MOD 2 - Battery Storage Facility

Roads and Maritime Services has reviewed the documentation supporting the
proposed modification for the placement of a battery storage system on
the site of the proposed solar farm. It is noted that the battery
storage system is to be located within the northern part of the solar
farm site and that the additional traffic generation is not
significant when compared to the approved daily volumes limitations as
per the current consent.

The proposed transportation and construction of the battery storage
system will need to be addressed as part of the required TMP for the
construction of the overall facility.

Based on the documentation provided Roads and Maritime Services
advises that it would have no objection to the proposed modification

Further to your email dated 6 March 2019 seeking OEH comments on the
modification to Condition 1 of SSD 8113 for the Hay Solar Project, we
provide the following:

The modification seeks approval to install a battery storage system on
the eastern side of the approved site sub-station. The proposed
battery system will cover an area of approximately 30,000m2 and is to
be located within the approved development footprint and outside
identified areas of native vegetation and cultural heritage
sensitivity within the site.

Given this, OEH has no issue with the proposed modification.

We note that if the modification is approved, the development would
continue to be subject to conditions 12 and 18 of the original
approval. These relate to site management plans for biodiversity and
Aboriginal cultural heritage.

In regards to your email correspondence dated the 6th of March 2019, Fire
& Rescue NSW confirms receipt of the request for agency input for Hay
Solar Farm (SSD 8113 Mod 2) Exhibition of Modification Application.

It is FRNSW experience that small and large scale photovoltaic
installations present unique electrical hazard risks to our personnel
when fulfilling their emergency first responder role. Due to the
electrical hazards associated with large scale photovoltaic
installations and the potential risk to the health and safety of
firefighters, both FRNSW and the NSW Rural Fire Service must be able
to implement effective and appropriate risk control measures when
managing an emergency incident at the proposed site.

Due to the emerging hazards and risks associated with battery storage
facilities, FRNSW recommends the following:

1. That a comprehensive ERP is developed for the site.

2. That the ERP specifically addresses foreseeable on-site and
off-site fire events and other emergency incidents (e.g. fires
involving solar panel arrays, bushfires in the immediate vicinity) or
potential hazmat incidents.

3. That the ERP detail the appropriate hazard control measures that
would need to be implemented to safely mitigate potential risks to the
health and safety of firefighters and other first responders
(including electrical hazards). Such measures would include the level
of personal protective clothing required to be worn, the minimum level
of respiratory protection required, decontamination procedures,
minimum evacuation zone distances and a safe method of shutting down
and isolating the photovoltaic and battery storage systems (either
totally or partially, as determined by risk assessment).

4. Other risk control measures that may need to be implemented in a
fire emergency (due to any unique hazards specific to the site) should
also be included in the ERP.

5. That two copies of the ERP (detailed in recommendation 1 above) be
stored in a prominent `Emergency Information Cabinet' located in a
position directly adjacent to the site's main entry point/s.

6. Once constructed and prior to operation, that the operator of the
facility contacts the relevant local emergency management committee
(LEMC). The LEMC is a committee established by Section 28 of the State
Emergency and Rescue Management Act 1989. LEMCs are required to be
established so that emergency services organisations and other
government agencies can proactively develop comprehensive inter agency
local emergency procedures for significant hazardous sites within
their local government area. The contact details of members of the
LEMC can be obtained from the relevant local council.

7. To ensure that the facility's existing and proposed fire
prevention, detection, protection and firefighting measures are
appropriate to the specific fire hazards and adequate to meet the
extent of potential fires, a comprehensive fire safety study (FSS) is
recommended to be undertaken.

8. That the FSS is developed in accordance with the requirements of
Hazardous Industry Planning Advisory Paper No.2 (HIPAP No.2).

9. That the FSS is required to be approved by FRNSW. We request FRNSW
approval of the FSS is a condition of consent.

10. That the development of the FSS considers the limited operational
capability of local fire agencies and the need for the facility to
achieve an adequate level of on-site fire and life safety
independence.

11. To achieve a satisfactory level of fire safety, it is our
recommendation that the FSS is developed in close consultation with
FRNSW.

If you have any further queries regarding this matter, please contact
the Fire Safety Branch on 9742 7434 quoting your reference number.

Please see attached submission

Advice attached.