This was submitted to the examiners today.
I am fully aware that all deadlines for submission have passed, but the submission below is based on an important recent official document relevant to the several references to the 2012 battery fire in Flagstaff Arizona, that have been made throughout the CHSP Examination. The relevant regulator - Arizona Corporation Commission has recently (2/8/19) published its determination in that matter and in the matter of a more recent 2019 BESS fire and explosion in Surprise, Arizona. Given it's authoritative, definitive and conclusive nature, I am requesting that for completeness this submission is brought to the attention of the Examiners before they make their recommendation to the Secretary of State.
Addendum to Deadline 7 Submission by the Faversham Society to the CHSP Examination Relevant to the Dangers Associated with Lithium-ion Battery Energy Storage Systems
Determination by the Arizona Regulator – The Arizona Corporation Commission: August 2, 2019 RE: IN THE MATTER OF THE COMMISSION’S INQUIRY OF ARIZONA PUBLIC SERVICE BATTERY INCIDENT AT MCMICKEN ENERGY STORAGE FACILITY PURSUANT TO ARIZONA ADMINISTRATIVE CODE R14-2-101. (DOCKET NO.E-01345A-19-0076)
Throughout the course of the CHSP Examination, the Faversham Society and others have raised serious concerns about the safety of Li-ion Battery Energy Storage Systems (BESS) as evidenced by the incidence of runaway fires and explosions at BESS around the world. All such incidents involved BESS considerably smaller than that proposed by the applicants for CHSP. In our previous submissions and discussions during the examination, one of the more serious BESS fires - the 2 MWh battery fire in Flagstaff Arizona in 2012 was referenced, but at that time no conclusions had been drawn by the US authorities.
2 Summary of the Determination
Commissioner Sandra D Kennedy of the relevant Regulator - the Arizona State Commission, has now reported on the incident.
Her full report is here
Her conclusions are of great significance and include:
''The Flagstaff Fire Department report ''....references fires with ''10-15 ft flame lengths'' that grew into ''flame lengths of 50-75 ft'' with fire ''appearing to be fed by flammable liquids coming from the cabinets'' '. This highly significant piece of evidence shows how a fire can spread from one container to another and flatly contradicts the CHSP applicant's assertion that 100 containers are no more of a fire hazard than a single container and that any fire will be contained within a single container.
The Fire Department Report also states concerns about ''a serious risk of large scale explosion'' and ''the cabinets involved are full of lithium (sic) batteries that are extremely volatile if they come into contact with water.''
The Commissioner clearly states:
''Knowing now how easily a fire and/or explosion can evidently occur at these types of relatively small(2MW) lithium ion battery facilities, it appears that a similar fire event at a very large battery facility (250MW+) would have very severe and potentially catastrophic consequences, and that responders would have a very difficult time trying to handle such an incident.'' The BESS proposed for CHSP is even larger at 700MWh.
The Commissioner recommends that any large scale BESS should be ''built in isolation'' and says ''an explosion could potentially flatten buildings at some distance''. She also draws the analogy that ''a 2MW battery facility is equivalent to 1.72 tons of TNT'' This makes the CHSP BESS equivalent to 602 tons of TNT. This is 1/20th of the TNT equivalent of the Hiroshima atom bomb. Moreover the CHSP BESS is within one mile of Graveney village and two miles of the town of Faversham.
The Commissioner also reinforces our community's fears about batteries ''with chemistries that include compounds that can release Hydrogen Fluoride in the event of a fire and/or explosion and states clearly that ''those types of lithium ion batteries are not prudent and create unacceptable risks'' Moreover, contrary to the claims of the applicants the Commissioner reinforces Dr Erasin's evidence stating that ''large amounts of hydrogen fluoride could be released and dispersed that would affect and harm the public at a substantial distance downwind'' and adds that ''There would be concerns about lingering hydrogen fluoride contamination in the affected areas.''
The Commissioner is clear that: ''water should not be used to suppress a fire such as a battery facility...'' - yet this was the method the applicants and their advisors favoured for CHSP.
The Commissioner also lays down stringent requirements for the protection of responders (fire and rescue services etc) to any incidents. None of these has been acknowledged by the proposers or by KFRS.
Given the absence of National Planning Statements on BESS, it is important that the Examination is guided by authoritative sources with experience of BESS projects. We would urge that the attached ACC Determination is the most thorough and up-to-date such source currently available.
This Determination by the Arizona State Commission clearly reinforces the view of the Faversham Society and others, expressed in evidence to the Examination, that the risks associated with Lithium-ion batteries are unacceptable at any scale and especially when close to habitation. It is clear that a proposal for a Battery Energy Storage System close to Faversham, which will be over five times the size of the current largest in the world, poses unparalleled risks and must be regarded as recklessly dangerous and totally unacceptable.
Professor Sir David Melville CBE, BSc, PhD, FInstP, CPhys, Hon DSc, Sen Memb IEEE(USA)
Vice-ChairThe Faversham Society
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