Lithium ion battery manufacturing

[Sifu]

Is there any justification for classifying a manufacturing plant for lithium ion energy systems (battery systems) as an F-1, and not an H? They list the battery charging room as an H-3, but not the manufacturing areas.

I am asking for a HM report. They list the H-3, as existing, and it took a minute before I even realized that this was a change to a whole new MFR process for new materials. Seems a little suspect, I thought it was just a minor remodel of an existing plant with the same process but I went looking for how this was previously approved and realized my assumption was wrong. The plans sure present it as a minor remodel, not this change.

 

[steveray]

If they fall under the MAQ....yes

 

[Sifu]

If they fall under the MAQ....yes

Other than that? That is my justification for the HM assessment. This has a lot of moving parts. The previous occupancy was an F-1, which was perfectly fine. The DP must figure since it is just one process moving out (previous manufacture of carbon/fiberglass products) and another moving in then it must be fine. The problem is the building exceeds the area for an H-3 if that is what they end up being, and it was designed as unlimited area building for F-1, and all those limitations are exceeded. For context, it is about 100,000sf², devoted to lithium-ion battery manufacture and storage. The existing building had a small H-3 area (1% of the floor area), which was fine as far as I can tell, but if the main occupancy is H-3, they have real problems. I am not sure their DP understands this (the DP is local, this is a huge international corporation). FWIW, I only found ANY of this out by searching the address in our system, and by press releases for the new facility, not from the architect or plans. Red flag right away for me. My experience with this DP doesn't leave me feeling warn and fuzzy that they are up to this challenge.

 

[Sifu]

Heard back from the DP, who informed me that an HMA was prepared to address these issues, but they forgot to send it to me. Maybe it will be alright after all....

 

[Yankee Chronicler]

Heard back from the DP, who informed me that an HMA was prepared to address these issues, but they forgot to send it to me. Maybe it will be alright after all....

Or maybe not. Read the evaluation carefully. I'm always skeptical when they conveniently "forget" to submit something that's crucial to the design and permitting of the project.

 

[Sifu]

Or maybe not. Read the evaluation carefully. I'm always skeptical when they conveniently "forget" to submit something that's crucial to the design and permitting of the project.

The last project I had, which still isn't resolved followed a similar trajectory. The DP classified the building as H-4. My review comment was to provide a hazardous materials assessment. I waited, and waited. They requested a foundation only request to my boss because "I" was causing a delay. It was granted. They then submitted plans to answer my other comments, and addressed about half of them. Still I waited. They resubmitted the exact same plans, which garnered them the exact same comments. We are about 6 months in now. They submitted some MSDS sheets. I waited. The sent an unsealed hazardous assessment to me. It ONLY addressed fire protection, only addressed the flammable and combustible materials, and specifically disclaimed the health hazard chemicals. They said it was what the fire department wanted. Still I waited, 9 months now. I explained for the umpteenth time what was required. I received a call from an FPE. He advised the corporation had contacted him at the very beginning of the process, and he told them he would be happy to provide an HMA, and HMIS. He told them they would likely be required to have these in order to get a permit. Then he never heard back...until now. He told me things I didn't even know about the project, and laughed when I told him the architect refused to be the DP in responsible charge. He gave them his recommendation and price. 10 months now. The FPE has informed me that he will be providing the HMA, hopefully early next year. This is the funny/ironic thing. After all this, the FPE has told me they may not exceed the MAQ's, so H may go away, and with it many requirements. If they had only done this at the beginning....the DP clearly did not understand the ramifications of an H occupancy.

This DP is better. When I spoke with him yesterday, he said an HMA assessment was done, but didn't know why it wasn't submitted to me. He said it covered all the fire protection. It likely went to the FD, which is the route the above scenario took, and that only covered the fire protection. I told him I hoped it covered more than just that, so we'll see. Apparently they receive the lithium already packaged in cells, they combined them, package them, charge them and ship them. I am concerned that in a 80,000ft² factory they will exceed MAQ's, I will have to wait and see if the report addresses this. I did find out that a site visit was conducted with the CBO and the FD. On one hand this is good because they are already looped in, on the other hand, if the MAQ and control area issue was not discussed, and changes are required there will be some finger pointing.

 

[steveray]

There was a guy out of the midwest somewhere that did a good class on batteries and manufacturing thereof (and how woefully addressed they are in current codes) at the ICC ABM in St.Louis...Michael O'Brian...Concept Codes....I've got a phone number, PM me if you want it....

 

[Penguin87]

Is there any justification for classifying a manufacturing plant for lithium ion energy systems (battery systems) as an F-1, and not an H? They list the battery charging room as an H-3, but not the manufacturing areas.

I am asking for a HM report. They list the H-3, as existing, and it took a minute before I even realized that this was a change to a whole new MFR process for new materials. Seems a little suspect, I thought it was just a minor remodel of an existing plant with the same process but I went looking for how this was previously approved and realized my assumption was wrong. The plans sure present it as a minor remodel, not this change.

