knowledge of the normal and
abnormal operation of the BESS and associated equipment. This person will
have a deep understanding of the BESS failure modes, automatic and passive
safety systems associated with the BESS, and correct emergency response
procedures and action plans. This party will be responsible for the following
during an emergency of failure:
- Communicating with the Qualified Electrical Expert (BESS SME),
Emergency Response Coordinator, Local Fire Department, and BESS
Operator.
- Communicating the required setbacks and evacuation points that the
Local Fire Department should maintain to the Local Fire Department
- Collecting information from the BESS Operator regarding the BESS
status and its alarms
- Direct communication will be made from BESS SME to the BESS
manufacturer following an emergency event.
BESS Operator
Identity Nexamp
Responsibilities The following responsibilities fall under the BESS Operator's scope during an
emergency event:
- Actively monitor and control the BESS during its normal and abnormal
operations to the best of their ability. All monitoring and controlling will be
performed in line with the BESS Manufacturer's recommendations.
- Directly communicate with the Local Fire Department, Emergency
Response Coordinator, and BESS SME at the onset of the emergency
event and for the remainder of the emergency event.
Dispatching qualified personnel to the site
21
Local • ,rtment/Emergency ResponsePersonnel
Identity Lansing Fire Department
Responsibilities Will receive and review a copy of the Emergency Response Plan (ERP)for each site
and approve of the ERP prior to the BESS Owner sharing the document with all
stakeholders and conducting training.
Upon alarm,will coordinate with the Emergency Response Coordinator, and
BESS SME to receive an update on the emergency and ensure the BESS site is
safe to approach prior to engaging.
Will be required to maintain training for new members of the FD and maintaining
a copy of the ERP accessible to all members of the FD.
Incident Commander(IC)
Identity Lansing Fire Department
Responsibilities The person responsible for overall management of the incident and determines
which Command or General Staff positions to staff in order to maintain a
manageable span of control and ensure appropriate attention to the necessary
incident management functions.
Site Owner
Identity Wayne Straw(Straw Wayne L)
Responsibilities The owner of the premises upon which the battery system is installed.
22
4 Battery Management System (BMS)
MP2XL has an integrated battery management system (BMS)that tracks the performance,
voltage, current, and state of charge of the cells (among many other datapoints). The BMS is a
layered system, where each battery module has its own BMS and the MP2XL itself has a bus
controller supervising the output of all the battery modules at the AC bus level. The BMS is
engineered to react to fault conditions in an autonomous manner, with safeguards built into
firmware. These fault conditions include, but are not limited to, over-temperature, loss of
communication, over-voltage, and isolation. For instance, to prevent a cell over-temperature the
TMS is enabled by the BMS to cool the cells/module. This action by the BMS (which is just one
example of many ways the BMS can respond to a fault condition) can either prevent thermal
runaway from occurring in the cell or prohibit the propagation of thermal runaway to adjacent
cells. Depending on the severity of the fault condition, the BMS can automatically isolate the
affected battery module temporarily(less severe fault) or it can permanently disconnect the
module.
The BMS is the brain behind the energy storage system. Like how the Chief Officer will locate a
residential or commercial facility FACP to allow them to begin their basic size-up, the BMS
alongside the Site Controller will provide similar insight into the type of alarm, location and how
much of the energy storage system may be involved. As such, BMS data should be leveraged to
make informed decisions. The BESS SME will provide an interpretation of the BMS data and
conveying the data to the Chief Officer.
4.1 Alarm Matrix
List of Alarm Conditions Requiring Lansing Fire Department Response
An alarm matrix that explains the alarm, alarm description, and the resulting action from the BMS is
provided in Table 1. However, there may be additional indicators or information communicated
directly from Tesla to Nexamp that may be shared with the Lansing Fire Department
Table 1 Alarms Matrix
Alarm Alarm description
Name/Code
Alarm Response
If this alarm occurs, Tesla will
immediately contact Nexamp and
provide the system diagnosis.
