Preliminary Hazard Analysis

West Mokoan Solar Farm

892 Yarrawonga Development Pty Ltd (South Energy)

Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
Preliminary Hazard Analysis
West Mokoan Solar Farm
892 Yarrawonga Development Pty Ltd (South Energy)

Prepared by
Riskcon Engineering Pty Ltd
Unit 618 / 159 Ross Street
Forest Lodge, NSW, 2037
www.riskcon-eng.com
ABN 74 626 753 820

© Riskcon Engineering Pty Ltd. All rights reserved.

This report has been prepared in accordance with the scope of services described in the contract or agreement between Riskcon Engineering Pty Ltd and
the Client. The report relies upon data, surveys, measurements and results taken at or under the particular times and conditions specified herein. Changes
to circumstances or facts after certain information or material has been submitted may impact on the accuracy, completeness or currency of the information
or material. This report has been prepared solely for use by the Client. Riskcon Engineering Pty Ltd accepts no responsibility for its use by other parties
without the specific authorization of Riskcon Engineering Pty Ltd. Riskcon Engineering Pty Ltd reserves the right to alter, amend, discontinue, vary or
otherwise change any information, material or service at any time without subsequent notification. All access to, or use of, the information or material is at
the user's risk and Riskcon Engineering Pty Ltd accepts no responsibility for the results of any actions taken on the basis of information or material provided,
nor for its accuracy, completeness or currency.

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Quality Management

Rev Date Remarks Prepared By Reviewed By

A 21 April 2021 Draft issue for comment

0 30 April 2021 Issued Final Renton Parker Steve Sylvester

1 15 June 2021 Updated drawings

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Executive Summary
Background
892 Yarrawonga Development Pty Ltd (South Energy) is proposing to develop the West Mokoan
Solar PV and Battery Energy Storage System (BESS) project at Benalla-Yarrawonga Road,
Benalla (the project). The objective of the project is to provide support to the existing
National Electricity Network by generating energy in the 223.7 MW plant and providing temporary
storage until it is needed and stabilising rapid fluctuations events. The project will comprise up to
223.7 MW of installed Photovoltaic (PV) panels along with an approximately 20 MW of battery
storage along with associated infrastructure (i.e., substations, transformers, etc.).
South Energy has engaged Riskcon Engineering Pty Ltd (Riskcon) to prepare this PHA for the
project in addition to a review of the Fire Protection Quantity (FPQ) requirements as required by
the Victorian Dangerous Goods Regulation (VDGR) 2012 (Ref. [1][1]).

Conclusions
A hazard identification table was developed for the West Mokoan Solar Farm PV & BESS project
to identify potential hazards that may be present at the site as a result of operations or storage of
materials. Based on the identified hazards, scenarios were postulated that may result in an incident
with a potential for offsite impacts. Postulated scenarios were discussed qualitatively and any
scenarios that would not impact offsite were eliminated from further assessment. Scenarios not
eliminated were then carried forward for consequence analysis.
Incidents carried forward for consequence analysis were assessed in detail to estimate the impact
distances. Impact distances were developed into scenario contours and overlaid onto the site
layout diagram to determine if an offsite impact would occur. The consequence analysis showed
that no scenarios would have the potential to impact off site; hence, no incidents were carried
forward for detailed frequency analysis.
Notwithstanding this, a frequency assessment was prepared to highlight that the risk at the site
boundary would be zero (0) as the consequence contours would not impact over the site boundary.
As the risk was calculated to be zero (0) it would be below the acceptable criteria and would be
considered a permissible development.
In addition, incidents exceeding 23 kW/m2 were reviewed which indicated that the contours from
such incidents would not impact over the site boundary and therefore incident propagation would
not be expected to occur and would be below the acceptable criteria.
Based on the analysis conducted, it is concluded that the risks at the site boundary are not
considered to exceed the acceptable risk criteria; hence, the project would only be classified as
potentially hazardous and would be permitted within the current land zoning for the site.

Recommendations
Notwithstanding the conclusions drawn, the following recommendations have been made and
should be undertaken to cover the battery and inverter equipment as well as common hazards for
a mechanical site prior to the commencement of operations at the Solar PV and BESS project to
the extent dangerous goods exceed any thresholds:
• A submission to FRV shall be made for written advice in accordance with the VDGR.
• A Dangerous Goods (DG) risk assessment shall be prepared for the site.