How would you even be able to build a lithium ion battery manufacturing plant if the entire thing is a hazardous occupancy?

The Tesla gigafactory is around 5.4 million sf. Ford's BlueOval is 2.5 million SF. So unless they are building to Type IA construction, it would be banned under the IBC.

Anyways, are you suggesting that all lithium ion batteries are hazardous materials? These are being installed in cars, you know. The actual chemicals being used and stored would be subject to an HMIS that should be submitted to the AHJ for review and filled out by the building owner.

 

[Sifu]

How would you even be able to build a lithium ion battery manufacturing plant if the entire thing is a hazardous occupancy?

The Tesla gigafactory is around 5.4 million sf. Ford's BlueOval is 2.5 million SF. So unless they are building to Type IA construction, it would be banned under the IBC.

Anyways, are you suggesting that all lithium ion batteries are hazardous materials? These are being installed in cars, you know. The actual chemicals being used and stored would be subject to an HMIS that should be submitted to the AHJ for review and filled out by the building owner.

Not suggesting anything. Identifying lithium as a hazardous material and asking for an HMA to determine where/if control areas are required. Unfortunately the plans do not even indicate it is in use. I only found this out by researching the company and seeing a press release. Nowhere is it proposed that the entire facility is an H, but if there are quantities of the material that exceed the MAQ then changes would need to be made.

 

[Sifu]

Update:
I received the report from the FPE, it was puzzling. It largely relies on the 2024 codes because they contain more relevant and updated information than the previous codes. I find it enlightening, if not concerning.

In a nutshell, the '24 IBC removes the designation for many of the lithium battery and energy storage facilities as an H, and firmly places them into B, F1, S1, regardless of quantity. I had a good conversation with the FPE about this. I agree the 2018, written and voted on several years earlier than 2018, has little specific guidance on these types of facilities, so relying on the '24 IBC and IFC is more relevant.

I still have some confusion. The '18 and '24 IFC identifies lithium as a hazardous material as a flammable solid, and classifies them in H3 where MAQ's are exceeded. But then the '24 places a lot of these occupancies as classifications other than H3 (B, F1, S3). So it seems in the '24, Lithium is a hazardous material, and where MAQ is exceeded they list them as an H3, yet they also seem to list them as not H3, regardless of quantity. When I spoke with the FPE, their approach, based on this is that there is no hazardous material, therefore IBC 414 is not applicable, and in this case the classifications are F1 and S1.

There were significant code changes to the '24 codes for this material. The specific change, in the '24 IBC was proposed by representatives of Tesla. The change was approved as submitted.

 

[steveray]

Update:
I received the report from the FPE, it was puzzling. It largely relies on the 2024 codes because they contain more relevant and updated information than the previous codes. I find it enlightening, if not concerning.

In a nutshell, the '24 IBC removes the designation for many of the lithium battery and energy storage facilities as an H, and firmly places them into B, F1, S1, regardless of quantity. I had a good conversation with the FPE about this. I agree the 2018, written and voted on several years earlier than 2018, has little specific guidance on these types of facilities, so relying on the '24 IBC and IFC is more relevant.

I still have some confusion. The '18 and '24 IFC identifies lithium as a hazardous material as a flammable solid, and classifies them in H3 where MAQ's are exceeded. But then the '24 places a lot of these occupancies as classifications other than H3 (B, F1, S3). So it seems in the '24, Lithium is a hazardous material, and where MAQ is exceeded they list them as an H3, yet they also seem to list them as not H3, regardless of quantity. When I spoke with the FPE, their approach, based on this is that there is no hazardous material, therefore IBC 414 is not applicable, and in this case the classifications are F1 and S1.

There were significant code changes to the '24 codes for this material. The specific change, in the '24 IBC was proposed by representatives of Tesla. The change was approved as submitted.

My interpretation is that the "factory" can default to those lesser standards.....Until you bring in the H3 materials....So the building is likely to be mixed use separated....

 

[Sifu]

My interpretation is that the "factory" can default to those lesser standards.....Until you bring in the H3 materials....So the building is likely to be mixed use separated....

According to the 2024 IBC, and the IFC, and the code change proposal that prompted the new guidelines, an F1 using these materials and processes will be an F1, no matter the quantities. The FPE advised that in his opinion, based on these codes, the Li in this process is not "considered" a hazardous material. This is where I get a little puzzled, because in the 2024 IFC it is listed in the user notes to ch. 59, and in appx. E as a flammable solid. So my take away is that it is a flammable solid, but that the '24 codes do not consider it's use as a flammable solid that would prompt an H occupancy when the uses listed fall under the classifications for B and F1.

Here is a screenshot of the '24 IBC for B:

Here is the F1: