development application MCU24 0005 Battery Storage Facility

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Title
Key observations
section of standards to review for compliance. A total of sixty-two (62) hazards were identified.
Key observations include:
– The guide mentions the emerging concerns associated with cyber security risk but does not address any of these issues. This, alongside other malicious intent activities, is subsequently not captured within the risk assessment
– The guidance seems to be location and size agnostic, not differentiating between how to approach risk given these differences
– Lack of end-of-asset life and decommissioning considerations within the risk register
New York Battery Energy Storage System checklist
This checklist is primarily used to assist with field inspections of residential and small commercial battery energy storage systems. Although this document is applicable to energy storage systems in New York, it provides a step-by-step approach to approaching inspection activities. This may be relevant during the development of commissioning checklists. As this is outside the scope of this engagement, it is recommended that this checklist is reviewed when further detailed guidance is developed.
3.6.1 Case Study: Gaps identified in reference material following the Victoria Big Battery fire
Drawing on the discussions following the Victoria Big Battery incident in Victoria, Australia, it was found that grid- scale BESS facilities fall outside the definition of a Major Electricity Company (MEC) under the Energy Safety Act 1993; as they are assumed to fall within the definition of complex electrical installation. The result currently is that there was (and is) currently no formal requirement for an electricity safety management scheme and safety case demonstration to be provided for entities operating BESS facilities. ESV encourages voluntary submissions of electricity safety management schemes. Furthermore, there currently is no clear expectation as to what constitutes evidence of a safe BESS facility design for reference by ESV.
In a technical findings report issued by Fisher Engineering [68], Victorian Big Battery facility design general arrangement showed that the clearances between Megapack containers is 2,400 millimetres. Since it is unknown what maintenance practices were planned to be conducted on site, it is suggested a pragmatic consideration includes ability of vehicles (e.g., utility vehicle or site-specific small vehicles) to traverse site.
For areas of the site or equipment which have voltage greater than 1kV, AS 2067 prescribes minimum safety clearances.
In addition to these issues identified, the following was also found:
– At the time of the incident, there was no legal requirement to inform the CFA of the battery composition
– From a quality assurance perspective, downstream proponents are reliant on the guarantees provided by the OEM and their affiliate organisations
– Although a version of UL9540A3 was relied upon to demonstrate that thermal runaway would not occur and to justify that thermal escalation to other megapacks was improbable, a thermal runaway incident occurred. The Fisher Engineering report noted that the wind conditions for the certification were 30 to 40% of the prevailing wind conditions at the time of the incident [68].
The Fisher Engineering report also noted that there were gaps in the commissioning procedure, electrical fault protection devices and thermal roof design. Tesla has implemented several procedural, firmware and hardware mitigations to address these gaps to existing Megapacks at that time, as well as for future installations.
3 GHD has reviewed the Fisher Engineering report on the Victoria Big Battery fire (released in 2022) [68] for further information regarding testing stipulated within UL9540A
Document Set ID: 2630476
Version: 1, Version Date: 16/02/2024
GHD | Australian Energy Council Limited | 12591546 | Battery Energy Storage Systems 24