Grid Wise Battery Systems Australia GUIDELINES

Battery Energy
Storage Systems
Guidance Report
Australian Energy Council Limited
24 March 2023
The Power of Commitment
Project name AEC BESS HS&E Guidance and Trends
Document title Battery Energy Storage Systems | Guidance Report
Project number 12591546
File name 12591546-REP-0_BESS Guidance Report.docx
Status Revision Author Reviewer Approved for issue
Code
Name Signature Name Signature Date
S3 A R. Deo B. Geary / M. Erskine 30/01/23
D. Featherston R. Mills
S4 0 R. Deo James M. Erskine 24/03/23

Mackay
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This guidance report: has been prepared by GHD for Australian Energy Council Limited and may only be used and relied on by
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Section 1.2 of this report. This guidance report has been commissioned by the Australian Energy Council to initiate and
facilitate collaboration amongst its member organisations towards a harmonised leading practice approach for grid-scale BESS
facilities in Australia.
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The opinions, conclusions and any recommendations in this report are based on assumptions made by GHD described in this
report (refer Section 1.4 of this report as well as assumptions stated throughout the report). Due to the timeframe and budget
and evolving technology, a limited number of stakeholders were approached for this engagement and the references reviewed
as part of the literature search is not exhaustive. Further, the recommendations provided have been developed based on prior
industry work and it is expected that it will be challenged by the Australian Energy Council and its stakeholders and further
discussed prior to execution. GHD disclaims liability arising from any of the assumptions being incorrect.
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The Power of Commitment

Executive Summary
The transition to renewable energy generation requires energy storage solutions to preserve the current system
resilience, ensuring that supply matches the demand needs within Australia. The progressive advancement and
development of battery chemistry and technology has resulted in the global uptake of grid-scale Battery Energy
Storage System (BESS) facilities. There have been a number of larger BESS installations in the past decade;
most notably, the South Australian Hornsdale and Victorian Big Battery facilities. Although these grid-scale
applications of batteries are advantageous, there have been several self-heating, thermal runaway and other
incidents which have highlighted hazards and risks which need further consideration.
The Australian Energy Council (AEC) are aware of these issues and engaged GHD to develop guidance material
associated with grid-scale BESS facilities, with a focus on lithium-ion and vanadium chemistries.
The scope of this project is to produce a high-level risk assessment and develop guidance material which captures
the findings from the following activities and engagements completed:
– A high-level literature review, reviewing battery chemistries, thermal runaway and events which have occurred
over recent years, and key reference documentation utilised (e.g., Acts, Regulations, Standards, and other
existing guidance).
– Interviews with five (5) stakeholders who are involved in the lifecycle of BESS facilities.
With various thermal events occurring over recent years, good learnings have been translated into good practices
which are noted in this study. The main emphasis of this guidance material is on the good practices whilst noting
Legislation, Acts, Regulations, Standards, and other guidance material that are emerging or being currently
utilised.
This guidance material developed considers the following areas:
– Site selection, facility orientation, and facility configuration
– Safety case approach
– Emergency management planning
– Environmental offsite effects
This guidance material also utilises good principles drawn from a broader range of industries and facets of society
that are applicable to energy storage facilities. From this, it is proposed that BESS facilities are classified into
“types” based on their storage capacity and have varying assessments based on this classification. The proposed
“type” based classification is shown:
1. Type 1: Less than 50 MWh
2. Type 2: Between 50 MWh and 250 MWh
3. Type 3: Between 250 MWh and 1,500 MWh
4. Type 4: Greater than 1,500 MWh
Based on the literature reviewed and learnings from the stakeholder interviews, the risk profile of BESS facilities is
dependent on several factors, similar in some respects to the way risk evolves in other high hazardous industries.
Figure 7 illustrates the proposed approach to assess grid-scale BESS facilities, building upon the “type” based
classification scheme above.
A supporting high-level risk register is also provided, identifying a few preliminary risk scenarios utilising literature
findings, previous incidents and based on the interviews with stakeholders engaged as part of this work. The risk
register aims to primarily capture key risks associated with lithium-ion batteries (specifically lithium-ion phosphate
formulations) and vanadium redox flow batteries as they represent a significant cross-section of the current types
of BESS facilities present.
This guidance is an important step along a path of evolving knowledge and good practice for the expanding energy
storage scale and associated developing technology. All of this is essential for the societal journey to safely
achieving more sustainable energy.
GHD | Australian Energy Council Limited | 12591546 | Battery Energy Storage Systems i
This report is subject to, and must be read in conjunction with, the limitations set out in Section 1 and the
assumptions and qualifications contained throughout the report.
GHD | Australian Energy Council Limited | 12591546 | Battery Energy Storage Systems ii
Contents
1. Introduction 1
1.1 Background 1
1.2 Purpose of this guidance material 2
1.3 Scope and limitations 3
1.4 Assumptions 4
2. How was this guidance material developed? 5
3. Literature review 6
3.1 A brief summary of the evolution of battery chemistry 6
3.2 Grid-scale thermal runaway events 9
3.3 Occupational, Health and Safety (OH&S) considerations 15
3.4 Environmental considerations and implications 15
3.5 Other areas of consideration 17
3.6 Key observations from reference material 20
4. Discussion 25
4.1 General findings 25
4.2 Stakeholder interview summary 26
5. Guidance material 29
5.1 Purpose of the guidance material 29
5.2 Grid-scale BESS facility guidance 29
5.3 Site selection, orientation, and configuration 33
5.4 Safety case development 35
5.5 Emergency management plan 39
5.6 Environmental offsite effects 40
5.7 Supporting risk register 41
6. Conclusions and opportunities 43
7. References 45
Table index
Table 1 Stakeholders interviewed for development of guidance material 3
Table 2 Battery chemistry overview 6
Table 3 Overview of recent BESS fire events 11
Table 4 Summary of reference documentation 20
Table 5 Modelling conditions used for Figure 8 and Figure 9 33
Table 6 Summary of risk studies which may form part of a safety case demonstration 35
Table 7 Comparison between hydrocarbon storage facility events with BESS facility
events 42
Table 8 Abbreviations table 52
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Figure index
Figure 1 Power system interactions between grid and behind-the-meter energy supply
(Figure 4 in ref [1]) 1
Figure 2 Principle and configuration of the vanadium redox flow battery (Figure 2 in ref
[19]) 8
Figure 3 Thermal runaway states of a Li-ion cell and correlated mitigation strategies
(Figure 3 within Feng et. al [29]) 10
Figure 4 Victoria Big Battery fire incident [47] 13
Figure 5 Classification of cyber threats for the BESS (Figure 2 of ref [65]) 18
Figure 6 High level list of global standards used for BESS 20
Figure 7 BESS guidance flowchart 32
Figure 8 CFD simulated heat plumes from a BESS showing thermal contours of air
temperature (35°C calm wind conditions) 33
Figure 9 CFD simulated heat plumes from a BESS showing thermal contours of air
temperature (20 km/h with BESS long face aligned wind conditions) 34
Figure 10 Flowchart for the development of a safety case outline (Figure 9 of ref [71]) 37
Figure 11 Flowchart for HAZID study 41
Figure 12 Australian wind regions as defined in AS 1170.2 (Figure 3.1 (A)). Source:
AS 1170.2:2021. 58
Figure 13 Comparison of 3 pm annual wind rose plots. Source: BoM (2023). From top left
clockwise: Gladstone (Qld), Nowra (NSW), Perth (WA) and Latrobe Valley (Vic) 59
Figure 14 Annual average temperatures maps for Australia (top) and United Stated
(bottom). NB. 50°F = 10°C, 60°F  16°C, 70°F  21°C. 61
Figure 15 Annual average daily solar radiation map for Australia 62
Appendices
Appendix A Abbreviations
Appendix B Interview questionnaire
Appendix C Site selection requirements and considerations
Appendix D High-level supporting risk register
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1. Introduction
1.1 Background
Technical innovation, accelerated closure of coal-fired power generation plants, government policies, as well as
society’s growing environmental conscientiousness has seen a rapid uptake of renewable energy generation. The
2022 Integrated System Plan, released by the Australian Energy Market Operator (AEMO), highlights that the
forecasted withdrawal of approximately “8 gigawatts (GW) of the current 23 GW of coal-fired generation capacity
by 2030” [1] will introduce complexities within the National Electricity Market (NEM).
Figure 1 Power system interactions between grid and behind-the-meter energy supply (Figure 4 in ref [1])
As solar, wind, and other renewables transition into becoming primary energy resources, it will become
increasingly complex to preserve the current system resilience. The intermittent nature of renewables requires
energy storage solutions, with enhanced diversity and strategic redundancy, to ensure that supply matches the
demand needs (by volume and timing) of renewable-based electricity in Australia.
The advancement in battery chemistry and associated technology, combined with decreasing costs of supply, has
seen the global growth and uptake of grid-scale battery energy storage system (BESS) facilities (shown as a
contributor to transmission networks in Figure 1). The development of batteries for energy storage is expected to
significantly increase in the next decade, going from a global capacity of about 11 Gigawatt hour (GWh) in 2017 to
100 - 167 GWh or even 181 - 421 GWh1, in 2030 [2].
1
As specified within the International Renewable Energy Agency (IRENA) report, this represents a scenario where the “stationary battery
storage increases relatively in response to meet the requirements of doubling renewables in the global energy system by 2030” [2].
GHD | Australian Energy Council Limited | 12591546 | Battery Energy Storage Systems 1
There have been a number of BESS installations in the past decade; most notably, the South Australian Hornsdale
and Victorian Big Battery facilities are two of the larger sites globally. There are currently a number of grid-scale
BESS facilities under construction and a multitude of projects which are soon to begin or have been confirmed [3].
Despite the many advantages that electrochemical storage present, from an asset and public safety perspective
there have been numerous self-heating and thermal runaway incidents associated with Li-ion batteries [4] [5] [6].
These events have increased the awareness of thermal risks associated with Li-ion BESS installations, and have
highlighted that there are ‘unknown unknowns’ associated with large-scale electrochemical storage. With BESS
facilities, the number of electrical connections and piping couplings required increases with the number of battery
cells and modules. Until recently, there has been minimal variation in battery cell size, and with modular design
components of a set size, it is inferred that the number of failure points will tend to increase linearly with the size of
the facility. Therefore, larger facilities are likely to have more failures than smaller ones and, if not designed
properly, these failures can escalate to other nearby cells, modules and beyond. This is starting to change as
proponents, regulators and equipment manufacturers are actively embracing recent learnings alongside continual
technological and scientific advances.
Logically, larger facilities need more comprehensive safety control systems, and more detailed siting and layout
assessment than smaller facilities to achieve similar risk levels. Various stakeholders are seeking a consistent and
mature approach to implement the safety controls system to achieve well defined and acceptable risk levels.
The Australian Energy Council (AEC) are cognisant of these issues and how the accelerated pace towards a low
emissions future, although positive, poses challenges. Currently representing “20 major electricity and downstream
natural gas businesses operating in the competitive wholesale and retail markets [7],” the AEC secretariat
represent a team of energy analysts, economists, and public policy advocates. Members have recognised that the
experience and knowledge associated with managing conventional power stations is not wholly transferrable to
new energy generation and storage facilities. Utilising the AEC’s extensive network, GHD has been commissioned
to produce preliminary guidance material to initiate and facilitate collaboration amongst its member organisations
towards a harmonised leading practice approach for grid-scale BESS facilities in Australia.
1.2 Purpose of this guidance material

These recent battery thermal and explosion events have highlighted to the AEC the potential issues associated
with current operational grid-scale BESS facilities as well as those planned within the AEMO’s pipeline of new
facilities.
The purpose of this engagement is to provide the AEC with informed guidance material associated with grid-scale
(or commonly referred to as large-scale) battery energy storage facilities which will aim to capture the hazards and
risks associated with the life cycle of a BESS facility. Due to the accelerated pace of battery chemistry
development, the guidance material presented primarily focuses on lithium-ion based chemistries, with supporting
commentary on vanadium redox flow batteries. This report summaries GHD’s findings from:
– The literature review. The literature review completed examines the evolution of battery chemistry, issues
such as thermal runaway, and provides a summary of recent grid-scale BESS incidents. From this, GHD
reviewed the potential environmental and societal implications and identified potential gaps and opportunities
moving forward, thus informing the guidance material
– Review of relevant standards, acts, regulations, and available guidance material
– Interview sessions with five (5) relevant stakeholders, identifying how these parties currently form part of the
consultation and/or approvals processes needed for the development, operation, and decommissioning of
grid-scale BESS facilities
– Broader industry knowledge of good practice, and harmonised approaches of identifying and managing
safety, utilising the well-established fundamental principles and approaches from other industries and sectors,
such as the rail and transport industries, the power sector, oil and gas, dams, and nuclear
From these findings, this report articulates suggested key elements required for guidance material associated with
grid-scale BESS facilities. A supporting high-level risk assessment provides a summary of the potential safety,
health, environment, and quality issues identified during the aforementioned reviews and interviews. This was
subsequently translated into a guidance flow-chart to assist future stakeholders with implementing a consistent,
risk-informed approach to grid-scale BESS facilities.
1.3 Scope and limitations
The scope of this project is to (1) produce a high-level risk assessment and (2) develop guidance material which
captures the findings from the following activities and engagements completed:
– Literature review
– Relevant standards, acts and regulation review
– Findings from interviews with relevant stakeholders
– Existing guidance material review
The stakeholders interviewed are summarised in Table 1.
Table 1 Stakeholders interviewed for development of guidance material
Stakeholder Stakeholder Type Role / Team

Contemporary Amperex Technology Co., Original Equipment Technical Team members
Limited (CATL) Manufacturer (OEM)
Country Fire Authority (CFA) Fire authority Risk and fire safety specialist and advisor
The Victorian Energy Safety Regulator General Manager Electrical Safety, Head of
Commission, also commonly referred as Risk, and members from different groups
Energy Safe Victoria (ESV)
Queensland Government, Environmental Government regulator Member of Environmental Services and
Services and Regulation, Department of Regulation team
Environment and Sciences (DES)
Health and Safety Professional OEM Health, Safety, Environment and Quality
(HSEQ) Australasian Lead
This engagement represents a valuable step in assisting AEC in their journey towards creating a more formalised
guidance material and meeting their objective of promoting consistency and synergy between the various
stakeholders involved in the lifecycle of grid-scale BESS facilities.
Due to the proprietary nature of the some of the information, GHD relied upon publicly accessible information, as
well as what was shared during the stakeholder interviews. Within the constraints of the project, GHD have
identified recurring themes and areas of importance. Given the evolving nature of battery chemistry, technology
trends and market participants this document represents preliminary guidance that should continue to be
considered for further development and periodically reviewed with key stakeholders which the AEC subsequently
identify.
The following is excluded from the scope of this engagement:
– Prediction of future battery chemistry trends. Although this guidance material briefly discusses other batteries
chemistries (refer to Section 3.1), it is unknown whether these, or other battery chemistries, will complement
or replace the existing, common Li-ion chemistries currently utilised. This guidance material aims to provide a
considered, holistic approach for grid-scale BESS facilities, focusing primarily on the considerations and risks
associated with Li-ion batteries and also vanadium redox flow batteries.
– Development of guidance material associated with residential battery modules or community-scale BESS.
– Development of guidance material associated with use of combined energy storage systems. An example of
this includes sites which have battery and hydrogen energy storage systems; these combination storage
facilities have recently been referred to as renewable energy hubs [8]. Although these facilities will broadly
present a similar cross-section of risks, there are other factors such as the production and storage of
hydrogen which need to be taken into consideration and is beyond this scope of works.
– As the diversity of applications of energy storage is increasing, the reliability requirements of some
applications may affect the design, i.e., critical communications and detailed classification of grid scale BESS
facilities as critical infrastructure. Some of these evolving demands or compliance requirements may go
beyond the general good practice requirements developed and will need to be considered within guidance
materials moving forward. These considerations have been raised in this guidance, but detailed discussion
has been excluded from this scope.
– At a high level, the guidance provided within this document is aligned with the National Electricity Rules.
However, detailed assessment is required to validate this, which is outside the scope of this engagement.
– Philosophical and larger questions about BESS systems. These include:
• Whether BESS facilities are environmentally sustainable
• Whether a BESS is the right type of energy storage solution
• Heritage land site considerations during the siting optimisation exercise prior to BESS construction
• Any specific site location issues, including visual or other amenity considerations in urban and local
environments
• Any specific State regulatory requirements
– Development of consequence, likelihood, and risk rating descriptors for the high-level risk register. As the aim
of the risk register is to provide an initial draft pre-populated risk register for use. It is assumed that
organisation will review the risk register and transfer these risks to their respective templates and rank
accordingly, in doing so the users will also consider any further specific project and organisation specific
matters as is usual in conducting risk assessments.
1.4 Assumptions
The following assumptions were made as part of this engagement:
– Interviews and consultations
• As part of this engagement, several interviews and consultations were required with various State
regulators, Original Equipment Manufacturers (OEMs), and other authorities as listed in Section 1.3. To
effectively liaise with each, it was necessary for AEC to assist GHD with identifying key personnel.
Where needed, GHD suggested interviews with stakeholders which GHD have previously engaged with,
or have current contacts
• In addition to the above, follow up contact with participants for matters requiring clarification was
anticipated. At the time of writing GHD has yet to receive further feedback from those interviewees where
follow up queries subsequent to the interviews were made.
• Some of the information provided by stakeholders within these interview sessions is commercially
sensitive information. As such, all recordings or annotated notes will not be accessible without
permissions from the AEC or the interview participants. All recordings will be destroyed by GHD following
the completion of this engagement
– The energy storage market is rapidly growing, with new battery technology constantly emerging, as well as
regulatory approaches that are maturing. Whilst efforts were made to get the most recent information, there
will likely be emergent information and approaches in addition to these findings over the next few years. This
may supersede or amplify the importance of some of the information provided within this guidance and
material which is referenced
– The location of grid scale BESS facilities is dependent on many factors associated with their intended
utilisation in high voltage transmission networks. Each intended location will require its own independent
assessment, which may reveal additional considerations not addressed by this guidance material.
2. How was this guidance material
developed?
A number of Acts, Regulations, Standards, and guidance materials are currently available to instruct, or where
compliance criteria are not clearly defined, assist with the development of grid-scale BESS facilities. Some
guidance material, such as the Clean Energy Council’s (CEC) Best Practice Guide: Battery Storage Equipment [9],
previously sought to engage industry associations involved in this field to provide an “agreed minimum standard”
to be upheld in Australia. However, the accelerated pace of development, in combination with the time and
involvement required to update Acts, Regulations, Standards, and guidance materials, has seen widely relied upon
material in need of review and updating for this expanding field.
This guide has been developed to assist the AEC in their objective to promote consistency and synergy between
the various stakeholders involved in the lifecycle of grid-scale BESS facilities. As discussed in Section 1.3, this
document represents a preliminary step towards the development of further, comprehensive guidance, and is
primarily focused on Li-ion chemistries. Unlike the CEC guide which aims to present safety hazards associated
with different “types” of storage (i.e., battery module, pre-assembled battery system equipment and pre-assembled
integrated battery energy storage system equipment), this guidance draws on the growing trend of increasing site
storage capacity and is focused on assisting in differentiating and categorising the minimum assessment
requirements for these grid-scale installations.
To gain an understanding of the key issues and concerns, recurring themes, and developments across a spectrum
of remits, GHD completed a literature review (Section 3) and interviewed five (5) organisations (see Table 1 for
stakeholders who participated in this engagement). It should be noted that GHD utilised existing industry
connections to contact the CFA and ESV, while AEC reached out to the remaining participants. These stakeholder
consultations were held in an interview-style arrangement, with GHD facilitating the interviews which were
approximately an hour in duration. To assist these conversations, GHD prepared a list of questions (refer to
Appendix B) which was used as a basis for each consultation. It was recognised that there was a need to have
differing prompts due to the spectrum of organisations and the respective remits of the interviewees.
In the event where participants were unable to answer questions or needed to consult other members within their
organisation to verify responses, GHD provided the questions following the interview. However, no further
responses were further received during this engagement.
The findings from the literature review and the interview process were subsequently consolidated within a high-
level risk register. It is recognised by GHD that there is existing guidance material available (CEC Best Practice
Guide [9]) and the purpose of this register is not to replicate this material. Instead, the register provided within
Appendix D, aims to capture risks which have importance for good practice design features of the facility, including
quality, environmental, operability, and end-of-life considerations.
As this guidance material is meant to be utilised by multiple organisations, which would all have different risk
management processes (thus, different risk matrices and descriptors), the risk register provided does not aim to
develop consequence, likelihood and risk rating descriptors. Rather, it provides an initial pre-populated risk register
which organisations can then transfer into their respective templates and rank accordingly. Alternatively, as the
AEC progresses the development of this risk assessment, organisations who are members of the AEC should
socialise this register and define the likelihood, consequence, and risk descriptors.
Finally, GHD present preliminary guidance (Section 5) recommendations which drawn upon fundamental
principles such as recognised good safety approaches, emerging standards and codes, and leading regulatory
requirements.
It is expected that this material is distributed and reviewed with other AEC members to further develop and
subsequently refine prior to publication. Compliance with this guide does not replace or substitute compliance with
existing Acts, Regulations, Standards, and other statutory obligations.
3. Literature review
This literature review aims to provide a summary of the material drawn upon to synthesize the grid-scale BESS
guidance material. The sources which formed part of this review were determined based on current relevance
(e.g., UL 9540A which is used to demonstrate propensity of thermal runaway propagation) and material which
interview participants acknowledged played a role in their decision-making process. It has been acknowledged that
battery penetration into the energy storage sector has “outstripped our actual knowledge of the risks and hazards
associated with them [10]”. Therefore, in addition to the above, this review also aims to identify areas of interest,
concern and gaps within existing literature based on fundamental risk understanding.
As this field is evolving, with many concurrent efforts underway to manage existing battery chemistries,
technologies and understanding of how to manage the lifecycle of BESS facilities develops, it is acknowledged
that the sources used to inform this guidance material may be revised or become outdated in the short-term future.
This literature review aims to distil the information reviewed into practicable elements, the learnings of which can
be transferrable as grid-scale BESS facilities advance.
The review is divided into the following sections:
– A summary of the evolution of battery chemistry (Section 3.1)
– Grid-scale BESS facility thermal runaway events (Section 3.2)
– Grid-scale BESS facility Occupational Health and Safety (OH&S) considerations (Section 3.3)
– Grid-scale BESS facility Environmental considerations and implications (Section 3.4)
– Other areas of consideration (Section 3.5)
– Key observations from reference material (Section 3.6).
As lithium-ion chemistry, specifically lithium iron phosphate (LFP) is the dominant battery chemistry used in grid-
scale BESS facilities, Section 3.2 to Section 3.6 primarily focuses on this. However, issues identified in Section 3.4
provide commentary on areas which are specific to vanadium redox flow (VRF) batteries. Furthermore, Section 3.5
posits other areas of concern which would be applicable across a spectrum of battery chemistries.
3.1 A brief summary of the evolution of battery

chemistry
The advancement in battery chemistry and associated technology combined with decreasing costs, has resulted in
grid-scale BESS facilities becoming a viable means of promoting the accelerated uptake of renewable energy
options. Of the available types of energy storage devices, batteries are considered desirable due to the ability to
connect in series and / or parallel to increase power capacity or adapt to requirements of specific applications [11].
Optimal battery chemistry is being sought after, with multiple efforts underway to progress existing formulations
[12]. The following provides a high-level summary of battery chemistries which have been used in grid-scale BESS
applications or have been expressed as potential alternatives during stakeholder consultations.
Table 2 provides an overview of the advantages and potential hazards and disadvantages associated with each
chemistry discussed within this section.
Table 2 Battery chemistry overview
Battery chemistry Advantages Disadvantages and hazards

Lithium-ion – Energy efficiency >90% [13] – Potential for thermal runaway (greater for
Li-ion chemistries are – High energy density, ranging between 100-265 Nickel Manganese Cobalt (NMC)
diverse. Nickel- Watt hours per kilogram (Wh/kg) formulation). Most electrolytes are
Manganese-Cobalt flammable. This has been evidenced and
– Wide availability and cost effective is further discussed in Section 3.2.
and Iron Phosphate
formulations are – Due to high energy density, footprint of land – Limited temperature performance window
commonly used required for facility is comparatively lower than (i.e., not compatible with extreme cold or
within BESS facilities other low energy density formulations hot conditions)
– Compatibility issues
Battery chemistry Advantages Disadvantages and hazards
– Reactive and hazardous in off-nominal
conditions
– Previous incidents of failures of safety
systems during electrical surges
– Potential for explosion from gas
accumulation of gases produced in a fire
Lithium-ion polymer – Reduction, or in some cases elimination, of – Costly and therefore grid-scale
battery thermal runaway potential applications may not yet be viable from a
– Greater energy density than non-polymeric Li- commercial perspective
ion chemistries
– Due to high energy density, footprint of land
required for facility is comparatively lower than
other low energy density formulations
Vanadium redox flow – Better safety and efficiency with long life cycle – Low energy density in comparison to Li-
battery – Easily able to scale up energy storage capacity ion formulations, therefore large facility
footprint is required [15]
– Longer expected operational performance and
life in comparison to Li-ion batteries, – Potential for vanadium electrolyte to be
released into the environment if there is a
– Broad temperature operation envelope, loss of containment event
operating between -20 °C and 50 °C [14]
– Elimination of cross-contamination risks in
comparison to other existing flow batteries as
the same material is used in both half cells
– Lack of combustible materials used for
construction
Sodium-ion battery – Moderate energy density, with research – Electrolyte solvation issues
underway to achieve densities of up to 200
Wh/kg
– Abundant element in comparison to lithium
– Non-flammable chemistry (however,
flammability is dependent on exact
compositions)
Lithium-ion batteries
Li-ion present fundamental advantages over other chemistries, making them the current favourable battery
chemistry utilised for grid-scale energy storage solutions:
– Li has the lowest reduction potential of any element, allowing Li based batteries to have the highest possible
cell potential
– Li is the third lightest element and has one of the smallest ionic radii of any single charged ion
– The monovalent charge reduces Li-ion mobility.
These factors allow Li-based batteries to have high gravimetric and volumetric capacity and power density.
Commonly used battery chemistries in grid-scale BESS facilities are Li-ion Nickel-Manganese-Cobalt (NMC) or Li-
ion Iron Phosphate (LFP) formulations [16]. As an example, LFP batteries now have energy densities which range
between 100 and 265 Wh/kg which is significantly greater than the 90 Wh/kg density quoted a decade ago [16].
Equipment manufacturers, such as Tesla, have transitioned from NMC batteries to LFP batteries, largely due to
the LFP’s reduced thermal runaway propensity at higher operating temperatures, as well as other characteristics
like increased battery life [17] [18].
Other Li-ion chemistries and formulas, such as Li-ion polymer batteries are being investigated as certain
formulations are quoted to achieve greater safety (e.g., reduction or elimination of thermal runaway), increased
energy density, material stability within a greater operating envelope, and an enhancement in overall performance.
Issues such as thermal runaway, and desires to develop safer options without compromising performance, has
promoted further research and development into investigating alternate chemistries (which may or may not be
lithium based) for grid-scale BESS applications.
Vanadium redox flow battery
An attractive alternative currently being trialled globally is the use of vanadium redox flow (VRF) batteries. The
energy in these batteries is stored in a liquid vanadium electrolyte and the change in valence of the vanadium ions
facilitates the movement of protons through the membrane, charging and discharging the battery [19]. A schematic
of the redox flow battery is provided in Figure 2.
Figure 2 Principle and configuration of the vanadium redox flow battery (Figure 2 in ref [19])
Sumitomo Electric recently brought online one of the world’s largest VRF BESS in northern Japan [20]. This
project builds upon an existing 15 Megawatt (MW) / 60 Megawatt hour (MWh) VRF system commissioned in 2015
in Hokkaido (in partnership with Hokkaido Electric). Another project which was commissioned in 2022 is the Dalian
Rongke Power VRF system in Dalian. The first phase of the project has a capacity of 100MW / 400MWh, and the
second phase will see the site operate at full capacity of 200MW / 800MWh [21] .
The advantages conferred with this technology with regards to grid-scale BESS applications include, but are not
limited to, the following [22]:
– Easily able to scale up energy storage capacity.
– Longer expected operational performance and life in comparison to Li-ion batteries,
– Consistent performance, with a broad temperature operation envelope, making it a candidate for regions
which experience temperatures approximately between -20 °C and 50 °C [14]
– Elimination of cross-contamination risks in comparison to other existing flow batteries as the same material is
used in both half cells.
– Lack of combustible materials used for construction.
– Low likelihood of fire (dependent on the electrolyte composition).
Although the all-vanadium redox flow battery is a promising technology for grid-scale energy storage, the
comparatively low energy density compared to Li-ion batteries, combined with the stability of vanadium electrolyte
solutions outside of their operational envelopes makes it a less favourable choice in some respects.
Sodium ion battery

Another battery chemistry which may be an alternative candidate to Li-ion based batteries are sodium-ion (Na-ion)
batteries. Similar to VFR batteries, Na-ion batteries present many advantages compared with Li-ion batteries.
Although explicit announcements regarding use of Na-ion batteries for grid-scale BESS applications has not been
sighted, it is known that they are or will be utilised in other applications. CATL’s first-generation Na-ion battery has
an energy density of approximately 160Wh/kg per single battery cell, and in 2021 it was announced that there
were plans to use these for electric vehicle applications [23]. This battery technology is an appealing alternative,
given its environmental abundance, non-flammable nature, and reduced susceptibility to temperature changes
relative to Li-ion batteries [24]. However, as the comparatively lower energy density and issues encountered with
electrolyte stability at certain voltages [25] are seen as two disadvantages associated with the Na-ion batteries.
3.2 Grid-scale thermal runaway events

3.2.1 Thermal runaway
Despite the many advantages associated with electrochemical energy storage, there have been numerous self-
heating and thermal runaway incidents at grid-scale BESS facilities over the past decade. Therefore, there is a
growing concern that more thermal events will occur as the demand increases for the construction and use of grid-
scale energy storage facilities globally.
As defined by Sauer [26], a thermal runaway incident is “where one exothermal process triggers other processes,
finally resulting in an uncontrollable increase in temperature. This can result in the destruction of the battery or, in
severe cases, in fire.” The critical aspect of escalation to a thermal runaway event is if the initiating event or fault
results in enough heating to lead to a reaction where the rate of heat generation exceeds the rate of heat loss – a
self-supporting exothermic reaction [27].
While thermal runaway is a possible consequence of a variety of failure modes, it can be broadly categorised into
the following groups [28]:
– Electrical abuse (e.g., overcharging / discharging)
– Thermal abuse (e.g., overtemperature)
– Mechanical abuse (e.g., external impact)
– Existing, latent defect (e.g., electrolyte leaks, faulty components).
With respect to Li-ion batteries, extensive studies have been conducted to understand the mechanistic pathways
which promote thermal runaway events. This knowledge can then be used to develop effective mitigation
measures to either eliminate or reduce such occurrences. A study by Feng et al. [29] aimed to summarise such
mitigation strategies and provided a time-sequence system level map to illustrate to readers how mitigation
measures could interrupt the various thermal runaway pathways identified. This is provided as Figure 3.
Figure 3 Thermal runaway states of a Li-ion cell and correlated mitigation strategies (Figure 3 within Feng et. al [29])
Controls for thermal runaway and fire include, but are not limited to, the following [30]:
– Additives to be mixed with or replace the flammable solvent.
– A separator that is fire resistant with thermomechanical stability and ion-transport resistance.
– Current Interrupt Devices (CID).
– Positive Temperature Coefficient devices.
– Safety or pressure vent.
– Remote monitoring of voltage, current, and resistance for abnormal results.
– Gas detection sensors.
– Appropriate cooling of battery system.
– Calorimeter to measure internal heat generation.
– Minimum prescribed separation distances between battery units.
– Thermal insulation within a battery unit.
– Fire suppression systems – water-based suppression was considered effective against propagation of battery
fires [16] by allowing cooling of neighbouring battery modules to prevent escalation of thermal runaway
events.
It is important to note the temperature triggering a self-sustaining exothermic reaction varies between Li-ion
batteries as it is dependent on a range of factors, such as the electrolyte used. Thus, the mitigation strategies and
design controls should be assessed on a case-by-case basis.
Bodies such as the CEC have documented detailed control measures within their BESS Best Practice Guide and
accompanying risk assessment, in addition to the list presented above [9]. Separately, OEMs and proponents
responsible for BESS facility site operations have been building upon this existing material or completing other risk
assessments (such as Failure Mode Effectiveness and Criticality (FMECA) analysis) to determine appropriate
control measures2.
Managing fires in battery modules poses a particular threat as there is the potential for fires to spread to other
modules, emit toxic or flammable gases, with the potential to cause an explosion [31].
3.2.2 Past grid-scale BESS thermal runaway events

Despite our collective understanding of thermal runaway propagation and the various mechanistic pathways it can
follow, there are still gaps being identified. A review of highly publicised grid-scale BESS incidents within the past
decade demonstrates this, and the iterative improvements being made as a result of the learnings. A high-level
overview is provided in Table 3, noting that this is not an exhaustive list.
Table 3 Overview of recent BESS fire events
Date Event Facility Location Comments

Size
2017 to Multiple Various South Korean More than twenty (20) fires due to BESS facilities have
present events facility BESS occurred in South Korea since August 2017. In response to
sizes facilities these incidents, a fire investigation committee was formed to
review each event, analyse the root causes and distil the
findings as part of an incident report. The report, which was
released on 11 June 2019 concluded that there were four
major cause categories for the BESS fires [32]:
– Insufficient battery protection systems against electric
shock
– Inadequate management of operating environments
– Faulty installation (due to human error)
– Insufficient integration of the protection and management
system of the BESS
April 2019 Battery fire 2 MW / 2 Arizona After an extensive independent investigation [16] [33], it was
MWh Public found that the following were contributing factors which led to
Service the explosion:
McMicken – Internal defect within the LG Chemical batteries (Li-NMC)
BESS facility which initiated an “extensive cascading thermal runaway
event”
– Lack of thermal barriers between battery cells
– Storage container design did not allow the vapour and
gases produced during the incident to vent, leading to a
build-up of flammable / explosive gases within the
container
– Inadequate emergency response plan which did not
instruct personnel how to extinguish the fire or specify the
entry procedure
April 2021 Battery fire 4 MW / 8 Yurika Bohle Yurika managed the site and on 8 April 2021 a fire was
MWh Plains, reported at the BESS.
Townsville, Specific details of the incident have not been publicly
Queensland communicated. Publicly available information is that Tesla
BESS facility powerpacks were initially installed at the facility and the fire
occurred during commissioning [34].
July 2021 Battery fire 300 MW / Moorabool, The Tesla Megapack batteries were of a Li-NMC chemistry
450 MWh Victoria Big [35]
Battery BESS It was stated by Energy Safe Victoria that the probable root
facility cause of the thermal escalation event was a leak in the
internal coolant system of the Tesla Megapack 1.0 design in
combination with unmapped SCADA systems during the
commissioning.
2
These have been sighted as part of separate confidential engagements GHD has been involved in or have completed as part of other
engagements. Although specifics cannot be shared within this document, key mitigations are embedded within the list above.
Date Event Facility Location Comments
Size
The event started in one megapack and escalated to another,
and thermal radiation from this fire damaged two adjacent
megapacks.
September Overheating 400 MW / Monterey
2021 & incident 1,600 County, Li-ion battery modules, which formed part of Phase I of the
February MWh California Moss Landing BESS, were operating above their operational
2022 Phase I & Moss Landing temperature limit. Vistra Energy communicated that the
Phase II BESS facility safety features of the facility responded as expected:
targeted sprinkler systems were triggered for the impacted
modules and personnel were made aware of the operational
limit exceedance [36].
Following investigation, in January 2022 it was reported that
the overheating of the battery was not the cause of the
incident. Rather, it was possibly due to a fan bearing causing
smoke which triggered the water system. Due to faulty
couplings, the water system improperly sprayed the battery
racks which led to overheating of the batteries [37].
In early 2022, Phase II was taken offline. It was reported that
a sprinkler system released water onto the battery racks,
similar to what occurred in Phase I [38].
April - Multiple Multiple Various Three BESS fires occurred in the US in California and
August events facilities BESS Arizona. The first in California was contained to a single
2022 facilities battery module due to the correct function of the safety
systems [39].
The second was an explosion of a BESS in a caravan park
attached to a solar system in California. There were no
injuries reported but nearby structures were severely
damaged [40].
The final was in Arizona, a BESS unit was smouldering and
required intervention to provide ventilation [41].
The causes of the incidents had not been reported.
September 10 battery 182.5 MW Monterey Initial reports suggest that the first event appeared to be a
2022 packs catch / 730 MWh County, repeat of the incident which occurred in September 2021 [38]
fire California (described two rows above).
Elkhorn A second incident occurred in September causing a highway
BESS facility closure due to possible hazardous gas releases during a fire
incident [42], [43].
October Battery fire 25 MW / Hainan, A fire occurred during commissioning at a 100 MW
2022 50 MWh China photovoltaic project at a sea salt farm. The battery was
allowed to burn itself out while being monitored by firefighters
[44].
McMicken BESS incident

Following the McMicken BESS fire the Det Norske Veritas (DNV) led investigation revealed that although the fire
suppression system had worked as intended it was “not capable of preventing or stopping cascading thermal
runaway in a BESS” [16]. Despite the fire suppression system being designed and operated with the governing
requirements at the time of the incident, this event demonstrated that requirements need to be tailored to BESS
facilities and cannot simply be taken, replicated, and applied without accounting for site specific considerations
and technological differences.
Victoria Big Battery incident

The Victoria Big Battery (VBB) thermal runaway incident which occurred on 30 July 2021 saw two Tesla
Megapacks heat damaged and two megapacks heat affected to various extents during testing and commissioning
activities. This thermal event escalated beyond the confines of one Megapack and impacted adjacent Megapacks
to various degrees, some of which were located approximately three metres away, as shown in Figure 4. An
incident report published on the Victorian Big Battery website states that the Tesla Megapacks present at the site
during the initial commissioning period passed the UL9540A test. As quoted in the report “In addition to cell and
module level tests, Tesla performed unit level tests to evaluate, among other faire safety characteristics, the
potential for fire propagation from Megapack-to-Megapack [45].”
This demonstrated that thermal runaway of one unit could have a greater reach not previously considered. An
investigation led by ESV stated that the probable root cause of the event was “a leak within the Megapack cooling
system that caused a short circuit that led to a fire in an electronic component [46]”. Tesla have since updated their
Megapack configuration (MP2XL) and now use LFP chemistry, along with a revised design of the modules. Their
UL9540A testing of the latest units indicates no thermal event propagation potential of suitably spaced
Megapacks.
Figure 4 Victoria Big Battery fire incident [47]
Moss Landing incidents

There have been three incidents at the Moss Landing Energy Storage facility located California; two of which were
associated with the system owned operated by Vistra Energy (400 MW / 1,600 MWh) BESS and the other
associated with the Elkhorn Battery (182.5 MW / 730 MWh) which was commissioned in April 2022. An
investigation into the Vistra Energy BESS Phase I thermal event found that due to faulty couplings, the water
system improperly sprayed the battery racks which led to overheating of the batteries. The corrective actions from
this incident included “sealing gaps between the floor levels containing battery racks to prevent water leaking from
one down to the other, testing all heat suppression equipment thoroughly and reviewing the programming of the
Very Early Smoke Detection Apparatus (VESDA) [36].” A similar incident occurred for Phase II.
The cause of the Elkhorn BESS fire is currently being investigated. Unlike the Vistra Energy fires, this incident led
to the partial closure of a highway and local residents were advised to take shelter and close windows due to the
risk of exposure to hazardous materials [43].
In summary:
These events highlight that there may still be further understanding to be developed of how the overall battery
systems design and implementation, general facility design (including orientation and inter module spacing), and
external factors influence the initiation and propagation of battery thermal runaway events. Although there is
literature demonstrating how battery modules are assessed with Computational Fluid Dynamic (CFD) modelling
[29], whole of site analysis with respect to consequences from thermal runaway have not been sighted as part of
this engagement. However, Airflow Sciences Corporation [48] have recently demonstrated capability to model
BESS facilities to assist “authorities and utilities making crucial decisions about evacuations, site design, and
BESS unit locations, and [how] they can play a vital role in a site’s risk mitigation planning.” Thus, due to the
growing complexity and size of BESS facilities, there is a need to view each facility on a case-by-case basis and is
further discussed in Section 5. .
3.3 Occupational, Health and Safety (OH&S)
considerations
Guidance material on the OH&S considerations for residential, small commercial buildings and community scale
battery energy storage applications is widely available. For example, Worksafe Queensland provides high-level
guidance on the safety implications of incorrect installation and the need to have competent workers to install
BESS, “safe work practices” in place, as well as compliance with relevant legislation, rules, and standards [49].
The Department of Mines, Industry Regulation and Safety Building and Energy (DMIRS) of Western Australia
provides a guide for electrical contractors, that also provides guidance on some OH&S matters. However, specific
guidance which focuses on OH&S of permanent or transient workers within grid-scale BESS facilities was not
sighted during this review.
3.4 Environmental considerations and implications

3.4.1 Environmental impact during normal operations
There are few environmental impacts from the normal operations of a Li-ion BESS. In urbanised areas, large scale
BESS facilities may have a nearby ‘heat island’ effect on its surrounds, however, little information is available in
the public literature. Specifically, the BESS units and associated power equipment produce heat while operating;
this coupled with solar radiation could increase the ambient temperature in and around the BESS facility.
Therefore, heat pollution may be a potential side effect on the facility as well as adjacent areas during normal
operations. It should be noted that this localised heat island effect could be higher than that of typical low and
medium density urban locations, however studies have not been conducted for this exercise and representative
thermal modelling for an entire site (including a case study) was not sighted during this review.
Noise emissions during normal operation are currently being considered by stakeholders and their impact on
residential receptors located in close proximity to BESS facilities [50] [51]. As an example, ACEnergy, a utility-
scale solar farm BESS provider, have listed potential noise control strategies within their publicly available
assessment findings. These include:
– “Ensuring inverter units are fitted with suitable manufacturer noise reducing kits
– Configuring battery storage container air conditions units to maximise noise shielding in the direction of
residential receptors. This will include the construction of four-side acoustic barriers around the air conditions
units internally lined using sound absorbing materials
– Construction of localised acoustic barries around the proposed inverter units combined with an independent
acoustic barrier”
Due to the continuous operation of BESS facilities and the modular nature of the facilities, it has been
recommended that noise levels are assessed for (1) different modes of operations and (2) at different times (e.g.
daytime and night-time).
3.4.2 Environmental impact during and following a fire event

Unlike normal operations, significant environmental impacts may be possible in the event of the Li-ion BESS fire.
This impact is magnified given the extent of the fire, and the time and resources it takes to extinguish. The two
primary impacts include:
– Fire water runoff generated during the control of a fire, impacting local flora and fauna and contaminating soil,
groundwater and/or surface water.
– Air emissions produced during combustion.
The Victorian CFA have recommended within their guidance material that “infrastructure is provided for the
containment and management of fire water runoff…[and] may include bunding, sumps and/or purpose-build
impervious retention facilities.” A reference to Australian Standard (AS) 4681-2000 Section 7.3.9 Control of run-off
is provided as a recommended resource to review. Although not required, CFA state that the site water
management plan “may” include information on the containment and disposal of contaminated fire water.
While water runoff can generally be contained using a robust site drainage design, air emissions cannot be
contained to the site, and can extend to a distance downwind of the site. Thus, is the potential for people in the
vicinity of a BESS facility fire to be exposed to hazardous gases such as asphyxiants and irritants [52]. This
occurred during the Elkhorn BESS facility fire in September 2022, prompting a nearby highway closure to minimise
exposure to possible hazardous gases [43]. Following draft review, Synergy have stated that their local first
responders will apply water spray downwind of a fire to minimise transfer of smoke particulates beyond the site.
Although the gases released are dependent on the battery chemistry [16], gases that may be emitted include:
– Fluorine [53]
– Hydrogen
– Carbon monoxide
– Carbon dioxide
– Methane
– Ethylene
– Propylene
– Nitrogen oxides
– Hydrogen Cyanide
– Hydrogen Fluoride
The fire risk profile of VRF BESS facilities is significantly lower than Li-ion as mentioned in Section 3.1. This is
dependent on the electrolyte composition, specifically the degree of hydration. Therefore, when considering the
use of VRF batteries, fire risk should still be reviewed.
3.4.3 Environmental impact due to loss of containment event

There is also potential for environmental impact if there is a loss of containment from Li-ion BESS, such as loss of
containment of refrigerant, loss of containment of coolant, and/or loss of containment of oil from transformers on
site. Depending on the amount lost, all three scenarios identified have the potential to pollute groundwater and
runoff into local water mains if adequate protection measures are not in place. As there are a spectrum of
refrigerants and coolants which may be utilised for these systems, in conjunction with the quantities varying
between battery module size and overall site configurations, and various safety mechanisms in place to detect
leaks, detailed literature on these loss of containment scenarios were not sighted as part of this review.
Comparatively, VRF BESS facilities hold more electrolyte with pipework, pumps, and other infrastructure like
traditional process plant operations. Although some VRF battery developers claim that the electrolyte they have
proprietarily developed is non-toxic [54], other sources state that the addition of sulphuric acid or hydrochloric acid
which make up the electrolytic composition, as well as the vanadium itself, are toxic and corrosive [55].
Furthermore, another concern is the fumes which could be released during a loss of containment event of the
electrolytic solution.
3.4.4 Environmental impact during decommissioning

From a reliability perspective, battery modules will be a key item requiring replacement throughout the operational
life of the facility. It is likely that individual battery modules will be decommissioned progressively, with the potential
to replace these decommissioned modules with improved, compatible equivalents which may possess greater
energy storage capacity. This could occur sequentially rather than an entire facility battery upgrade as it is
relatively easy to isolate and disconnect battery racks from the overall module, and likewise modules from the
overall battery pack, and then replace with an updated component.
Key areas of concern when considering the disposal of battery modules (or battery racks which are housed within
the modules) include (1) sustainability, (2) potential for environmental discharges, and (3) the fire risk. Normally,
there is some state of charge within the battery cells at decommissioning. There is latent chemical reactivity of the
battery cells to oxygen or water (i.e., an oxidising agent), so adequate care is needed in the removal, handling,
and disposal of the cells.
There are a growing number of recycling facilities for processing lithium and other chemistry batteries overseas. In
Australia, the amount of lithium recycled is comparatively low but is likely to improve due to growing sustainability
impetus and due to the increase in price of lithium. Approximately 92% of the lithium battery material can be
recycled, thus there is a driver to recycle this material so it can be utilised again. OEMs such as Tesla [56] [57] and
CATL [58] recycle their batteries, and independent facilities, like Ecobatt in Australia recycle lithium batteries [59].
Apart from some specific suppliers, in general there needs to be more specific guidance regarding the disposal
and recycle processes, as each will have unique attributes.
With respect to VRF batteries, the electrolytic solution can be reused with minimal documented degradation.
Unlike Li-ion battery facilities, if the capacity of a VRF BESS is looking to be upgraded, the infrastructure which will
be replaced as part of the decommissioning process will mainly include the electrolytic tanks [10], piping and, if
needed, pumps. The Australian Battery Recycling Initiative (ABRI) have assessed the vanadium flow battery
recycle potential [60], noting that vanadium, acid, and plastics could be recovered in the process.
During the literature search, the following discussion points were not sighted and have been put forward here for
further consideration:
– As battery chemistry and technology evolves, it is likely that the overall large energy storage sites will
increase in power output and storage capacity. The overall power systems could be expanded from a
modularity perspective, i.e. adding extra modules like the Neoen Hornsdale facility, so the disposal would
likely still be at the modular level, but in greater quantities.
– Owners and regulators may eventually require OEM providers to further articulate broader asset management
plans which provided detailed decommissioning considerations for proponents responsible for site operations.
Key aspects may include decommissioning of components within battery modules; the battery module itself;
and how the site design influences the decommissioning process. If these processes are not well developed
or adequately communicated, it is possible that there may be environmental effects from disposal and landfill
of spent batteries as the battery cells leach into the surrounding areas (unless the disposal locations are
sealed and capped appropriately).
3.5 Other areas of consideration

In addition to the above, GHD have highlighted other areas of consideration which are pertinent to BESS facilities
given their growing capacity and land footprint. Inadvertent interactions (such as mobile plant, vehicle-to-vehicle,
or vehicle-to-person) and interaction with the general public during construction, commissioning, and operation are
important factors which need to also be considered for BESS facilities. This section focuses on areas which are
currently maturing and want to use this guidance material as an opportunity to begin stakeholder conversations
around these matters.
3.5.1 Deliberate acts of physical damage

For numerous reasons, some members of the public may not like a BESS facility at a particular location. There are
many avenues for complaint and protest and in most cases, objections remain civil and peaceful. However, there
are some individuals or groups in the community that may want to escalate objections or wish to cause disruption
with the potential to take their objections further by physically damaging a facility with an act of sabotage.
Typically, good stakeholder management appropriate for the project will often manage this range of risks.
One control is the use of secure boundary fences for safety and deliberate acts, especially given the potential for
BESS facilities to be remote and unmanned.
A more difficult protective consideration is the risk from gun fire, either deliberate or accidental. Recently in the
United States (North Carolina) there have been some shootings of electrical substations, on 3 December 2022,
with investigations being undertaken by the US Federal Bureau of Investigation. [61] FBI has stated that the
damage led to a power outage to 45,000 customers with a state of emergency being declared.
More recently on 17 January 2023, there have been reports of damage to a third substation. This third apparent
act of damage did not cause any disruption to electrical supplies. It is also being investigated by the FBI. [62]
Due to the differences in Australian ownership and usage of guns, it is generally considered that the risk profile for
a gunfire event in Australia is lower than that in the United States, but it is not a (near) zero risk. Like other
infrastructure around Australia, the growing presence of BESS facilities will naturally attract a full spectrum of
behaviours (potentially ranging from graffiti and vandalism to terrorism), similar to that of rail and other
infrastructure facilities.
Australia utilises Crime Prevention Through Environmental Design (CPTED) approaches [63], and there is a range
of guidance material which is used in other industries. Currently, GHD have not sighted explicit incorporation of
CPTED into BESS designs and operation, apart from the usual aspects of buffer zones, warning signs, security
fencing and surveillance systems typical of power facilities. Physical damage to Li-ion cells is a known mechanism
for a thermal runaway event. It is unlikely to be practical and/or cost effective to eliminate all of the potential of
damage due to a deliberate act.
However, like rail, aviation and other facilities and infrastructure, consideration of simple methods or design
features, either in the BESS modules themselves or with the site layout and physical provisions should be
undertaken as part of the design to reduce the risk so far as is practicable.
3.5.2 Cyber vulnerability

As a follow on from physical methods of damage, there is the potential for cyber vulnerability to achieve similar
outcomes, and even broader ranging events. As seen recently in the media, there have been multiple cyber
security breaches of various organisations, with some breaches severely disrupting services such as Colonial
Pipeline cyberattack [64].
Although the scope of this guidance material is to review other areas (see Section 1.3) cyber security and
vulnerability considerations should be given to existing and future BESS facilities moving forward. In 2021,
Kharlamova et al. [65] flagged that there is a lack of extensive review on battery cybersecure design and
operation. As discussed, there are several interconnected parts which, if attacked, may render the whole system
inoperable.
An example provided is the potential for a false state of charge estimation, providing a false command which could
be detrimental to operations. A graphical summary of the types of cyber threats is provided as Figure 5.
Figure 5 Classification of cyber threats for the BESS (Figure 2 of ref [65])
Kharlamova et. al provide a comprehensive review of cyber security considerations for grid-scale BESS facilities,
demonstrating that this is a plausible area based on the precedents set from other cyber and terrorist attacks.
The recent increase in the size and number of battery facilities poses unique issues. The convergence of new
battery chemistry, remote internet-based energy management technology, high response control systems and
diverse facility locations have not historically been seen anywhere around the world. In the near-term future, many
larger facilities (over a gigawatt hour in capacity) and possible multi-stacked arrangements may exist. This
presents a new range of threat scenarios. These threats could manifest in primary, secondary and tertiary safety
risks to Australians.
Where:
– Primary safety threats are associated with the on-site facility / systems
– Secondary safety threats are the localised, off-site area
– Tertiary safety threats are associated with the broader grid effects from power outages or instabilities.
BESS facilities can be unmanned, particularly if they are in isolated areas, and operated remotely. Networked
systems can be vulnerable to bad actors with the potential to trigger unwanted events. As a technology grows in its
presence in society, the profile of cyber hacking interest in this technology also increases. Cyber security should
be a consideration when managing threats to BESS facilities as there is the potential for a range of consequences
from a loss of control.
There is a growing awareness amongst regulators who are exploring how cyber security pertains to their
jurisdictions. This is a growing area and the growing dependency on grid-scale energy storage requires further
jurisdictional scrutiny for safety and grid performance. Regulators should be coordinating more globally about this
for better consistency, and energy storage system providers will need to provide more substantial evidence of the
cyber security their systems do (or do not) have.
3.5.3 Land value impacts

Although land planning requirements are currently in place, guidance on how community growth around existing
BESS facilities is being considered has not been sighted. As population growth continues, concerted efforts are
being made to further develop existing suburbs, or to create new estate packages. This development will see the
reclassification of land, such as the transition from peri-urban locations into urban as residential property
expansion continues. Battery facilities, like the Victoria Big Battery, are currently installed in rural locations, as
these facilities generally require a large amount of land, depending on type and energy storage requirements. As
the population begins to migrate further out, it is possible that existing BESS facilities may affect land values.
Conversely, as technology progresses and the footprint required to produce a comparable amount of energy
reduces, there is also potential to construct a BESS facility within existing residential areas, which may also impact
land values.
Thus, considerations for the land requirements will also need to be included in planning new communities and
expansions. Questions such as ‘will the risk profile of properties surrounding the BESS facility be impacted?’ need
to be considered moving forward. Considerations for locating BESS facilities in existing communities will need to
include fire risks, and natural environment, noise, visual and other amenity impacts.
3.6 Key observations from reference material
The development, construction, and subsequent operation and reliance on grid-scale BESS facilities has outpaced
the development of Acts, Regulations, Standards, and other guidance materials used to inform such ventures to
date. The material relied upon by constructors and designers, regulators, and operators is region specific;
therefore, the list of documents discussed within this section is not exhaustive.
An example of the diversity of Standards and notable guidance material relied upon globally for BESS is illustrated
by Figure 6, extracted from Ampace Technology Energy Storage Solution material.
Figure 6 High level list of global standards used for BESS
Table 4 provides a summary of the key findings during review of relevant source material. Due to time limitations,
the review was focused on some of the materials which were identified as references by stakeholders interviewed
or from prior engagements associated with BESS facilities. It is noted that the references are not exhaustive, and
there are many other relied upon resources available.
Table 4 Summary of reference documentation
Title Key observations

Australian Acts, Regulations and Standards
Work Health and Safety Act 2011 The WHS Act states the following for duty of designer: “The designer must
ensure so far as is reasonably practicable, that the plant, substance or structure
is designed to be without risks to the health and safety of persons.”
Therefore, under the WHS Act, persons who control or manage workplaces are
obligated to ensure the health and safety of people ‘so far as is reasonably
practicable’ (SFAIRP). This legislation requires consideration of risk control
measures and safe systems of work, which for BESS facilities may relate to:
– Housekeeping, including vegetation management
– Maintenance activities (vehicle, plant, and equipment)
– Security
– Emergency considerations (egress, ease of evacuation)
AS/NZS ISO 14001:2016 Environmental The ISO standard describes environmental management systems for
management systems - Requirements organisations with a systematic approach. The standard describes
with guidance for use environmental management from planning through to performance evaluation.
The standard may relate to BESS facilities in relation to environmental aspects
such as:
– Emissions and releases to land or water
– Waste generation and raw material requirements
– Considerations to be included during planning
Emergency preparedness and response
AS/NZS ISO 45001:2018 Occupational The ISO standard describes requirements for OHS management systems which
health and safety management systems could apply to operators, contractors, and visitors to site etc of BESS facilities.
- Requirements with guidance for use The standard may relate to BESS facilities in relation to:
– Hazard identification process requirements
Defining OHS objectives
AS/NZS ISO 9001:2016 Quality The ISO standard describes the requirements for a quality management system
management systems – Requirements that can apply to any organisation to improve its overall performance. This
standard may relate to BESS facilities in terms of:
– Risk-based thinking and employing preventative action
– Ensuring the facility abides by the required policies and standards
– Determining the required knowledge and competence of workers
General quality assurance requirements for BESS facilities
National Standard for Construction Work The national standard defines the requirements “to protect persons from the
[NOHSC:1016 (2005)] hazards associated with construction work”. This could apply to BESS facility
installations during the construction phase or during maintenance or upgrade
activities as the client or designer of a construction project.
AS/NZS 5139:2019 Electrical AS/NZS 5139:2019 details the general installation and safety requirements for
installations - Safety of battery systems BESS. This standard applies to battery systems with a nominal voltage between
for use with power conversion 12 V D.C and 1500 V D.C, with a rated capacity equal to or greater than 1kWh
equipment and no more than 200kWh. It outlines potential hazards related with BESSs and
other associated battery systems, and details installation methods to minimise
the risk of these hazards.
Key observations include:
– Standard discusses installation and safety requirements for BESSs
connected with power conversion equipment (PCE) but does not specifically
include PCE itself in their requirements
– The standard provides a detailed overview of installation and commissioning
requirements but not decommissioning
– Sufficient clearance from the BESS for safe egress is given to be “no less
than 1 metre”
– Mentions that the installation of pre-assembled integrated BESS must take
into account spacing requirements between multiple BESS and other
associated equipment but does not identify what these requirements are
– The standard has in-depth detail about pre-assembled battery systems but
lacks large-scale battery systems (it does briefly mention requirements for
parallel battery system). The standard makes comments on “larger
installations” but does not provide any further detail about them.
AS/NZS 4681:2000 The storage and – AS/NZS 4681:2000 details the safety requirements for Class 9 dangerous
handling of Class 9 (miscellaneous) goods and articles. Although it provides a detailed information on storage
dangerous goods and articles and handling of dangerous goods, there is minimal information on batteries.
There is no information available on lithium-ion batteries (there is limited
information on the storage and handling of lithium batteries), vanadium
redox flow batteries, or sodium-ion batteries.
AS 2067:2016 Substations and high – Applicable if the rated AC/DC voltage is greater than 1 kV
voltage installations exceeding 1kV A.C. – AS 2067 states that for equipment with a rating above 1 kV a minimum
ground safety clearance of 2,440 millimetres is required
AS/NZS 1170.2:2021 Structural Design – Wind and seismic loading on facilities, and tolerable design thresholds
Actions – Wind Actions
Victorian Dangerous Goods (Storage Regulations 54 and 55 of the Dangerous Goods (Storage and Handling)
and Handling) Regulations 2012 Regulations 2012 may be required depending on the nature and quantity of
material on site.
– Regulation 54/55 states that “An occupier of premises where dangerous
goods are stored and handled in quantities that exceed the relevant
quantities specified” will request written advice from the relevant emergency
services authority to reduce the risk of a catastrophic scenario by reviewing
or altering the design of the fire protection system and through an
emergency plan.
International Standards and guidance
ISO 22320:2018 Security and resilience The ISO standard describes guidelines for incident management and is
– Emergency management – Guidelines applicable to any industry that is involved in responding to incidents of any type
for incident management. or scale. This standard details a general incident management structure and
process which may be applicable to BESS facilities.
UL 9540A Battery Energy Storage UL 9540A is a test standard which is utilised to develop data on the fire and
System Test Method deflagration hazards from thermal runaway and its propagation. The standard
aims to systematically assess thermal runaway and propagation in energy
storage system at cell, module, unit, and installation levels. It is being utilised
globally by original equipment manufacturers, such as Tesla [66] and CATL [67],
as a means of demonstrating that thermal runaway is improbable (within the
testing parameters used)
The data from the testing may be used to design fire protection methods to
mitigate against the hazards generated
– The testing requirements for batteries in the for UL 9540A unit level fire test
analysis is not necessarily tested at ambient temperatures analogous to
environmental temperatures in Australia.
– As provided by Synergy following the draft AEC BESS report review, if cell-
to-cell propagation test is passed, then the module-to-module test is not
required. If module-to-module propagation test is passed, then unit-to-unit
test is not required. Therefore, there may not be any testing to confirm
module-to-module or unit-to-unit propagation will not occur in the event
thermal runaway propagates beyond a cell.
The increased temperature and wind speed at the locations of Australian sites
may negatively affect the likelihood of thermal runaway.
UL 9540 Energy Storage System UL 9540:2020 sets out the requirements for energy storage systems used for
Requirements receiving and storing energy in a form that can be converted to electrical energy
to power a local / area electric power system. The standard provides an
assessment of the compatibility and safety of individual parts of the energy
storage system (e.g., power conversion system, battery system, etc.).
– Includes hazardous fluid control (e.g., toxic vapours, spills)
– Includes general information on fire protection, suppression, and
propagation for energy storage systems (ESS’s)
– Includes large scale fire testing for electrochemical type ESS (Note: Test
requirements are found in UL 9540A) and is required for certification in
Australia
– Requirements (including testing and evaluation) for batteries,
electrochemical capacitors, hybrid battery-capacitor systems or flow
batteries used in electrochemical ESS are found in UL 1973.
– The standard identifies that a Leakage Test, Strength Test, and Hydrostatic /
Pneumatic Test are required for ESS that contain hazardous fluid. The test
procedure and acceptable results are also given.
– Requirements for installation and maintenance are given but the standard
provides minimal information on decommissioning requirements.
NFPA 855 (2020) Standard for the NFPA 855 is a standard for installation of “Stationary Energy Storage System”
Installation of Stationary Energy Storage and a 2023 version is being produced and outlines “the minimum requirements
Systems for mitigating the hazards associated with ESS”.
The standard includes information on operations and maintenance as well as
commissioning and decommissioning of units. It currently covers different types
of chemistries and configurations.
– The standard does not focus on large scale installations
– Minimum separation distances are described as “3 feet”
The 2023 version should be reviewed when available
IEC 62933-5-1:2021 Electrical energy Part 5-1 of IEC 62933 specifies safety considerations regarding EES systems
storage (EES) systems - Safety integrated with the electrical grid. It outlines the potential hazards,
considerations for grid-integrated EES consequences, and safeguards associated with EES systems. An example of
systems - General specification the main risk scenarios for lithium-ion batteries is available in Annex A. No other
specific information can be found on large-scale battery facilities. The standard
also includes system testing for various EES system malfunction scenarios. A
set of guidelines and manuals that should be considered is also outlined in the
standard.
IEC 62933-5-2:2020 Electrical energy Part 5-2 of IEC 62933 outlines the safety requirements for people, surroundings,
storage (EES) systems - Safety and other living beings for electrochemical energy storage systems. This
requirements for grid integrated standard is applicable for the entire lifecycle of BESS. This part of the standard
EES systems - Electrochemical based includes a general risk analysis for BESS. Protective considerations to reduce
systems risk are outlined in the standard. Specific preventative measures are found in
IEC 62933-5-1. Operation and maintenance of BESS is also outlined, including
design revisions and end of service life management. Annex B includes hazard
considerations specific for Lithium-ion batteries, and Vanadium redox flow
batteries. Annex C includes large-scale fire testing on BESS, referencing UL
9540A
Other guidance material
Design Guidelines and Model Facilities that support the generation of electricity in Victoria include wind energy
Requirements – Renewable Energy facilities, solar energy facilities and battery energy storage systems. These
Facilities (2022) facilities are the focus of this guideline. CFA recommends the adoption of a risk
management process, in line with AS/ISO 31000- 2018: Risk Management
Guidelines, to identify and address fire risk at renewable energy facilities.
Within the guidance material, CFA reviews:
– The site firewater requirements
– Inter-module distances, and
– Water run-off requirements. CFA recommend containment be provided as
per AS 4681-2000: The storage and handling of class 9 dangerous goods
(Section 7.3.9: Control of run-off).
In the event of a fire, suppression water will contain potentially toxic substances.
CFA design guide recommends that water runoff needs to be managed through
the inclusion of physical infrastructure including, for example, bunding, sumps
and/or impervious water retention facilities, with an equivalent capacity to the
fire protection system provided on-site
These guidelines advocate a holistic approach to fire and emergency risk
management.
Where the facility includes a battery energy storage system or other significant
quantities of dangerous goods, a request for emergency services written advice
under Regulations 54 and/or 55 of the Dangerous Goods (Storage and
Handling) Regulations 2012 may be required. The quantity of dangerous goods
must be determined for the purposes of requesting emergency services written
advice. For lithium-ion based battery energy storage systems, the net weight of
the lithium-ion battery cells (rather than the gross weight of the battery
enclosure/container) must be provided.
Clean Energy Council (CEC) reference The CEC, with support and guidance various industry associations, produced a
material (2018) guide and accompanying risk register to develop a “best practice guide” which
stipulates the minimum safety requirements for Lithium BESS facilities within
Australia. The best practice guide presents different methods to address
hazards and provides a list of applicable standards to review as part of this
process. However, as noted within the disclaimer, this document was current at
the time of publishing and the standards referred to within the guide, and also
within the risk register, have either been revised or are now updated given the
fast-paced nature of battery development since 2018.
The risk register separates the risks based on the battery configuration (e.g.,
battery module or preassembled battery system), and provides base control
measures to incorporate. As guidance, each risk indicates the relevant clause /
section of standards to review for compliance. A total of sixty-two (62) hazards
were identified.
– 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 This checklist is primarily used to assist with field inspections of residential and
System checklist 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
4. Discussion
4.1 General findings
As demonstrated from the literature review and high-level review of reference material above, the growth and
integration of grid-scale BESS facilities had outpaced the development of Acts, Regulations, Standards (both local
and international) and other guidance available. Recent thermal events, such as the case study example provided
in Section 3.6.1, have reinforced this, as well as highlighting to various stakeholders that their remits and
responsibilities needed to be assessed and redefined. Recent efforts by stakeholders have addressed these gaps
to some extent. Although beyond the scope of this engagement, it was noted that each State within Australia has
differing regulatory requirements, reinforcing the need for the development of harmonised guidance material.
Key features of a more harmonised approach are emerging, whereby stakeholders who are involved in differing
stages of the grid-scale BESS facility lifecycle, are involved in the update, revision, and development of Acts,
Regulations, Standards, and other guidance material moving forward, this approach is positive and is consistent
with the proactive approach and support being led by the AEC.
Whilst it was found that there is significant research effort directed to engineer an optimal and safe battery
chemistry, it was found that there is not as much research focused on determining the influence of facility wide
factors (such as site selection, facility orientation, battery stacking arrangements, and centralised versus
decentralised storage) on thermal events.
The current guidance is mostly location and facility size agnostic and as a result does not provide guidance on
how to approach safety and risk to consider those differences. It is noted that the CFA guidance material briefly
addresses these factors (refer to Section 5.3.1 of CFA document [69]) by asking the following: “Does the proposed
layout of the site impact fire risk? Is the fire service infrastructure safely accessible? Are there hazards or
infrastructure that may impact safe evacuation?”
The sources reviewed provided detailed mechanistic pathways, with supporting mitigation measures, that could be
utilised to decrease the likelihood of thermal runaway from occurring or further propagating. From our discussions,
these events and their potential facility wide implications present a major concern to multiple stakeholders given
the Victoria Big Battery incident. However, current standards, such as UL9540A, do not necessarily simulate
conditions which are representative of the conditions within Australia and also within the facility itself (e.g.,
microclimate formations due to heat island effects).
This, again, reinforces the need for further research and development in the assessment of facility-wide risks.
CFA’s guidance implicitly addresses this need, recommending that a Fire Safety Study is conducted in accordance
with NSW Planning's Hazardous Industry Planning Advisory Paper 2: Fire Safety Study Guidelines [70] and that
risk is approached in line with AS/ISO 31000- 2018: Risk Management Guidelines.
There is minimal guidance on the process and consequences associated with decommissioning such facilities
based on the resources sighted. As grid-scale BESS facilities are a relatively new development, with major
facilities less than a decade old, information regarding decommissioning of large capacity sites is not currently
publicly available. The CEC’s guidance material briefly addresses this process, and a risk is provided within the
pre-populated risk register. UL 9540:2020 Energy Storage System Requirements, a standard which is utilised by
OEMs, provides requirements for installation and maintenance activities, but does not include detailed
decommissioning information.
Similar to the installation, operation and maintenance of a BESS site, decommissioning represents is a key stage
within the lifecycle of a BESS, and therefore further information needs to be developed and provided. Due to the
likely variability in battery chemistry composition in the near future, the increase in storage capacity, as well as the
possibility of sequentially decommissioning battery modules rather than a whole-of-site decommissioning process,
further instruction is required by OEMs. Areas such as environmental implications (including recycling), OH&S and
potential to replace current battery modules with greater capacity modules need to be further developed.
Other considerations, such as environmental impacts from loss of containment events (a key consideration for
VRF batteries with large quantities of vanadium electrolyte) were not thoroughly documented in the resources
reviewed. Based on learnings from other industries, loss of containment can lead to groundwater contamination
and result in runoff if there are inadequate containment measures associated with the design. Similarly, literature
on malfeasant activity (in the form of deliberate physical damage to a facility or via cyber-attack) and potential
influence on land value were not sighted. As briefly explored in Section 3.5, these are other relevant areas which
need to be considered during the planning and operation of grid-scale BESS facilities. Although the scope of this
engagement is primarily focused on thermal, OH&S and environmental risks, it is important to note that given the
growing size of these facilities, the risks associated with these other associated matters should be considered
when assessing installations.
Lastly, from an OH&S perspective, the literature search result indicated a gap in efforts (i.e. there is an
opportunity) regarding the need to incorporate human factors within the design. This is a critical aspect of other
high-risk industries with large facilities, such as rail, aviation, and oil and gas, which stipulate that human factors
need to be considered (through various assessments) for a safer, more useable and understandable design.
While the above areas present opportunities for future areas of focus, it is important to note that emerging and
updated material, such as the 2022 edition of the CFA guidelines, NFPA 855:2020 Standard for the Installation of
Stationary Energy Storage Systems, UL9540:2020 (and associated testing standard UL9540A) have helped
considerably in the journey towards a consolidated, safety-informed approach in the development of grid-scale
BESS facilities.
4.2 Stakeholder interview summary

All interviewees acknowledged that collaboration is needed to proactively bridge gaps continuously being identified
with BESS facilities. Furthermore, interviewees expressed that national harmonisation is desirable, noting that this
may be difficult to achieve.
It was acknowledged that the CEC’s Best Practice Guide involved regulatory and manufacturer engagement at the
time of development. However, it has not been updated since 2018 and draws upon standards which are now
either outdated or no longer applicable. There are also a number of ways to demonstrate compliance within the
support CEC risk register, making it difficult to enforce. Therefore, the guidance cannot be relied upon for further
BESS developments but may provide a good starting point for safety considerations.
Although beyond the scope of this engagement, ESV expressed the need to fundamentally review existing
legislation to ensure that accountability and anomalies in the current Acts and Regulations are addressed. A major
issue identified by ESV is the absence of an Australian Standard for large energy storage battery facilities. Efforts
are being made to expedite the creation and subsequent release of an appropriate standard, however as an
interim measure, technical guidance will represent an iterative update of the existing CEC guidance.
From the interviews, it is understood that ESV are in the process of developing technical guidance material and
recognise that the CFA guidance material is one of the few resources which addresses the requirements for fire
management at a BESS facility (as per stakeholder interviews). It was conveyed that the technical guidance
material that ESV are developing will touch on fire systems and fire suppression, but it will likely not be
prescriptive. ESV communicated that the expectation will be that a “rigorous” risk assessment process is
undertaken, mirroring the risk-based approach within the CFA guidance.
Discussions with CFA representatives revealed that the guidance material has undergone four updates to capture
changes and new initiatives within the BESS industry and Li-ion chemistry development. CFA representatives
communicated that the organisation is trying to get a national position on BESS to achieve consistency and are
seeking feedback from international fire safety specialists to further enhance their guidance. The following issues
were identified:
– Water supply
– Access, bushfire, and firefighter safety
– Separation distances between batteries as well as separation distances between batteries and other utilities
on site.
The Victoria Big Battery incident demonstrated the importance of all the above issues, where radiant heat impact
was observed between two banks of batteries which were approximately 2.4 metres apart (a bank of battery
contains four (4) megapack units). Similar to ESV, CFA expressed the need for an Australian Standard for
batteries, explicitly mentioning the installation process. Additionally, when asked about the implications of stacking
arrangements, CFA mentioned that although stacking has not directly been taken into consideration in their
guidance, the need to complete a risk assessment (including a fire safety study) and comply with AS 2419 Fire
Hydrant Installations would capture risks. It was agreed that this may be an issue in the next decade due to urban
pressures.
CFA have also consulted with WorkSafe New South Wales about the classification of grid-scale BESS facilities as
Dangerous Goods facilities. If this occurs, then will allow more legislative purview about what needs to be
introduced into these facilities.
From an OEM’s perspective, members of the technical team at CATL stated that they are looking into double layer
battery module solutions. With regards to centralised or decentralised utilities for battery modules, CATL
expressed that the preference was to keep utility support systems decentralised as it promotes better consistency.
The greatest risk currently being faced by CATL within the Australian market is demonstrating that thermal
runaway potential is minimal given the Victoria Big Battery incident. In conjunction with the mitigation measures
integrated into the design, CATL are looking to address these risks by in-house battery chemistry research and
development.
A Health and Safety professional reinforced the concerns expressed from the interviews with CFA and ESV,
regarding:
– Growing desire to fit greater storage capacity in a given parcel of land.
– Proper access and egress within the facility, noting that for some facilities there is only one access gate,
posing potential safety issues during emergency situations
– Entrapment issues given the limited space between battery module rows.
Similar to feedback provided by CFA, an OHS professional recognised that there is not enough guidance provided
for the installation of grid-scale BESS facilities. It was also noted that from contractor management perspective
there are differing licencing requirements across States, which may delay installation and construction activities.
Lastly, a representative from the Queensland Government (Environmental Services and Regulation, Department
of Environment and Sciences) stated that there are currently no Environmentally Relevant Activities (ERAs) with
the Environmental Protection Regulation 2019 that are specifically for batteries. Some of the electricity generating
facilities do already utilise battery technology. There may be bespoke conditions that are within their approvals that
deal with the risks. However, environmental issues are not broadly get assessed. This is assessed on a case-by-
case basis.
From an environmental management perspective, BESS facility owners need to demonstrate through modelling
during the application that there would be no nuisance / amenities related impacts. However, thermal modelling
and microclimate formations is currently not considered.
In summary:
– Regulatory authorities and other stakeholders recognise that their jurisdictional presence and involvement in
future energy storage facilities needs to be further defined, with clear guidance on when they should be
involved in the BESS facility engagement process.
– Existing legislation needs to undergo a fundamental change as technology progresses. Similarly, the existing
CEC guidance is difficult to utilise given the innumerable ways to demonstrate compliance. Guidance material
(both technical and non-technical) needs to be to unambiguous and well-defined to prevent this from
occurring again.
– A risk-based approach is preferred, assessing each facility on a case-by-case basis. By doing so, the
specificities, such as battery chemistry consideration, fire water requirements, and broader site selection and
configuration, can be justifiably presented to relevant stakeholders.
– It is likely that battery stacking will be required, given the interest already being expressed to OEMs. This
needs to be investigated moving forward and incorporated as a scenario or future consideration in all
guidance materials, and eventual Standards.
– Further involvement from HSEQ and environmental stakeholders is needed to further develop guidance in
these areas. Early involvement is key as it may dictate site selection and facility design.
– The material relied upon by constructors and designers, regulators, and operators is region specific. Based on
the feedback received from stakeholders interviewed, there is no definitive standard to refer for holistic
guidance on BESS facilities
– Although UL9540A is relied upon, it was expressed that further simulation work is not completed by OEMs.
Results from such modelling may be requested by regulators and may be mandatory moving forward.
5. Guidance material
5.1 Purpose of the guidance material
The purpose of the guidance material is to provide a high-level, risk-informed approach to assess grid-scale BESS
facilities. Based on the learnings summarised in Section 3 and Section 4 of this report, the degree of assessment
required for a grid-scale facility is dependent on the battery chemistry, proposed site location and layout, the
storage capacity of the facility, as well as the neighbouring receptors.
To adequately assess facilities and the complex interdependencies it possesses, the approach taken is to
categorise BESS facilities into different “types” based upon energy storage capacity. This principle is used in the
major hazard facility classification process, and it is considered a practical way to delineate energy storage
systems. This will also promote a consistent assessment approach associated with different “types” of facilities
moving forward.
The guidance material in this document considers the following areas:
– Site selection, facility orientation, and facility configuration
– Safety case approach
– Emergency management planning
– Environmental offsite effects.
This guidance is designed to assist the AEC in their journey towards the development of further, comprehensive
guidance material. While this guidance can be applied to differing battery chemistries, the facility “type”
categorisation is primarily for Li-ion and VRF BESS facilities. The principals noted can be translated across to
different battery chemistries and technologies, but it is recommended that the “type” thresholds and recommended
assessments are reviewed prior to finalisation of guidelines.
5.2 Grid-scale BESS facility guidance

