AwSV gui­dance paper: Impli­ca­ti­ons for lithium-ion bat­te­ries

What is an AwSV gui­dance docu­ment on lithium-ion bat­te­ries?

The AwSV, the Ordi­nance on Instal­la­ti­ons for the Hand­ling of Sub­s­tances Hazar­dous to Water (wgS), has a broad scope of appli­ca­tion. It aims to pro­tect bodies of water from the harmful effects of these sub­s­tances. This applies to sys­tems such as hea­ting oil con­su­mer sys­tems as well as slurry, liquid manure and silage see­page sys­tems. Lithium-ion bat­te­ries are a new addi­tion and are now also regu­la­ted by the AwSV.

What does the AwSV regu­late?

The AwSV spe­ci­fies requi­re­ments for the hand­ling of ready-made, sta­tio­nary bat­tery cells that use lithium in their cell che­mis­try (lithium-ion bat­te­ries, LIB), as well as for the bat­tery modu­les and sets assem­bled from them. This includes:

• Sto­rage
• Instal­la­tion requi­re­ments
• Appli­ca­tion sys­tems
• Pro­duc­tion faci­li­ties

Howe­ver, the AwSV does not include lithium-ion bat­te­ries that are used in mobile or non-fixed appli­ca­ti­ons, such as in elec­tric vehic­les, for the trans­por­ta­tion of goods or in the pri­vate sec­tor. There is also a de mini­mis limit of 0.22 cubic meters for liquid sub­s­tances and 200 kg for solid sub­s­tances hazar­dous to water (Sec­tion 1 (3) AwSV). Instal­la­ti­ons below this limit are not sub­ject to the AwSV.

What signi­fi­cance does the AwSV paper have for the sto­rage indus­try?

The AwSV paper has a key role to play in the appr­oval of Li-ion bat­tery sys­tems. It pro­vi­des infor­ma­tion on tech­ni­cal requi­re­ments and obli­ga­ti­ons for water pro­tec­tion that ope­ra­tors of such sys­tems must com­ply with. The regu­la­tion is aimed in par­ti­cu­lar at com­pa­nies that ope­rate sys­tems for hand­ling sub­s­tances hazar­dous to water, such as sys­tems for sto­ring, trea­ting or fil­ling these sub­s­tances. Whe­ther lithium-ion bat­te­ries actually involve the hand­ling of sub­s­tances hazar­dous to water was a recur­ring point of dis­cus­sion during the pre­pa­ra­tion of the infor­ma­tion sheet. After all, bat­te­ries have casings that must not be ope­ned during their entire ser­vice life. From the point of view of the AwSV, the main focus for sta­tio­nary bat­te­ries is now on leakage and extin­gu­is­hing water reten­tion.

What does the BVES recom­mend?

The BVES par­ti­ci­pa­ted inten­si­vely in the con­sul­ta­tion on the draft, with a detailed tech­ni­cal state­ment. The asso­cia­tion argues that bat­te­ries do not handle sub­s­tances hazar­dous to water (wgS), as is the case with slurry or oil plants, as bat­tery modu­les must not be ope­ned during their ser­vice life. Nevert­hel­ess, the BVES gives top prio­rity to the safety of plant ope­ra­tion and envi­ron­men­tal pro­tec­tion. Cle­arly, con­cerns about water pro­tec­tion in bat­te­ries are to be taken seriously and regu­la­ted. BVES has pro­vi­ded its exper­tise on the cur­rent state of the art as well as a range of exis­ting regu­la­ti­ons and pro­ven safety mea­su­res to deve­lop a solu­tion that recon­ci­les water pro­tec­tion stan­dards with sus­tainable and eco­no­mical bat­tery ope­ra­tion. Bat­te­ries are cri­ti­cal to the trans­for­ma­tion to a sus­tainable energy sys­tem and a green indus­try. Wit­hout energy sto­rage, there will be no energy tran­si­tion. Bat­te­ries with dif­fe­rent cell che­mis­tries are high-tech pro­ducts that are alre­ady pro­tec­ted by pro­ven norms and safety stan­dards and will have to pro­vide even stric­ter proof of safe pro­duc­tion, trans­por­ta­tion and use in the future. The EU Bat­tery Regu­la­tion (BattVO), recently enac­ted, regu­la­tes the entire value chain of bat­te­ries, from pro­duc­tion to recy­cling, and also addres­ses safety issues in a new and man­da­tory way. Fire pro­tec­tion is a cen­tral issue when using bat­te­ries. Modern bat­tery sys­tems are desi­gned in such a way that the source of a fire is very limi­ted and can­not spread to neigh­bor­ing modu­les or con­tai­ners. The defec­tive module should be able to react wit­hout exter­nal influence, wher­eby the escape of hazar­dous sub­s­tances into the ground is excluded. The EU BattVO (2023/1542) now brings the so-cal­led pro­pa­ga­tion test for sta­tio­nary sto­rage sys­tems into play at a cen­tral point. This test, which has been in use for 15 years, has pro­ven its worth in che­cking how far a fault pro­pa­ga­tes within the bat­tery sys­tem and whe­ther the bat­tery housing remains int­act. The pos­si­ble results of this test range from no pro­pa­ga­tion, to pro­pa­ga­tion only within a bat­tery module but not bet­ween bat­tery modu­les, to com­plete pro­pa­ga­tion throug­hout the bat­tery sys­tem. Many bat­tery sys­tems are not desi­gned to be extin­gu­is­hed with water. It is regu­la­ted and recom­men­ded in fire pro­tec­tion reports and coor­di­na­ted with the local fire depart­ment. In this case, the AwSV infor­ma­tion paper also sti­pu­la­tes that extin­gu­is­hing water reten­tion can be omit­ted. The BVES fire pro­tec­tion gui­de­lines are now being updated, and the new ver­sion will also con­tain recom­men­da­ti­ons with respect to the AwSV gui­dance docu­ment.

Con­clu­sion

Water pro­tec­tion is a very serious issue for the sto­rage indus­try. Safety stan­dards have always been very high, espe­ci­ally in Ger­many, and will be fur­ther increased. This is ano­ther reason why there has never been an acci­dent invol­ving a large bat­tery in ope­ra­tion. It is important that the water pro­tec­tion requi­re­ments are tech­ni­cally well-foun­ded and easy to imple­ment so as not to hin­der the growth of the sto­rage sec­tor. The energy tran­si­tion needs energy sto­rage sys­tems, and bat­tery sto­rage sys­tems are a vital part of the sto­rage land­scape. This requi­res uncom­pli­ca­ted com­mu­ni­ca­tion and pro­ces­ses in appr­oval pro­ce­du­res.