By David Wojick
Washington State’s environmental agency, the Department of Ecology, recently took comments on dual draft Programmatic Environmental Impact Analyses (PEIS) for wind and solar developments. Unfortunately while each had a section on grid battery fires there was significant confusion as each cited a regulation that as I read it does not apply to grid scale battery complexes.
So I posted the comments below to help them develop the desperately needed regulations.
“Comments of David Wojick, Ph.D. on the Washington Department of Ecology “draft PEIS for wind and solar” regarding the potential impact of grid scale battery fires
Submitted October 26, 2024
The wind and solar PEIS address the very serious issue of spontaneous fire in the huge battery complexes that often accompany wind and solar projects.
In particular section 3.6.1.1 of appendix G in both PEIS says this:
“WAC 51-54A-0322 includes requirements for storage of lithium-ion and lithium metal batteries. Permits are required when more than 15 cubic feet of most battery types are accumulated. A fire safety plan is required and must include emergency responses to be taken upon detection of a fire or possible fire. Where required by the fire code official, a technical opinion and report complying with Section 104.8.2 should be prepared to evaluate the fire and explosion risks associated with the storage area and to make recommendations for fire and explosion protection. The report must be submitted to the fire code official and should require the fire code official’s approval prior to issuance of a permit. In addition to the requirements of Section 104.8.2, the technical opinion and report should specifically evaluate the potential for deflagration of flammable gases released during a thermal runaway event.“
Unfortunately it is highly likely that this regulation does not apply to wind and solar battery complexes. It covers battery storage while these complexes are batteries in use. Thus they are likely exempt under this exception listed in section 322.1:
“2. New or refurbished batteries packed for use with the equipment, devices, or vehicles they are designed to power.“
In this case the equipment being powered is the grid, including stabilization.
It appears that this regulation is either not applicable to wind and solar battery complexes or it is being ignored. In either case this raises the reasonably likely impact of a huge multi-battery fire. That impact needs to be properly assessed, not just mentioned in passing as these draft PEIS seem to do.
An example may be helpful. I recently wrote an article on the desperate national need for standards of design and emergency preparedness for grid scale battery complexes. The title is “Grid scale battery fires loom large.”
By coincidence my example is the Washington State wind-solar-battery project at Horse Heaven. Lax permitting of a very dangerous project is my focus.
Here is the relevant excerpt :
“Now let’s turn to permitting these facilities where I have another example that speaks volumes. This is a facility that just got permitted by Washington State. It is a combined wind, solar and battery project with a proposed storage capacity of 300 MW…. It might have 200 huge lithium battery units. That number is not disclosed.
The project is named the Horse Heaven Wind Farm despite its massive solar and battery components. The name, usually shortened to Horse Heaven, is truly ironic because it will be no place for horses. Horse Hell might be better.
The permitting authority is the Washington Energy Facility Site Evaluation Council or EFSEC for short. The permit is called a Site Certification Agreement or CSA and Horse Heaven just got one, with a big push from the Governor.
The astounding point is that there was no discussion, or even recognition, of the fire threat posed by this enormous lithium battery facility. The CSA has numerous requirements for lots of issues, big and small, right down to the facility having water to keep the road dust down. There is nothing on having a million or so gallons to prevent a catastrophic conflagration, nor on the environmental impact of such.
This is wildfire country so there should be liability insurance for harm to others from a fire. Other potential sources of harm are huge amounts of contaminated water runoff as well as toxic air emissions, especially if the whole facility burns.
This neglect no doubt flows from the Horse Heaven Application. The App is over 500 pages long and I can find just one sentence about battery fires. Buried in a long paragraph on PDF page 366 we read “Lithium-ion battery storage may pose a risk of fire and explosion due to the tendency for lithium-ion batteries to overheat.”
This single sentence does not even refer to the project. For that matter there are only a few paragraphs about the battery facility in the entire App, mostly just describing it in general terms. There is nothing about the number of giant battery containers or that it is a huge project in its own right, posing an equally huge fire threat. In fact the App says they might double deck these container sized battery units which is absurd given the risk of setting off a chain reaction in the whole complex.