Based on the literature reviewed and learnings from the stakeholder interviews, the risk profile of BESS facilities is
dependent on a number of factors. These include:
– The battery scale: Is the battery for grid-scale applications?
– The battery type: What is the battery chemistry? What type of technology (e.g., redox) is being utilised?
– The energy storage capacity: How much electrical energy can the grid-scale facility store?
This parallels the way risk evolves in other high hazardous industries as the type of material storage as well as the
quantity changes the overall safety and assessment requirements of the site.
Figure 7 illustrates the proposed approach to assess grid-scale BESS facilities, capturing the interdependency of
the above factors.
Although the scope of this engagement is to provide guidance for grid-scale BESS facilities focused primarily on
Li-ion BESS and VRF BESS, shaded in grey are a number of matters that it is expected will require consideration
and review as these resources are used in future. These include:
– Residential and community-scale BESS’s
– Other battery types (including chemistries and technologies)
– Further assessments which many be required for Type 1 and 2 categories.
The guidance is meant to be challenged and further developed by AEC members. Therefore, it is expected that
this flowchart will be revised as more stakeholder input is incorporated.
The range of stored energy is categorised into four (4) types:
1. Type 1: Less than 50 MWh
Typically containerised energy storage system
2. Type 2: Between 50 MWh and 250 MWh
Typically on a modular basis typically delivered in containers
3. Type 3: Between 250 MWh and 1,500 MWh
Energy storage facility that requires a larger footprint, with battery modules arranged in bank (cluster) or
island formations
4. Type 4: Greater than 1,500 MWh
Energy storage facility that requires a larger footprint, with battery modules arranged in bank (cluster) or
island formations. Land constraints may become an issue given the larger storage capacity required
Type 1 and Type 2 represent smaller scale facilities, while Type 3 and Type 4 represent larger facilities requiring
more detailed and further assessments. The aim of this guidance is not to be prescriptive (i.e., detailing the
specific sections, parts and/or clauses of legislation. Acts, Regulations, Standards, and other guidance material).
Rather, this guidance is meant to be a resource highlighting key areas for consideration.
As expressed throughout this report, this field is evolving and prescribing specific requirements would likely yield
only temporarily beneficial guidance given that subsequent updates to supporting references will continue to
evolve. This guidance distils the findings and presents, at a high-level, what should be completed for each Type
category presented.
Although assessments such as ‘critical infrastructure and cyber security assessment”, “detailed safety in design
and human factors assessment’ are only noted for Type 3 and Type 4 BESS facilities, this guidance is meant to be
challenged and further developed by AEC members. Therefore, it is expected that this flowchart will be revised as
more stakeholder input is incorporated. As depicted within the figure, Type 3 and Type 4 facilities require a
coordinated and collaborative assessment process that involves all stakeholders, including regulators.
5.2.1 Key guidance steps

In addition to the flowchart provided below, suggested key intermediary steps to support facility development,
safety documentation, engagement, and approvals. This will support the risk identification, assessment process
and potential safety case required for the specific facility
1. Articulating the battery energy storage opportunity and key project drivers.
2. Proposed power and capacity characteristics of the facility, including any foreseeable expansions to the size,
capacity and footprint of the battery facility
3. Proposed site location, defining the facility size (i.e., layout and projected land use) and configuration.
4. Research local jurisdictional requirements (Council, State and Federal requirements)
5. Identify and consult key regulators and stakeholders, with considerations given to neighbouring community
engagement
6. Amenity and environmental assessment
7. Initial discussions based on requirements with the regulators. It is suggested at early design stage to
incorporate key requirements (tolerable safety and environmental criteria) into key contractual documents
8. Develop a checklist of compliance needed from relevant Legislation, Acts, Regulations, Standards, and
guidelines. Initiate early risk assessment process, assessing risks against tolerability thresholds, and
commencing SFAIRP approach. Ensure these are clearly outlined in contract documents to key suppliers and
contractors.
9. Outline and communicate key risk and safety documentation requirements to OEM providers
10. Develop a communications plan for key stakeholders
11. Develop initial safety case documentation with independent specialists and internally
12. Develop suitable detailed engineering design and confirm the safety documentation. Outline conformance to
key tolerability requirements
13. Submission of key documentation for assessment.
Figure 7 BESS guidance flowchart
5.3 Site selection, orientation, and configuration
Site selection is a key step in the development of grid-scale BESS facilities. As expressed by CATL, a major
limiting factor for BESS facilities is temperature. High temperatures result in faster battery degradation, as the
battery will have a consistently higher operating temperature. Furthermore, humidity may influence performance,
with the potential for condensation during operation if greater than a specified percentage.
However, as mentioned in Section 4.1, little consideration has been given to the shape and/or alignment of BESS
modules on a site. Appendix C provides a detailed overview of:
– The meteorological conditions that should be reviewed as part of the BESS facility design.
– Guidance on separation distances between battery modules, referring to existing guidance provided by
Standards and/or other guidance material.
As larger facilities are proposed, appropriate site selection and site alignment will become a more important
consideration. For an individual site and BESS configuration, wind patterns may impact performance of some of
the battery modules from time-to-time due to downwind heat plume/heat island effect.
Following the Victoria Big Battery thermal runaway event, publicly available information was utilised to produce
preliminary thermal models of the facility. Two simulated examples are shown in Figure 8 and Figure 9. The
modelling conditions used for these figures is summarised in Table 5.
Table 5 Modelling conditions used for Figure 8 and Figure 9
Modelling conditions Figure 8 Figure 9

Ambient temperature 35°C 35°C
Wind speed Calm conditions 20 km / hr
Wind angle - Wind is parallel to the long face of the facility
layout
During calm and light wind conditions, the air discharged by the BESS modules rises vertically away from the site;
the simulation illustrates that each module cooling system is effectively operating independently (as generally
designed).
Figure 8 CFD simulated heat plumes from a BESS showing thermal contours of air temperature (35°C calm wind conditions)
For a 20 km/h (at 10 m reference height) wind aligned with the long axis of the BESS site, modules located near
the downwind side of the site can be exposed to elevated ambient air temperatures. The thermal contour slice
illustrates that some of the Megapack units in the centre of the facility reach have the potential to reach
temperatures between 60°C and 70°C on a 35°C day and is above the operational envelope of Tesla Megapacks.
Figure 9 CFD simulated heat plumes from a BESS showing thermal contours of air temperature (20 km/h with BESS long face
aligned wind conditions)
For the simulations shown, local ambient temperatures near individual modules inside the site could be 10 to 15 C
higher than the upwind ambient. Thus, it is possible that module performance derating could ensue as a result of
inappropriate site selection and facility orientation given the prevailing meteorological site conditions.
The inter-module spacing used in the model approximates the distances between modules at the Victoria Big
Battery site. Despite complying with the required specifications at the time of design and construction (some of
which are discussed in Appendix C), Figure 9 demonstrates that the pathways between modules can potentially
exceed 50 °C, presenting O&HS risks.
As demonstrated by these simulations, larger facilities (Type 3 and Type 4) require complex modelling to inform
risk assessments and safety case developments.
In addition to the above considerations, it is also important to understand noise issues. Differing modes of
operation (e.g., normal operations, during commissioning, etc.) may have differing emissions which can impact
nearby residents. Observationally, noise assessments appear to be in their infancy for these types of facilities.
OEMs, regulators, and operators should utilise the well-developed principles from other environmental impact
study areas and apply this to BESS facilities.
5.4 Safety case development
For larger facilities (classified as Type 3 and Type 4), regulators may need demonstration that the equipment
selection and facility design meet acceptable safety levels on-site and off-site. Typically, facilities must
demonstrate safety to a level So Far As Is Reasonably Practicable (SFAIRP).
If a SFAIRP safety argument were to be provided to a regulator for larger grid-scale BESS facilities, the discussion
would need to clearly demonstrate the rationale for selection and exclusion of available options. An interesting
example would be the selection of the Li-ion battery chemistry. It is well known that the NMC-aluminium
formulations have a higher propensity for thermal runaway than LFP chemistry batteries. In this case, the regulator
would expect a convincing argument for the selection of an NMC formulation (or another similar chemistry with
similar susceptibility). Suitable arguments may centre around better safety management systems and containment
versus cost differences in chemistry, or the availability of materials.
Similarly, for layout and orientation, SFAIRP demonstration would need to address the potential compromise
between facility space and layout, available safety systems and thermal capabilities of the modules (taking into
consideration heating, ventilation, air conditioning, etc.) with the level of risk. For aviation and nuclear industries,
high integrity safety systems (such as functional safety systems) are utilised to offset the intrinsic risk nature of
specific events. If OEM suppliers can provide suitable information, or provide certification against 62619, the
battery management systems (BMS’s) do need to operate with multiple layers of protection, due to the large
number of BMS units, and thermal runaway potential. Larger energy storage systems could also utilise high
integrity systems as part of a SFAIRP argument. The typical outline of a safety case process to demonstrate
SFAIRP is shown in Figure 10.
Smaller facilities could complete appropriate aspects outlined but to a lesser degree. A simpler SFAIRP
demonstration could be contained in the smaller facility documentation.
As quoted from the Safe Work Australia Guide for Major Hazard Facilities: Preparation of a Safety Case
“The development of the safety case outline will generally require the operator to:
– Understand what processes and systems are required by Chapter 9 of the [Work Health and Safety] WHS
Regulations
– Understand the purpose of the safety case
– Identify what information will be required to prepare the safety case
– Identify any existing information that might be used to meet these requirements
– Carry out a comparison or analysis which evaluates the existing information against the requirements and
determine what extra information is required to prepare the safety case (gap analysis or similar)
– Determine how to obtain the extra information
– Plan to evaluate how well the major hazard facilities meets the requirements of Chapter 9 of the WHS
Regulations, and how to establish what actions, systems or processes are required to meet any deficiencies
– Write the safety case outline.”
The typical risk studies which form part of a safety case demonstration are summarised in Table 6.
Table 6 Summary of risk studies which may form part of a safety case demonstration
Assessment Type Comments

Project risk assessment Captures broader risk considerations associated with the lifecycle of the project. It is expected
that stakeholders regularly update the project risk assessment.
Hazard Identification Completed to identify the range of hazards applicable to the site/project
(HAZID)
Hazard and Operability Completed to identify hazards and operability issues applicable to the site/project.
Study (HAZOP)
Safety and Operability Completed to identify hazards and operability issues applicable to the electrical aspects of a
Study (SAFOP) site/project. Conducted for electrical systems from power through to end points.
Assessment Type Comments
Control Hazard and A CHAZOP is used to assess the control system for critical issues and unsafe failure modes. It
Operability Study represents a modified hazard and operability study to assess the control systems or safety
(CHAZOP) systems associated with the project undergoing review.
Layers of protection Significant risk scenarios arising from the HAZOP, SAFOP and CHAZOP undergo a LOPA.
assessment (LOPA) The aim to determine if functional safety (safety integrity levels) are required for certain safety
or environmental functions.
Failure Modes, Effects FMEA and FMECA are completed to identify failures modes which may potentially cause
(and Criticality) Analysis product or process failure. While a FMEA is qualitative, a FMECA offers a degree of
FMEA/FMECA quantitative input taken from sources of known failure rates.
Quantitative and Semi- Completed to assess the consequences and risks associated with basic site layout
quantitative Risk and configurations and distances, as well as demonstrating the overall facility effect on the safety
consequence modelling of onsite personnel and offsite population.
Risk and consequence modelling is important in the identification and quantification of risks
inside and outside the boundaries of a hazardous facility. It is generally conducted for a new
hazardous facility development or when there are material changes to storage within an
existing site.
Fault Tree analysis Completed to assess how systems fail using deductive, Boolean logic to identify methods to
reduce risk, thus determining event rates for safety incidents or specific system level failures.
Event Tree analysis Completed to assess the probabilities of certain outcomes from an initiating event, using a
forward, top-down, Boolean logic approach.
Reliability, Availability and Completed to assess how various system component and sub-component failures can
Maintainability Study contribute to an overall system failure. This study is then used to determine and confirm the
(RAMS) reliability against key targets.
Reliability Block Modelling By representing the system as a series of blocks, reliability block modelling is used to
determine the critical components of that system. The failure rates of equipment (at the
componentry and sub-componentry levels), design and safety configurations, operating
philosophies and maintenance strategies can be quantitatively assessed and the impact to the
system performance can be found. The system can then be assessed against defined
reliability and safety criteria.
Computational Fluid Modelling the heat plumes generated by the facility, and determining intra- and inter-site
Dynamic modelling effects (i.e., adjacent module effects), along with interactions with local natural and built
environment.
Establish the Context
• Information:
a) Existing information – Collate relevant existing documents and information e.g.,
risk/safety related studies prepared for development approvals, compliance status with
approval conditions.
b) Validity of existing hazard analyses, HAZOPs, fire safety studies, hazard audits and
status of implementation of recommendations.
• Identify information needed and additional work to be done (gap analysis).
• Decide on tools and techniques to be used and resources required.
• Establish decision making criteria – justify any adopted risk criteria (i.e., qualitative, or
quantitative). Compare with criteria adopted in similar situations.
• Ensure mechanism for clear, auditable documentation of the process and the results.
Safety Assessment
• Hazard identification - identify all major incidents, major incident
• hazards and Schedule 15 chemicals.
• Identify existing risk controls.
• Conduct risk assessment – consequence estimation, likelihood estimation and risk
analysis (include whole of site with existing risk controls in place).
• Risk evaluation against the adopted criteria.
No
• Identify additional control measures.

• Select control measures to be adopted.
• Justification for accepting/rejecting identified Have risks been
controls (cost benefit analysis etc.). eliminated or
• Investigate and evaluate failure modes and minimised
SFAIRP?
rates for controls.
• Evaluate residual risk.
• Compare residual risk against criteria.
Yes
• Implement selected risk controls – SFAIRP achieved.

• Identify, set performance criteria and leading indicators for all (existing and new) controls.
• Update risk assessment and safety assessment.
• Document maintenance and test frequencies used in risk evaluation and include in SMS.
Monitor / verify / validate the performance Is SFAIRP

