HomeMy WebLinkAbout13a Hazard Mitigation Analysis (HMA) - Site specific_052626 ne #.#i; mp
Site-Specific Hazard Mitigation Analysis
Jerry Smith Storage
Lansing,339 Jerry Smith Rd. ,
• •
Respondent
Primary Contact:
Eli Shandelman
Product Manager, Energy Storage Solutions
Nexamp, Inc.
101 Summer Street, 2nd FI
Boston, MA 02110
eshandelman@nexamp.com
Table of Contents
Introduction 3
Applicable Codes and Standards 3
Site 4
Nearby Exposures 5
Fire Department Access and Water Supply 5
Energy Storage System 6
Hazard Mitigation Analysis 9
UL 9540A Testing 10
Failure Mode and Effects Analysis (FMEA) 11
Analysis Approval 16
Site-Specific Exposure Assessment 17
References 20
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 2
Introduction
On behalf of Jerry Smith Storage, Nexamp has developed a Site-specific Hazard Mitigation
Analysis (HMA) for the Lithium-ion Battery Energy Storage System(BESS) sited on 339 Jerry
Smith Rd., Lansing,NY 14882. This study includes a comprehensive analysis of hazards and
risks associated with the BESS to assess the overall effectiveness of its capability in mitigating
various battery failure scenarios.
The HMA consists of this report, a Failure Modes, and Effects Analysis (FMEA) in MS excel
format(ref.1),An FMEA is one of several methods of conducting an HMA.
Applicable Codes and Standards
This report and the overall HMA package for the Jerry Smith Storage Energy Storage site was
developed in alignment with the following applicable codes:
• 2025 Fire Code of New York State (2025 FCNYS) & 1207 Electrical Energy Storage
Systems (ESS)
• New York State Electric Code
• New York State Building Code
• NEC
• NFPA 855 Standard for the Installation of Stationary Energy Storage, 2023 Edition
• UL 9540 Standard for Energy Storage Systems and Equipment, 3Yd Edition, 2023
• UL 9540A Standard for Test Method for Evaluation Thermal Runaway Fire Propagation
in Battery Energy Storage Systems, 41h edition
• IEC 60812 Failure Modes and Effects Analysis
• NFPA 72 National Fire Alarm and Signaling Code, 2016 Edition
• UL 1642 Standard for Lithium Batteries, 2020 Edition
• UL 1741 Standard for Inverters, Converters, Controllers and Interconnection System
Equipment for Use with Distributed Energy Resources
• UL 1973 Standard for Batteries for Use in Stationary, Vehicle Auxiliary Power and Light
Electric Rail (LER)Applications
The Town of Lansing is the Authority Having Jurisdiction(AHJ) and has the responsibility for
reviewing and approving BESS siting in Lansing,NY. The Hazard Mitigation Analysis has been
requested to comply with the requirements of 2025 FCNYS.
NFPA 855 Section 4.4.2 states that the hazard mitigation analysis shall evaluate the
consequences of the following failure modes:
1. A thermal runaway or mechanical failure condition in a single ESS unit
2. Failure of an energy management system or protection system that is not covered by the
product-listing failure modes and effects analysis (FMEA)
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 3
3. Failure of a required protection system including,but not limited to, ventilation(HVAQ,
exhaust ventilation, smoke detection, fire detection, fire suppression, or gas detection
NFPA 855 Section 4.4.3 states that the AHJ shall be permitted to approve the hazard mitigation
analysis as documentation of the safety of the ESS installation if the consequences of the
analysis demonstrate the following:
1. Fires will be contained within unoccupied ESS rooms for the minimum duration of the
fire resistance rating specified in Section 9.6.4
a. Not yMlicable, as this is an outdoor system and is a pre-engineered and pre-
certified cabinet-style ESS enclosure
2. Fire and products of combustion will not prevent occupants from evacuating to a safe
location
a. Not applicable as this is a non-occupied outdoor ESS.
3. Deflagration hazards will be addressed by an explosion control or other system
Site
L
The Jerry Smith Storage Battery Energy Storage (BESS) Project consists of a 5 MW/23.5 MWh
(4-hour duration)battery energy storage system. The project is located on the southeast portion
of the property at 339 Jerry Smith Rd., Lansing,NY 14882. The project will use advanced
lithium-ion battery and control technology that are contained in environmentally rated enclosure
(`BESS Unit" or"Tesla Megapack 2XL"). The BESS will consist of Six(6) Tesla Megapack
2XL with associated wiring, cabling, meters, and site controller and data acquisition equipment.
The Megapack 2XL will be located at grade on concrete pads and provided site access via a main
gate on the northeast side of the site fenced in area. As such,the Megapack 2XL enclosure (the
BESS)will be protected from unwarranted access.
Fire department staging and apparatus access is accommodated outside the primary vehicle gate,
allowing emergency responders to establish operations without entering the project fence line.
Figure I -Site location and layout
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 4
M
y
1
. u
Figure 2 BESS Area-Zoomed In
Nearby Exposures
The site is located with few exposures in the nearby vicinity.Nearby exposures include:
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 closes section of PV
array)
b. Construction: Steel and PV modules
Fire Department Access and Water Supply
The nearest fire station(Lansing Fire Department Station 3) is located approximately 2.3 miles
from the BESS site (1235 Ridge Road, Lansing,NY 14882).
In the event of an emergency on-site, primary fire department staging should be used. The
staging area will be defined upon discussions with Lansing Fire Department
No fire hydrants or permanent water supplies for firefighting operations are noted in the
immediate area. Water supply is assumed to be delivered by Lansing Fire Department via the
available fire trucks to maintain the surrounding units and exposures cool and moist. It is not
recommended to apply lots of water directly to a unit during a thermal event.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 5
Energy Storage System
The BESS consists of six(6) Tesla Megapack 2XL (MP2XL) cabinet-style ESS unit, with a
system rating of 979.2 kW/ 3916.8 kWh power and energy capacity, respectively. Each MP2XL
unit consists of nine (9)bays, which are designed as follows:
• Eight(8)battery bays—each consisting of three (3)battery modules for a maximum of 24
battery modules
• One (1)bay containing the thermal cabinet and customer interface bay with Battery
Management System(BMS).
The MP2XL is a design evolution of Megapack 2 (MP2), which leverages the same core
technology platform(cells, vents, sparker system, etc.). Each MP2XL unit contains up to 24
battery modules and has a slightly greater footprint than the MP2 (which contains up to 19
modules), and also uses identical components including batteries, converters, and explosion
protection system.
Each battery module is composed of 336 prismatic Lithium-iron-phosphate (LFP)battery cells.
The MP2XL is nearly fully populated with battery racks, electrical components, safety systems,
and thermal management systems—making it a non-walk-in BESS unit. As such, the MP2XL
cannot be physically entered by site personnel, first responders, or members of the public at any
time. The MP2XL is secured and can only be accessed with a key or access code.
The MP2XL is equipped with several protective safety system including the BMS,thermal
management system, and Tesla site controller(connected to Tesla's and Nexamp's Network
Operating Centers), connected to a fire alarm system, and Tesla's proprietary deflagration
control system. Each safety system provides an additional layer of protection against different
failure modes/conditions attributed to lithium-ion incidents or failures and provides an immense
contribution to the overall safety of the MP2XL and the site.
The MP2XL and constituent components are tested and certified to UL 9540,UL 1642,UL
1973, IEC 62619, and IEC 62933-5-2. UL 9540A (4th Edition) large-scale fire testing was
performed at the Cell, Module, and Unit level(Installation level testing was not required, as all
Unit level performance criteria were met). From the UL 9540A Unit level report by TUV:
Based on the limited module propagation observed during MP2 testing(7 cells in
runaway) the behavior would be the same with MP2XL. With the increase in volume and
spanker count, the deflagration risk is minimized. The testing performed on MP2 is
considered harsher with higher gas concentrations, and fundamental engineering
analysis for MP2XL shows comparable behavior as worst case.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 6
RL
0101, 01010, 01 01 01 01 01
Figure 3—MP2AL Internal components:(1)Battery Modules Bays, (2)Thermal Cabinet, (3)Customer Interface Bay, (4)IP20
Thermal Roof Enclosure, (5)IP65 enclosure
Testa Site Controller and Monitoring
Each Tesla MP2XL project includes a Tesla Site Controller where the Site Controller is designed
to communicate, monitor, and control all the equipment within the energy storage system. The
Site Controller communicates via ethernet connection and built-in cellular modem to
communicate on-site and off-site, respectively. Off-site communications are directed toward
Nexamp and Tesla's Network Operations Centers (NOC).