One can easily think from the Application that the batteries are of no significance and that appears to be exactly what has happened at the EFSEC.
This systematic neglect looks to be what is happening around the country. We desperately need a national code or standard covering this issue. The National Fire Protection Association says it is working on one, but it is up to the permitting authorities to make something happen.
The growing threat of grid scale battery fires is a very serious issue calling for equally serious action.“
See https://www.cfact.org/2024/10/01/grid-scale-battery-fires-loom-large/
To continue, Horse Heaven is in dry, wildfire prone country and I have read that 100,000 people live within 5 or 6 miles of it. Clearly there is a real threat of enormous property damage and even loss of life if a battery fire gets out of control. This potential impact needs to be included in the PEIS assessment as it is likely to be true for many battery complexes throughout much of the State. Most of the State is dry.
I therefore recommend as follows:
Washington State needs to quickly promulgate and enforce fire safety regulations specifically for grid scale battery complexes. These should cover emergency planning and preparedness, where the latter includes both facility design and material readiness. Design includes container spacing and other necessary engineering features. The material readiness includes having a supply and delivery system for water and/or fire suppressants as needed to prevent a chain reaction of container fires.
In closing I disagree with the PEIS statements that grid scale battery fires are “very rare” as this makes it sound like the threat is not serious which it surely is. There are relatively few battery complexes in America yet there have been a significant number of fires. See for example
A large number of grid scale battery complexes are presently proposed for Washington State and the scale of the threat is correspondingly enormous.
I am happy to discuss any of the above issues or to provide additional information.
Respectfully submitted,
David Wojick, Ph.D., exPE
Policy analyst and advisor to CFACT
Committee for a Constructive Tomorrow”
End of comments submitted.
Here’s hoping they listen.
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Nothing will be done until the brown stuff hits the air conditioning and then the blame game will start.
I was about to say similar.
My sense is that the Ecology Dept wants to regulate grid battery complexes so maybe something will happen.
David,
the Ecology Dept wants the power to regulate, in the way they see as fitting at the time.
Giving them that power may result in a good poke in the eye to the renewable people, but the power does not go away … it is still there for them to use in the future when, as they see it, it is needed.
Be careful how you encourage, delegate, or reinforce power to entities such as this.
They already have the power. I am trying to direct it to useful ends.
Any rules MUST consider the chemistry involved.
For instance, in the days of grid power being DC, large battery banks were used for grid leveling, some of these were a full city block (small block?) of lead acid batteries, Still used today are large banks of lead acid in use in telephone central offices. Is there any fire problem with these. Obviously they know about and know how to deal with H2 emissions.
We are also hearing frequently of new chemistries for cars motive batteries being on the horizon. Whatever comes after Lithium based, will probably have different fire/explosion potentials, if any, and regulations must be aimed only at those specific risks and not assume ALL chemistries are prone to the risks of lithium batteries.
We should not fall into the trap of sever, Lithium inspired, regulation of non hazardous batteries as is so typical of regulators.
As electro-chemical batteries contain both parts of a chemical reaction, they have the same sort of risk as other explosives. The more energy stored, the larger the possible reaction.
At least, LiIon batteries seem to reliably deflagrate, rather than detonating.
“they have the same sort of risk as other explosives.”
Ever hear of a lead-acid battery catching fire or exploding, assuming proper venting of H2.
“assuming”?
I had a lead acid battery explode in my car.
Still within warranty. It blew when I turned the car on.
Lead does not explode
H2SO4 does not explode
Hydrogen does explode, but it has to be contained or its gone as it is lighter than air. So obviously, your lead acid battery vent was faulty.
Of course the issue here is can a dangerous fire start, or just a rare, contained event. Lead and H2SO4 are well known to NOT BURN easily. Same for lead oxide. The weight is not a problem for grid leveling. Cycle life is the only issue that I am aware of and one wonders how many people are working to extend that.
Some other chemistries have high density but are not considered rechargeable. We forget that an alkaline D cell is around 23 Whr.
I had to replace a lead-acid battery on my motorboat. I put the new one on the pontoon and started to uncouple the old one in the battery locker. After about 5 minutes the new one exploded on the pontoon. Granted it was sitting in the sun but it was a cold Scottish winter day.
