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Do you need fire suppression for 3x Powerwalls in Northern California?

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Yes, 9540A is the standard for "Evaluating thermal runaway fire propagation in battery energy storage systems"

If you dig into the text of the new R327 this is the standard required, to justify closer ESS separation than 3'

OK, I just reviewed the currently published versions of CRC R327 and CFC 1206, as per Codes and have a few comments:

1) For the record, I think the jurisdictions applying CFC 1206 to single family residences are violating CFC 102.5. R327 is quite reasonable, it just requires the stationary battery system to be listed (which I take to mean UL 9540, not UL 9540A) and protected from vehicle impact. But i understand it is difficult to fight the AHJ, so the rest of my comments are on CFC 1206.

2) I don't see any mentions of "80 kWh" as a threshold anywhere

3) 1206.2.10.1 now requires all prepackaged and preengineered storage battery systems to be listed to UL 9540 (again, not 9540A). To my reading of 1206.2.8.3 Exception 2, that means they are exempt from the spacing requirements.

4) 1206.2.10.3 requires the battery system to transmit an alarm to an "approved location" in the event of elevated temperature, short circuit, or over/under voltage. Do the Powerwalls support this?

5) 1206.2.10.7 requires thermal runaway control where specified by 1206.2.12, but 1206.2.12 clearly omits lithium ion from the technologies requiring that. So I take that to mean that Powerwalls do not need UL 9540A listing.

6) On the other hand, 1206.2.11 requires sprinklers, and I see no relief for residential occupancies (other than my point 1 above) unless you put the Powerwalls in a bathroom of size not exceeding 55 square feet.

Cheers, Wayne
 
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The OSFM clarification that AHJ are using states that there is confusion in the application of 1206 vs R327. Per the clarification, they can use the newest version of R327 and 1206. I copied in those relevant pages here.

1206 pages.png
R327 pages.png
 
OK, I just reviewed the currently published versions of CRC R327 and CFC 1206, as per Codes and have a few comments:

...



Lol here's a document published by the City of Campbell in January 2020 ... the absurdity of the proposed requirements is laughable.
https://www.ci.campbell.ca.us/DocumentCenter/View/16634/ESS-Handout

Show on the plans a warning sign with the following information (see example plaque that follows this checklist):

o 8” x 10” plaque on or adjacent to the main disconnect to state the number of energy sources (e.g., utility power, PV panels and energy storage system) along with shut-off instructions.

o Include a map or schematic to indicate the location of the power sources and disconnects. The map or schematic shall be in the correct orientation when one is standing in front of the main disconnect.

o The plaque shall be on an .080 aluminum backer with white lettering on red vinyl on 3M Schotchlite reflective vinyl (or equivalent). Letter shall be Helvetica Med Compact or Calibri or equivalent.


When I make my plaque, I'm going to make it 8.5 x 11 and use Bank Gothic font.
 
Lol here's a document published by the City of Campbell in January 2020 ... the absurdity of the proposed requirements is laughable.
https://www.ci.campbell.ca.us/DocumentCenter/View/16634/ESS-Handout




When I make my plaque, I'm going to make it 8.5 x 11 and use Bank Gothic font.
\

I know right?! Welcome to my life for the last 10 months.

If you need someone with a CNC laser engraver, let me know, the plaque requirements are so varied I jsut bought one of my own to print these at will.
 
Having worked on fire issues for the last year, I do know that fire departments are careful with batteries. Having the fire department approve a location for powerwalls and have a few limits on their location is entirely realistic and cautious.

It is not that they are particularly dangerous, it is just being wise in how they are placed.

The fire departments have a lot of ordinances for a variety of things: turn arounds for fire trucks, vegetation clearances etc...

not much to freak out about...
 
\

I know right?! Welcome to my life for the last 10 months.

If you need someone with a CNC laser engraver, let me know, the plaque requirements are so varied I jsut bought one of my own to print these at will.



Assuming Sunrun ever gets to the point of having us deliberating over bollards, heat sensors, and plaques, I'm definitely going to take you up on that offer haha.

Why is it that I haven't really heard about all these weird things until now? I feel like folks here on TMC were getting their PWs installed without much hassle even though the middle of 2020? But now all these regulations make adding residential Powerwalls the most complex residential project I've ever seen.
 
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Lol here's a document published by the City of Campbell in January 2020 ... the absurdity of the proposed requirements is laughable.
Haven't actually read them, I got to the first page referencing Table 608.1--CFC Section 608 is now "Commercial Kitchen Cooking Oil Storage". So those guidelines are out of date.

This page on the state website shows that the only approved Campbell ordinance amending the state codes is ordinance 2255:

2019 Ordinances

which is available here:

Municode Library

So the only thing you have to legally comply with in Campbell is the current state codes and the ordinance 2255.