(assurance) of risk controls (SMS and sustained?
audits) (SMS) No
Yes
Risk minimisation SFARP achieved and sustained (SMS, EP)
Figure 10 Flowchart for the development of a safety case outline (Figure 9 of ref [71])
5.4.1 Human factors
In addition to the list above, Human Factors assessment may be required. Human Factors engineering and
assessments are used within multiple industries, such as rail, aviation, oil and gas, to assess how people and the
built systems interact [72] [73]. As BESS facilities get larger in size, the range and nature of Human Factors issues
are likely to increase. From the literature and material reviewed to date as part of this engagement, there is no
explicit instruction to complete a Human Factors assessment for grid-scale BESS facilities.
There are a range of ergonomic and anthropometric considerations for people to safely and effectively carry out
various tasks on energy storage facilities. Factors such as frequency of tasks, complexity of tasks, weight of
materials and equipment carried, distances, and consequences of errors all need to be considered in a Human
Factors assessment.
For larger energy storage facilities, a Human Factors assessment may be valuable to undertake, given the
interdependency of facility layout with maintenance and operational needs. Some of the issues to consider through
the lens of a human factors assessment might include:
– Movement of larger equipment across the site: Larger equipment may need to be carried over longer
distances to complete routine activities. Thus, better tools (e.g., lighter), lifting equipment and transport
systems may be required to assist personnel in executing their tasks.
– Compatibility of module spacing with required activities: Spacing between battery modules (i.e., between rows
of battery modules) needs to be compatible with the range of maintenance equipment required for the site.
Furthermore, consideration must be given to egress between battery module rows during operational and
maintenance task, such as inspections, cleaning, and filter checks.
– Achieve site reliability and maintenance objectives: Complete FMECA and Reliability, Availability and
Maintainability (RAM) assessments to evaluate whether the overall site reliability and maintenance objectives
can be realistically achieved, and the nature of operational and maintenance requirements by personnel are
understood and appropriately managed.
– Local heat effects and microclimate formation: Microclimate formation as a result of localised hot zones may
be present across the site. Therefore, work related heat stress out on the site may be an issue, giving rise to
the need for heat stress work cycle calculations and assessment. These hot zones, or localised heat islands,
may be exacerbated during hotter months.
– Specialised activities on site: Larger or unique facilities may require special activities to be undertaken by
operational and maintenance staff.
– Visibility: Limited visibility of workers in and amongst the facility units may also need to be considered in terms
of worker safety and communications.
The extent of Human Factors assessment will be dependent on the complexity and scale of the grid-scale BESS
facility. For larger, more complex facilities, a Human Factors Integration Plan (HFIP) and Early Human Factors
Assessment (EHFA) is advisable. The EHFA is designed to accelerate consideration of Human Factors issues,
risks and opportunities by design leads, thereby setting the expectations and activities for Human Factors
integration within the design program. A HFIP then defines the integration of Human Factors issues, providing
appropriate assurance procedures to guide these activities.
For smaller, simpler facilities, a basic Human Factors assessment alongside the Safety in Design register may
suffice. As noted for other areas of consideration, this will need to be reviewed on a case-by-case basis.
5.5 Emergency management plan
A detailed, site-specific emergency management plan (EMP) for grid-scale BESS facilities is essential to ensure
that the facility is prepared for an emergency incident. This is to minimise damage sustained to the site, ensuring
the safety of onsite personnel, emergency responders and the community, and minimising any period of disruption
to operations and supply.
As detailed by the CFA [69]:
“An EMP details the structures, procedures, resources, training for managing emergencies. EMPs must be
specific to the infrastructure, operations and location of facilities, and informed by a sound risk management
process. An Emergency Management Plan may also assist employers to meet their obligations under the OH&S
Act in providing a workplace that is safe and without risks to heath.”
Credible scenarios need to be considered for emergency plan formulation. Some prompts to review include the
following:
– Is it plausible or probable for a single or multiple battery modules to catch fire or explode?
– What are the credible hazards and risks present for the BESS facility being reviewed? This includes fire
scenarios (internal and external initiators)
– For cyber hacking, is it possible for multiple units to drive to full or zero power with loss of control function?
– Is there potential for frequency control and ancillary services (FCAS) malfunction and consequent grid
instability issues?
In line with CFA, it is recommended that the EMP is consistent with the requirements within AS/NZS 3745
Planning for emergencies in facilities. Furthermore, it is recommended that the EMP is updated to reflect any
subsequent amendments to this standard [74] [75].
AS/NZS 3745 outlines key components to include within an EMP, as summarised in Figure 3.1 of AS/NZS 3745.
In Section 10.1.2 of CFA’s guidance material details mandatory elements to be included within EMPs for all
renewable facilities, specifying that they must cover construction and operational phases for the site. There are
also additional mandatory requirements for BESS facilities. Furthermore, CFA details other optional, but highly
recommended, contents which they expect within EMPs. The CFA guidance represents the current leading
practice and should be utilised as it builds upon the principles within AS/NZS 3745 and the learnings from the
Victoria Big Battery incident.
Consideration should be also given to modifying the mandatory and optional contents within EMPs based on the
facility ‘types’ outlined earlier. This will need to be further discussed with the CFA and other stakeholders to ensure
alignment of stakeholder expectations.
5.6 Environmental offsite effects
The regulatory approvals and compliance, and ongoing management of environmental offsite effects required for
BESS facilities will be dependent on facility location and jurisdiction. It is important to note that specific regulations
and requirements may vary depending on the jurisdiction, and the facility operator should consult with relevant
authorities to ensure compliance.
The following steps are generally involved:
– Environmental Impact Assessment (EIA):
An EIA is typically required to assess the potential environmental impacts of the facility, including impacts on
air and water quality, neighbouring wildlife and habitats, and human health. The EIA will also identify
mitigation measures to minimise these impacts.
– Development Application and Approval:
The facility will need to obtain development approval from the relevant local, State, or Federal government,
which will involve assessing the facility's compliance with relevant planning and environmental regulations.
Identify the key documents needed for each approval and application.
– Environmental Management Plan:
An EMP will need to be developed and implemented, outlining the measures that will be taken to minimise the
environmental impacts of the facility, such as air and water pollution control, waste management, noise
management and biodiversity conservation.
– Licensing and Permits:
The facility will need to obtain any necessary licenses and permits for its operations, such as air, water
consumption and discharge permits, noise management and comply with relevant regulations.
– Monitoring and Reporting:
Regular monitoring of the facility's environmental performance will be required (air, water, noise and solid
waste), and the facility will need to report this information to the relevant authorities. This may include water in
retention ponds or dams.
– Community Engagement:
It is important to engage with local communities and stakeholders to keep them informed about the facility's
operations and potential impacts and address any concerns they may have. A stakeholder management plan
is best developed early in a project and undertaken at key points throughout the project phases.
– Decommissioning Plan:
A plan for the decommissioning of the facility will also need to be prepared and approved.
Some detail on the key offsite effects would include:
– Bushfires and ember attacks
– Fugitive air emissions from single module or other for the credible scenario failures
– Refrigerant, coolants, and/or electrolyte releases
– Volatiles from any hydrocarbons utilised for operational and maintenance requirements
– Washdown chemicals
– Adequate pondage for fire water. Demonstrate site discharge water is separate from local catchments and
waterways.
– Noise emissions (in some areas, noise barriers may be required where the facility is closely sited to urban
areas)
For larger facilities, thermal emissions monitoring may be required, especially if there is interaction with nearby
solar farms or other facilities that may have a cumulative effect or be affected by the energy storage facility.
5.7 Supporting risk register
A number of preliminary risk scenarios were identified, utilising literature findings, previous incidents and based on
the interviews with stakeholders engaged as part of this work. As discussed in Section 3.1, battery chemistry and
technology are rapidly advancing to maximise performance capabilities while upholding safety. Therefore, this risk
register aims to primarily capture key risks associated with Li-ion (specifically, LFP) batteries and VRF batteries as
they represent a significant cross-section of the current types of BESS facilities present.
Although the risks identified may be applicable to other battery chemistries, there are also distinctive risks (e.g.,
chemistry specific risks, unique facility configuration), that need to be added. As such, the risk register provided
(refer to Appendix D) is a preliminary assessment tool.
This risk assessment represents a hazard identification study (HAZID), capturing related risks, their causes, and
resultant consequences. Furthermore, the register details standard control measures and proposes additional
controls measure which may or may not be needed based on the facility needs. As the aim of the register is to
provide a pre-populated list of hazards (and associated controls, consequences, and controls), it is assumed that
organisation will transfer these risks their respective templates and utilise organisational-specific likelihood and
consequence descriptors to rank the risks accordingly. Thus, these areas of the risk register have been left
unfilled.
The risk register aims to categorise the risks identified into different ‘risk categories’:
– Design
– Effluent
– Environmental
– Environmental / Hazardous Material
– Equipment
– Occupational, Health and Safety
– Project
– Security.
This is not an exhaustive list, and stakeholders should continue to add to or amend the risk categories as required.
The typical methodology expected to be applied when reviewing and updating the pre-populated register is
illustrated in Figure 11.
Define scope/battery limits of study
Select Hazard Category
Identify Hazard and Cause
Identify consequence, maximum consequence category, and existing controls
Identify initial consequence, likelihood, and risk ranking
Propose recommendations or potential controls to address shortfalls
Identify residual consequence, likelihood, and risk ranking
Next Hazard
Figure 11 Flowchart for HAZID study
This register aims to complement the existing risks within the CEC’s Best Practice Guide risk register by capturing
other issues of concern, including cyber security, visual amenities, noise and importance of stakeholder
engagement. The guidance provided in Appendix D focused on principles which exist in Acts, Regulations,
Standards and current supporting guidance, and does not detail which clauses / parts of standards need to be
reviewed for each risk identified.
As discussed throughout this report, the rapid pace of development of this technology will result in these
references being superseded or outdated. Where applicable, currently relevant Acts, Regulations, Standards, and
guidance are listed as current control measures. But the overriding purpose of the register is to capture the
forward momentum in societal stakeholder thinking with regards to energy storage safety - which may not yet be
formally and explicitly captured in existing reference material.
A total of forty-one (41) risks were identified. A legend within the register is provided to distinguish between risks
which are Li-ion- or VRF-specific risks or are applicable to both types of BESS facilities. There is a comments
column within the risk register which provides additional information, such as past events, to support the risk
relevance.
As with other previous investigations and available material, the risk register captures that there are multiple
scenarios or pathways by which uncontrolled energy release can occur, escalating to thermal runaways and fire
events. This is not dissimilar to other liquid fuel storage facilities; the primary difference being the way in which the
energy release occurs. Table 7 outlines key features of comparison between hydrocarbon facilities of a similar
size.
Table 7 Comparison between hydrocarbon storage facility events with BESS facility events
Area Hydrocarbon storage Lithium battery unit Vanadium battery flow

cell
Fire and For fire and explosion events: For fire and explosion events: Due to the intrinsic
explosion - Vapour - Stored energy within the properties of the flow
BESS batteries, the cells do not go
- Heat and/or ignition source thermal. However, it is
- Fuel - Presence of short circuit or possible that an energy
exposing the lithium-based release from the aggregate
chemistry to water or oxygen collection of cells is enough
to initiate fires in associated
adjacent equipment, albeit
less frequent
Size Standalone large singular tank or Currently is constrained by Larger assembly due to
multiple large tanks (i.e., tank container modular sizes, which are lower energy density
farms) then arranged / configured into (compared to lithium)
battery banks or islands, limiting
escalation
Infrastructure Pumps and pipework present Electrical cable work Pumps and pipework
present to move electrolyte
Electrical cable work
Energy density Generally higher energy density Moderate energy density with Low energy density with a
due to the energy density of liquid reactive lithium chemistry low volatility liquid.
hydrocarbons prior to oxidation and
large quantity of liquid fuel present
(major hazard facility level)
Toxicity Dependent on the nature of the Combustion products can have Toxic electrolyte which,
liquid fuel. Release is harmful to toxic off-gases (detailed in the risk depending on the
aquatic life, the environment and is assessment) and toxic firewater chemistry, is harmful to
an irritant runoff aquatic life, the environment
and is an irritant
6. Conclusions and opportunities
As we transition towards renewable sources for energy generation, our dependency on energy storage grows to
uphold current network resilience. The global uptake of grid-scale BESS facilities has been rapid; with two of the
world’s largest facilities currently in Australia. Although beneficial, events such as the Victoria Big Battery fire in
2021 and other global grid-scale incidents, demonstrated that further work is required in conjunction with existing
requirements. Australia is largely dependent on overseas manufactured equipment for energy storage systems.
This guidance report consolidates learnings from the literature review, findings from stakeholder consultations, and
broader industry knowledge to present a preliminary guide to approaching assessment of grid-scale BESS
facilities moving forward. Refer to Section 5.2 to view the BESS guidance flowchart and Section 5.2.1 for
supporting intermediary steps.
Although the scope of this engagement was limited to review of grid-scale BESS facilities, specifically Li-ion and
VRF, additional guidance needs to be developed for:
– Other battery chemistries and battery technologies
– Residential-scale battery energy storage
– Community-scale battery energy storage
– Energy storage systems involving a combination of storage types, for example battery and hydrogen energy
storage systems (referred to as renewable energy hubs).
6.1.1 Key considerations moving forward

Similar to all documentation, this guidance is an evolving document. From this engagement, multiple stakeholders
have conveyed that other technical guidance is being developed. It is recommended that the AEC engages with
other stakeholders to assist in the development of guidance material that aims to support or complement the
upcoming developments. Key considerations include:
– The likely growth in physical size and capacity of BESS facilities
As this will likely occur in the near- and medium-term future, there needs to be harmony and consistency
between States on the regulatory assessment.
– Promoting consistency as this helps set broader expectations from international suppliers.
This includes the likes of CATL, Tesla, LG Energy Solution and many other OEMs. Australia has an
opportunity to influence further international thinking about the safety of energy storage systems. This also
helps Australia’s sovereign reputation as well as our international presence on the BESS front.
– Classification as critical infrastructure.
Although beyond the scope of this engagement, it is recognised that with the increased dependence on
various forms of energy storage there may be a need to classify them as critical infrastructure. This
categorisation of the infrastructure must be suitably incorporated at the very early stage of the BESS design
lifecycle. Thus, certain reliability criteria are required early on in the design.
– Resource constraints
As Australia transitions away from the traditionally segregated energy and distribution sectors, State
regulators may experience resource constraints as traditional participants in the energy sectors are largely
funding their activities. There is a need for State-by-State regulator resourcing and skill to assess BESS
facilities. Therefore, owners of complex installations (such as BESS facilities) should provide funding moving
forward.
– Combining energy storage mediums
As we continue to grow in our dependence on energy storage systems, new innovative approaches in storage
technology, including combination of storage mediums, will become more prevalent. For these systems,
thought must be given to the development of combined threshold classifications.
– Safety-case thinking
Whilst certification at the unit and module level is important, it should still be viewed as an important
component of safety case thinking, but not to replace the SFAIRP argument.
This guidance represents an opportunity for stakeholders in Australia to influence the future requirements and
assessments of grid-scale BESS facilities. It will be in the interests of the AEC, associated members, and
regulators in Australia to continue its collaboration and also engage with and participate in international forums and
bodies to influence revisions to existing standards and the development of future standards.
Australia is actively progressing along the risk development curve of energy storage and is one of the nations at
the forefront of facility size and knowledge on the global level (e.g., Victoria Big Battery and the South Australian
Hornsdale facilities). We can therefore leverage our knowledge and influence the global trends during the safety
management maturation of these facilities, which will be advantageous to all involved.
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Appendices
Appendix A
Abbreviations
Table 8 Abbreviations table
Term Definition
AC Alternating Current
ACCC Australian Competition and Consumer Commission
AEC Australian Energy Council
AEMO Australian Energy Market Operator
AFAC Australasian Fire and Emergency Service Authorities Council
AHJ Authority Having Jurisdiction
AS Australian Standard
BESS Battery Energy Storage System
BMS Battery Management System
CATL Contemporary Amperex Technology Co., Limited
CEC Clean Energy Council
CFA Country Fire Authority
CFD Computational Fluid Dynamics
CHAZOP Control Hazard and Operability Study
CID Current Interrupt Devices
CPTED Crime Prevention Through Environmental Design
DC Direct Current
DELWP Department of Environment, Land, Water and Planning
DES Department of Environment and Sciences
DMIRS Department of Mines, Industry Regulation and Safety Building and
Energy
DNV Det Norske Veritas
EES Electrical Energy Storage
EHFA Early Human Factors Assessment
EIA Environmental Impact Assessment
EMP Environmental Management Plan
ERA Environmentally Relevant Activities
ESA Electricity Safety Act 1998
ESMS Electrical Safety Management Schemes
ESS Energy Storage System
ESV The Victorian Energy Safety Commission, also commonly referred as
Energy Safe Victoria
FCAS Frequency Control Ancillary Services
FDIA False Data Injection Attack
FMEA Failure Modes and Effects Analysis
FMECA Failure Mode Effect and Criticality Analysis
GW Gigawatt
GWh Gigawatt hour
HAZID Hazard Identification
HAZOP Hazard and Operability Study
Term Definition
HFIP Human Factors Integration Plan
HIPAP Hazardous Industry Planning Advisory Papers (NSW Planning)
HSEQ Health, Safety, Environment and Quality
ICNIRP International Commission on Non-Ionising Radiation Protection
IRENA International Renewable Energy Agency
ISO International Standards Organization
kV Kilovolt
LFP Lithium iron phosphate
LGA Local Government Areas
Li-ion Lithium-ion
LOPA Layers of Protection Assessment
MEC Major Electricity Companies
MHF Major Hazard Facility
MW Megawatt
MWh Megawatt hour
Na-ion Sodium ion
NEM National Electricity Market
NFPA National Fire Protection Association
NMC Li-ion Nickel-Manganese-Cobalt
NSW New South Wales
NZS New Zealand Standard
OH&S Occupational Health and Safety
OEM Original Equipment Manufacturer
QFES Queensland Fire and Emergency Services
QLD Queensland
RAMS Reliability, Availability and Maintainability Study
SAFOP Safety and Operability Study
SCADA Supervisory Control and Data Acquisition
SFAIRP So Far As Is Reasonably Practicable
UGL UGL Limited
UL Underwriters Laboratories
V Volt
VBB Victoria Big Battery
VESDA Very Early Smoke Detection Apparatus
VRET Victorian Renewable Energy Targets
VRF Vanadium Redox Flow
Wh/kg Watt hours per kilogram
WHS Work, Health and Safety
Appendix B
Interview questionnaire
The following questions / discussion items were used by the GHD team during interviews with relevant
stakeholders. Refer to Section 4.2 to review the main findings from each interview.
General questions:
– Have there been any issues within your jurisdiction associated with currently operating BESS facilities?
– Have you been consulted as part of BESS facility installations / commissioning processes to date? If so, in
what capacity? Have there been any discussion about decommissioning these sites in the future?
Regulator specific questions:
– What are the current acts and regulations that cover grid-scale BESS regulation?
– What have been the key challenges associated with BESS regulation?
• Gaps and ambiguities in the current regulations
• Gaps and potential opportunities in roles and responsibilities
• Is there a plan for consistency of regulation across the States? What about globally?
– Are there any thoughts of adopting international regulations in Australia? If so, what are these and which
elements are of interest?
– Are there any plans to add new regulatory requirements?
– How are you made aware of and what is the process of assessing new BESS facilities
– Do you envisage that different scale facilities would/should have different regulations applied? [GC]
– What are the regulatory requirements for dealing with a fire at a BESS facility?
– Are there any separation distances you require between a BESS facility and other sites/residences? If so,
what are they? Is there a particular Standard or guideline? If not, how should BESS facility owners
demonstrate suitable buffer distances?
OEM specific questions:
– What are the regulations that you are becoming most aware of internationally? If so, what are these?
– What are the current / future requirements around BESS fires and explosions?
– Without releasing commercial in-confidence information, how does your BESS handle thermal runaway
incidents? What do you do to prevent thermal runaway? Do the thermal management systems have
redundancy capacity?
– Is there undue reliance on particular standards which may be restrictive (e.g., UL9540A)?
– Are there any plans to change the configuration of battery packs? For example, will they be stackable
(double, triple)? Centralised vs. decentralised utilities for the modules (fire systems, cooling)
– What do you perceive as best current practice in the HSE space for BESS [GC]?
– What do you perceive as emerging / future practice in the HSE space for BESS [GC]?
– What are the greatest risks you face? What are you doing about these?
– In the event of a BESS fire, are there any specific requirements or operations that a site operator or
emergency responder must be aware of? Is the response to a fire the same for all different BESS types?
– What measures can be implemented to prevent fire spread throughout a BESS site?
– What climatic conditions may cause operational limitations?
• How much testing of BESS modules has been carried out in climatic conditions similar to Australia?
– Is downwind thermal heat plume considered when providing BESS modules for a particular site?
General concluding questions:
– What would you like to be done differently?
• Are there aspects of BESS facilities that concern you?
• Are there concerns about future trends of these batteries and associated facilities?
• Are the current locations, configurations, site footprints, general design, etc. of these facilities of
concern?
– Will the public be consulted in preparation for BESS installations? Will this be fed into future guidelines? For
example, land that is currently being used may become residential areas which could impact land valuation
later on (i.e., urban pressures)?
Appendix C
Site selection requirements and
considerations
C-1 Meteorology
C-1-1 Wind
Consideration of wind loading impacts should be undertaken prior to selecting a BESS site. AS/NZ 1170.2:2021
Structural design actions Part 2: Wind Actions [76] is a key source of guidance. The northern Australia coast is
dominated by cyclonic wind conditions, stretching at least 50 km inland and up to 100 km along parts of the
Western Australian coast between 20 ° and 25 ° latitude, as shown in the wind region map in Figure 12, extracted
from AS 1170.2 (Fig 3.1(A)).
Along with resistance to wind loading, depending on the site, consideration of BESS module flying debris impact
resistance should be undertaken. Thermal runway events can occur should battery cells become physically
damaged. AS/NZ 1170.2:2021 (Section 2.5.8) provides guidance, however, individual OEM suppliers should be
consulted.
Figure 12 Australian wind regions as defined in AS 1170.2 (Figure 3.1 (A)). Source: AS 1170.2:2021.
"On a broad scale, Australia is dominated by westerlies in southern parts of the continent and easterlies (trade
winds) in the northern parts. On regional and local scales wind speed and direction are affected by terrain,
vegetation and meteorological factors such as the monsoon regime, tropical cyclones, sea/mountain breezes,
frontal systems and convective activity."4(BoM, 2023)
Some examples of wind rose for four locations throughout Australia are shown in Figure 13. Annual 3 pm has
been selected as afternoons and evenings are more likely to be the times of greater BESS demand.
4
http://www.bom.gov.au/climate/maps/averages/wind-velocity/ Accessed 15/01/2022 @ 5:26 pm.
Figure 13 Comparison of 3 pm annual wind rose plots. Source: BoM (2023). From top left clockwise: Gladstone (Qld),
Nowra (NSW), Perth (WA) and Latrobe Valley (Vic)
C-1-2 Temperature
Commercially available BESS scale batteries will generally be manufactured with the greatest sales market in
mind. Sales to the United States of America will be utmost in mind. However, in terms of climate, the United States
is generally a cooler climate. A comparison of average annual mean temperatures of Australia and the United
States is shown in Figure 14. About half of the Australian mainland has an average temperature greater than
21 °C. This compares to less than 10 percent of the United States.
When viewing the areas of highest solar radiation in Australia, shown in Figure 15, areas of highest solar radiation,
best suited for solar arrays, also correspond to the areas of Australia with average temperatures greater than
21 °C.
Elevated temperature does not prevent a BESS module from operating as in-built cooling mechanisms will prevent
overheating, with one such mechanism being a de-rating of available output/input power. Therefore, the total
number of unaffected operational hours should be considered when selecting a site. Paradoxically, highest energy
demand, and therefore greatest chance of a BESS supplying to the grid is more likely when air temperatures are
greatest. Whole of BESS expected life can be affected by elevated temperatures, with battery life reduced when
cell ambient temperature exceeds 35 °C [77] [78].
10°C
16°C
18°C
21°C
21°C
Figure 14 Annual average temperatures maps for Australia (top) and United Stated (bottom).
NB. 50°F = 10°C, 60°F  16°C, 70°F  21°C.
Figure 15 Annual average daily solar radiation map for Australia
C-2 Separation distances
Separation distances between module and site are provided in at least two of the reviewed Standards/Guidelines.
C-2-1 NFPA 855