Nobody could explain it but the supplier replaced it and took it up with the manufacturer who put it down to faulty manufacturing.
As a kid I used to like tossing flashlight D cells into the camp fire. So yes. It’s deafening.
I’m not aware of any flammable materials in a carbon-zinc cell.
serious issue of spontaneous fire
Not to mention the nasties emitted from battery fires. Even worse is the complete waste of money. An EV refuse truck, apparently, costs £580,000…
The lithium battery-powered trucks were recently launched under Sadiq Khan, the Mayor of London, as part of a green initiative to reduce carbon emissions in the capital.
https://notalotofpeopleknowthat.wordpress.com/2024/10/28/electric-bin-lorry-bursts-into-flames-in-central-london/
Over half a million quid a pop.
No maintenance!
I bet the insurance premium just went up.
The broadcast msm completely ignored this ‘event’.
The electric bin lorry didn’t burst into flames; the fire ( probably from a ruptured vape or scooter battery) was in the compactor body (see the burn marks ), the rest of the lorry seems OK.
Probably?
Yeah, right.
The Westminster City Council is putting forth that statement. I’m inclined to believe it. If it had been the lorry’s battery set, the fire would have been much more spectacular. More like the bus fires we’ve seen in recent years.
Would you believe a smoldering cigarette? I wouldn’t.
“Emission free” vehicles is a myth.
serious issue of spontaneous fire
I don’t have a benchmark to translate “serious issue“.
Are we talking death and taxes (100%) or lottery jackpot (0.000001%)?
Large lithium ion or lithium metal batteries should require containment buildings built to nuclear power plant standards.
The funny thing is alkali metals are a popular feature in school chemistry lessons; chuck a small bit in a dish of water etc.
None of that seems to compute when people buy an EV. One thing I wonder is, have the batteries involved in spontaneous combustion previously been damaged in some way without the driver knowing?
When I took high school freshman basic science back in ’64 – the teacher dropped what I think was a tab of lithium in a glass of water. It flamed up- right to the ceiling and burned some of the asbestos (??) ceiling. The son of the school principle was in that class and almost certainly ratted on the teacher. That was his last year at the school.
Some teachers have no real idea. A friend of mine worked as a science tech – prepping demonstration experiments etc – faux pas’ included things like requesting a gas jar of Fluorine – in a dodgy old fume cupboard.
Elemental Fluorine has no place in an educational exercise of any kind, regardless of how top-notch the fume extraction is.
One thing I wonder is, have the batteries involved in spontaneous combustion previously been damaged in some way without the driver knowing?
Sometimes, sometimes now. A dendrite formation that penetrates the polymer causes a short and that’s all it takes. Nothing is perfect.
I have had to deal with incidents of lithium primary cells venting. One was due to human error. The other just happened. We learned from the second that storing the cells on their sides was not optimum and mandated storage with the cylindrical axis oriented to the z-axis (up).
There have been multitudes of reports of battery fires in laptops and cell phones. Given the plastic cases of both, it obviously was not due to physical damage. Improper charging cannot be eliminated. Use passed known life limitations is also part of it.
Lithium Reacting With Water – Stock Image – A500/0674 – Science Photo Library
Joseph Z’s teacher missed the “small bit” part of the instructions.
There are two factors at play, the energy density, which can only increase in the quest for longer range for EV’s, which then trickles into storage batteries as the high production volumes for EV’s reduces the price. The higher the energy density the fiercer and longer the combustion.
Then you have the BMS (battery management system0 which controls the rate of charge, voltages etc, good quality BMS’s will stop charging when the conditions start to deviate from the ideal, cheap and nasty BMS’s used on eBikes etc are just not to be trusted.
So longer term it can only get more risky.
Asking such questions proves you are a denier, and is doubleplus ungood crimethink.
Humor – a difficult concept.
