Managing Commissioning Risk for Utility-Scale Battery

Energy Storage Systems (BESS)

Target Audience: Energy Risk Engineers, Underwriters, Risk Managers​

Focus: Commissioning Phase Exclusively​

Date: December 19, 2025

Prepared by John Munno, Energy Risk Engineer

1.0 Executive Summary

The commissioning phase represents the most critical period of technical risk transfer

in a utility-scale Battery Energy Storage System (BESS) project lifecycle. This phase is

where design assumptions and component warranties are validated against integrated,

live performance. For risk professionals, rigorous commissioning is the primary control

for mitigating latent defects, ensuring safety system functionality, and establishing a

performance baseline that underpins operational reliability and financial projections.

Failures during or emerging from inadequate commissioning—such as undetected

thermal hotspots, software integration errors, or protection system

misconfigurations—can precipitate immediate catastrophic losses or chronic

underperformance. This paper provides a detailed technical framework for evaluating

commissioning protocols, identifying key risk indicators, and verifying that the process

delivers a truly bankable and insurable asset. A well-executed commissioning plan,

compliant with NFPA 855 and UL 9540A standards, is the strongest single predictor of

long-term BESS risk profile.

2.0 Commissioning as a Risk Management Gate

Commissioning is not a simple "power-on" test. It is a structured, sequential process of

inspection, static testing, dynamic testing, and performance verification that transforms

a constructed asset into an operational one. For insurers and risk managers, it serves as

the final quality gate before commercial operation, directly addressing:

●​ Latent Defect Risk: Identifying installation errors, manufacturing flaws, and

integration faults.
 ●​ Safety System Integrity: Proving the functionality of the Battery Management
System (BMS), thermal management, fire detection, and suppression systems
under realistic conditions.
●​ Performance Warranty Baseline: Creating the definitive benchmark for capacity,
efficiency, and responsiveness against which future degradation and warranty
claims are measured.
●​ Cyber-Physical Integration: Validating that control software, grid interfaces, and
safety systems interact as designed without unforeseen behaviors.

3.0 The Commissioning Process: A Phased Technical

Breakdown

A comprehensive commissioning program follows a strict sequence. Shortcutting any

phase introduces unacceptably high risk.

3.1 Phase 1: Pre-Commissioning & Documentation Review

This phase ensures all prerequisites are met before energization.

Key Activities:

●​ Documentation Audit: Verification of complete as-built drawings, manufacturer

datasheets, Factory Acceptance Test (FAT) reports for major components (BMS,
PCS, EMS), and software version control logs.
●​ Site Inspection: Verification of proper installation per design: cable routing and
torquing, equipment grounding, container and rack spacing (per NFPA 855),
ventilation, and fire suppression system installation.
●​ Safety System Readiness: Confirm all smoke, heat, and gas detection sensors
are installed and connected to the central alarm panel. Verify the fire suppression
system is charged and armed.

Risk Engineer's Checklist:

​ FAT reports reviewed and signed off for BMS, PCS, and EMS.
​ As-built drawings match physical installation, especially electrical single lines
and safety system layouts.
​ All work permits, lock-out/tag-out (LOTO) procedures, and emergency response
plans are site-approved.
​ Verification that thermal management system (coolant loops, chillers) has been
leak-tested and charged.
3.2 Phase 2: Cold Commissioning (De-energized Functional Testing)

All systems are tested without applying high voltage to the battery stacks.

Key Activities:

●​ Continuity & Insulation Resistance Testing: Megger testing of all DC and AC

cables to identify insulation faults or grounding errors.
●​ Communications Network Validation: Ensuring all CAN, Ethernet, and fiber links
between BMS, rack controllers, PCS, and the Energy Management System (EMS)
are operational and error-free.
●​ Control Logic & Software Testing: Simulating inputs to the BMS/EMS to verify
alarm thresholds, control setpoints, and shutdown sequences function as
programmed.
●​ Safety System Functional Testing: Manually triggering each detection zone to
confirm alarm annunciation, suppression system activation signals, and
ventilation controls.

Risk Engineer's Checklist:

 ​ Insulation resistance values meet or exceed manufacturer and IEEE standards.
​ BMS can correctly communicate with every rack and report cell-level
voltage/temperature.
​ All programmed alarms (e.g., high/low cell voltage, temperature differential,
ground fault) trigger appropriately in the SCADA system.
​ Fire alarm signal successfully initiates HVAC shutdown and suppression system
pre-release alarms.

3.3 Phase 3: Hot Commissioning (Energized Integrated Testing)

The system is progressively energized and tested under low-power conditions.

Key Activities:

●​ Sequential Energization: Following a strict procedure to first energize auxiliary

loads, then medium-voltage switchgear, then the PCS, and finally individual
battery strings or racks.
●​ Initial Charge/Discharge Cycles: Conducting low-current ("soft") cycles on
individual racks or blocks to condition cells and collect initial performance data.
●​ Grid Synchronization Test: Verifying the PCS can seamlessly connect to and
disconnect from the grid at zero power exchange.
●​ Subsystem Integration Tests: Testing the interaction between the EMS setpoints
and the physical response of the PCS and BMS.