Thermal Management System
The thermal management system is a cooling and heating system that is independent of other
systems within the MP2XL and consists of a closed loop liquid cooling system that circulates
coolant. This coolant is a 50150 mixture of ethylene glycol and water, and R-134a refrigerant
throughout the battery module bays to maintain safe and correct operating temperatures. The
BMS allows for battery and ambient temperatures to be monitored. If the temperature within the
battery modules exceeds or drops below required temperature range, the BMS will either
temporarily or permanently disconnect the battery module or even the MP2XL (depending on the
fault condition). The Site Controller provides Tesla and Nexamp control and monitoring of the
BMS. An overview of the notifications is provided below:
• Tesla Site Controller provides an alert (Warning or Alarm) to the local operations center
and can directly communicate via text alert that the BESS has faulted, and which fault or
warning has specifically been triggered
• If the temperatures fall back within the operating limits,the system and/or effected
battery module will reintegrate into the system operation and the Tesla Site Controller
will communicate this reintegration via text alert that the system warning or fault has
been cleared
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 7
Battery Management System
The Tesla MP2XL is pre-engineered and delivered with a BMS that is designed and tested to UL
standards and industry best practices by the battery manufacturer, Tesla. The BMS is capable and
responsible for monitoring the status of numerous system parameters and fault conditions, which
includes but is not limited to loss of communications, over/under voltage, over/under
temperature, etc. The BMS protects the system by initially isolating the effected battery module
and determine if preset systems parameter thresholds have been breached. If system parameter
thresholds have been breached, the BMS will permanently disconnect battery module level
contactors that will physically disconnect (electrically isolate)the battery modules from the rest
of the system. Note that if a BMS disconnect a battery module, it will be required to be manually
reengaged and cannot be done remotely.
Fire(flame)Detection Systems
The MP2XL does not have an internal fire detection system.
Coordination of MP2XL control during a fire event and response would be reliant upon trained
staff either remotely or on-site as defined by the Emergency Response Plan.
Deflagration Protection
The MP2XL is pre-engineered and delivered with an explosion control system designed to
mitigate the risk of uncontrolled deflagration. The explosion control system consists of twenty-
six (26) overpressure vents and twelve (12) sparkers/igniters. The sparkers are evenly distributed
throughout the MP2XL enclosure and are designed to quickly ignite flammable gases before they
become a deflagration hazard. The sparkers will ignite gases as they are generated and then they
are vented through the exterior of the MP2XL using the overpressure venter located at the top of
the MP2XL enclosure.
Electrical Fault Protection Devices
Multiple levels of passive and active electrical protections are provided for the MP2XL. At the
battery module level, overcurrent protection is provided for each module in the form of single-
use fusible links,providing interruption of overcurrent in the battery module in the case of an
abnormal electrical event. Inverter modules, which are installed at each of the battery modules,
are equipped with both DC protection via high-speed pyrotechnic fuse for passive or active
isolation of battery modules, as well as dedicated AC contactor and AC fuses should an
abnormal electrical event occur at the inverter module on the AC side of the circuit.
Additionally, the MP2XL is equipped with DC ground fault detection system and AC circuit
breaker with ground fault trip settings for distribution system protection.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 8
Hazard Mitigation Analysis
As per 2025 FCNYS, one format for an HMA is an FMEA that adheres to IEC 60812 (ref. 3) and
UL 9540. As such, IEC 60812 serves as the guide for the FMEA developed for the Jerry Smith
Storage project. The FMEA represents a robust set of failure modes associated with the BESS.
