Richard Ellenbogen
This post was put together by Roger Caiazza.
Earlier this year I assembled a post describing a white paper by Richard Ellenbogen M.E.E. titled The Intrinsic Danger of Siting Utility Scale Lithium Based Energy Storage Systems In Densely Populated Areas. In this post I summarize his New York State Public Service Filing An INES Type Scale to Rate Battery Energy Storage System (BESS) Incidents and a Comparison of 50 Years of US Nuclear Generating Plant Operation with the Past 2-1/2 Years of BESS Operation in the Unite“From a public safety standpoint, if you’ve decommissioned three nuclear reactors, why would you want to install a BESS facility in populated areas that is far less safe?”d States (“PSC Filing”). I italicized Ellenbogen’s direct quotes in the rest of this post.
Ellenbogen’s Introduction
NY State has become the proverbial “Lady that Swallowed the Fly”, with the fly being state energy policy over the past several years that has led to the NYISO warning about blackouts and major generation shortages in the very near future. NY State’s solution, or cure for those years of failed policy, has been to swallow the entire barnyard and all of the animals in it without adequately reviewing the consequences of their actions. For those unfamiliar with the parable, the lady dies at the end.
This is a very ironic situation because over the past 37 years, NY State has decommissioned three functioning nuclear reactors, Shorham’s 820 MW in 1989 and Indian Point’s two reactors with a combined 2000 MW capacity between 2020 and 2021. All of the units were shuttered essentially because of public fear of the systems and the associated political pressure.
That makes comparing nuclear plant safety with BESS safety a valid comparison for utility system viability and that is what this document will explain in detail. As the comparisons will show, a nuclear plant is a statistically far safer facility to have located in any community than a BESS System. The nuclear industry is far more regulated and has far more stringent reporting requirements, and as a result over its entire history dating back 65 years, it has caused far less, if any, environmental damage than a BESS industry that is less than a couple of decades old. In spite of that, NY State seems determined to inflict damage on its local communities to try and mitigate the damage from its failed energy policies.
Methodology
Ellenbogen reviewed nuclear incidents rated by the International Nuclear and Radiological Event Scale (INES) since 1975 and then used Perplexity AI to determine if there was a similar BESS event scale. Finding none he used Perplexity AI to develop a similar rating system and applied starting on January 1, 2024. The next figure shows the INES scale and summarizes the different levels.
Ellenbogen submitted the following query to Perplexity AI to rate BESS incidents.
Build a comparison dashboard between the IAEA’s INES nuclear safety scale and the NFPA 855 Standard for Stationary Energy Storage Systems. Contrast their methods of categorizing risk, detailing how each approach measures hazard severity (INES uses radioactive release, NFPA 855 uses fire-suppression and containment metrics). Include a summary of how battery industry analysts actually classify ‘thermal runaway’ events compared to nuclear ‘accident’ levels 4–7, and synthesize current industry frameworks for reporting site-level battery fires and containment failures into a structured, side-by-side positioning report
Ellenbogen Results
As is documented in the PSC Filing Appendix 3, the response was that there has only been one Level 4 INES event in the past 50 years and that was 47 years ago. The only other event, referenced as SL-1, occurred in 1961 and that was not a commercial nuclear plant. It was an experimental military reactor built when the nuclear industry was in its infancy.
Table 1 summarizes the eight Level 2 and higher events that have occurred at US nuclear plants since 1975. Radiation release was only associated with the Level 5 event at Three Mile Island and after 46 years, there have been no deaths associated with that event and no environmental damage. There was one level 3 event in 2002, 24 years ago, and six level 2 events with the latest being 16 years ago. That was related to an electrical fire in switchgear and not to the reactor. That type of fire also occurs in utility substations and goes unnoticed unless it turns the night sky blue over NY City. No radiation release was associated with the seven Level 2 and Level 3 incidents and there was no local impact from any of them.
Table 1: INES Level 2+ at US Nuclear Generating Plants Since 1975
As a comparison to the nuclear safety record documented above are the ten BESS incidents that have occurred in the United States during a period of 2-1/2 years since January 1, 2024, one twentieth of the timeframe of the nuclear analysis and one sixth of the timeframe since the last Level 2 or higher nuclear incident.