Simultaneously, Nexamp' s NOC
will be seeing alarms which will
trigger an immediate call to the
Maximum Maximum battery cell temperatures across all Lansing Fire Department.
Battery battery modules within a Megapack
Temperature Nexamp will request that the
Lansing Fire Department is
dispatched, and Nexamp will
dispatch their EH&S and Asset
Management personnel.
Upon further diagnosis, additional
action may be administered. If this
23
alarm results in a battery fire, the
Emergency Response Plan (ERP)
will be in effect.
If this alarm occurs, Tesla will
immediately contact Nexamp and
provide the system diagnosis.
Simultaneously, Nexamp' s NOC
will be seeing alarms which will
trigger an immediate call to the
Lansing Fire Department.
Nexamp will notify Lansing Fire
Department of the alarm and
Megapack provide a diagnosis (if available).
Inverter Fault All inverters in the Megapack are faulted Nexamp will communicate that
they will update the fire
department on the conditions of
the BESS.
Tesla and Nexamp will shut down
the BESS to troubleshoot the
issue. Personnel will be
dispatched if the issue cannot be
resolved remotely.
If this alarm occurs, Tesla will
immediately contact Nexamp and
provide the system diagnosis.
Simultaneously, Nexamp' s NOC
will be seeing alarms which will
trigger an immediate call to the
Lansing Fire Department.
Nexamp will notify Lansing Fire
Extreme Department of the alarm and
Temperature Battery cells have reached a temperature above provide a diagnosis (if available).
Warning the cell temperature warning threshold Nexamp will communicate that
they will update the fire
department on the conditions of
the BESS.
Tesla and Nexamp will shut down
the BESS to troubleshoot the
issue. Personnel will be
dispatched if the issue cannot be
resolved remotely.
24
If this alarm occurs, Tesla will
immediately contact Nexamp and
provide the system diagnosis.
Simultaneously, Nexamp' s NOC
will be seeing alarms which will
trigger an immediate call to the
Lansing Fire Department.
Extreme Battery cells have reached a temperature above Nexamp will ask that Lansing Fire
Temperature the cell temperature fault threshold Department is dispatched, and
Fault Nexamp will dispatch their EH&S
and Asset Management
personnel.
Upon further diagnosis, added
action may be administered. If this
alarm results in a battery fire, the
Emergency Response Plan (ERP)
will be in effect.
If this alarm occurs, Tesla will
immediately contact Nexamp and
provide the system diagnosis.
Simultaneously, Nexamp' s NOC
will be seeing alarms which will
trigger an immediate call to the
Lansing Fire Department.
Nexamp will notify Lansing Fire
Power Megapack Power Electronics are experiencing an Department of the alarm and
Electronics Over overtemperature provide a diagnosis (if available).
Temperature Nexamp will communicate that
they will update the fire
department on the conditions of
the BESS.
Tesla and Nexamp will shut down
the BESS to troubleshoot the
issue. Personnel will be
dispatched if the issue cannot be
resolved remotely.
A safe start up procedure following an alarm event is covered in the O&M manual and
Tesla emergency response guide included in Nexamp's supporting documentation
package.
5.1 Thermal runaway
Thermal runaway is a chemical process where self-heating in a battery exceeds the rate of cooling
causing high internal temperatures, melting, off-gassing/venting. And in some cases, fire or
25
explosion. Thermal, mechanical, and electrical abuse can lead to thermal runaway, internal short
circuit from manufacturing defects, or the development of metallic dendrites that from internal short
over time.
Flammable and potentially explosive gases (generally white in color)typically evolve when an
energy storage system goes into thermal runaway and may be released in large quantities from
battery cells or modules. Fire and explosive incidents may result, and precautions as described in
the sections below should be observed.
5.2 Fire and Re-ignition
Lithium-ion battery fires can burn at extremely elevated temperatures (upwards of 1000°C)and are
generally not easily extinguished. Fire growth may be slow, fast, or ultra-fast(e.g., during
deflagration event). In nature and may last for several hours before the battery modules are
completely consumed. Furthermore, even when a lithium-ion battery fire appears to be fully
extinguished, re-ignition risk may still be present hours or even days after there are no visible signs
of fire.
Application of water to affected battery modules may potentially prolong the incident, and decisions
to apply water should be made in coordination with the System Owner/Operator, and other
required SMEs.
•
O Indicators which may provide insight into what is happening or about to happen
during an incident may include:
• Smoke or flames
• Change in smoke color
• Change in velocity or volume of smoke production
• Sounds-popping and/or hissing
• Smell —sweet smell
WARNING: Risk of Re-ignition
Do NOT assume the fire is out as the fire event unfolds. A lithium-ion battery fire
which has seemingly been extinguished may flare up again if all cells within the
enclosure have not been completely consumed. The risk of battery re-ignition can
remain present for hours or even days after the smoke/flame is initially detected.
5.3 Explosion
Lithium-ion batteries release flammable off-gases during thermal runaway which, if allowed to
accumulate within the enclosure, may create an explosive atmosphere, posing serous risk to first
responders and nearby exposures. These gases may accumulate within the energy storage system
enclosure as levels above the Lower Explosive Limit(LEL). At sufficiently high accumulations,
gases can also exceed their Upper Explosive Limit(UEL), at which point ventilation may bring the
environment back into flammable limits, this creating a new explosion risk.
It may be difficult to ascertain conditions within the enclosure if smoke and gas are not visible
outside of the enclosure. Furthermore, a single battery cell may release enough flammable off-gas
to generate an explosive atmosphere within the enclosure. Therefore, any failure or alarm condition
should always result in the assumption of potential explosion risk. Any fire personnel operating on
scene should utilize both 4/5 gas meters as well as thermal imaging camera to help determine if
any gas components are venting from the site.
26
WARNING: Risk of Explosion/Deflagration
An explosion/deflagration /over-pressure event is a critical hazard, and any
emergency on-site should always be addressed with full awareness of potential
factors which may lead to such an event.
Any failure or alarm conditions should result in the assumption of an
explosion risk.
5.4 Electrical Shock
Even if a battery may look to be destroyed by fire and/or other means, there is a potential that the
battery still holds stranded energy and remains energized. De-energization of the system or any
removal of the battery or battery component shall only be performed by a trained and competent
individual with proper PPE.
Normal overhaul of the energy storage system enclosure shall not be attempted by the fire
department in any circumstances, as there are considerations for handling damaged batteries
requiring equipment and expertise that must be called to site. Once the scene is secured, these
actions may be undertaken by trained experts under close supervision.
WARNING: Risk of Stranded Energy
Always treat the batteries as Energetic Hazardous Materials, as stranded energy is
likely to still be present. Traditional Fire Department overhaul should not be
ztconducted due to the potential for stranded energy.
5.5 Arc Flash
All energy storage systems and related electrical equipment shall always be treated as energized
(Energetic Hazardous Material).
Qualified PPE and training are required when working or accessing equipment within an Arc Flash
Boundary. In general, when in direct proximity to the battery enclosure, wear non-melting or
untreated natural fiber long-sleeve shirt, long pants, safety glasses, hearing protection, and proper
gloves. AR plant clothing is also acceptable. Maintain arc flash boundary until completion of any
task.
5.6 Toxic Smoke and Gas Emission
Lithium-ion batteries may release copious quantities of flammable and toxic gas when undergoing
failure and pos an inhalation hazard. Chemicals consumed during a thermal runaway event will
produce smoke.
The energy storage system site perimeter should not be entered during a fire or off-gassing event
unless there is an imminent threat to life safety, at which time only professionally trained and
equipped public safety personnel may enter. This entry shall be with full fighter protective gear to
include self-contained breathing apparatus (SCBA), 4/5 gas meters and a thermal imaging camera.
