HomeMy WebLinkAbout12a Jerry Smith ESS_Fire Safety Compliance Plan N exa m p Energy Storage Fire Safety
Compliance Plan
Document Scope
This document provides a reference guide describing how Nexamp's standalone battery
energy storage system (BESS) projects comply with the New York State Fire Code (NYSFC)
2025,specifically Chapter 12 -Section 1207: Electrical Energy Storage Systems.
The purpose of this document is to summarize how the energy storage system proposed for
the following project meets the applicable requirements of NYSFC Section 1207:
• Jerry Smith Energy Storage Project
This document presents a structured review of the relevant code provisions and identifies
how the project design, equipment specifications,operational procedures,and supporting
documentation demonstrate compliance with the applicable fire code requirements.
This document does not reproduce the full text of the New York State Fire Code and should
be reviewed in parallel with the official NYSFC 2025 publication and other applicable codes
and standards.The document is intended to support review by the Authority Having
Jurisdiction (AHJ),fire departments, and other stakeholders evaluating project safety and
code compliance.
This document describes the fire code requirements only as they apply to the proposed
outdoor,grid-scale electrochemical energy storage systems for the referenced projects.
Additional requirements may apply based on local jurisdictional amendments,site-specific
conditions,or determinations by the AHJ.
Project design, installation,and operation will also follow applicable national standards and
referenced codes including where applicable:
• NFPA 855 -Standard for the Installation of Stationary Energy Storage Systems
• NFPA 70-National Electrical Code
• UL 9540-Energy Storage System Safety Standard
• UL 9540A-Thermal Runaway Fire Propagation Testing
• Applicable New York State Building and Fire Codes
Supporting project documentation referenced in this compliance guide may include:
• Hazard Mitigation Analysis (HMA)
• Emergency Response Plan (ERP)
• System commissioning documentation
• Manufacturer safety and certification documentation
• Site design drawings and equipment layouts
• Operations and maintenance procedures
This document is intended to assist regulators,fire officials,and project stakeholders in
reviewing the safety design of the energy storage systems and verifying compliance with
the applicable fire code requirements.
References
The following codes,standards,and project documents are referenced throughout this
compliance guide:
• New York State Fire Code (NYSFC) 2025 -Chapter 12, Section 1207
• New York State Building Code (2025)
• NFPA 855 -Standard for the Installation of Stationary Energy Storage Systems
• NFPA 70-National Electrical Code
• UL 9540 - Energy Storage Systems
• UL 9540A-Test Method for Evaluating Thermal Runaway Fire Propagation
• Project Hazard Mitigation Analysis (HMA)
• Project Emergency Response Plan (ERP)
• Manufacturer equipment documentation
Fire Safety Compliance Plan — NYS Fire Code 2025
Chapter 12 -Section 1207 Electrical Energy Storage Systems (ESS) Compliance Checklist
This table is intended to document compliance with NYS Fire Code Section 1207 for Energy
Storage Systems.
Code Section Requirement Project Compliance Plan Supporting
Summary Documents Notes
1207.1 General General application statement in code. No
applicability of compliance requirement set forth.
ESS fire code
requirements
1207.1.1 Utilities and General application statement in code. No
Industrial compliance requirement set forth.
applications
1207.1.2 Mobile ESS N/A as this is not a mobile ESS
1207.1.3 Scope General application in code for applicable
energy capacity. Lithium-ion set at 20 kWh
and above.No compliance requirement set
forth
1207.1.4 Permits Nexamp plans to work with the town of clay to Nexamp permit applications
required for obtain the following permits to comply with and town/planning board
installation, this section: sessions
modification,or 1. Building permit
removal of ESS 2. Operating ermit
1207.1.4.1 Communication N/A as this section is related to lead-acid and
utilities nickel-cadmium batteries
1207.1.5 Construction Nexamp has provided the following to comply - Nexamp HMA
Documents with this section: - Nexamp ERP
- Location and layout diagram of area in - Megapack 2XL
which ESS is to be installed. Specification
- Details on the hourly fire-resistance - Megapack 2XL Fire
ratings of assemblies enclosing the Protection Engineer
ESS. Report
- The quantities and types of ESS to be - Nexamp site layout
installed. - Megapack 2XL
- Manufacturer's specifications,ratings, Compliance
and listings of each ESS summary
- Description of energy(battery) - Megapack NFPA 855
management systems and their Compliance Guide
operation - Nexamp
- Location and content of required commissioning plan
signage - Nexamp
- Details on fire suppression,smoke or Decommissioning
fire detection,thermal management, plan
ventilation,exhaust and deflagration - Megapack
venting systems,if provided commissioning
- Support arrangement associated with protocol
the installation,including any seismic
restraint.
