California is requiring 50% of electricity to come from renewable sources by 2030 to reduce greenhouse gas emissions and address climate change. This is increasing the need for battery storage to ensure grid reliability as more intermittent renewable energy is added. Many new battery technologies are being deployed, but regulations have not caught up, requiring safety risk assessments of these technologies. Hazard analyses should be conducted throughout the lifecycle of battery storage projects to identify and mitigate risks, improving safety and reducing incidents. These analyses require a multidisciplinary team and are a valuable tool for safely implementing new battery technologies.

1. In today’s world there exists an “energy trilemma”, a
phrase coined by one of the lecturers from my
coursework at Vermont Law School. Mr. Michael
Dworkin referred to the energy trilemma as the
competing interests of system reliability, financial and
environmental costs. He stated, “that for almost
everyone, one of these three issues is most important.”
While all three have important merit, this article will
focus on system
reliability, new
regulatory
requirements, and the
need for proper risk
assessment of next
generation technology
being introduced to
meet these
requirements.
In this post-election time-period, there are many
questions related to the impacts to Climate Change policy
in the U.S.; however, California has boldly stated that it
will continue down the path of greenhouse gas reduction
and legislation. Not too long ago, SB350 included a
provision to reduce fossil fuel consumption in the state
by 50% by 2030 in an effort to speed up the
“electrification” of our mobile sources, but this provision
was removed in order for the remaining parts of the bill
to pass. One remaining part of this bill, which was
signed in to law, requires that the electricity generated
must be generated from 50% renewable sources by 2030
and tasked the California Public Utilities Commission
(CPUC) with ensuring those targets are met.
In addition to these targets, many of the utility companies
have also been required to ensure system reliability, as
there had been predictions for blackouts last summer and
during certain periods of 2017. System reliability, along
with the requirement to use more renewable energy to
feed the grid has brought about a growing need for cost-
effective and reliable battery storage. There are many
technologies for battery storage and new ones are being
developed at a rapid pace. Technologies such as molten
salt, vanadium flow batteries, lithium batteries, dual
charge acid batteries, hydrogen fuel cells, etc. are being
deployed in the field as “proof of concept” projects or to
simply provide added system reliability by storing excess
electrical energy for use during peak hours.
Additionally, even in the midst of a Trump
administration’s promise to reduce Climate Change
regulations, California will continue its focus on carbon
reduction. California counts for so much of U.S. auto
sales, that its rules have become the de facto national
standard, and the Air Resources Board (ARB) is helping
to design zero emission vehicle standards in other parts
of the world, including China and Quebec (Bloomberg
BNA, “California Maps Go-It Alone Path on Car
Emissions For Trump Era”, November 15, 2016). With
the anticipated continuation of the electrification of our
roads, so will the need for battery storage of electricity
become increasingly important. One manufacturer,
Tesla, has incorporated 500kW batteries into some of its
Supercharger Stations™ in efforts to reduce the demand
charge on utilities when car owners are charging. (“How
Tesla Superchargers Outsmart the Electric Car
Industry”, Nikki Gordon-Bloomfield, June 6, 2013).
It is also fairly safe to say, that the regulations, codes and
standards are still catching up with each of these
emerging technologies, and the issue of reliability gets
coupled with the need for safety in deployment and
operation of these systems. Organizations, such as the
National Fire Protection Association (NFPA) have been
“Risk is like fire: if controlled it will
help you, if uncontrolled it will rise
up and destroy you”
-Theodore Roosevelt

2. updating existing codes to keep up with some of these
technologies. Yet, not all are covered, and the need for a
thorough safety and environmental risk assessment
becomes strategically important.
Many laws and regulations now place demands on
organizations that handle certain hazardous materials,
including U.S. federal and state legislative initiatives, as
well as international requirements such as the European
Union’s Seveso II Directive. (“Guidelines for Hazard
Evaluation Procedures”, Wiley, 3rd
Edition). But many
of them do not
regulate the
storage and
operation of next
generation, large
capacity batteries.
However, some of
these rules do have
a “general duty
clause” which
requires an
employer to provide a work environment free from
hazards. In this sense, establishing a robust risk
management program is recommended.
A hazard analysis is an organized effort to identify and
analyze the risks associated with a particular process or
activity. It helps to pinpoint weaknesses in a system so
that it can be properly mitigated to prevent those
weaknesses. These hazard evaluations should be
performed throughout the life of a process as an integral
part of an organizations process safety program (Ibid,
Wiley).
There are many different types of methodologies that can
be used in the execution of a hazard analysis, such as:
 Preliminary Hazard Analysis
 Checklists Analysis
 What-If Analysis
 What-If/Checklist Analysis
 Hazard and Operability Study
 Failure Modes and Effects Analysis
 Fault Tree Analysis
 Event Tree Analysis
The one selected depends on where one in is in the life
cycle of the process. For instance, using the What-If or
the What-If/Checklist Analysis is often beneficial when
the process is in its conceptual design stage; whereas the
Hazard and Operability Study is better suited once there
is a fully designed system or the system is further along
in its life cycle.
The benefits of conducting a hazard evaluation,
especially for these new emerging battery technologies,
are many, including improved community and regulatory
agency relations, more efficient operation of the system,
safer operation of the system and an overall reduction in
incidents. While no hazard evaluation program is a
guarantee against an incident, it is a valuable component
of a company’s risk management program.
High quality hazard evaluations require the use of a
multidisciplinary team. Usually members of the team
will come from key positions within the organization,
such as maintenance, operations, safety, and
environmental leaders. There is considerable resource
commitment required, therefore it is highly
recommended to have a skilled person leading these
evaluations. Do not underestimate the position of the
“scribe” either. The “scribes” job is to document the
evaluation conversations and discussions and is an
invaluable member of the team. These detailed notes
will benefit the process hazard analysis and its
documentation.
As battery technology is improving and being
implemented for a wide variety of operations, consider
the benefits of risk analysis prior to the processes
implementation. It can be a valuable tool for the safety
and longevity of operations.
Jane Besch, CSP, Principal at Geosyntec Consultants.
626-788-4637 or jbesch@geosyntec.com.
Made in Office 2007 for office2007.comMade in Office 2007 for office2007.com
[Date]