A fog pattern from a handline or monitor nozzle may be an effective way to control the off-gassing
event on the exterior of the battery enclosure from migrating to unwanted areas. However, if water
is used in extinguishing flame, these gases can become acids which may cause skin irritation if in
direct contact with the acid.
27
WARNING: Toxic Gases
Copious quantities of toxic smoke and gas may be emitted from the ESS during
/A\ battery off-gassing or fire situations.
Proper PPE including SCBA should be worn by first responders.
5.7 Additional Hazards and Considerations
For additional hazards associated with leaked coolant, leaked refrigerant, leaked electrolyte, or
emergency considerations during storage, operation, transportation, or first aid measures, and
disposal procedures, please see the Tesla Industrial Lithium-ion Battery Emergency Response
Guide and Tesla Application note: Considerations for Hazardous Material Business Plans.
Notification Matrix
To be updated upon discussion with Lansing Fire Department
7 Emergency Response
Considerations
7.1 Emergency Contacts
A list of emergency contacts associated with this installation is provided in Section 3.16.
7.2 Equipment and Personnel Protective Equipment (PPE)
Full firefighter protective gear shall be worn in any response to a fire and/or explosion event or if
there is any sign a fire may be present or likely to be present at any time during the event. The
Officer in Charge should have a 4/5 gas meter available, along with a thermal imaging camera
(TIC).
If there is no risk of fire or explosion present, arc-related (AR) protective clothing to protect against
arc flash and electrical shock shall be worn. Jewelry such as necklaces, rings, bracelets, etc. shall
be removed to avoid contact with any electrical hazard
Prober PPE shall include use of Self-Contained Breathing Apparatus (SCBA).
7.3 APIE (Analyze, Plan, Implement, and Evaluate)
Framework
APIE is a framework commonly used for emergency incident preparation and development of
proper response protocol(s). The four elements of the framework are Analyze, Plan, Implement,
and Evaluate. An example of APIE framework with simplified sample details pertaining to an
emergency incident is as follows:
• Analyze: Provide signs and monitoring signals that indicate incident escalation (e.g., fire or
explosion) may take place which first responders should be aware of.
• Plan: Delineate the danger zone to mitigate first responders and bystanders (pedestrians,
vehicular traffic, residents, etc.)
• Implement: Enforce evacuations, street closures, reduced pedestrian, and first responder
exposure, and other impact areas that have a life safety concern, as applicable.
28
• Evaluate: Provide continuous monitoring and feedback of the incident and adjust
accordingly to ensure ongoing safety of any bystander or responder in the impact area.
7.4 Scene Size-up — Command and Control
• Initiation of emergency response shall be activated as per the current protocol. If there is
any threat or potential threat to life safety, 911 shall immediately be called to the aid of
public safety responders. An initial scene assessment shall be conducted from all sides
(360-degree scene size up) if possible, and a concise assessment shall be given to
incoming responders. Hazards and facility safety concerns such as high voltage areas or
electrical concerns shall be announced to all responders.
The scene assessment shall include the following in plain language (no codes,
abbreviations, acronyms, etc.):
• Location of the incident (Where)
• What has happened
• What is currently happening
• Whether there are any injuries or unaccounted for individuals
• What needs or other resources should be requested or brought to site
An Incident Command System (ICS) shall be established immediately and shall include the
designation of roles. The primary command post location shall be located at the Fire Department
Staging Area. If public safety is summoned to the incident, the ICS shall be a Unified Incident
Command System (ICS).
One-site staff(if applicable) shall immediately go to the designated muster point(s), which will be
the command post location unless designated differently by the Incident Commander. Incident
Command shall designate the individual in charge of accountability. Accountability shall be
reported as soon as possible. If available and able, another individual shall control any traffic and
guide first responders to the scene.