- A commissioning plan
- A decommissioning plan
- A fire safety and evacuation plan
- Peer reviewer identification and
qualifications NYSERDA
1207.1.5.1 Utilities N/A as the ESS is not owned and operated by
Applicabili electric utility
1207.1.6 Hazard Nexamp has developed and created site - Nexamp HMA
Mitigation specific HMA's for the project it is proposing. - Megapack 2XL Fire
Analysis Protection Engineer
Report
1207.1.6.1 Fault condition The HMAs provided have evaluated the - Nexamp HMA
consequences of the following failure modes: - Megapack 2XL Fire
1. A thermal runaway condition of single Protection Engineer
electrochemical ESS unit Report
2. A mechanical failure of a
nonelectro chemical ESS unit(N/A)
3. Failure of any battery(Energy)
management system or fire protection
system within the ESS equipment that
is not covered by the product listing
FMEA.
4. Failure of any required protection
system external to the ESS,including
but not limited to ventilation,exhaust
ventilation,smoke detection,fire
detection,gas detection or fire
suppression system
1207.1.6.2 Analysis The HMAs will be provided to Lansing Fire - Nexamp HMA
approval Department(Fire Code Official) for review - Megapack 2XL Fire
and approval Protection Engineer
Report
1207.1.7 Large-scale fire The Tesla Megapack 2XL has been tested to UL - Megapack 2XL Fire
test 9540A at the cell,module,and installation Protection Engineer
levels. Report
1207.1.8 Fire Nexamp,as the system owner shall at their - Nexamp
Remediation expense mitigate the hazard or remove decommissioning
damaged equipment from the premises to a plan.
safe location where a fire or other event has - Nexamp HMA
damaged the ESS. - Nexamp Emergency
Response Plan
1207.1.8.1 Hazard Support Nexamp as the system owner is responsible - Nexamp Emergency
Personnel for ensuring thar one or more hazard support Response Plan
personnel is dispatched within 15 minutes - Nexamp
and arrive to the premise within 4 hours. Decommissioning
Nexamp itself alongside contracted hazard Plan
support SMEs will attend to this
responsibility.These personnel will remain on
duty continuously after the fire department
leaves the premise and until the damaged
energy storage equipment is removed from
the premises or earlier if the fire code official
indicates the public safety hazard has been
abated.
1207.1.8.2 Duties On-duty support personnel will be - Nexamp Emergency
responsible for the following: Response Plan
1. keeping diligent watch for fires, - Nexamp
obstructions to means of egress and Decommissioning
other hazards. Plan
2. Immediately contact the fire
department if their assistance is
needed to mitigate any hazards or
extinguish fires.
3. Take prompt measures for
remediation hazards in accordance
with decommissioning plan.
4. Take prompt measures to assist in the
evacuation of the public from the
structures
1207.1.8.3 Qualifications All Nexamp (employed and contracted) Nexamp to provide list of
personnel will be trained in design, personnel and
operations,and special hazard mitigation qualifications prior to
associated with the ESS facility.All personnel construction.
will be knowledgeable of the fire safety plan,
pre-incident plan,emergency operations plan,
and HMA.All personnel will have completed
the following classes:
1. ICS-100, Introduction to the Incident
Command System
2. IS-200: Basic Incident Command
System for Initial Response
3. IS-700,An introduction to the National
Incident Management System
1207.2 Commissioning, General section overview.Requirements
decommissioni outlined in subsections below
ng,operations
and
maintenance
1207.2.1 Commissioning The ESS being placed in service will be done in - Nexamp
accordance with the commissioning plan that commissioning plan
has been approved prior to initiating - Megapack
commissioning. commissioning
protocol
- Nexamp
decommissioning
plan.
- Nexamp ERP
1207.1.1 Initial During the commissioning process the ESS - Nexamp
Acceptance shall be evaluated for proper operation in commissioning plan
Testing accordance with manufacturer's instructions - Megapack
and commissioning plan prior to final commissioning
approval.Nexamp will commission the system protocol
alongside Tesla personnel
1207.2.1.2 Commissioning A commissioning report describing the results - Nexamp
Report of system commissioning will be provided to commissioning plan
the fire code official prior to final inspection Megapack
and approval and maintained at an approved commissioning
on-site location. protocol
1207.2.2 Operations and Nexamp has provided its 0&M plan and - Tesla 0&M manual
Maintenance Tesla's 0&M manual.The ESS will be operated
and maintained in accordance with the
manual and a copy shall be retained at an
approved on-site location.