Cheers, Wayne
 
Haven't actually read them, I got to the first page referencing Table 608.1--CFC Section 608 is now "Commercial Kitchen Cooking Oil Storage". So those guidelines are out of date.

This page on the state website shows that the only approved Campbell ordinance amending the state codes is ordinance 2255:

2019 Ordinances

which is available here:

Municode Library

So the only thing you have to legally comply with in Campbell is the current state codes and the ordinance 2255.

Cheers, Wayne


Lolol I hope my Costco sized cooking oil is in compliance with the new ordinances... there's a lot of potential energy in that delicious fatty oil.

I'm in unincorporated Contra Costa; I really hope I can get these 3 PWs installed (on the side of the garage ... not the wall that the headlights point at) before I have to surround my home with bollards, fire suppression, and 0.080 aluminum plaques.


Edit: Forgot the not. Borat would be disappointed.
 
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Here's the text of the clarification
Question:
Which part of Title 24 California Code of Regulations Building Standards and code section appropriately controls the installation of at-home batteries within a Group R-3
(residential) occupancy structure?
Part 2.5 the California Residential Code (CRC) section 327 or part 9 the California Fire Code (CFC) section 608?
Response:
The International Code Council adopted the Energy Storage Systems (ESS) with the intent to have the residential energy storage systems that are listed with UL 9540 comply with the installation requirements of the Residential Code and the Electric Code. The limit of 20 kWh in the Residential Code was to allow the permitting requirements established in the Fire Code. The final adopted version was not clear on how the Fire Code requirements were met with the residential application.
This issue has been corrected in the 2021 International Fire Code and International Residential Building Code for Energy Storage Systems. The California Building Standards Commission (CBSC) have adopted these regulations in the 2019 Intervening Code Cycle. These regulations will become effective on July 1, 2021.
The local Authority Having Jurisdiction can, at their discretion, currently approve installations based on the regulations found in the 2019 Intervening Code Cycle, because they have been adopted by the CBSC.


As far as locations, the back wall where headlights point is almost certainly subject to damage. Plan on putting them up high on the wall, use a side wall, or install bollards.
 
Here's the text of the clarification
Question:
Which part of Title 24 California Code of Regulations Building Standards and code section appropriately controls the installation of at-home batteries within a Group R-3
(residential) occupancy structure?
Part 2.5 the California Residential Code (CRC) section 327 or part 9 the California Fire Code (CFC) section 608?
Response:
The International Code Council adopted the Energy Storage Systems (ESS) with the intent to have the residential energy storage systems that are listed with UL 9540 comply with the installation requirements of the Residential Code and the Electric Code. The limit of 20 kWh in the Residential Code was to allow the permitting requirements established in the Fire Code. The final adopted version was not clear on how the Fire Code requirements were met with the residential application.
This issue has been corrected in the 2021 International Fire Code and International Residential Building Code for Energy Storage Systems. The California Building Standards Commission (CBSC) have adopted these regulations in the 2019 Intervening Code Cycle. These regulations will become effective on July 1, 2021.
The local Authority Having Jurisdiction can, at their discretion, currently approve installations based on the regulations found in the 2019 Intervening Code Cycle, because they have been adopted by the CBSC.


As far as locations, the back wall where headlights point is almost certainly subject to damage. Plan on putting them up high on the wall, use a side wall, or install bollards.


I think you should ask for a raise at work...

Sorry I meant to say I'm trying to put them on the side of the garage; NOT the back wall where the headlights point. Sorry for the confusion.
 
Here's the text of the clarification
Can you provide the citation for that text?

The limit of 20 kWh in the Residential Code
There is no 20 kWh limit in the current CRC, so I don't know what they are talking about.

The local Authority Having Jurisdiction can, at their discretion, currently approve installations based on the regulations found in the 2019 Intervening Code Cycle, because they have been adopted by the CBSC.
This text to me means that the local AHJ can not require compliance with the regulations found in the 2019 Intervening Code Cycle yet, because they don't go into affect until July 1, 2021. "Can currently approve" is not equal to "can currently require"

I finally tracked down the 2019 Intervening Code Cycle revisions relevant to this discussion, they were passed in August, They are found here:

Commission Meeting August 13-14 2020

And the relevant documents are, I believe:

https://www.dgs.ca.gov/-/media/Divi...g-August-2020/SOS/SFM0219Pt25FETFINALSOS.docx
https://www.dgs.ca.gov/-/media/Divi...ust-2020/SOS/SFM-04-19-Pt9-FET-FINAL-SOS.docx

I haven't had a chance to review them, I'll do that later.