— Lt. Saavik
O/T Attenburghee refuses…
“”David Attenborough said he didn’t need BBC’s pronunciation guide for new documentary
The 98 year-old ‘has met most of the animals, his great voice pronounces them all correctly straight off the bat’, says producer
The broadcaster and natural historian, 98, was said to have “politely” declined the offer of a guide to naming the animals and places because of the breadth of his experience and knowledge on the subject.
https://www.telegraph.co.uk/news/2024/10/29/sir-david-attenborough-bbc-asia-nature-documentary/
Pity he couldn’t refuse to lie about the alleged climate confused walrus.
Why isn’t battery technology developing batteries that don’t catch fire and that have other beneficial properties such as higher capacity, longer life and lower price?
It may not be possible. There are less fire prone ones being produced now, but they are lower density and seem to be a long time coming.
https://www.perplexity.ai/search/new?q=pending&newFrontendContextUUID=f06723fc-e405-4fbc-b62c-4139999d3684
20 years away is the general metric
Physics is a bitch.
There are limits in chemistry.
There is constant effort applied to do exactly what you are suggesting.
At issue is, the more energy per unit volume, the more ways a failure gets “exciting.”
Perfection is unobtainium.
The Search for the Magic Battery is long and ongoing.
There is a website called “The Cool Down”. That site has been running articles about every 2 weeks on a new battery breakthrough. Such articles have been less frequent recently. Maybe we know everything there is to know?
re: “Why isn’t battery technology developing batteries ”
Just off the top of memory I’ve seen, so far, in my lifetime (consumer-level technology), LeClanche (Zinc-Carbon) cells, Mercury cells, Lead-acid cells, Ni-Cad (Nickel Cadmium) cells, Ni-MH, Lithium cells, Lithium-Ion rechargeable cells, Lithium iron phosphate rechargeable (LiFePO4 offering safety margin improvement over Li-Ion but reduced density).
Now, I left out limited use, lab-grade proto and special-application tech.
Oops – left out Alkaline (zinc manganese) cells.
In most engineering challenges like this, all variables cannot be optimized at the same time.
Yes, engineering is a bitch too.
Here’s everything you need to know about LiFePO4 or LFP batteries.
https://www.neware-usa.com/news/neware_news/LiFePO4_Battery/69.html
“Lithium Iron Phosphate (LiFePO₄ or LFP) batteries are a type of lithium-ion battery that uses lithium iron phosphate as the cathode material and graphite as the anode. Known for their high safety, long cycle life, and thermal stability, LFP batteries have become increasingly popular in the electric vehicle (EV) industry. They offer a lower energy density compared to other lithium-ion chemistries, such as Nickel Manganese Cobalt (NMC) or Nickel Cobalt Aluminum (NCA), but their enhanced safety profile and longer lifespan make them particularly attractive for certain applications.
In the automotive sector, LFP batteries are extensively used by leading EV manufacturers like Tesla and BYD. Tesla, for instance, has integrated LFP batteries in its standard range Model 3 and Model Y vehicles. This strategic move allows Tesla to offer a more affordable option while ensuring safety and longevity, especially appealing in markets with less developed charging infrastructure. The use of LFP batteries helps Tesla mitigate the risks associated with battery thermal runaway and provides a more stable performance over time.”
Whilst the lower energy density of LFP batteries is a disadvantage, this is apparently being addressed, according to the following site.
https://www.ampinvt.com/blog/innovations-in-high-voltage-lifepo4-battery-technology-for-2024/
“The innovations in high voltage LiFePO4 battery technology for 2024 will have a significant impact on the electric vehicle industry. These batteries will provide higher energy density, improved cycle life, increased power density, enhanced safety, and reduced cost. This will make them even more attractive for electric vehicles and other applications.”
EVs are best suited for urban/suburban daily commute to work, grocery, and grandma’s house. Further, apartment dwellers in multi-storied units don’t have charging. Smaller, cheaper hybrids will be better suited for these situations. Companies will realize this and dial back on $70,000 bemouths. New battery technology is coming. Maybe before GM, Ford, and Stellantis go broke.
Google Earth will show where to find Horse Heaven Hills. It has been claimed that an early visitor to the rolling hills – grass covered – said: ”Surely this is Horse Heaven!”
Non-locals may encounter the area on WA Route #221 Between Prosser and Paterson, two stops on wine-touring weekends.