1207.2.2.1 Ongoing All systems that monitor and protect ESS - Tesla O&M manual
inspection and installation will be inspected and tested in
testing accordance with manufacturer's instructions
and the 0&M manual.All inspection and
testing records shall be maintained in the
0&M manual.Nexamp and Tesla will conduct
24/7 monitoring of the system for planned
and unplanned maintenance,with planned
maintenance occurring at least once a year.
1207.2.3 Decommissioni Nexamp will notify the code official prior to - Nexamp
ng the decommissioning of the ESS,with decommissioning
decommissioning being performance in plan
accordance with the decommissioning plan. - Nexamp ERP
1207.3 Equipment General section overview.Requirements
outlined in subsections below
1207.3.1 Energy storage The ESS is listed to UL 9540 - Megapack 2XL
system listings Compliance
Summary
- Megapack 2XL Fire
Protection
Engineering Report
1207.3.2 Equipment Chargers,inverters,and EMS are covered as - Megapack 2XL
listings part of the UL 9540 listing Compliance
Summary
- Megapack 2XL Fire
Protection
Engineering Report
1207.3.3 Utility Inverters are listed and labeled in accordance - Megapack 2XL
interactive with UL 1741 Compliance
systems Summary
1207.3.4 Energy Storage The EMS will continuously monitor and - Megapack 2XL
Management balance cell voltages,currents,and specification
System temperatures within the manufacturer's - Megapack 2XL Fire
specifications.The EMS shall disconnect Protection
electrical connections to the ESS or otherwise Engineering Report
place it in a safe condition if potentially - Nexamp HMA
hazardous temperatures or other conditions
such as short circuits,over voltage or under
voltage are detected.
1207.3.4.1 Monitoring of The ESS shall be continuously(24/7) - Nexamp HMA
energy storage monitored at an attended monitoring station - Nexamp ERP
management by both Nexamp and Tesla's remote - Tesla 0&M Manual
system operations centers.The EMS will monitor - Tesla Emergency
temperature,voltage,state of charge for each Response Guide
enclosure on site.The monitoring facilities
will,without delay,make the following
notifications in the event the ESS exceeds or
appears likely to exceed thresholds at which
fire,explosion or other serious adverse
consequences may result:
1. Notify the local fire department
through the emergency dispatch
system.
2. Notify the fire code official to alter the
AHJ of the unsafe condition.
3. Notify hazard support personnel to
alert such individuals to be ready to
provide technical assistance to the
and/or respond to the incident
location.
4. Notify the manufacturer of the ESS to
make a qualified representative
available to provide technical
assistance to the responding hazard
support personnel,fire code official
and fire chief.
1207.3.4.1.1 Remote Nexamp and Tesla shall arrange for data
Monitoring of transmissions from the ESS EMS to an
energy attended remote monitoring facility staffed by
management trained and knowledgeable persons retained
system and by Tesla or Nexamp.
re ortin
1207.3.5 Enclosures The Tesla Megapack 2XLs enclosures are - Megapack 2XL
constructed with steel and are deemed Specification
noncombustible construction. - Megapack 2XL Fire
Protection
Engineering Report
1207.3.6 Repairs Repairs of the ESS will be performed by Tesla - Tesla 0&M manual
certified and qualified personnel.
