David Wojcik
Washington state’s environmental agency, the Department of Ecology, recently commented on dual draft Planned Environmental Impact Analyzes (PEIS) for wind and solar development. Unfortunately, while everyone has a section on grid battery fires, there is a lot of confusion because everyone cites a regulation that, as far as I know, does not apply to grid-scale battery complexes.
Therefore, I am posting the following comments to help them create much needed regulations.
“Comments by Dr. David Wojcik on the Washington Department of Ecology's Draft Wind and Solar PEIS on the Potential Impact of Grid-Scale Battery Fires”
Submission date: October 26, 2024
Wind and Solar PEIS solves the very serious problem of spontaneous combustion in large battery complexes that often accompanies wind and solar projects.
In particular, Section 3.6.1.1 of Appendix G in both PEIS states:
“WAC 51-54A-0322 covers storage requirements for lithium ion and lithium metal batteries. A permit is required for most battery types when the cumulative volume exceeds 15 cubic feet. A fire safety plan is required and must be included in the Emergency response in the event of a fire or the possibility of a fire. If required by the fire code official, a technical opinion and report consistent with Section 104.8.2 shall be prepared to evaluate the fire and explosion risks associated with the storage area and to make recommendations for fire and explosion protection. The report must be submitted to the Fire Code Official and requires approval by the Fire Code Official before a permit is issued. In addition to the requirements of Section 104.8.2, the technical opinion and report shall specifically evaluate the release of flammable gases during a thermal runaway event. Possibility of deflagration.
Unfortunately, this regulation most likely does not apply to wind and solar arrays. It covers battery storage, and these complexes are the batteries in use. Therefore, they may be exempted under the exceptions listed in Section 322.1:
” 2. New or refurbished batteries packaged for use in the equipment, devices or vehicles they are designed to power.
In this case, the equipment being powered is the grid, including stabilization equipment.
It appears the regulation either does not apply to wind and solar arrays or is being ignored. In either case, this increases the likelihood of a fire involving multiple batteries. This impact needs to be properly assessed and not just mentioned in passing as is the case in these draft PEIS.
An example may help. I recently wrote an article about the nation’s urgent need for design and emergency preparedness standards for grid-scale battery packs. The headline is “Grid-scale battery fire looms.”
Coincidentally, my example is the wind solar cell project in Horse Heaven, Washington. My focus is on the lenient permission given to a very dangerous project.
Here are relevant excerpts:
“Now let's turn to permitting these facilities, and I have another very compelling example. This is a facility that was just permitted by the state of Washington. It's a combined wind, solar and battery project with a proposed storage capacity of 300 megabytes. Watts… It may have 200 huge lithium battery cells. That number has not yet been disclosed.
Although the project has a large number of solar and battery components, it is still named “Matiantang Wind Farm”. The name is often abbreviated to “Horse Paradise,” which is ironic indeed because it will no longer be a habitat for horses. Horse hell might be better.
The permitting agency is the Washington Energy Facility Site Evaluation Commission (EFSEC). The license is called a Site Certification Agreement, or CSA, and Horse Heaven just received it after a strong push from the governor.
What is shocking is that the fire threat posed by this massive lithium battery facility is not discussed or even recognized. The CSA made numerous requests for issues large and small, even including facilities to provide water to reduce road dust. Having a million gallons or so of water will not prevent catastrophic fires or the environmental impact of such fires.
This is wildfire country, so liability insurance should be purchased for injuries caused to others by fires. Other potential sources of hazards include large amounts of contaminated water runoff and the emission of toxic air, especially if the entire facility burns.
This neglect undoubtedly stems from the Horse Paradise app. The app is over 500 pages long and I could only find one sentence about battery fires. In a long paragraph on page 366 of the PDF, we read that “Lithium-ion battery storage may pose a risk of fire and explosion due to the tendency of lithium-ion batteries to overheat.”
This sentence makes no mention of the project at all. For that matter, there are only a few paragraphs about the battery facility in the entire app, and most just describe it in general terms. There is no increase in the number of giant battery containers, nor does it indicate that it is a huge project in its own right, posing the same huge fire threat. In fact, the application states that they may double store these container-sized battery units, which is ridiculous given the risk of causing a chain reaction throughout the complex.
One can easily assume from this filing that batteries don't make any sense, and that seems to be exactly what happened with EFSEC.
This systemic neglect appears to be happening across the country. We urgently need a national code or standard that covers this issue. The National Fire Protection Association said it is working on an option, but implementation is up to permitting authorities.
The growing threat of grid-scale battery fires is a very serious issue that requires equally serious action.
See https://www.cfact.org/2024/10/01/grid-scale-battery-fires-loom-large/
Moving on, Horse Paradise is in dry, wildfire-prone country, and I read that 100,000 people live within 5 or 6 miles of it. Obviously, if a battery fire gets out of control, there is a real threat of huge property damage or even loss of life. This potential impact needs to be incorporated into the PEIS assessment, as this is likely to be the case for many battery complexes across much of the state. Much of the state is in drought.
Therefore I suggest the following:
Washington State needs to quickly enact and enforce fire safety regulations specifically for grid-scale battery complexes. These should cover emergency planning and preparedness, which includes facility design and material preparation. The design includes vessel spacing and other necessary engineering features. Material preparation includes supply and delivery systems for water and/or extinguishing agents as needed to prevent cascading container fires.
Finally, I disagree with PEIS's statement that grid-scale battery fires are “very rare” because it doesn't sound like the threat is serious, but it is. There are relatively few battery complexes in the United States, but there are a lot of fires. See example
https://www.firetrace.com/fire-protection-blog/us-has-suffered-second-highest-number-of-major-storage-fires
With numerous grid-scale battery complexes currently planned for Washington state, the scale of the threat is correspondingly huge.
I am happy to discuss any of the above issues or provide additional information.
Respectfully submitted,
David Wojick, PhD, former PE
CFACT Policy Analyst and Advisor
https://www.cfact.org
Committee for a Constructive Tomorrow”
Comment submission ends.
Hopefully they will listen.
Relevant