Figure 3 lists the ten incidents based upon the INES/BESS rating system created by Perplexity. There have been two Stage 4 events with major discharge of gases and heavy metals, four Stage 3 events and Four Stage 2 events. Note that two of the Stage 3 events were the newer LFP technology, and the description associated with them is “Better Contained”, not “Fully Contained.” Additionally, “Better” is a very relative term when the bar has been set so low by prior events. Also note the comment about the reporting vacuum regarding sub-ignition events. Contrasted with over 50 years of nuclear plant operation with no environmental damage, the record of Lithium based BESS systems over 1/20th the timeframe with significant environmental damage is abysmal. This is all fully documents in the PSC Filing Appendix 2
Figure 3: Battery Incidents at US Utility Scale Energy Storage Facilities Since 1/1/2024
Ellenbogen Implications
Ellenbogen also asked Perplexity: If battery fires release gases and heavy metals, how does that compare to a Level 2 nuclear generator incident that has no radiation release?
His submittal included the following Perplexity response:
BESS Fire Emissions vs. Level 2 Nuclear Plant Incident: What’s Actually Released
This is one of the most analytically uncomfortable asymmetries in the entireframework. The short answer: a Level 2 nuclear plant incident releases nothing into the environment by definition, while a Stage 2–4 BESS fire releases a chemically complex, multi-pathway hazardous plume that would trigger federal reporting requirements under almost any other industrial sector.
In the prior statement, Perplexity was stating that the Stages in its BESS Scale don’t correlate on an“Apples to Apples” equivalent with the INES Scale because a Level 2 Nuclear Event is far less impactful on the surrounding environment than its determination of a Stage 2 BESS Event. The effects of that and the chemicals released are documented in Appendix 4 and echo what was presented in my previous filling.
While the newer LFP BESS systems are better, they are not foolproof and they are not as benign as the installers would have you believe.
Further, the statement that a Stage 2–4 BESS fire releases a chemically complex, multi-pathway hazardous plume that would trigger federal reporting requirements under almost any other industrial sector, is indicative of the fact that not clearly documenting these events has the “ignorance is bliss” effect on both the public and policy makers.
Ellenbogen noted that Perplexity also had the following suggestion regarding Policy Implications for Grid Scale Deployment of BESS Systems:
As utility-scale BESS Installations grow to multi-GWh scale in locations like New York, California, and Texas – often sited in or near dense grid interconnection zones – the absence of a standardized, post event severity classification system creates an analytic blind spot. The nuclear sector’s INES framework, for all its limitations, enables regulators to benchmark the severity of events across time and geographies. An equivalent BESS classification standard – one that integrates EUCAR cell-level data, UL 9540A propagation outcomes, and EPRI root cause taxonomy into a unified, publicly reportable Severity number – would represent a significant advancement in grid-level energy storage risk management.
That type of framework does not exist and based upon the lack of information available to the public and their representatives, decisions about these systems are being made in an information vacuum where the only stimulus is BESS money being dangled in front of the noses of towns without any attention being paid to the potential downstream consequences. To understand the full ramifications of this information gap, readers are encouraged to read the full incident histories of the ten events that are documented in PSc Filing Appendix 5. The event history with consequences and evacuations starts on page 35 and the entirety of Appendix 5 was constructed without human intervention or prejudices.
Ellenbogen Conclusion
The BESS Industry has a far worse safety and environmental record over the past 2-1/2 years than the nuclear industry has over the past 50 years, a period twenty times as long. NY State regulators and policy makers are ignoring these facts and allowing these systems to be installed in populated neighborhoods while also ignoring the potential consequences. The fact that the BESS industry is immune from regulations that would “trigger federal reporting requirements under almost any other industrial sector “, clearly documents how far the state and the industry has to go before allowing widespread installations of these systems. Regulators are not ensuring the public’s safety. They are only trying to put a band-aid on years of utility system mismanagement.
The following unsolicited conclusion generated by Perplexity documents the problem far better than any human could.. While the IAEA would not be the regulating agency for BESS Systems, the Department of Energy could be.
The Regulatory Gap in One Number
The 6 nuclear plant Level 2 events (1996–2010) all involved zero radiation release — pure defense-in-depth degradation. Every one triggered mandatory NRC notification, IAEA submission, and public INES rating. The BESS equivalent — a BMS anomaly, suppression margin reduction, or near-ignition precursor — has no federal reporting pathway, no IAEA submission, and no public rating requirement. That asymmetry is the structural argument Section 07 of the dashboard documents in real incident terms.
The Level 2 nuclear comparison doesn’t show that nuclear is more dangerous than BESS. It shows the opposite problem: the nuclear framework is so mature it captures events that cause zero harm, while the battery framework misses events that cause documented, measurable, multi-pathway environmental harm.
Based upon the prior information, the question has to be asked, “From a public safety standpoint, if you’ve decommissioned three nuclear reactors, why would you want to install a BESS facility in populated areas that is far less safe?”
Ellenbogen is the President [BIO] of Allied Converters and frequently copies me on emails that address various issues associated with the New York Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here: Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems”. He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies at both his home and business two decades ago.