As such,Nexamp has assessed the failure modes with a numerical scale shown in Figure 4.
kale Ocamence Detection severlty
Remote Certain Vert Low
Law High Low
3 Imoderate Medium ivloderat
H4h Low High
'fiery High Impossible V&YHigh
Figure 4-Numerical scales for FMEA table
The site-level HMA is built upon the product-specific FMEA developed by the Original
Equipment Manufacturer, Tesla. The product-specific FMEA is confidential in nature and cannot
be shared without a direct NDA with Tesla. As such, the focus of this report and the HMA
package is the site-specific HMA (in the form of an FMEA). The site-specific FMEA develops
the product-specific FMEA further to include local hazards and failures specific to this facility
such maintenance, vehicular traffic, and nearby exposures.
In leveraging BESS OEM documentation, safety manuals, test data, and industry best practices,
Nexamp utilized the following two-staged method to develop Jerry Smith Storage FMEA:
1. Assessing the severity and likelihood of each failure mode without the safeguards in
place to identify risk rankings.
2. Assessing the severity, likelihood, and detectability of the same failure modes with
safeguards in place to calculate the Risk Priority Number(RPN)
a. The RPN is a numeric risk assessment that is a result of the product of severity,
likelihood, and detectability of a given failure mode. This supports a scale
associated with the potential risks of the BESS.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 9
This two-staged approach supports a comprehensive assessment of the effectiveness of the
safeguards Tesla(BESS OEM) and Nexamp have incorporated into the Jerry Smith Storage
project.
For the site-level HMA, Nexamp defined low, medium, and high-risk rankings for the failure
modes based on corresponding risk priority number(RPN)that are inclusive of safeguard
considerations. The RPN designations are as follows:
• Low risk if RPN<12
• Medium risk if 12 <RPN<25
• High risk if RPN>25
UL 9540A Testing
The Tesla MP2XL has been tested to UL 9540A 4th edition at the cell, module, and unit levels.
The UL 9540A test was conducted by TUV Rhineland a well-reputable and certified Nationally
Recognized Testing Laboratory (NRTL). The UL 9540A results are summarized in a separate
report commissioned by Tesla and an independent consultant. Through unit level testing
determined to be conducted in accordance with the UL 9540A testing standard where thermal
runaway was initiated in a single module located towards the bottom of the rack. This location
was selected as it was determined to be the best location to analyze both vertical and horizontal
thermal runaway propagation. For the test, both BMS and thermal management system were
disabled as to not interfere with the results of the test(which the test standard requires).
Figure 5- UL 95404 Unit Level Test,Initiation location
Thermocouples were placed across several areas of the battery module, battery cells, and
enclosure, an instrumented wall, and other M2XL units. In addition, heat flux sensors were
installed at several distances ranging from 3-30ft. The test set up is displayed in Figure 6.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 10
Back Target
tnstrurneWed
wall
HF1 &HF2 HF3 1� �FIFI 1� I
Initiating VIP2 Side Target
I%-
HF4 3 HF5
Front Target HFs
HF7
On 1:1 Lire Battery Mcclules Hat Flux Selrisoi '�' Initiatlnn- Ekternai Flame D61ectors
Figure 6-UL 9540A Unit Level Test, Test Arrangement
Upon heating of the initiating battery cell, thermal runaway was achieved at a temperature of
462°F at 78 minutes into the test. A second cell entered thermal runaway at 93 minutes into the
test(15 minutes after the first). Cell venting was observed at the 99-minute mark of the test.
During testing, thermal runaway did not propagate through the initiating module and no
significant temperature was observed in adjacent modules. In addition, no external flaming,
flying debris, re-ignitions, or explosions were observed during the test. The maximum unit
temperature was measured at 9.9 °F over ambient conditions. The maximum heat flux at the
target wall was measured at 0.0 kW/m2. Lastly, light smoking or off-gassing was observed,with
no free-flowing electrolyte leakage or runoff observed as well.
Failure Mode and Effects Analysis (FMEA)
Per 2025 FCNYS Section 1207.1.6, the analysis shall evaluate the consequences of the following
failure modes and others deemed necessary by the AHJ:
1. A thermal runaway or mechanical failure condition in a single ESS unit
2. A mechanical failure of a nonelectrochemical ESS unit(not applicable)
3. Failure of any battery (energy)management system or fire protection system within the
ESS equipment that is not covered by the product listing failure mode effects analysis
(FMEA)
4. Failure of any required protection system external to the ESS, including but not limited to
ventilation (HVAC), exhaust ventilation, smoke detection, fire detection, gas detection or
fire suppression system
Jerry Smith Storage—Hazard Mitigation Analysis—May 2026 11
For this analysis,Nexamp has considered only a single failure mode at a time. The following
table provides a summary of the HMA findings, with each failure mode prescribed by NFPA 855
and FCNYS assessed in the site-level FMEA:
Table 1-NFPA 855 and FCNYS HMA Failure Modes
Compliance Requirement Nexamp Assessment
1. A thermal runaway condition in a A number of passive and active measures are
single electrochemical ESS unit implemented to reduce the potential of a
thermal runaway event from occurring
including BMS control and active cooling to
internal components. Battery modules and
cells have been listed to UL 1973 and UL
1642.
Should a thermal runaway event occur,
additional mitigative measures are provided to
prevent further propagation of failure
throughout the system.
2. A mechanical failure of a Not applicable, as the Tesla MP2XL is an
nonelectrochemical ESS unit electrochemical ESS unit.
3. Failure of any battery (energy) In the event of a failure of module-level BMS,
management system or fire protection the Megapack-level BMS (which may be
system within the ESS equipment that considered the Energy Management System
is not covered by the product listing (EMS) or Energy Storage Management
failure more effects analysis (FMEA). System(ESMS)) shall isolate effected
modules, mitigating against further
propagation of failure across the system.
Should a failure of the Megapack-level BMS
occur, each module is equipped with a
dedicated BMS to provide corrective actions
in case of detection of abnormal operation
outside of set parameters. To further isolate
any failure stemming from a failure of the
energy storage management system, passive
and active electrical fault protections are
provided at multiple levels, as described in
respective sections of this report.
The Tesla BMS and Site Controller alongside
Nexamp's EMS and NOC,provide active
monitoring of temperature,voltage, current,
and other parameters. The BMS and Site
Controller will take corrective action to
isolate failures. In addition, several layers of
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 12
electrical protections are included in the
MP2XL and at the site-level.
Should failure of an energy management
system result in a thermal runaway event, a
number of mitigative barriers are
in place to prevent further propagation of
failure.
4. Failure of any required protection Failure of Exhaust Ventilation System
system external to the ESS, including
but not limited to ventilation (HVAC), Not applicable, as the Megapack 2 XL does
exhaust ventilation, smoke detection, not utilize an exhaust ventilation system,
fire detection, gas detection, or fire instead using sparker system and overpressure
suppression system. vents for explosion control.
Failure of Smoke,Fire, or Gas Detection
System
The Tesla Megapack 2 XL does not utilize
smoke or gas detectors, instead opting for
external IR detection for fire detection.
Should IR detection systems fail, it is
anticipated that BMS fault notifications shall
be transmitted to remote 24/7 Network
Operations Center(NOC), alerting system
owner to abnormal conditions. Data from the
BMS may be communicated to project SMEs
to provide guidance to the fire department in
case of emergency.
Failure of Fire Suppression System
The Megapack 2 XL does not utilize fire
suppression(either water-based or non-water-
based), instead using sparker system to burn
off-gasses before an explosive condition is
allowed to accumulate within the enclosure.
Furthermore,UL 9540A Unit level testing
indicates that no flaming occurred and that no
propagation of heat from the initiating unit to
adjacent units/modules reached levels
capable of initiating cell venting or thermal
runaway.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 13
The subsections below provide an overview of the assessment of each of the failure modes
includes in Table 1. The site-level FMEA attachment of the HMA package provides greater
detail in the form of an FMEA all major failure modes noted above and the mitigations
implemented to reduce the potential propagation of a failure or hazard. Please refer to the site-
level FMEA for a more comprehensive overview of these failure modes.