Risk Engineer's Checklist:

​ Pre-energization safety "walk-down" and LOTO clearance confirmed for each

step.
​ In-rush currents and harmonic distortion are within acceptable limits during
startup.
​ Thermal imaging (infrared) scans of all electrical connections performed under
initial load to identify hotspots.
​ BMS-reported state of charge (SOC) aligns with integrated current measurement.

3.4 Phase 4: Performance Validation & Acceptance Testing

The system performs its contractual duties at full power to prove commercial readiness.

Key Activities:

●​ Capacity (SoH) Test: A full, nameplate-rate discharge from 100% to 0% SOC (or
specified cut-off) to measure total available energy against the warranted
nameplate capacity. This establishes the initial State of Health (SoH).
●​ Round-Trip Efficiency (RTE) Test: Multiple charge-discharge cycles at varying
power levels to calculate net energy delivered vs. net energy consumed, verifying
it meets guaranteed efficiency (typically ~85% for Li-ion).
●​ Grid Service Function Tests: Demonstrating contracted capabilities like frequency
regulation, automatic generation control (AGC) response, and ramp rate control.
●​ Protection System Live Tests: Verifying that over-current, over/under voltage, and
frequency protection relays trip as designed using injected signals or controlled
grid disturbances.

Risk Engineer's Checklist:

​ Independent, calibrated revenue-grade meters used for all performance

measurements.
​ Capacity test results are within warranty tolerance (e.g., ≥ 98% of nameplate).
​ Response time to grid signals meets ISO/RTO requirements.
​ All test results are documented in a formal Site Acceptance Test (SAT) report,
signed by the owner, EPC, and supplier.

4.0 Critical Risk Indicators During Commissioning

Risk engineers should treat the following as major red flags requiring immediate

resolution before proceeding.

●​ Compressed or Omitted Stages: Attempts to combine or skip cold

commissioning to accelerate schedule.
●​ Missing or Incomplete FAT/SAT Documentation: Inability to produce component
test reports from the factory.
●​ Persistent Communications or Ground Fault Alarms: Indicates systemic
installation or software issues.
 ●​ Thermal Imbalance: Temperature differentials >5°C between parallel strings or
modules at steady state.
●​ Inadequate Safety Protocols: Lack of clear LOTO, absence of fire watch during
hot work, or first responders not on notice during high-power testing.
●​ Unresolved Punch List Items: Carrying significant outstanding items, especially
related to safety systems, into performance testing.

5.0 Underwriting & Risk Assessment Framework for the

Commissioning Phase

5.1 Pre-Commissioning Due Diligence Questions

For underwriters reviewing a project prior to commissioning, demand answers to:

Process & People:

 1.​ Who is the lead commissioning authority, and what is their specific experience
with BESS of this chemistry and scale?
2.​ Is the detailed, step-by-step commissioning plan approved by all parties (Owner,
EPC, OEM)?
3.​ Are the commissioning team and site safety manager independent from the
construction team?

Design & Compliance:​

4. Are all major components UL 9540 listed, and is the system design certified to

comply with NFPA 855?​

5. Has the integrated control software (BMS/EMS) undergone independent

cybersecurity review?

5.2 On-Site Monitoring & Verification

For risks requiring site visits or third-party review:

1.​ Review the Commissioning Log: Demand daily logs that match the master plan.
Note any deviations, faults, and resolution times.
2.​ Witness Critical Tests: Prioritize witnessing the BMS functional test, a live
protection relay test, and the final capacity/RTE test.
3.​ Audit Documentation in Real-Time: Ensure test result sheets are signed
contemporaneously, not compiled retrospectively.

5.3 Post-Commissioning Risk Closure

1.​ Secure the Final SAT Report: This is a key underwriting document. It must include
all test data, punch list closure proof, and formal sign-off.
2.​ Establish the Performance Baseline: The initial SoH and RTE from the SAT report
become the reference points for monitoring operational degradation and
validating warranty claims.
3.​ Verify Training & Handover: Confirm that owner/operator personnel have
completed systems training, and all manuals, passwords, and as-built drawings
have been transferred.
6.0 Conclusion: Commissioning as the Foundation of
Insurability

For risk professionals, the commissioning phase is not merely a technical milestone but

the foundational process that determines the inherent insurability of a BESS asset. A

rigorously executed commissioning plan, validated by experienced professionals and

documented with unassailable clarity, is the most effective tool to de-risk the complex

technological convergence within a BESS. It directly mitigates the primary causes of

early-life failure and provides the essential baseline for quantifying long-term

performance risk. Underwriters should view investment in comprehensive, independent

commissioning not as a project cost, but as a critical risk mitigation expense that

secures asset value and operational viability for the life of the project.

Disclaimer: This white paper is for risk assessment guidance. It does not replace formal

engineering review, safety standards, or policy wording. Always consult with qualified

BESS commissioning experts for specific projects.