1207.3.7 Retrofits N/A as Nexamp is not retrofitting an existing
ESS
1203.7.1 Retrofitting N/A as Nexamp's ESS is not lead acid or nickel
lead acid and cadmium
nickel cadmium
1203.8 Replacements N/A as an ESS is not being replaced
1203.9 Reused or N/A as the ESS is not reused or repurposed
repurposed equipment
equip ment
1207.4 General ESS General section overview.Requirements
installation outlined in subsections below
re uirements
1207.4.1 Electrical All ESS disconnecting means that are not - Nexamp site layout
Disconnects insight of the main electrical service - Nexamp single line
disconnecting means,placards,or directories diagram
will be installed at the location of the main
electrical service disconnecting means
indicating the location of stationary storage
battery system disconnecting means in
accordance with NFPA 70
1207.4.2 Working Access and working spaces are provided and - Nexamp site layout
clearances will be maintained about all electrical - Nexamp single line
equipment to permit ready and safe operation diagram
and maintenance of such equipment in - Tesla 0&M Manual
accordance with NFPA 70 and the - Tesla design manual
manufacturer's instructions
1207.4.3 Fire-resistance- N/A as the ESS is not in a room or other
rated indoor area
separation
1207.4.4 Seismic and The ESS will comply with the seismic design - Tesla site design
structural requirements in Chapter 16 of the Building manual
design Code of New York State.This will be shown on - Nexamp site layout
Nexamp's construction set drawings - Megapack 2XL
specification
1207.4.5 Vehicle Impact ESS area is be surrounded by fences and noise - Nexamp Site Layout
protection barriers.Each Megapack 2XL is IK09 impact - Megapack 2XL
rated. specification
1207.4.6 Combustible No combustible materials are storage in the - Nexamp site layout
storage ESS area or enclosures.Any combustible
material is sited at least 10ft from any ESS
enclosure/cabinet despite the requirement
being 3ft
1207.4.7 Toxic and Each Megapack 2XL is equipped with - Megapack 2XL
highly toxic deflagration vents at the top of the enclosure specification
gases and equipped with 12 sparkers for gas - Megapack 2XL Fire
management Protection
Engineering Report
1207.4.8 Signage Nexamp will provide signs on or adjacent to
the Megapack 2XL units. Signs are designed to
meet both requirements outlined below and
NFPA 70:
1. "Energy Storage System"and"Battery
Storage System"
2. The identification of electrical ESS
technology present(lithium-ion
3. "Energized Electrical Circuits"
4. "Apply no water'
5. Current contact information,including
phone numbers,for personnel
authorized to service the equipment
and for fire mitigation personnel.
6. Relevant hazard warnings,maps of the
site,ESS enclosures,and associated
equipment and isolation distances that
response personnel should maintain
from ESS involved in fire or where
there may be a risk of explosion or
deflagration.
7. Most recent date the sign was
produced or updated.
8. Identification of multiple power
sources
1207.4.8.1 Sign Features All signs installed by Nexamp will:
1. Be a minimum size of 18 inches by 24
inches.
2. The letters providing warnings
identified in 1,3,and 4 of section
1207.4.8 at least 5 inches in height.
3. The number designating all other
required information of at least 1 inch
in height.
4. Characters and their background will
have a non-glare finish. Characters will
contrast with their background,with
either light characters on dark
background or dark characters on a
light background
1207.4.9 Security of The ESS area will be fenced and secured - Nexamp site layout
installations against unauthorized entry.
1207.4.9.1 Video The ESS area will be monitored by camera
monitoring 24/7 and will provide the following:
1. A minimum look back period of 72
hours.
2. Surveillance coverage of the ESS
enclosures and the entry points of the
facility
3. In the case of an incident,the video
surveillance will be made available to
the fire department and fire code
official for viewing
1207.4.10 Occupied work N/A as the ESS is not an occupied work center
centers
1207.4.11 Open rack N/A as there are no open rack installations
installations
1207.4.12 Walk in units N/A as the Megapack 2XLs are not walk in
units
1207.5 Electrochemical General section overview.Requirements
ESS protection outlined in subsections below
1207.5.1 Size and Large-scale fire testing demonstrates the - Tesla site design
separation ability for larger than 50 kWh groupings and manual
smaller than 3ft separation distances between - Megapack 2XL Fire
Megapack 2XL enclosures Protection
Engineering Report
1207.5.2 Maximum N/A as there are no fire areas within rooms
allowable and walk-in units
uantities
1207.5.2.1 Mixed N/A as this ESS only uses one type of
electrochemical electrochemical system (lithium-ion)
energy systems
1207.5.3 Elevation The ESS is not installed on a floor located - Nexamp site layout
more than 75 feet above the lowest level of
fire department vehicle access-it is on grade
with such access.
1207.5.4 Fire Detection Not applicable as the ESS is not in a room, - Megapack NFPA 855
indoor area or walk-in unit.However,BMS Compliance guide
and video cameras will be capable of detecting - Nexamp site layout
fires. - Megapack 2XL Fire
Protection
Engineering Report
1207.5.4.1 System status N/A as the ESS is not a lead-acid or nickel-
cadmium battery system
1207.5.4.2 Alarm criteria In accordance with Tesla's instructions and - Nexamp ERP
registered design professional's specifications
for the ESS,alarm activation criteria will be
set to minimize non-emergency alarm
activations for all fire detection,temperature,
other emergency system sensors
1207.5.5 Fire N/A as the ESS is not in a room,building, or
Suppression walk-in unit.
Systems
1207.5.6 Maximum ESS The Tesla Megapack does not exceed the - Megapack
enclosure size maximum size and has dimensions of specifications
approximately 28.5 ft x 6 ft x 9 feet high.
