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Documenting and Verifying Safety of ESS Installations Under Current CSR

The focus of this effort by the Compliance Guide Task Group (CG TG) under this CSR WG is to develop materials to foster more timely consideration and approval of ESS under current CSR. This addresses a critical need related to how an ESS proponent can document that an ESS is safe and how an authority having jurisdiction (AHJ) can validate the ESS is safe.

Codes, standards, and regulations govern the safety of the built environment, which includes ESS technology and its application in the built environment. They are developed in the voluntary sector and adopted and applied by numerous entities including utilities, federal, state, and local government. In absence of mandatory adoption, it is adopted in the private sector through caveats tied to insurance, project funding, and other mechanisms. These documents typically lag technology development and application because it takes time to develop and adopt them; however, they are needed to inform the development of technical information and documentation of technology.

Eventually, CSR “catch up with” the technology and provide specific and prescriptive criteria that “memorialize” what is considered acceptable. Those CSR are subsequently adopted and, being specific and prescriptive, provide needed guidance to significantly simplify ESS consideration and approval. Until CSR are updated, noting over time as CSR are updated technology also evolves so CSR will always need updating, a provision in CSR associated with Alternative Methods and Materials (AMM) can provide for their review and approval. The basis for AMM is the approval of an ESS where what is proposed can be documented and found to be no more hazardous, nor less safe, than other things specifically and prescriptively addressed in the CSR. Without guidance in applying current CSR to ESS and where relevant the AMM provisions, the review and approval, and resultant safety, of ESS will be more challenging because each AHJ may have different approaches associated with what documentation they will want, when considering an ESS installation under the AMM provisions.

Additionally, each ESS proponent is likely to develop and advocate for their own approach to making their case for equivalent safety under the AMM provisions.

Under the CG TG effort, a document to support the short-term review and approval of ESS technology will be developed. It will focus on specific and prescriptive provisions of national-level standards and model code, as well as the AMM provisions of those documents where the CSR do not provide needed specifics. This activity envisions the availability of a more generic document that can be used by ESS proponents to help them identify the documentation they will need to support compliance with current CSR, as well as any AHJ in guiding their application of current CSR in the review and approval of an ESS. This document is intended to address the critical need for timely and uniform ESS safety review and approval of installations. It also will inform ongoing activities of a long-term nature intending to update current CSR to more specifically and prescriptively provide the needed criteria to document and verify ESS safety as covered in CSR.

An outline is under development. Please contact Pam Cole (pam.cole@pnnl.gov) for more information.