Appeal 35044

1207.5.3 Elevation

Electrochemical ESS shall not be located where the floor is located below the lowest level of exit discharge (#2). Exception number 5 allows the fire code official to approve installation on lower floors.

Allow installation of LiFePO4 Batteries in the basement.

This basement is currently constructed with a cement floor, 8" thick concrete walls, and a ceiling of pan decking with approximately 17" of concrete above. We propose installing a fully grouted CMU wall with a 90 min hollow metal door to isolate the battery storage area from the egress stairs for the basement.

The battery systems are too heavy to place on the roof and there is not enough lot area to allow required separation from property lines and existing structures. By installing them in the basement we will be able to restrict access, improving safety for the general public. The batteries are necessary to allow MOWP to provide their community services by providing power stability and continued operations in times of emergency.

1207.5.1 Size and Separation

Code section requires batteries to be in groups of 50 kWh separated by 3 feet. Exception 4 allows the fire code official to approve larger quantities.

Allow installation of (3) 233 kWh LiFePO4 battery units.

Battery units are in a self-contained cabinet with integrated battery management system, liquid cooling, flammable/explosive gas detection, flammable/explosive gas exhaust, smoke detection, temperature detection, aerosol fire extinguish, siren and strobe alarm, and emergency stop button.

The units have these certifications UL1973, UN38.3, UL60730-1, UL9540A, UL9540, NFPA 69, UL 1741 Supplement SB - 3rd Edition, UL 1741 Supplement SA - 3rd Edition, SunSpec compliant, California Rule 21 compliant, EE2030.5, IEEE1547-2018, IEEE1547.1-2020, OpenADR

By using the self-contained all-in-one solution, we are able to provide higher energy storage safer than the 50 kWh groups defined in the code.

1207.5.2 Maximum Allowable Quantities

The code section limits the total size of battery storage to 600kWh per table 1207.5. Exception 1 allows for the fire code official to permit sizes that exceed table 1207.5.

Allow 699 kWh of battery storage, three of the proposed units.

Code lumps all Lithium-ion batteries in one category, however, the LiFePO4 chemical makeup of the proposed batteries is significantly more stable than other Lithium-ion batteries.

Battery room will have access restricted to the general public. Battery units are in a self-contained cabinet with integrated battery management system, liquid cooling, flammable/explosive gas detection, flammable/explosive gas exhaust, smoke detection, temperature detection, aerosol fire extinguish, siren and strobe alarm, and emergency stop button.

The units have these certifications UL1973, UN38.3, UL60730-1, UL9540A, UL9540, NFPA 69, UL 1741 Supplement SB - 3rd Edition, UL 1741 Supplement SA - 3rd Edition, SunSpec compliant, California Rule 21 compliant, EE2030.5, IEEE1547-2018, IEEE1547.1-2020, OpenADR

In order to use the self-contained units with all the included safety features the smallest size is 233 kWh. To be able to provide the maximum level of community service in an emergency situation MOWP needs a minimum of 600 kWh of battery storage. This also maximizes the benefits of the PV system on site.