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• A DG register shall be prepared for the site.
• A site manifest shall be prepared at the site in accordance with Schedule 3 of the Victorian
Dangerous Goods Regulation (VDGR).
• The site shall notify the Regulator (i.e. WorkSafe Victoria) of the presence of DGs.
• A site layout shall be prepared for the site in accordance with Schedule 3 of the VDGR.
• A placard schedule shall be prepared for the site to ensure the correct placards are installed.
• An Emergency Response Plan (ERP) shall be prepared for the site and submitted to the Fire &
Rescue Victoria (FRV).
• An Emergency Services Information Booklet (ESIB) shall be prepared for the site and submitted
to the FRV.
• The transformers shall be designed according to the requirements detailed in AS 1940-2017
“The storage and handling of flammable and combustible liquids” to minimise the potential for
fire or explosion to occur within the transformers.

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Table of Contents

Executive Summary i

1.0 Introduction 1
1.1 Background 1
1.2 Objectives 1
1.3 Scope of Services 1

2.0 Methodology 2
2.1 Multi-Level Risk Assessment 2
2.2 Risk Assessment Study Approach 3

3.0 Site Description 4

3.1 Site Location 4
3.2 Adjacent Land Uses 4
3.3 Sensitive Receptors 5
3.4 Detailed Description 6
3.4.1 PCUs 6
3.4.2 Battery Storage 8
3.5 Quantities of Dangerous Goods Stored and Handled 9

4.0 Fire Protection Quantity Assessment 10

4.1 Introduction 10
4.2 Assessment 10
4.3 Implications 10
4.3.1 Risk Assessment 11
4.3.2 Register 11
4.3.3 Manifest 11
4.3.4 Notification to the Regulator 12
4.3.5 Emergency Response Plan 12
4.3.6 Emergency Services Information Booklet 12
4.3.7 Placard Schedule 12
4.3.8 Site Layout 12
4.3.9 General 12

5.0 Hazard Identification 13

5.1 Introduction 13
5.2 Properties of Dangerous Goods 14
5.3 Hazard Identification 14
5.4 Li-Ion Battery Fault, Thermal Runaway and Fire 15
5.5 Electrical Equipment Failure and Fire 16
5.6 Transformer Internal Arcing, Oil Spill, Ignition and Bund Fire 16
5.7 Refrigerant Gas Release and Asphyxiation Hazard 17
5.8 Release of Diesel, Ignition and Pool Fire 18

6.0 Consequence Analysis 19

6.1 Incidents Carried Forward for Consequence Analysis 19
6.2 Li-Ion Battery Fault, Thermal Runaway and Fire 19
6.3 Transformer Internal Arcing, Oil Spill, Ignition and Bund Fire 20

7.0 Frequency Analysis 22

7.1 Incidents Carried Forward for Frequency Analysis 22
7.2 Total Fatality Risk 22
7.3 Comparison Against Risk Criteria 22
7.4 Incident Propagation 22

8.0 Conclusion and Recommendations 23

8.1 Conclusions 23

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8.2 Recommendations 23

9.0 References 25
Hazard Identification Table 26
A1. Hazard Identification Table 27
Consequence Analysis 29
B1. Incidents Assessed in Detailed Consequence Analysis 30
B2. Spreadsheet Calculator (SSC) 30
B3. Radiant Heat Physical Impacts 33
B4. Li-Ion Battery Fault, Thermal Runaway and Fire 34
B5. Transformer Internal Arcing, Oil Spill, Ignition and Bund Fire 34
Site Layout 36

List of Figures
Figure 2-1: The Multi-Level Risk Assessment Approach 2
Figure 3-1: Site Location 4
Figure 3-2: Surrounding Land Uses 5
Figure 3-3: Sensitive Receptors 6
Figure 3-4: Typical Single Inverter 7

Figure 3-5: Typical Double Inverter 8

Figure 3-6: Typical BESS 8
Figure 5-1: Cathode and Anode of a Battery (Source Research Gate) 15
Figure 5-2: Refrigeration Flow Diagram 17
Figure 6-1: Li-Ion Battery Module Fire Radiant Heat Contours 20

Figure 6-2: Transformer Bund Fire Radiant Heat Contours 21

List of Tables
Table 2-1: Level of Assessment PHA 2
Table 3-1: Maximum Classes and Quantities of Dangerous Goods Stored 9
Table 4-1: Fire Protection Quantity Assessment 10

Table 5-1: Properties* of the Dangerous Goods and Materials Stored at the Site 14
Table 6-1: Radiant Heat from a Li-Ion Battery Fire 19
Table 6-2: Radiant Heat from a Transformer Bund Fire 20
Table 7-1: Total Fatality Risk 22

List of Appendix Figures

Appendix Figure B-1: Heat Radiation on a Target from a Cylindrical Flame 30

List of Appendix Tables

Appendix Table B-1: Heat Radiation and Associated Physical Impacts 33
Appendix Table B-2: Heat Radiation Impacts from a Li-Ion Battery Fire 34
Appendix Table B-3: Heat Radiation Impacts from a Transformer Bund Fire 35

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Abbreviations
Abbreviation Description