Recently installed solar facilities near Ellensburg can be seen here:
46.962763, -120.479436; and here: 46.973928, -120.573920
As a resident of Washington, I thank you very much, David, for your intervention here. Our governor is so enamored of wind and solar that he will do everything he can to suppress any opposition, even well-reasoned concerns like this. He and the rest of the climate cult support putting these battery farms all over the state — not just in areas like Horse Heaven, but embedded deep in urban areas. Not only are they a significant fire risk, but very noisy and not good neighbors at all. Washington has had radical environmentalists sabotage electrical infrastructure in the past, and if you think shooting a 50-caliber rifle into a transformer causes problems, imagine doing the same thing to a lithium-ion grid-scale battery. But the governor simply does not care about the risk, because he is a climate change zealot who firmly believes that the planet is at risk of becoming uninhabitable due to anthropogenic climate change. I cannot wait for him to be out of office at the end of this year. As bad as his likely successor is, at least he doesn’t appear to be such an over-the-top climate zealot (although he will still be beholden to the climate cult for his election to office).
The trouble with using regulations as a means of control is that in some future time, the other side will get to play controller. Then what?
“The power to tax is the power to destroy” is a quote from Chief Justice John Marshall in the 1819 Supreme Court case McCulloch v. Maryland.
Regulatory changes here in Washington, and I’m sure they happen in a similar fashion in other states are generally accomplished two ways – the State Legislature proposes a bill which is apparently argued and commented on, and either adopted into law or rejected; or more insidiously the State Department of Ecology under the auspices of its role under the federal EPA as protector of the air, soil, and water resources of the State propose and eventually adopt a regulatory change which also goes through a comment period prior to eventual adoption.
It is the development of the language of the proposed changes that is the real issue in my opinion. Most ‘lawmakers’ that put forth bills to the legislature are placed on committees that develop the bills. The actual wording of the proposed law changes cannot be expected to come from the actual committee members, as for the most part they are not subject matter experts (in this case in the field of battery-electric storage at grid scale). So, the technical portions of the bill are obtained from other, outside think-tank sources, or more as we have seen with the recent “Climate Commitment Act’ adopted here in WA, the bulk of the proposed bill language is basically plagiarized from the State of California Climate rules. In other cases, special-interest groups such as Labor Unions and Native American interests (as example) inject language to the committee members developing the bill that only really benefits themselves.
So, for real movement in adopting more targeted and real-world regulatory change regarding grid-scale battery safety issues, subject matter experts would need to provide technical support to either the legislative committee developing the bills, and/or the State DOE.
In one man’s opinion. Thoughts?
Best regards,
MCR
Yes there are lots of engineering issues. The National Fire Protection Association is supposed to be working on a new standards for grid batteries.
Nice work David. I can’t imagine the frustration working with these people. They are liars and cheats the whole lot of them. We desperately need individual accountability for these mongrels. Lying and cheating is not okay, they have to be stopped.
Here in southeastern Washington State, the Benton PUD held a series of forums last week to inform its customers that affordable reliable electricity is in jeopardy. I attended one of these forums.
These topics were included in the forums:
— Northwest is Close to Blackouts – How Did We Get Here?
— Washington and Oregon Clean Energy Policies – Global & U.S. Perspectives
— Washington Energy Strategy – Challenges and Concerns
— Where Do We Go From Here? – Near and Long Term
For those of you around the country and around the world who have been closely following the issue of reliable electricity, you will find that many of the topics you’ve been reading about and talking about are included in these two presentations.
Presentation Slides: Carbon-Free Electricity Policies Impacts and Perspectives
Presentation Slides: Q and A Session
Needless to say, the position the Benton PUD and its management is taking on this issue doesn’t sit well with the politicians on the west side of the state.
However, it is the west-siders in Oregon and in Washington who are most likely to be first to feel the adverse consequences of the region’s Net Zero energy policies.
grid scale battery fires are “very rare”I know of at least 30 fires in garbage trucks that were thought to have been caused by lithium batteries thrown in wheely bins and then there are the fires in ships and in public car parks ALL caused by EV’s.Very rare?Maybe WE should sue the manufacturers of said batteries?