1207.5.7 Vegetation All areas within 10ft from the ESS will be - Nexamp site layout
control cleared of vegetation and managed such that - Tesla site design
no vegetation growth occurs.Gravel will be manual
installed on all sides of each ESS enclosure
and within the BESS area.
1207.5.8 Means of Egress All means of egress on site ensure safe egress - Nexamp site layout
Separation under fire conditions and allow for at least
10ft of separation.
1207.6 Technology- General section overview.Requirements
s ecific ESS outlined in subsections below
protection
re uirements
1207.6.1 Exhaust N/A for lithium-ion technology as per Table
ventilation 1207.6
1207.6.2 Spill control N/A for lithium-ion technology as per Table
and 1207.6
neutralization
1207.6.3 Explosion Each Megapack 2XL consists of deflagration - Megapack 2XL Fire
Control vents on the roof as a means of explosion Protection
control. In addition, 12 sparkers are fitted Engineering Report
within each Megapack to reduce the potential - Nexamp ERP
of built-up flammable/explosive gas to protect - Nexamp HMA
against a deflagration
1207.6.4 Safety caps N/A for lithium-ion technology as per Table
1207.6
1207.6.5 Thermal ESS is listed to UL 9540 and has conducted - Megapack 2XL Fire
Runaway large-scale fire testing under UL 9540A Protection
Engineering Report
- Megapack 2XL
compliance
summary
- Megapack NFPA 855
Compliance guide
1207.7 Indoor This section is N/A as this ESS is an outdoor - Nexamp site layout
installations installation
1207.8 Outdoor ESS General section overview. Requirements
installation outlined in subsections below.
1207.8.1 Remote The ESS is considered a remote outdoor - Nexamp site layout
outdoor installation as the ESS is located more than
installations 100ft from lot lines and public ways
1207.8.2 Installations The ESS is not considered an installation near - Nexamp site layout
near exposures exposures as it is classified as a remote
outdoor installation as per 1207.8.1
1207.8.3 Clearance to The ESS located outdoors is separated by a - Nexamp site layout
exposures minimum of 10 feet from the following
exposures:
1. Lot lines
2. Public ways
3. Buildings
4. Stored combustible materials (N/A)
5. Hazardous materials (N/A)
6. High-piled stock(N/A)
7. Other exposure hazards
1207.8.4 Exterior wall N/A as the ESS in not installed on the exterior
installations walls of any buildings. Each ESS unit is ground
mounted to a concrete pad
1207.9 Special Section is N/A as the ESS is not located on a
Installations rooftop or open parking garage
1207.10 Mobile ESS Section is N/A as the ESS is not a mobile ESS.
requirements ESS is stationary.
1207.11 ESS in Group R- Section is N/A as the ESS is not located in a
3 and R-4 Group R-3 or R-4 occupancy
occupancies
1207.12, Peer review Nexamp will be responsible for retaining and
1207.12.1, furnishing the services of a registered
1207.12.1.1, professional engineer or special expert to
1207.12.1.2, perform a peer review,subject to the approval
1207.12.2 of the fire code official.This will either be
facilitated by NYSERDA's Peer Review Process
or Nexamp will directly contract ESRG for this
service.A peer review report will be
commissioned and provided to all AHJs
1207.13 First responder Nexamp has developed an ERP for the facility, - Nexamp ERP
pre-incident with a draft plan included in its permit - Megapack 2XL Fire
plan application and provided to the fire code Protection
official/fire department.The plan will be Engineering Report
further developed in consultation with the - Nexamp HMA
Lansing Fire Department and will adhere to
the requirements in Section 11 of Annex G of
NFPA 855.
1207.13.1 First responder Nexamp will provide an annual visit and - Nexamp ERP
site review of the pre-incident plan developed to
familiarization the Lansing Fire Department
1207.14, ESS third party Nexamp will facilitate a third-party fire safety
1207.14.1 fire safety inspection performed every 3 years or more
inspection frequently as requested by the fire code
official.The inspection will be performed by a
registered profession engineer or special
expert.The ESS third-party fire safety
inspection shall cover the following:
1. Structural integrity and weather
tightness of enclosures
2. Operation and maintenance of the ESS
3. Emergency operations plan
4. Hazard mitigation analysis
5. Electrical inspection
6. Explosion control verification
7. Monitoring procedures and history
8. Alarm activation criteria and history.
9. System performance concerns
10. Fire protection system (s) and testing
records.
11. Ventilation system
12. Other items requested by the AHJ