ADG Australian Dangerous Goods Code

AS Australian Standard

CBD Central Business District

DGs Dangerous Goods

ERP Emergency Response Plan

ESIB Emergency Services Information Booklet

FCAS Frequency Control Ancillary Services

FPQ Fire Protection Quantity

FRV Fire & Rescue Victoria

HIPAP Hazardous Industry Planning Advisory Paper

O&M Operations & Maintenance

PHA Preliminary Hazard Analysis

Pmpy Per million per year

PV Photovoltaic

SEP Surface Emissive Power

SEPP State Environmental Planning Policy

SSC Spread Sheet Calculator

VDGR Victorian Dangerous Goods Regulation

VF View Factor

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1.0 Introduction
1.1 Background
892 Yarrawonga Development Pty Ltd (South Energy) is proposing to develop the West Mokoan
Solar PV and Battery Energy Storage System (BESS) project at Benalla-Yarrawonga Road,
Benalla (the project). The objective of the project is to provide support to the existing National
Electricity Network by generating energy in the 233.74 MW plant and providing temporary storage
until it is needed and stabilising rapid fluctuations events. The project will comprise up to 233.74
MW of installed Photovoltaic (PV) panels along with an approximately 20 MW of battery storage
along with associated infrastructure (i.e., substations, transformers, etc.).
South Energy has engaged Riskcon Engineering Pty Ltd (Riskcon) to prepare this PHA for the
project in addition to a review of the Fire Protection Quantity (FPQ) requirements as required by
the Victorian Dangerous Goods Regulation (VDGR) 2012 (Ref. [1]).

1.2 Objectives
The key objectives of this PHA are to:
• Complete the PHA according to the Hazardous Industry Planning Advisory Paper (HIPAP) No.
6 – Hazard Analysis (Ref. [2]);
• Assess the PHA results using the criteria in HIPAP No. 4 – Risk Criteria for Land Use Planning
(Ref. [3]); and
• Demonstrate compliance of the site with the relevant codes, standards and regulations (i.e.
Planning and Environment Regulation, OHS Regulation, 2017 Ref. [4]).
• Conduct a review of the Fire Protection Quantity (FPQ) under the Victorian Dangerous Goods
(Storage and Handling) Regulations 2012 (VDGR, Ref. [1]).

1.3 Scope of Services

The scope of work is to complete a PHA study for the West Mokoan Solar PV and BESS project
located at Benalla-Yarrawonga Road, Benalla to assist in evaluating possible dangerous goods
and demonstrating the project is safe to operate and compliant with the relevant codes, standards,
and regulations. The PHA study aims to support planning permit application PA2000978 and the
potential requirement for the application to be referred to WorkSafe in accordance with Clause
66.02 of the Benalla Planning Scheme. The scope does not include any other assessments which
may be required as a result of this study nor any other South Energy facilities

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2.0 Methodology
2.1 Multi-Level Risk Assessment
The Multi-Level Risk Assessment approach (Ref. [5]), although published by the NSW Department
of Planning, Industry and Environment, has been used as the basis for the study to determine the
level of risk assessment required. The selection of this framework is due to the absence of a
suitable Victorian guideline or policy. The approach considered the development in context of its
location, the quantity and type (i.e. hazardous nature) of Dangerous Goods stored and used, and
the project’s technical and safety management control. The Multi-Level Risk Assessment
Guidelines are intended to assist industry, consultants and the consent authorities to carry out and
evaluate risk assessments at an appropriate level for the project being studied.
There are three levels of risk assessment set out in Multi-Level Risk Assessment which may be
appropriate for a PHA, as detailed in Table 2-1.
Table 2-1: Level of Assessment PHA
Level Type of Analysis Appropriate If:

1 Qualitative No major off-site consequences and societal risk is negligible

2 Partially Quantitative Off-site consequences but with low frequency of occurrence

3 Quantitative Where 1 and 2 are exceeded

The Multi-Level Risk Assessment approach is schematically presented in Figure 2-1.

Preliminary Screening
(Qualitative Assessment)

Risk Classification and

Prioritisation

Not potentially
Hazardous –
No Further
Analysis
Qualitative Partial Quantitative Risk
Analysis (Level 1) Quantitative Analysis (Level 3)
Analysis (Level 2)

Figure 2-1: The Multi-Level Risk Assessment Approach

Based on the type of DGs to be used and handled at the proposed project, a Level 2 Assessment
was selected for the Site. This approach provides a qualitative assessment of those DGs of lesser
quantities and hazard, and a quantitative approach for the more hazardous materials to be used
on-site. This approach is commensurate with the methodologies recommended in “Applying SEPP
33’s” Multi Level Risk Assessment approach (DPIE, 2011). The selection of this framework is due
to the absence of a suitable Victorian guideline or policy.