At the same time as these activities are occurring, the Emergency Response Coordinator or other
designated SME shall immediately contact the 24/7 Networks Operations Center to establish
available data from the BMS and communicate this to the Incident Commander or other
appropriate individuals.
WARNING: Risk of Explosion/Deflagration
An explosion/deflagration /over-pressure event is a critical hazard, and any
emergency on-site should always be addressed with full awareness of potential
factors which may lead to such an event.
Any failure or alarm conditions should result in the assumption of an
explosion risk.
WARNING: Toxic Gases
Copious quantities of toxic smoke and gas may be emitted from the ESS during
/0\4 battery off-gassing or fire situations.
Proper PPE including SCBA should be worn by first responders.
29
7.5 Determine Fire Protection Approach
The decision to utilize water spray or to provide thermal cooling via hose lines should be made in
coordination with System Owner/Operator, and any other required SMEs.
Caution should be exercised if water is applied directly to the exterior of an affected Energy
Storage System enclosure, as this will not stop a thermal runaway event and may potentially delay
combustion. Defensive firefighting tactics are generally recommended, with water being applied to
nearby exposures for cooling, as necessary. Any hose line operations should be limited to hose
and master stream application from outside of the BESS sound barrier structure, at least 100ft
away from the BESS, and as far back as hose and stream range allow.
A fog pattern from a handline or monitor nozzle may potentially be utilized to control smoke and
gas released from the affected enclosure and prevent them from moving to unwanted areas.
In all instances, power shut down and isolation involving any high voltage feeder lines must be
confirmed before any defensive measures are taken involving application of water to the site.
WARNING: Risk of Re-ignition
Do NOT assume the fire is out as the fire event unfolds. A lithium-ion battery fire
which has seemingly been extinguished may flare up again if all cells within the
enclosure have not been completely consumed. The risk of battery re-ignition can
remain present for hours or even days after the smoke/flame is initially detected.
7.6 Incident Monitoring and Evaluation
Continuous monitoring and feedback on the incident should be provided as the situation evolves.
Consultation with the System Owner/Operator, and any other required SMEs should be held to
guide incident response and determine appropriate next steps.
If available, real-time BMS data from the 24/7 Networks Operations Center should be utilized (e.g.,
temperature, voltage, or other critical measurements)to monitor the spread of failure and assess
the health the ESS to help guide response procedures as the event unfolds.
8 Response Tactics
8.1 Explosion Incident
In case of fire or thermal runaway events, explosive or deflagration event may occur potentially
subjecting personnel to overpressure and projectile hazards. An initial exclusion area should be
established, based on the discretion of the Incident Commander, to guard against any blast
overpressure. Staging or operations should not be in direct alignment with the energy storage
enclosure and should be established at angles relative to the sides of the enclosures if possible. If
available, shielding via the built environment should be utilized to protect against high
temperatures, overpressure events, or projectile hazards.
A minimum of one hundred(100 ft) shall be maintained between individuals and the incident
cabinet (see 100ft radius shown in Figure 3).
Notify neighboring property owners of the BESS area of the emergency event and to remain away
from the property If the System Operator has informed that the automatic E-Stop has not been
triggered, attend to Manual E-Stop. The Manual E-Stop will disconnect the energy storage system
electrically.
30
Gas monitoring shall always be continuously conducted, and gas meters shall be affixed to all
responders to warn of potential atmospheric risks. If possible, gas readings from inside the cabinet
shall be attempted to be gathered from an exterior point prior to any entry.
WARNING: Risk of Explosion/Deflagration
An explosion/deflagration /over-pressure event is a critical hazard, and any
emergency on-site should always be addressed with full awareness of potential
AS factors which may lead to such an event.
Any failure or alarm conditions should result in the assumption of an
explosion risk.