NFPA 855 (2023) [79] provides specifications relating to clearance to exposures and separation distances.
A minimum 0.9 m (3 ft) separation distance is required between groups or modules and other modules and walls,
with each module having a maximum allowable energy storage capacity of 50 kWh. This spacing and/or maximum
energy rating can be changed subject to acceptable fire and explosion testing results.
Combustible vegetation needs to be cleared and controlled within 3 m (10 ft) of any BESS.
Sensitive exposure areas such as, but not limited to, public ways, buildings, stored combustible materials, high
piled stock require a separation distance of at least 3 m (10 ft) from the BESS. However, there are provisions that
do allow this distance to be reduced, such as freestanding fire barriers, but the reduction does not allow a
separation distance smaller than 0.9 m (3 ft).
NFPA 855 refers to the Authority Having Jurisdiction (AHJ) as the organisation, office or individual responsible for
enforcing the requirements of a code or standard or for approving equipment, materials, an installation design or
an operating procedure.
C-2-2 CFA renewable energy facility design guidelines

The CFA has published a set of design guidelines for various renewable energy facilities, including BESS facilities.
[69] In some areas these guidelines are more conservative than NFPA 855, but in other areas less prescriptive.
For example, the CFA stipulates a minimum 10 m combustible vegetation separation distance (fire break) for
BESS facilities. This is to prevent radiant heat from a (bush/grass) fire impacting on the BESS.
Unlike NFPA 855, CFA does not prescribe a distance between battery modules, but instead refers to a separation
distance informed by radiant heat output that will prevent spread between modules.
In Victoria, the CFA is not required to be notified of a renewable energy facility planning application. However,
applications may be sent to CFA for their comment. Therefore, as defined in NFPA 855, the CFA would not be an
AHJ, and their guidelines may not be enforced.
Appendix D
High-level supporting risk register
BESS Revision: 0
Hazard Identification (HAZID) Register
Project: Project No.: Vanadium redox flow battery related risks

Title: AEC BESS Guidance Risk Register Client: Lithium-ion battery related risks
Revision: FINAL Document Date: 24/3/2023 Risks related to both vanadium redox flow batteries and lithium-ion batteries
Residual Risk
Initial Risk Rating
Rating
Consequence
Consequence
Risk Rating
Risk Rating
Likelihood
Likelihood
Hazard I.D. Project Area Hazard Description Cause Consequence Standard Control Measures Risk Owner Potential Control Measures And Actions Responsibility By When Decision / Status Comments / references
- Damage to BESS - Designed to Industry Acts and Standards

- Escalation of event (i.e. (Occupational Health and Safety Act, AS/NZS
propagation to neighbouring ISO 14001:2016, AS/NZS ISO 45001:2018,
- Include remotely accessible flammable gas monitoring to detect
Production and BESS modules) UL1973, UL9540) including deflagration control
presence of flammable gases
accumulation of - Injury to onsite personnel (pressure sensitive vents and sparker system)
- Include appropriate signage and site manifest to identify hazardous
flammable gases in - Injury to surrounding - Compliance with applicable requirements from
chemical hazards associated with the contents of BESS Arizona fire 2019
1 Environmental Flammable gases battery enclosure with populations (neighbouring NFPA 855 and UL9540A
- Consider and confirm unintended consequences of a noise wall if it Victorian Big Battery fire 2021
ignition resulting in fire or industries, residents) - Vegetation management / clearance around
is implemented, including accessibility to and from site, accumulation
explosion and thermal - Bushfire, damage to BESS
of hazardous gases and confinement of heat within the site ("heat
runaway environment - Site specific emergency response and
island effect")
- Heat radiation to the management plan
transformer. Transformer - Multiple access and egress points on site to
overheats and fails. allow fire authority to access the fire water tank
- Include remotely accessible flammable gas monitoring to detect

presence of flammable gases
- Include appropriate signage and site manifest to identify hazardous
chemical hazards associated with the contents of BESS
- Incorporate presence of toxic gases being generated from the BESS
- Designed to Industry Acts and Standards
into site Emergency Response Procedures, including appropriate
(Occupational Health and Safety Act, AS/NZS
exclusion zones, PPE for Emergency Responders, and
ISO 14001:2016, AS/NZS ISO 45001:2018,
communications required to neighbouring industries and local Toxic gases from recent PG&E (California)
UL1973, UL9540)
- Injury to onsite personnel residents fire were HCN, CO, and trace amounts of
Thermal runaway in - Compliance with applicable requirements from
- Injury to surrounding - Confirm what toxic materials (type and volume) are produced from HF
BESS (including NFPA 855 and UL9540A
populations (nearby industrial the BESS and ask the vendor to provide information on products of
2 Environmental Toxic gases initiation) leading to - PPE for emergency response team and onsite
area or residential) combustion Toxic gases can be generated due to the
production and personnel
- Impacts to local flora and - Determine the potential toxic hazard impact zone around the BESS incomplete combustion of gases
dispersion of toxic gases - Site specific emergency response and
fauna using suitable air dispersion modelling with consideration of wind generated during the initial thermal
management plan
speeds and directions runaway phase
- Selection of appropriate battery chemistry
- Prepare information for community of the potential hazards to
- Design of battery modules to slow and limit
residents of toxic gas dispersion from the BESS, once dispersion
rate of gas generation
modelling is complete
- Consider and confirm unintended consequences of a noise wall if it
island effect")
- Vegetation Management / clearance around

BESS (Asset Protection Zone with landscaping
treatment, fencing and retaining constructed
- Confirm fire water supply requirements to manage a BESS fire and
from fire resistant materials)
determine the fire system scope of work (e.g., onsite tank, water main,
- Access and egress suitable for prevention
etc.)
activities and firefighting
- If a noise wall is required for the site, reconsider the size of the Asset
- Damage to BESS leading to - Housekeeping/maintenance to remove debris
Protection Zone to ensure it is sufficient
disruption of power supply build up
- If a noise wall is required for the site, ensure noise wall material is
- Damage to power supply - Fire water requirements meet required
fire resistant
infrastructure causing guidance (e.g., CFA guidance material)
- If a noise wall is required for the site, determine the thermal radiation
disruption of power to - Other buildings within the BESS facility
External thermal source consequences for the site inside the noise wall
community compound are designed for adequate fire
(e.g. fire at neighbouring - Include a procedure to shut down BESS during conditions where fire
- Hardware failure protection
3 Environmental External fire facility or bushfire) can spread externally into site (e.g. bushfire) as part of standard
- Heat radiation to the - Site specific emergency response and
resulting in overheating operating protocols
transformer. Transformer management plan
of BESS - Position and design air conditioning vents on site buildings and BESS
overheats and fails. - Procedure/ controls for correct storage of any
cabinets to prevent debris build up and fire propagation
- Potential for escalation to a chemicals/ combustible materials brought
- Investigate designing louvres and shields on air intakes to batteries
thermal runaway event (and onsite, to be away from units (if applicable)
- Consider and confirm unintended consequences of a noise wall if it
propagation between units) - All equipment clearances in accordance with
AS2067
- Selection of appropriate battery chemistry
island effect")
- Design of battery modules to slow and limit
- Use of non-combustible materials for all adjacent hardware &
rate of gas generation
equipment
- Bushfire risk assessment
-Non-combustible elements used for

construction
- Ember attack ignites exposed - Site specific emergency response and
cables management plan
etc.)
- Damage to BESS leading to - Procedure/ controls for correct storage of any
- If a noise wall is required for the site, ensure noise wall material is
disruption to power supply chemicals/ combustible materials brought
fire resistant
Bushfire in the local - Damage to power supply onsite, to be away from units (if applicable)
- Include a procedure to shut down BESS during conditions where fire
4 Environmental External fire bushland resulting in infrastructure causing - Fire water requirements meet required
can spread externally into site (e.g. bushfire) as part of standard
ember attack disruption of power to guidance (e.g., CFA guidance material)
operating protocols
community - Other buildings within the BESS facility
- Use of non-combustible materials for all adjacent hardware &
- Potential for escalation to a compound are designed for adequate fire
equipment.
thermal runaway event (and protection
- Complete Computational Fluid Dynamic modelling of the whole
propagation between units) - Insulation around battery module to limit heat
BESS facility
effects
- Bushfire risk assessment
12591546-REG-BESS Guidance Register.xlsm Page 1 of 6 Print Date: 3/24/2023

BESS Revision: 0
Residual Risk
Initial Risk Rating
Rating
Consequence
Consequence
Risk Rating
Risk Rating
Likelihood
Likelihood
- Damage to BESS leading to

- Design BESS units for worse case site ambient
disruption of power supply
Extreme temperature conditions with appropriate IP rating
- Degradation of equipment - Complete Computational Fluid Dynamic modelling of the whole
(e.g. hot day) or humidity - BMS to shut down BESS if temperature
- Hardware failure BESS facility
resulting in overheating exceeds high temperature threshold
- Reduction in BESS operating - Confirm fire water supply requirements to manage a BESS fire and
of BESS - Fire water requirements meet required
life determine the fire system scope of work (e.g., onsite tank, water main,
External ambient guidance (e.g., CFA guidance material)
- Deteriorating insulation etc.)
5 Environmental conditions / Note: A noise wall - Other buildings within the BESS facility
leading to injury to personnel - Consider and confirm unintended consequences of a noise wall if it
environment around the facility may compound are designed for adequate fire
- Unable to comply with is implemented, including accessibility to and from site, accumulation
increase the hazard protection
derating and regulatory of hazardous gases and confinement of heat within the site ("heat
through the potential for - Site specific emergency response and
requirements island effect")
a "heat island" management plan
- Potential for escalation to a - Selection of low noise fans and ventilation system design
- Selection of suitable battery chemistry
thermal runaway event (and
propagation between units)

BESS
loss of ancillary services (e.g.,
Severe storm event - Dual redundancy
Lightning strike to BESS monitoring)
6 Environmental during operation - Lightning protection study, and appropriate
unit - Potential for escalation to a
(lightning) lightning protections applied
thermal runaway event (and
- Site specific emergency response and
propagation between units)
management plan
- Conduct flood modelling of BESS site to determine potential impact

Flash flooding inundating - BMS to shut down BESS if temperature zones and design drainage to mitigate the effects
- Limited access to site
BESS facility, leading to: exceeds high temperature threshold - Determine impact of flooding at substation including expansion on
Severe storm event - Damage to BESS, with the
- ground instability - Site location considers flood regions and the BESS site (e.g. water runoff across site) and design drainage to
7 Environmental during operation potential to initiate a thermal
- high water levels incorporates suitable facility design height mitigate the effects
(flooding) runaway event depending on
(potential to submerge - Site specific emergency response and - Complete geotechnical studies to ensure stable ground conditions
the extent of the flooding
BESS units) management plan for light and heavy vehicles including in heavy rain / flooding events
and seismic events
- Civil design to comply with relevant standards

Flooding inundating - Limited access to site, - Conduct flood modelling of BESS site to determine potential impact
- Design of temporary works to manage erosion
construction site, leading delaying commissioning zones and design drainage to mitigate the effects
control
Storm water or local to: - Environmental impact - Local - Schedule construction in dry season to reduce the likelihood of
- Weather monitoring
8 Environmental flooding during - ground instability erosion, scouring, sediment environmental impacts from site drainage
- Environmental inspections
construction - high water levels flowing offsite - Complete geotechnical studies to ensure stable ground conditions
- Flood mapping of area
(potential to submerge - Onsite impact - ground for light and heavy vehicles including in heavy rain / flooding events
- Site location considers flood regions
BESS units) conditions and seismic events
- Construction management plan

BESS
- BMS to shut down BESS if temperature
- Generation of microclimate exceeds high temperature threshold
Windy conditions at around BESS facility - Other buildings within the BESS facility
BESS facility in - Potential for escalation to a compound are designed for adequate fire - If a noise wall is to be implemented, ensure it is compliant with
High winds during
9 Environmental combination with fire, thermal runaway event (and protection Australian Standards for wind loading
bushfire event
resulting in ember propagation between units) - Compliance with AS1170.2 - activation of site spray system if exists.
propagation and attack - Damage to surrounding BESS - Site specific emergency response and
facility infrastructure management plan
- BESS module design to withstand ember
attack and external heat with insulation
- Set back distances from falling objects (trees

- Damage to BESS units or powerlines) - Complete geotechnical studies to ensure stable ground conditions
Earthquake causing
10 Environmental Seismic event - Damage to BESS facility - Designed to AS1170.4 for light and heavy vehicles including in heavy rain / flooding events Dependent on location
ground instability
infrastructure - Site specific emergency response and and seismic events
management plan
- Ventilation system
- Maintenance strategy
- IP rating of the ventilation system
- Damage to BESS leading to - BMS to shut down BESS if temperature
- Inadequate IP rating loss modules exceeds high temperature threshold - Confirm current containment requirements for fire water used in
- Accumulation of dust - Potential for thermal runaway, - Vegetation Management / clearance around fighting a BESS fire (e.g., implement holding tank and treatment for
within BESS module, explosion / fire, leading to: BESS contaminated water) This scenario is dependent on the quality
11 Environmental Dust ingress to BESS resulting in overheating -> Injury to onsite personnel - Design includes two measures for explosion - Ensure all fire hazards are considered within a Fire Safety Study, and number of independent layers of
or electrical fault, -> Injury to surrounding mitigation (sparker system and deflagration including appropriate preventative and mitigative controls to ensure all protection.
potentially leading to populations (neighbouring panels in roof) hazard requirements are met
thermal runaway industries, residents) - Fire water requirements meet required - Thermal and airflow detectors
-> Bushfire guidance (e.g., CFA guidance material)
- Other buildings within the BESS facility
compound are designed for adequate fire
protection
- Undertake noise modelling to determine if a noise wall is required to

reduce noise impacts to nearby residential areas
Noise produced by BESS - Complete noise modelling - Consider and confirm unintended consequences of a noise wall if it
12 Environmental Noise impacting nearby Reputational impacts - Construction of a noise wall (if needed) is implemented, including accessibility to and from site, accumulation Applicable to all BESS facilities
residents and community - Suitable noise specification with supplier of hazardous gases and confinement of heat within the site ("heat
island effect")
- Utilise low noise fan and ventilation design

BESS Revision: 0
Residual Risk
Initial Risk Rating
Rating
Consequence
Consequence
Risk Rating
Risk Rating
Likelihood
Likelihood
- Determine the extent of contamination of water used to fight fires Experience from VBB fire (2021) that a
Potential runoff of and any potential environmental impacts if released BESS module fire requires 6hrs fire water
- Civil design to comply with relevant standards
Contaminated fire Fire at BESS requiring contaminated fire water into the - Confirm current containment requirements for fire water used in (TBC) and the fire water was not
13 Effluent - Fire water requirements meet required
water use of fire water environment resulting in fighting a BESS fire (e.g., implement holding tank and treatment for contaminated
guidance (e.g., CFA guidance material)
environmental damage contaminated water) Consider CFA guidance for relevant criteria
for fire water runoff in Victoria.

etc.)
- OEM QA procedures, SAT and FAT data - If a noise wall is required for the site, reconsider the size of the Asset
- Maintenance strategy Protection Zone to ensure it is sufficient
Thermal event within a - BMS to shut down BESS if temperature - If a noise wall is required for the site, ensure noise wall material is
battery module due to exceeds high temperature threshold fire resistant
various reasons - Damage to BESS leading to - Design includes two measures for explosion - If a noise wall is required for the site, determine the thermal radiation
including, but not limited module loss mitigation (sparker system and deflagration consequences for the site inside the noise wall
to, the following: - Heat radiation to the panels in roof) - Include a procedure to shut down BESS during conditions where fire
- Internal coolant leak transformer. Transformer - Fire water requirements meet required can spread externally into site (e.g. bushfire) as part of standard
- SCADA system offline overheats and fails guidance (e.g., CFA guidance material) operating protocols
Internal thermal source
during commissioning - Potential for thermal runaway, - Other buildings within the BESS facility - Position and design air conditioning vents on site buildings and BESS
14 Equipment (i.e., within the battery
- Short circuit explosion / fire, leading to: compound are designed for adequate fire cabinets to prevent debris build up and fire propagation
module)
- Leakage of water to -> Injury to onsite personnel protection - Investigate designing louvres and shields on air intakes to batteries
below cells resulting in -> Injury to surrounding - Designed to Industry Standards (UL1973, - Consider and confirm unintended consequences of a noise wall if it
damage and thermal populations (neighbouring UL9540, AS2067) is implemented, including accessibility to and from site, accumulation
runaway industries, residents) - Compliance with applicable requirements from of hazardous gases and confinement of heat within the site ("heat
- Internal cell defect (e.g. -> Bushfire NFPA 855 and UL9540A island effect")
manufacturing error) - Complete mapping of the supervisory control - Use of non-combustible materials for all adjacent hardware &
and data acquisition (SCADA) system to the equipment.
control system and provide full data functionality - Thermal imaging camera(s) included in O&M toolkit, allowing for
and oversight to operators monitoring of system in event of suspect behaviour.
- Ensure all fire hazards are considered within a Fire Safety Study,
including appropriate preventative and mitigative controls to ensure all
hazard requirements are met
- Conduct an Arc Flash study as part of BESS cabinet design for arc
Fault in AC and DC - Designed to relevant standards (arc flash flash containment
Electrical equipment electrical equipment in rating, isolations) - Implement suitable operational procedures for LOTO, switching, etc.
15 Equipment Injury to onsite personnel Lessons learned from Chinchilla BESS
fault BESS resulting in arc - Live equipment procedures This includes procedures for substation operation during construction
flash / commissioning of BESS interface
- Develop and follow suitable lift plan for lifting of BESS equipment
- Designed to applicable electrical Standards to
Contact with over live BESS modules during construction, operation, replacement
BESS installation minimise touch and step potential
underground utilities Injury to personnel from step and decommissioning
16 Equipment earthing and connection - Lift plan for lifting of BESS equipment over live Lessons learned from Chinchilla BESS
and step and touch and touch potential - Implement suitable operational procedures for LOTO, switching, etc.
to existing earth mat BESS modules during construction, operation,
voltages This includes procedures for substation operation during construction
replacement and decommissioning
/ commissioning of BESS interface
- Insulation failure - Earthing Standards covered in battery storage

