As discussed during the consultation display in Sellindge, my primary concern relates to “worst-case” containment in the event of a thermal runaway. To that end, I would appreciate clarification on the following points:
- Battery Pod Separation – What will be the distance between each individual battery pod?
Individual separation distances will meet the July 2024 revision of the draft guidance currently under consultation by the National Fire Chiefs Council (NFCC) https://nfcc.org.uk/consultation/draft-grid-scale-energy-storage-system-planning-guidance/ Additionally the battery container system selected for the project will meet all certification requirements for safe operation within the UK. Whereby the technology to be used has, incorporated energy storage system safety and certification methods and accepted industry wide standards when exploring safe distances between containers. Other fire protection measures, include:- 24/7 remote monitoring of temperature, pressure, gas, noise, and other indicators
- Automatic shutdown systems to prevent faults from escalating
- Built-in fire suppression systems within each battery unit
- Emergency Management Plans and on-site inspections to ensure safe operation
- On-Site Water Storage – How many litres of water will be stored in on-site tanks for emergency use in the event of a thermal runaway?
A minimum of 228,000 litres of water will be stored on site, meeting the requirements of the NFCC guidance. - Contingency Measures – Once the on-site water supply is depleted, what is the secondary or “Plan B” response?
The proposed scheme will meet the NFCC guidance for water storage capacity for use when attending to a thermal event/fire incidences on site. In line with NFCC best practices for fire prevention and emergency response. - Site Construction and Bunding – Will the entire slab on which the battery storage facility is built be bunded to prevent contaminated water from entering the Stour watercourse?
The BESS compound will be constructed to fully comply with all environmental regulations. Although, the entire BESS slab is not bunded, if an emergency incident occurred no water contaminated during an incident would enter the Stour watercourse. A valve on the scheme’s SuDs pond is designed to close in an emergency preventing any water from leaving the site allowing the pond to capture contaminated water. This contaminated water is then tested and safely treated or removed from site, protecting local land, watercourses, and groundwater from pollution or chemical contamination. A Fire Water Management Plan well be included in the planning submission demonstrating how the project ensures environmental protection and effective firefighting, in the unlikely event of a fire related incident. - Screening of the Site – Initial discussions indicated that 3-metre screening would be installed. would you consider a higher screening to provide more effective visual mitigation?
Proposed site would sit well within the existing landform and be integrated further into the fabric of the existing landscape by the use of cut and fill techniques. The site will be fully screened to mitigate any landscape impacts on nearby receptors. - Transport Management – Could we be provided with a copy of the transport plan, including:
- The anticipated number of vehicles passing Holmdene during the construction phase
This information will be included within the Outline Construction Traffic Management Plan that forms part of the planning submission. - The expected duration of these works
A construction period of 12 months in total is anticipated. - Measures that will be implemented to minimise dust and disruption
An Outline Construction Environmental Mitigation Plan, will be included within the planning submission, identifying and setting out necessary mitigation measures to reduce or prevent potential effects upon the environment and nearby sensitive receptors during the construction phase of the development.
- The anticipated number of vehicles passing Holmdene during the construction phase
- Noise Levels – Please confirm the decibel (dB) sound report for the site, particularly in relation to Holmdene, taking into account existing motorway traffic from the M20.
The proposed development has been assessed against the requirements of BS4142 in accordance with the Noise Policy Statement for England and National Planning Policy Framework. The results of this will be included in the Noise Impact Assessment included within the planning submission pack. - Sustainability and End-of-Life Management – Given my professional background in hazardous waste classification, assessment, and regulation (mainly to the UK Government) as well as my involvement in the waste management sector, I would like to understand what sustainability measures are planned for the ongoing operation of the facility, including the end-of-life management and disposal or recycling proposals for the batteries.
The proposed development will comply with all environmental and sustainability regulations during its lifetime. When BESS containers finally reach their end of life, they will be disposed of by the manufacturer, adhering to the Waste Batteries and Accumulators Regulations 2009 (“the Regulations”), for the recycling of Industrial Batteries in the United Kingdom. Essentially, this means that the producer is required to ‘take back’ the batteries for recycling of the raw materials, ensuring safe disposal preventing batteries and accumulators from being incinerated or dumped in landfill sites. This recycling will be performed off-site at appropriately licensed premises.
Will the access road from Kennett Lane have gates to prevent our “traveller “friends from driving down and pitching up tent …?
Yes, there will be gates at Kennett Lane controlling egress of the internal access track to the BESS compound.