Failure mode-1: A thermal runaway condition in a single electrochemical ESS unit
Thermal Runaway is defined as follows by NFPA 855:
"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 it can dissipate, potentially leading to off-
gassing, fire, or explosion"
The MP2XL incorporated multiple layers of safety protections to reduce the overall
potential for thermal runaway as well as limit the spread of thermal runaway across
adjacent battery cells and/or modules. The battery cells have been listed to UL 1642 and
tested to UL9540A. The battery modules and racks have been listed to UL 1973 and
tested to UL 9540A. The MP2XL has been listed to UL 9540 and tested to UL 9540A.
In the event of thermal runaway propagated from a single cell, several barriers are in
place to limit the spread of heat, off-gas accumulation, fire spread, or other hazards. The
BMS and other communications and controls systems transmit information that could
indicate a potential thermal runaway allowing for the MP2XL controls or system
operators to attempt to prevent the thermal runaway failure entirely. The information
relayed through the Site Controller can be accessed by site-personnel and remote
operators 24/7.
The consequence of accumulation of flammable gases from a thermal runaway failure is
addressed by the Tesla MP2XL effectively doing the following:
1. Preventing the accumulation of flammable gases with the sparker system
2. Safely exhausting the products of combustion through overpressure vents that are
on the top of the MP2XL
The fire department is expected to respond during a BESS thermal runaway incident. The
fire department will be trained to respond to the hazard and will have an Emergency
Response Plan that is developed well before the construction and operation of the BESS.
The Emergency Response Plan will be reviewed annually, and regular training will be
provided by the BESS owner.
Mechanical failure conditions can be both caused by internal and external factors. The
Tesla Megapack 2XL has several mitigations to mechanical failures such as impact
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 14
protection. The MP2XL enclosure is IK09 impact rated, and the site is designed with a
site boundary wall (sound barrier) and bollards to further prevent impact protection.
The MP2XL can detect Thermal Management System mechanical failures such as
coolant leaks or blockages and has passive containment areas for coolant. The BMS and
site controller will trigger an alarm and notify Nexamp/Tesla of the need for
repair/replacement.
Unauthorized access and vandalism are prevented by the site fence line. Access is
restricted by a locked gate in which only authorized personnel and first responders are
allowed to access.
Mechanical failure caused by misuse or mishandling is mitigated by robust training and
focus to adhering to the manufacturer's O&M manuals. Furthermore, only certified
personnel can partake in O&M activities. Similarly, so for installation, commissioning,
and decommissioning.
Failure mode-2: Failure of any battery (energy) management system or fire
protection system within the ESS equipment that is not covered by the product
listing failure more effects analysis (FNMA).
The Tesla MP2XL is pre-engineered and equipped with module, rack, and system level
BMS functionality alongside the Tesla Site Controller, both of which provide robust
monitoring and control of the MP2XL. Upon detection of any temperature, voltage, or
current measurements beyond the manufacturer's predefined setpoints,protective
corrective action will be initiated by both the Site Controller and BMS. This continuous
monitoring and control ensure that abnormal conditions are prevented and if they occur,
they are prevented from cascading throughout the system.
The Site Controller sends a text alert that system has a warning or that it has reached a
fault condition. These notifications will be sent to Tesla and Nexamp directly. Nexamp
will communicate these conditions to the Moyers Corners Fire Department.
Failure mode-3: Failure of any required protection system external to the ESS,
including but not limited to ventflation (HVAC), exhaust ventilation, smoke
detection, fire detection, gas detection, or fire suppression system.