-Implement suitable operational procedures for LOTO, switching, etc.
Earth fault on the DC - Water ingress battery Damage to BESS leading to (AS5139, AS3000)
17 Equipment This includes procedures for substation operation during construction Lessons learned from Chinchilla BESS
systems failure disruption of power supply - Vegetation management / clearance around
/ commissioning of BESS interface
- Equipment fault BESS
- Integrally bunded tank within the diesel

generator unit
- Low quantity of diesel stored (Less than 1000 - Recommend compliance with the minor storage provisions of
Diesel leak resulting in
Fire in diesel generator Heat radiation impact to L). Section 2.3 of AS1940 for diesel storage and refuelling
18 Equipment ignition and fire in the
unit (if applicable) adjacent structures - Storage faculty is classified as minor under AS - For less than 1,000 L separation from buildings is unrestricted but
diesel generator unit
1940 and no segregation is required. 1.5 m from structures is recommended for access purposes
- Adjacent building are non-combustible
material
- Use of fire detection

- Staff available near site for quick response if
remote communication becomes unavailable
Fire in panel and potential loss
- Switch gear is fail safe and can be operated
Electrical fault in of communication equipment
19 Equipment Communication panel manually
communications panels fire growth into the room and
- Room is constructed from non-combustible
adjacent equipment.
materials (low fuel load)
- Low energy equipment in the communications
panel.
- Use of early smoke detection and gas

suppression to mitigate fire risk before damage
Fire in panels, loss of fire
Fire Protection & can occur to the system
protection system equipment,
20 Equipment VESDA Panels - Electrical fault in panels - Equipment should be rated to withstand and
impaired fire suppression
Control Room detect fire in its vicinity
capabilities
- Fire system circuit is design as fail safe
- Extra low voltage panel wiring

BESS Revision: 0
Residual Risk
Initial Risk Rating
Rating
Consequence
Consequence
Risk Rating
Risk Rating
Likelihood
Likelihood
- External impact (e.g.,

- Safety rails and bollards
vehicle) to high voltage - Equipment damage
- Fencing around site
equipment, BESS units, - Damage to BESS leading to
- Not many vehicles required/expected during - Implement dedicated walkways and crossing points to reduce risk of
or surrounding module loss. Depending on the
operation and maintenance vehicle interactions with pedestrians
21 Equipment External impact infrastructure, due to extent of impact, there is
- Minimum compliance with AS2067, AS3000 - Implement site speed limit to reduce risk of vehicle interactions with
fatigue, speeding, loss of potential for thermal runaway,
and other requirements pedestrians and collisions with BESS and associated equipment
vehicle control, - Potential for injury to onsite
- Site speed limit
inadequate road personnel
- Steel frame of module
condition
- Trained, competent, and qualified staff

- OEM maintenance procedures
- Cell failure, loss of
- Fire water requirements meet required
performance
guidance (e.g., CFA guidance material)
- Potential for thermal runaway,
- Other buildings within the BESS facility
explosion / fire, leading to:
compound are designed for adequate fire - Confirm fire water supply requirements to manage a BESS fire and
Failure during Error in maintenance of -> Injury to onsite personnel (if
22 Equipment protection determine the fire system scope of work (e.g., onsite tank, water main,
maintenance BESS present)
- Designed to Industry Standards (UL1973, etc.)
-> Injury to surrounding
UL9540, AS2067)
populations (neighbouring
- Compliance with applicable requirements from
industries, residents)
NFPA 855
-> Bushfire
- Site specific emergency response and
management plan
- Lift and construction sequencing plan which

details lifting of BESS equipment over live BESS
Dropped loads during
modules during construction, operation,
installation due to poor Although this risk specifically refers to live
replacement and decommissioning
load placement or lifting batteries being dropped on site, this is risk
Dropped objects during - Equipment damage - Constructability and maintainability
23 Equipment failure (live batteries is applicable to all grid-scale BESS
construction - Injury to onsite personnel assessment and plan for the BESS site, to
dropped during facilities which require lifting equipment at
ensure adequate provision for future work
construction or heights
activities on the site
replacement)
NFPA 855
- Lift plan which details lifting of BESS

equipment over live BESS modules during
construction, operation, replacement and
Dropped loads during Although this risk specifically refers to live
decommissioning
Dropped objects during operation and batteries being dropped on site, this is risk
- Equipment damage - Constructability and maintainability
24 Equipment operation and maintenance due to poor is applicable to all grid-scale BESS
- Injury to onsite personnel assessment and plan for the BESS site, to
maintenance load placement or lifting facilities which require lifting equipment at
ensure adequate provision for future work
failure heights
activities on the site
NFPA 855
- Specification includes access requirements for

maintainability and emergency response
purposes
- Inadequate spacing
- design of two separate paths of egress
between BESS module - Injury to onsite personnel - Conduct a hazardous area assessment to determine the locations
- Layout review (in a later project stage) once
rows (e.g. only - Emergency responders of release points in relation to potential ignition sources
the preferred supplier has been awarded
- Restricted BESS facility unable to reach BESS as - Consider and confirm unintended consequences of a noise wall if it
25 Emergency Accessibility - Minimum compliance with AS2067, AS3000
access / egress routes spacing between battery banks is implemented, including accessibility to and from site, accumulation
and other requirements
for emergency is insufficient for vehicle of hazardous gases and confinement of heat within the site ("heat
evacuation and movement island effect")
NFPA 855
responders
- Engage with local fire authorities and other
emergency services during layout design and
site commissioning process
- Layout review (in a later project stage) once

- Injury to personnel (e.g.
the preferred supplier has been awarded
ergonomics)
- Inappropriate layout of - Minimum compliance with AS2067, AS3000
- Two way foot traffic not
BESS area and other requirements
Occupational, Health possible when completing
26 Accessibility - Inadequate spacing - Compliance with applicable requirements from
and Safety checks and maintenance with
between BESS module NFPA 855
one battery module cabinet
rows - Inclusion of OH&S team during layout review
door open due to current
discussions
spacing requirements
'- Low physical maintenance design of facility
BESS facility
microclimate due to
External ambient
Occupational, Health BESS operation in - Injury to personnel (heat
27 conditions / - Site specific OH&S plans
and Safety conjunction with hot exhaustion and/or heat stroke)
environment
ambient conditions
(>40DegC)
- Review of OEM BESS safeguards to prevent

high voltage exposure in various abuse
conditions (e.g. battery modules sealed within
enclosures in sub-groups)
- Isolation and earthing on switchgear, boards
Occupational, Health Contact with HV Personnel contact with Electrocution leading to injury and inverters
28
and Safety equipment damaged battery module or fatality - Provide interlocks on HV electrical equipment
to minimise contact with HV electrical hazards
- Develop an Energy and Isolation Standard for
the site to minimise contact with HV electrical
hazards

BESS Revision: 0
Residual Risk
Initial Risk Rating
Rating
Consequence
Consequence
Risk Rating
Risk Rating
Likelihood
Likelihood
- Ensure BESS units are stored per storage precautions

recommended by OEM
- Ensure the emergency response procedure includes a plan to
Leaked battery coolant leading - PPE when working in vicinity of battery units
BESS damage resulting evacuate the area in the case of a gaseous or liquid loss of
to (gloves, protective clothing)
in leaked battery coolant containment
Environmental / - Skin irritation - Containment of leaks and spills
29 Contact with coolant (e.g., due to mechanical - Include in the emergency response plan the requirement to
Hazardous material - Environmental release and - Compliance with EPA guidelines
damage) which does not minimise the exposure to hazardous gases by the use of respiratory
impact - Site specific emergency response and
escalate to thermal event protection
management plan
- Determine the maximum volume of coolant that can be released in
any credible loss of containment scenario and design suitable
containment
- Battery modules stored outside (adequate

ventilation)
BESS damage resulting - PPE when working in vicinity of battery
- Include in the emergency response plan the requirement to use self-
Environmental / Hazardous material - in leaked refrigerant Skin irritation or frostbite (if modules
30 contained breathing apparatus (SCBA) in the case of a refrigerant
Hazardous material refrigerant (e.g., due to mechanical exposed to liquid refrigerant) - Site specific emergency response and
leak
damage) management plan
- Determine volume of refrigerant per battery
module
Item 2 talks about toxic combustion

- Battery modules stored outside (adequate
BESS damage during products. This issue is talking about
ventilation)
fire resulting in release of Exposure to toxic/corrosive decomposition of refrigerant (not
- PPE when working in vicinity of battery - Include in the emergency response plan the requirement to use self-
toxic/corrosive decomposition products combustion) that results from overheating
Environmental / Hazardous material - modules contained breathing apparatus (SCBA) in the case of a refrigerant
31 decomposition products impacting of BESS.
Hazardous material decomposition products - Site specific emergency response and leak
(i.e. refrigerant - Onsite personnel
management plan - Determine volume of potential decomposition products
decomposition - Nearby residents Decomposition products include HF,
- Limited volume of refrigerant per battery
chemicals) halogens, halogen acids, and possibly
module
carbonyl halides
- Possibility of release of electrolyte is very

BESS damage resulting remote (not much is in free liquid form but
Leaked electrolyte leading to: - Ensure the emergency response procedure considers leaked (or
Environmental / Hazardous material - in release of flammable rather contained in electrodes) PPE includes: air purifying respirator,
32 - ignition of vapours suspected leaked) electrolyte - use of PPE, ventilation of area,
Hazardous material electrolyte electrolyte (hydrocarbon - Cells are in sealed steel compartments able to safety goggles, gloves, protective clothing
- irritation to eyes and skin cleaning spills using dry absorbent material
+ LiPF6) contain liquid from a number of cells (to be
confirmed)
- Security fencing
Unauthorised access Intentional access to site - Confirm site security can be monitored using humans (control room)
- CCTV and monitoring
33 Security from members of the with no malicious intent Injury to members of the public or technology (CCTV / AI) Applicable to all grid-scale BESS facilities
- Site security plan for the BESS site (e.g.
public (e.g. protestors) CPTED assessment and design of BESS facility
mobile patrol, monitoring etc.)
- Security fencing
- CCTV and monitoring
Unauthorised access Intentional access and - Confirm site security can be monitored using humans (control
Damage to BESS and injury to - Secure battery unit cabinets design
34 Security from members of the damage to BESS (e.g. room) or technology (CCTV / AI) Applicable to all grid-scale BESS facilities
onsite personnel - Locked control room
public sabotage, theft)
- Site security plan for the BESS site (e.g.
mobile patrol, monitoring etc.)

module loss - Conformance to the Security of Critical
- Heat radiation to the Infrastructure Act
transformer. Transformer - User authentication (e.g., two factor) and site
Intentional cyber attack - Assess degree of impact from loss of operation as per Section 10 of
overheats and fails security protocol / verification
of BESS facility, resulting Security of Critical Infrastructure Act (https://www.cisc.gov.au/critical-
- Potential for thermal runaway, - Regular cyber auditing (including routine
in multiple, targeted infrastructure-centre-subsite/Files/register-critical-infrastructure-
35 Security Cyber attack explosion / fire, leading to: system penetration testing) Applicable to all grid-scale BESS facilities
thermal runaway events, assets.pdf )
-> Injury to onsite personnel (if - Configuration of appropriate systems
or events that cause grid - Complete cyber security training for staff
present) architecture (e.g., distributed, segmented,
stability issues - Network and software penetration testing
-> Injury to surrounding centralised)
populations (neighbouring - Encrypted, secure communications
industries, residents) - Software updates and regular backups
-> Bushfire
- Community consultation
Non-acceptance from
- Stakeholder management plan including
community and
- Project delays resulting in communication/education to community about
stakeholders due to:
Lack of stakeholder financial impacts, disruption to overall benefit of facility and proactively clear
- Disruption of local
36 Project engagement / operations misconceptions on safety/environmental Applicable to all grid-scale BESS facilities
habitat
consultation - Protests impacts
- Environmental damage
- Reputational impacts - Early engagement with relevant regulatory
- Noise
authorities (e.g. fire authorities, land planning
- Safety concerns
authorities, electrical etc.)

BESS Revision: 0
Residual Risk
Initial Risk Rating
Rating
Consequence
Consequence
Risk Rating
Risk Rating
Likelihood
Likelihood
- Inadequate ventilation of the

battery units due to stacked
configuration
- Increase in heat island effect,
increasing local microclimate
- Limited land space conditions
- Advanced thermal and fire modelling
available for BESS - Damage to unit on ground
- Advanced ventilation approaches
facility construction due level
- Advanced battery chemistry and design suitable for such
to land value increases, - Unable to access stacked
arrangements
movement to peri-urban units for maintenance without
37 Design Stacked battery units - Advanced insulation and fire protection systems
locations working at heights permit. This
-> Fire detection (including, VESDA, IR and thermocouples)
- Creative approach to may present ergonomic issues
-> Fire suppression (investigating feasibility and benefit of centralised
get more storage - Potential for thermal runaway,
suppression)
capacity within the same explosion / fire, leading to:
- Rack and module isolation systems
footprint -> Injury to onsite personnel (if
present)
-> Injury to surrounding
populations (neighbouring
industries, residents)
-> Bushfire
- Discharge of energy
- Release of coolant,
- OEM inspection and testing program prior to
- Damage during loading refrigerant, other hazardous
shipping to site
or unloading of battery materials, leading to short
- OEM transportation guidance
unit into or out of circuit
38 Design Transport - Inspection and testing program in place which - Advanced battery design, and module protection
shipping container - Damage to the battery cell or
details the inspection measure required upon
(assuming brought in wiring structure leading to short
unloading the battery modules at site
from overseas) circuit
- Transportation insurance
- Damage to the exterior of the
battery module
Loss of containment of
electrolyte from - Site containment measures, such as bunding
Vanadium Redox Flow - Discharge of potentially toxic to AS1940 or equivalent, implemented to Applicable to VRF BESS facilities.
grid-scale BESS facility and corrosive electrolyte into prevent spread
as a result of: the environment - PPE when working in vicinity of cells Long duration flow batteries will require
- leaks from associated - Exposure to toxic/corrosive - Site specific emergency response and storage of large volumes of chemicals that
39 Effluent Vanadium electrolyte
infrastructure (e.g., electrolyte impacting management plan will likely trigger screening thresholds for
piping) - Onsite personnel - Qualified personnel conducting maintenance hazards analysis and require consideration
- failure of the electrolyte - Nearby residents - Monitoring of tank levels, pressure and other for handling and storage of corrosive
tanks criteria to either directly or indirectly indicate loss materials
- during maintenance of electrolyte
activities
- Environmental impact - Dangerous goods legislation Applicable to VRF BESS facilities.

Internal fire Production and
- Exposure to onsite personnel - MSDS
40 Environmental accumulation of toxic
and potentially offsite - Toxicity and handling requirements Dependent on electrolyte composition and
External fire and/or flammable gases
population - Thermal monitoring associated physical/chemical properties
Exceeding environmental
- Exposure to onsite and offsite
EMI International Reference:
population with the potential for - Metal shielding of the modules
41 Equipment EMF Commission on Non- https://www.icnirp.org/cms/upload/publicati
significant absorption greater - Distribution and low intensity of the modules
Ionising Radiation ons/ICNIRPemfgdl.pdf
than 100kHz
Protection (ICNIRP)

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Battery Energy

S4 0 R. Deo James M. Erskine 24/03/23

GHD Pty Ltd | ABN 39 008 488 373

The Power of Commitment

1.2 Purpose of this guidance material

Table 1 Stakeholders interviewed for development of guidance material

Stakeholder Stakeholder Type Role / Team

3.1 A brief summary of the evolution of battery

Table 2 Battery chemistry overview

Battery chemistry Advantages Disadvantages and hazards

Sodium ion battery

3.2 Grid-scale thermal runaway events

3.2.2 Past grid-scale BESS thermal runaway events

Table 3 Overview of recent BESS fire events

Date Event Facility Location Comments

McMicken BESS incident

Victoria Big Battery incident

Figure 4 Victoria Big Battery fire incident [47]

Moss Landing incidents

3.4 Environmental considerations and implications

3.4.2 Environmental impact during and following a fire event

3.4.3 Environmental impact due to loss of containment event

3.4.4 Environmental impact during decommissioning

3.5 Other areas of consideration

3.5.1 Deliberate acts of physical damage

3.5.2 Cyber vulnerability

3.5.3 Land value impacts

Figure 6 High level list of global standards used for BESS

Table 4 Summary of reference documentation

Title Key observations

3.6.1 Case Study: Gaps identified in reference material following the

4.2 Stakeholder interview summary

5.2 Grid-scale BESS facility guidance

5.2.1 Key guidance steps

Table 5 Modelling conditions used for Figure 8 and Figure 9

Modelling conditions Figure 8 Figure 9

Assessment Type Comments

• Identify additional control measures.

• Implement selected risk controls – SFAIRP achieved.

Monitor / verify / validate the performance Is SFAIRP

Risk minimisation SFARP achieved and sustained (SMS, EP)

Define scope/battery limits of study

Select Hazard Category

Identify Hazard and Cause

Identify consequence, maximum consequence category, and existing controls

Identify initial consequence, likelihood, and risk ranking

Propose recommendations or potential controls to address shortfalls

Identify residual consequence, likelihood, and risk ranking

Figure 11 Flowchart for HAZID study

Area Hydrocarbon storage Lithium battery unit Vanadium battery flow

6.1.1 Key considerations moving forward

C-2-1 NFPA 855

C-2-2 CFA renewable energy facility design guidelines

Hazard Identification (HAZID) Register

Project: Project No.: Vanadium redox flow battery related risks

- Damage to BESS - Designed to Industry Acts and Standards

- Include remotely accessible flammable gas monitoring to detect

- Vegetation Management / clearance around

-Non-combustible elements used for

12591546-REG-BESS Guidance Register.xlsm Page 1 of 6 Print Date: 3/24/2023