Cheers, Wayne
 
Lol here's a document published by the City of Campbell in January 2020 ... the absurdity of the proposed requirements is laughable.
https://www.ci.campbell.ca.us/DocumentCenter/View/16634/ESS-Handout




When I make my plaque, I'm going to make it 8.5 x 11 and use Bank Gothic font.

I have a ton of red stickers on the side of my house (where power comes into my home) that say (among other things) that I have energy storage on site, along with my home address, and a rough schematic of where the energy storage is in a line drawing of my home.

When I got the powerwalls, a few more of those red stickers were added than when I got solar in 2015, but its pretty unsightly actually. I just got used to it, and only really go over there when I take the trash out, but yeah.. tons of stickers. The one with my home and the sketch drawing does appear to be a thicker type as well, but I dont know if its actually aluminum...
 
I have a ton of red stickers on the side of my house (where power comes into my home) that say (among other things) that I have energy storage on site, along with my home address, and a rough schematic of where the energy storage is in a line drawing of my home.

When I got the powerwalls, a few more of those red stickers were added than when I got solar in 2015, but its pretty unsightly actually. I just got used to it, and only really go over there when I take the trash out, but yeah.. tons of stickers. The one with my home and the sketch drawing does appear to be a thicker type as well, but I dont know if its actually aluminum...


I think the stickers are par for the course. IMO, the 8 x 10 x 0.080 inch thick aluminum plate is going way overboard compared to stickers. Next, they'll require the plate to be acid etched and dipped in a bath of pure unicorn piss and ambrosia to make the edges less sharp.

Actually instead of bollards, maybe I can just get a HUGE 8 ft by 4 ft plaque with an integrated crumple zone to protect the Powerwalls. And the plaque can have an integrated fire suppression system that just poops flame retardant foam all over my garage if high heat is detected. This way the plaque serves 3 purposes. Hell I might as well see if I can get Sunrun to put the Powerwalls inside the plaque.
 
I think the stickers are par for the course. IMO, the 8 x 10 x 0.080 inch thick aluminum plate is going way overboard compared to stickers. Next, they'll require the plate to be acid etched and dipped in a bath of pure unicorn piss and ambrosia to make the edges less sharp.

Actually instead of bollards, maybe I can just get a HUGE 8 ft by 4 ft plaque with an integrated crumple zone to protect the Powerwalls. And the plaque can have an integrated fire suppression system that just poops flame retardant foam all over my garage if high heat is detected. This way the plaque serves 3 purposes. Hell I might as well see if I can get Sunrun to put the Powerwalls inside the plaque.

sorry to report .. unicorn piss has been deemed a carcinogen in the state of CA ... you will need another red sticker to address the use of it.
 
....When I make my plaque, I'm going to make it 8.5 x 11 and use Bank Gothic font.

Assume you’re joking. Sunrun will produce all of the safety warning labels and apply them where required just like Tesla Energy and everyone else does. Our location plaque on our exterior MSP being a combo unit is fit to the width of the panel section. We have red stickers on exterior panels, conduit, inverter, interior load centers but I don’t think ours looks as prolific as I’ve seen from some homeowner photos. Is this dependent on the city or AHJ?

DF1B76C6-3BA5-4D24-BB07-D62345EFD751.jpeg


As for the specifics of the signage, it’s for the safety of the firefighters/utility workers and should be standardized so it doesn’t rust, is easily spotted at night with a flashlight and legible - thus specifying the font. Not really different from standardizing on traffic signs etc. so not surprised it is spelled out in code but an confused why it’s something to call out here.

As for why people on the forum here haven’t been talking about it, it hasn’t applied to many cities and @Vines started a thread awhile back when code changes were first becoming an issue for installers in some fire districts where his company was doing installs. He warned then that these changes were likely to be adopted more widely.
 
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Assume you’re joking. Sunrun will produce all of the safety warning labels and apply them where required just like Tesla Energy and everyone else does. Our location plaque on our exterior MSP being a combo unit is fit to the width of the panel section. We have red stickers on exterior panels, conduit, inverter, interior load centers but I don’t think ours looks as prolific as I’ve seen from some homeowner photos. Is this dependent on the city or AHJ?

View attachment 602755


I'm kind of half joking. The joke is Bank Gothic. That font is ugly as hell and overused.

The not-joke is that I will probably need to get in touch with @Vines to use his fancy CNC engraver to make one of these outdoor plaques since these rule changes are adding a bunch of new red tape that seems to have snuck up in recent months. Between new language around heat sensors, fire extinguishers, bollards, plaques, etc I can see my installation dragging well into 2022.

The label you show in your picture is probably on acrylic and probably some UV rated polymer. If all I needed was that label then yeah; it's a non issue since everybody has that plackard. But now there's a chance may need Sunrun to have access to 0.080 aluminum plate, 3M reflective lettering, and a CNC machine to make a new plaque design.
 