The explosion/deflagration protection system is designed with redundancies such that not
all sparkers and/or overpressure vents are required, and the failure of a portion of the
sparkers or overpressure vents will not impact the overall performance of the combined
safety system. This is due to the protection system being overdesigned as to avoid the
worst-case scenario. If all sparkers fail, the overpressure vents are sized accordingly to
relieve all potential overpressure from the accumulated gases within MP2XL.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 15
Per NFPA 855 Section 4.4.3 and FCNYS states that the AHJ shall be permitted to approve the
hazard mitigation analysis as documentation of the safety of the ESS installation if the
consequences of the analysis demonstrate the following:
1. Fires will be contained within unoccupied ESS rooms for the minimum duration of the
fire resistance rating specified in Section 9.6.4
2. Fire and products of combustion will not prevent occupants from evacuating to a safe
location
3. Deflagration hazards will be addressed by an explosion control or other system
Analysis Approval
Per FCNYS Section 1207.1.6.2, the AHJ shall be permitted to approve the hazard mitigation
analysis as documentation of the safety of the ESS installation if the consequences of the
analysis demonstrate the following:
1. Fires will be contained within unoccupied ESS rooms or areas for the minimum duration
of the fire-resistance-rated separates identified in Section 1207.7.4.
2. Fires involving the ESS will allow occupants or the general public to evacuate to a safe
location
3. Deflagration hazards will be addressed by an explosion control or other system
Table 2 provides an evaluation of consequences of all failure modes required by FCNYS Section
1207.1.6.2.
Table 2-FCNYS Analysis Approval
Compliance Requirement Nexamp Assessment
1. Fires will be contained within Not applicable. The Megapack 2 XL is
unoccupied ESS rooms for the intended for outdoor ground-mounted
minimum duration of the fire installations only and shall not be installed
resistance rating specified in Section within any ESS rooms or structures
9.6.4
2. Fires and products of combustion will Compliant. The facility shall not be occupied
not prevent occupants from evacuating except for maintenance purposes. However, in
to a safe location the event of a failure during maintenance,
hazardous conditions are anticipated to be
detected by the Megapack BMS.
Additionally, voluntary testing and third-party
analysis performed on products of
combustion from the Megapack 2/XL at
locations 20 ft and 5 ft conclude no traces of
Mercury or 27 different
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 16
metals tested for. HF was detected at values
of 0.10 and 0.12 ppm over the course of the
test—
far below accepted NIOSH Immediately
Dangerous to Life or Health (IDLH) value of
30 ppm for HF.
3. Deflagration hazards will be addressed Compliant. The Megapack 2 XL is equipped
by an explosion control or other with deflagration protection in the form of
system pressure sensitive vents and sparker system
designed to ignite any flammable gases and
release in a
controlled manner before they are allowed to
accumulate and create an explosive
atmosphere within the enclosure.
Site-Specific Exposure Assessment
4 i i
To understand whether the product HMA aligns with the site-level HMA, an exposure
assessment stemming from the product to external exposures must be conducted. This is
performed through a comprehensive analysis of testing reports and independent review of the
technology and its test results.
Tesla has commissioned several technical assessments,tests, and analyses on its MP2XL product
through independent engineers and NRTLs. In the Megapack 2XL Fire Protection Engineering
Report a detailed analysis of the MP2XL's UL 9540A test results is provided. In this analysis, it
was demonstrated that at no point during the UL 9540A test did the heat flux generated from the
thermal runaway event exceed 1.3 kW/mZ, which is a performance criteria of the UL 9540A test.
Following the UL 9540A test, Tesla conducted additional product testing and fire modeling for
the MP2XL. This consisted of destructive testing that exceeded the requirements of UL 9540A
and subsequently required for the UL 9540 listing (which the MP2XL is listed to). The test was
performed on a fully populated MP2XL. Using the results from this test, Tesla generated a heat
flux model that provided the maximum predicted heat flux at various targets, located at various
distances. Figure 7 details the results of heat flux modeling.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 17
Radiation Condition Target Location Maximum Predicted
Emitting From and distance Heat Flux (W/m')
bin 5,125
18 in 4,400
MP2/2XLCabinet With or Back and Side
(hot surface) Without Wind Targets �ft 3,65(?