8.2 Fire Incident
In the event sensors within the BESS containers detect a fire or thermal runaway, the BESS
container undergoes an emergency stop of operations, including isolation of batteries via contactor
located at the battery rack level. The unit or system should be shut down manually if possible and
Tesla Energy Technical Support should be contacted for assistance. The Manual E-Stop will
disconnect the energy storage system electrically.
A minimum of one hundred(100 ft) shall be maintained between individuals and the incident
BESS containers.
Notify neighboring property owners of the BESS area of the emergency event and to remain away
from the property.
If there is no immediate threat to life safety
1. Allow the BESS to burn in a controllable manner until all fuel sources inside are depleted
2. A defensive approach should be considered utilizing water to cool and protect adjacent
exposures and mitigate the spread of fire to areas outside the sound barrier.
3. Remember that even after the BESS is isolated from the electric grid and there may still be
considerable stored energy in the batteries that poses a potential electric shock hazard to
anyone in the nearby vicinity.
Additionally, chemicals released during a fire or explosion event will be in a gaseous form and
primarily pose an inhalation hazard. A fog pattern from a handline or monitor nozzle may provide
an effective means of controlling an off-gassing event on the exterior of the BESS enclosure from
cascading to unwanted areas such as public muster points, emergency responders, building
intakes, etc.
In addition, hose streams may be also applied to adjacent exposures for cooling purposes. BMS
data available via the 24/7 Networks Operation Center should be closely monitored for the
adjacent system(s)for any indicators of heat impact or water damage and relayed to the
appropriate individual within the Incident Command System.
Following the partial or complete consumption of the system by fire, batteries may continue to
emit flammable gases and toxic gases for a period. Continuous monitoring of gas levels in and
around the incident location is recommended. Full firefighter PPE and SCBA shall be utilized until
gas levels are confirmed to be at a safe level. A Firewatch shall be provided to ensure that the
continued safety of the site after the emergency appears stable.
31
WARNING: Risk of Re-ignition
Do NOT assume the fire is out as the fire event unfolds. A lithium-ion battery fire
which has seemingly been extinguished may flare up again if all cells within the
enclosure have not been completely consumed. The risk of battery re-ignition can
remain present for hours or even days after the smoke/flame is initially detected.
8.3 Thermal Runaway or Off-Gassing Incident
A thermal runaway event may result in copious quantities of smoke and gas being released, which
may or may not be visible outside of the ESS enclosure itself, therefore, it is critical that any failure
or alarm condition result in the assumption of an explosion or fire risk.
In the event of a thermal runaway or suspected off-passing event,the following actions are
recommended:
1. Evacuate the area to a safe location a sufficient distance from the ESS enclosure involved.
2. If the alarm has not already signaled the Fire Department, immediately call 911
3. Call the System Owner/Operator as highlighted in Section 6.
4. Establish a safety perimeter around all sides of the energy storage system and remain
outside the sound barrier/BESS area. Do not allow personnel other than firefighters in
proper PPE to enter the safety perimeter and stay upwind of any smoke or off-gassing.
5. As the incident evolves, a fire or explosion event may occur, and procedures outlined in
Section 8.1 and 8.2 above should be followed based on the situation as it progresses.
WARNING: Risk of Explosion/ Deflagration
An explosion/deflagration /over-pressure event is a critical hazard, and any
emergency on-site should always be addressed with full awareness of potential
factors which may lead to such an event.
Any failure or alarm conditions should result in the assumption of an
explosion risk.
WARNING: Risk of Re-ignition
Do NOT assume the fire is out as the fire event unfolds. A lithium-ion battery fire
which has seemingly been extinguished may flare up again if all cells within the
enclosure have not been completely consumed. The risk of battery re-ignition can
remain present for hours or even days after the smoke/flame is initially detected.
WARNING: Toxic Gases
Copious quantities of toxic smoke and gas may be emitted from the ESS during
/A\ battery off-gassing or fire situations.
Proper PPE including SCBA should be worn by first responders.