I haven't had a chance to review them, I'll do that later.
OK, I had a chance to read through the 2019 Interim California Code Cycle requirements that will take effect July 1, 2021 (and for which jurisdictions may elect to permit work currently).

The good news is that they've properly coordinated the CRC requirements and the CFC requirements. CFC 1206.1 "Scope" has a nice clear "Exception" stating that Energy Storage Systems (ESS) in Group R-3 and R-4 occupancies (that includes all single family homes) are subject only to 1206.11. And CFC 1206.11 is an almost exact copy of CRC R327. So once these rules are in force, no question that you can ignore the CFC and just look at CRC R327 (for a single family home).

The other good news is that there's no requirement for sprinklers in CRC R327, which answers the OP's question for this version of regulations. Also nothing about aluminum signs (but I haven't checked the Electrical Code).

As to the CRC R327 requirements, a summary of notable points:

R327.2 All ESS have to be listed under UL 9540 (Powerwalls are, check)

R327.3.1 Spacing of 3 feet between individual units is required, but the ridiculous "3 feet from walls" is gone. Large scale fire testing results by the manufacturer can allow a reduction in the 3 feet separation requirement (haven't looked at the details of this).

R327.4 Powerwalls may only be installed in (A) garages, detached accessory structures, outdoors 3 feet from windows and doors "directly entering the dwelling unit" and (B) enclosed finished utility closets, basements, storage or utility spaces (finish with 5/8" drywall if not currently finished).

R327.5 Individual ESS units are limited to 20 kWh (Powerwall are, check). Aggregate capacity is limited to 80 kWh in locations in the list (A) in the previous paragraph, or 40 kWh in the locations in list (B).

R327.7 Indoor locations with an ESS need to have a smoke alarm, or a heat detector if smoke alarms aren't listed for use in the location type. I understand this to be standard type alarms, nothing exotic.

R327.8 Bollards if subject to vehicle damage

And that's basically all the important parts.

Cheers, Wayne

P.S. Some further details:

R327.1 This section says that if the ESS is labeled "For use in residential dwelling units" then none of the rest of R327 applies. Apparently this is a category under UL 9540A (a supplementary standard to UL9540 on thermal runaway testing) allowed for ESS using batteries whose individual cells meet certain performance requirements on the UL 9540A cell level performance test. I don't know what the requirements are, and I don't know if Powerwalls (using NMC technology) are capable of meeting them. So my assumption is this isn't going to happen for Powerwalls

I speculate that LiFeP03 might have a better chance of meeting these requirements, and if they could, and the Enphase products still use LiFePO3 and could achieve the labeling "For use in residential dwelling units", that would be a reason to pay more for the Enphase products.

R327.5 Further thoughts: the intention may be to impose the limits above across all location types, but the way it is written the locations in list (A) are subdivided into 3 types, and one could argue that you could have 80 kWh in each of the 3 types.

Also, the limits may be exceeded if the installation complies with CFC "1206.1 through 1206.9," but 1206.1 is the section that says Group R-3 and R-4 occupancies are exempt from Section 1206. So as written one could argue that's a null requirement, and there is no ESS capacity limit. I expect the intention would be better conveyed with the wording "1206.2 through 1206.9".
 
OK, I had a chance to read through the 2019 Interim California Code Cycle requirements that will take effect July 1, 2021 (and for which jurisdictions may elect to permit work currently).


Holy smokes - thanks for this info Wayne! I don't know where you're researching this stuff, but I'm glad you've been able to make some sense out of this. I guess even if Contra Costa County early-adopts R327 I should be able to comply.

The Garage wall is 268 inches from the garage door aperture itself to a side-door leading to the side of my house. This wall has no windows. I should be able to fit 3x Powerwalls even with 3 foot gaps between them and 3 feet away from each opening. I just hope they don't require bollards since it's the side of the garage.

One interesting takeaway is that it seems like the smoke/heat detector doesn't need to be a centralized alarm. @Vines had mentioned Santa Clara County was requiring a UL 521 compliant heat sensor which really limited his options. Based on your interpretation of R327.7, compliance could be achieved with pretty much any cheap alarm or a Nest Protect Gen 2 (it's not UL 521).

I think I'm going to get a manual fire extinguisher for my garage just in case lol.
 
Well the language in 2019 Interim CRC R327 says "a listed heat detector" I would think that by not specifying the listing required, something listed to UL539 would be sufficient, something like this:

120V AC/DC 135F w/Rate-of-Rise Heat Alarm

But I have no information about what is intended or how jurisdictions would interpret that language.

Cheers, Wayne

P.S. In my earlier post, I provided the links to the source documents I attempted to analyze.