4 ft 3,175
8 ft 2,900
Flames: Front of the No wind 9 ft 8,5U0
MP2/2XL Cabinet (vertical flames)
i r,Jrit Target
Flames: Front of the Worst-case wind
M P2/2XL cabinet (45'tilted flames} 8 ft 11"765
Flames:Top of the Worst-case wind Back and Side
MP2/2XL Cabinet (45'tilted flames) Targets +In 12,&28
Figure 7-Tesla Destructive Testing Heat Flux Results
Furthermore, the model was used to predict heat flux targets at distances of 8, 10, 20, 50, and
100 feet. This is further shown in Figure 8. The model demonstrates that the maximum heat flux
at 20 feet is approximately 3 kW/m2, at 50 feet is approximately 0.5 kW/m2, and at 100 feet is
less than 0.25 kW/m2.
Heat flux to the front of MP
1U
Sft
9 10(t
20ft
ti 50(t
-� 100ft
7
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X 5
LL
m 4
as
3
2
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Figure 8- Tesla Destructive Testing Heat Flux Model Prediction
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 18
Exposure Analysis
An impact of all exposures within 100 feet was assessed by Nexamp. Where exposures are
negatively impacted, Nexamp is required to implement mitigation measures. Note that the
analysis is based on predicted heat flux exposure to the subject locations based on the data
provided through Tesla. Exposures are defined in Section 9.6.2.7.1 of NFPA 855 (2026 edition)
as follows:
• Lot lines
• Public ways
• Buildings
• Stored combustible materials
• Hazardous materials
• High-piled stock
• Other exposure hazards not associated with electrical grid infrastructure
In the previous Nearby Exposures section of this document, Nexamp has identified residences
and the PV array as primary site exposures. As noted earlier, the residences are approximately
300—600 feet from the BESS; therefore, significantly reducing heat flux risk according to data
provided through Tesla. The PV array, approximately 50 feet from the BESS, as well as certain
other site exposures, were analyzed as potential hazards in Nexamp's FMEA. These include,but
are not limited to, vegetative/brush fire and BESS noise. Please refer to the MS Excel FMEA
provided as a separate document (Ref. 1).
In assessing the site layout, it is evident that heat flux risk minimal at any point of the 100-foot
radius with the heat flux anticipated to be at 0.25 kW/m2. The exposures within a 100ft radius of
the BESS include adjacent equipment associated with the BESS. Using the predicted heat flux at
those distances it is anticipated that both exposures would be subject to less than 0.5 kW/m2. It
should be noted that 1 kW/m2 is the equivalent of the nominal solar constant on a clear summer
day. In treating the fire as additive to the solar exposure, conservatively the heat exposure would
be less than 1.5 kW/m2. However, at a heat flux of less than 1.5 kW/m2 the risk is deemed to be
low.
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 19
References
1. Jerry Smith Storage FMEA. "Nexamp—Jerry Smith Storage—Hazard Mitigation
Analysis (FMEA)—Site specific 052626—CONFIDENTIAL.xlsx"
2. Jerry Smith Storage ERP. "Nexamp—Jerry Smith Storage—Draft BESS Emergency
Response Plan_052626.pdf'
3. IEC 60812,Analysis Techniques for System Reliability—Procedure for Failure Mode
and Effects Analysis (FMEA), 2nd Edition
4. Industrial Lithium-ion Battery Emergency Response Guide. For Tesla Industrial Energy
Products including Megapack and Powerpack. Tesla. Revision 2.7, 2024
5. Fire Protection Engineering and UL 9540A Interpretation Report. Fire and Risk Alliance.
Rev. 0, 2024
6. Application Note: Considerations for Hazardous Materials Business Plans. Tesla. 2024
7. Megapack 2XL Operation and Maintenance Manual. Tesla. Revision 11.13.2025
8. Megapack 2XL System Specification. Tesla. Revision 11.19.2025
9. Megapack 2XL Design and Installation Manual. Tesla. Revision 11.13.2025
10. Megapack 2XL Transportation and Storage Guidelines. Tesla Revision 11.13.2025
Jerry Smith Storage— Hazard Mitigation Analysis— May 2026 20