•
O Indicators which may provide insight into what is happening or about to happen
during an incident may include:
• Smoke or flames
• Change in smoke color
• Change in velocity or volume of smoke production
32
• Sounds -popping and/or hissing
• Smell —sweet smell
8.4 Alarm Incident
In the event of an alarm activation, the following actions are recommended:
1. Evacuate the area to a safe location a sufficient distance from the ESS enclosure involved.
2. If the alarm has not already signaled the Fire Department, immediately call 911
3. Call the System Owner/Operator as highlighted in Section 6.
4. Establish a safety perimeter around all sides of the energy storage system and remain
outside the BESS area. Do not allow personnel other than firefighters in proper PPE to
enter the safety perimeter and stay upwind of any smoke or off-gassing.
8.5 External Fire / Thermal Exposure Incident
For any type of external heat source or fire impingement(i.e., not resulting from the BESS), the
Incident Commander should be advised to review the BESS diagnostics with respect to SOH
information from the BMS data (i.e., temperature data) available from the 24/7 NOC to evaluate the
severity of the incident and assess the state of emergency. All precautions previously noted for fire
and explosion incidents should be observed (Section 8.1 and 8.2)
Note: The BESS area has design features that mitigate an external fire such as the setbacks, use
of gravel, vegetation management, and safety systems.
8.6 External Impact Incident
If a BESS enclosure is severely impacted causing a crushing or puncturing of the outer shell of the
BESS or battery enclosure, treat this as an emergency—notify 911 and other required parties
noted in Section 6.
Note: The Tesla Megapack 2XL is IK09 rated for impact protection.
9 Post Incident Operations
Handoff Procedures
Upon determination by Lansing Fire Department Incident Commander, when the energy storage
system is deemed safe, the System Operator shall ensure that the site is safeguarded until the
damaged system is removed, repaired, or replaced based on the approved Decommissioning
Plan filed with the building permit.
Activation of Decommissioning Plan
Decommissioning of the system shall take place in accordance with the Decommissioning Plan
filed with the building permit. Deactivation, de-energizing, dismantling and removal of the system
shall be conducted by trained and knowledgeable persons in accordance with manufacturer's
specifications.
10 Training and Exercises
The ERP serves as the platform for the training program and includes the following:
• System Overview
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• Equipment
• BMS
• Detection and Suppression
• Emergency System Shutdown
• Hazards
• Suppression agents and exposure control
• Response tactics
• Post-fire operations
Initial training for all stakeholders included in this ERP shall be undertaken before the construction of
the BESS facility. Refreshments training of the ERP will be offered at least one time annually
However, Nexamp will provide additional training at the request of any stakeholders included in the
ERP, particularly the Lansing Fire Department.
In accordance with best practices such as NFPA 855, drills should be conducted regularly to exercise
knowledge of the ERP and prepare stakeholders for a potential emergency. Over a three-year cycle,
drills will grow in complexity and will be evaluated to ensure the ERP can be executed as written.
Drills may be desktop, functional, or full-scale and will follow the FEMA/HSEEP doctrine (Link
provided below).
• Plan Cycle 1
o Cycle 1 drills will be basic in nature and consider the reasonable conditions that may
cause the Fire Service to respond to the Facility.
• Plan Cycle 2
o Cycle 2 will begin to evaluate more complex equipment failures where facility
personnel will collaborate with members of the first response community to mitigate
and contain the event.
• Plan Cycle 3
o Cycle 3 will represent the most complex scenario that can impact major system
components, neighbors, and the environment.
https://www.fema.gov/emergency-managers/national-prepared ness/exercises/hseep
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11 Revision Tracking
Rev Author(s) Effective Date Description of Revision(s)
0 Mohamed 05/26/2026 First Draft of Emergency Response Plan—Technology,
Kassamali, Eli Site, and Contact information included
Shandelman
1
2
3
4
5
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