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2.2 Risk Assessment Study Approach
The methodology used for the PHA is as follows;
Hazard Analysis – A detailed hazard identification was conducted for the site facilities and
operations. Where an incident was identified to have a potential off-site impact, it was included in
the recorded hazard identification word diagram (Appendix A). The hazard identification word
diagram lists incident type, causes, consequences and safeguards. This was performed using the
word diagram format recommended in HIPAP No. 6 (Ref. [2]).
Each postulated hazardous incident was assessed qualitatively in light of proposed safeguards
(technical and management controls). Where a potential offsite impact was identified, the incident
was carried into the main report for further analysis. Where the qualitative review in the main report
determined that the safeguards were adequate to control the hazard, or that the consequence
would obviously have no offsite impact, no further analysis was performed. Section 3.1 of this
report provides details of values used to assist in selecting incidents required to be carried forward
for further analysis.
Consequence Analysis – For those incidents qualitatively identified in the hazard analysis to have
a potential offsite impact, a detailed consequence analysis was conducted. The analysis modelled
the various postulated hazardous incidents and determined impact distances from the incident
source. The results were compared to the consequence criteria listed in HIPAP No. 4 (Ref. [3]).
The criteria selected for screening incidents is discussed in Section 3.1.
Where an incident was identified to result in an offsite impact, it was carried forward for frequency
analysis. Where an incident was identified to not have an offsite impact, and a simple solution was
evident (i.e. move the proposed equipment further away from the boundary), the solution was
recommended, and no further analysis was performed.
Frequency Analysis – In the event a simple solution for managing consequence impacts was not
evident, each incident identified to have potential offsite impact was subjected to a frequency
analysis. The analysis considered the initiating event and probability of failure of the safeguards
(both hardware and software). The results of the frequency analysis were then carried forward to
the risk assessment and reduction stage for combination with the consequence analysis results.
Risk Assessment and Reduction – Where incidents were identified to impact offsite and where
a consequence and frequency analysis was conducted, the consequence and frequency analysis
for each incident were combined to determine the risk and then compared to the risk criteria
published in HIPAP No. 4 (Ref. [3]). Where the criteria were exceeded, a review of the major risk
contributors was performed, and the risks reassessed incorporating the recommended risk
reduction measures. Recommendations were then made regarding risk reduction measures.
Reporting – On completion of the study, a draft report was developed for review and comment by
South Energy. A final report was then developed, incorporating the comments received by South
Energy for submission to the regulatory authority.

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3.0 Site Description
3.1 Site Location
The site is located at Benalla-Yarrawonga Road, Benalla which is approximately 230 km north of
the Melbourne Central Business District (CBD). Figure 3-1 shows the regional location of the site
in relation to the Melbourne CBD.

Site

Figure 3-1: Site Location

3.2 Adjacent Land Uses

The land is located in an regional / rural area surrounded by the following land uses, which are
adjacent to the site as shown in Figure 3-2 are:
• North – Farmland (rural)
• South – Special use / farmland (rural)
• East – Public use
• West – Defence munitions site (Thales).

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Figure 3-2: Surrounding Land Uses

3.3 Sensitive Receptors

The nearest residential locations are as follows and shown in Figure 3-3:
• 18 Farnley Road, the north of the site, approximately 700 metres from the site boundary.
• 81 Lake Mokoan Road, to the north of the site, approximately 150 metres from the site boundary
• 286 Farnley Road, to the north of the site, approximately 350 metres from the site boundary.
• 623 Benalla-Yarrawonga Road, to the west of the site, approximately 70 metres from the site
boundary.
• 524 Benalla-Yarrawonga Road, to the south of the site, approximately 150 metres from the site
boundary.

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Figure 3-3: Sensitive Receptors

3.4 Detailed Description

The purpose of the project is to provide energy to and support to the National Electricity Network
by generating electricity from the 233.74 MW installed capacity of PV panels and the 20 MW BESS
to arbitrage electricity demand fluctuations by storing electricity during off peak periods or when
there is surplus supply and discharging the stored electricity when demand is highest (i.e. generator
trips / shutdowns) or in peak periods. This is achievable due to the high response times achieved
through lithium-ion battery storage which can fill peak demands due to the quick dispatchability of
battery storage. The project will have capacity to store up to 20 megawatts (MW) of energy and
conceptually comprises the following key components:
• Approximately 531,216 solar PV panels on a single-axis tracking system mounted on aluminium
or steel piles with an installed capacity of up to 192 MW Alternating Current (AC) (234 DC
Capacity).
• Approximately 57 Power Conversion Units (PCU – Inverter buildings with hard standings).
• Direct Current (DC) and AC cabling for electrical reticulation.
• A designated substation and Operations and Maintenance (O&M) facility area that includes a
substation, a Battery Storage Facility/Energy Storage System (ESS) of up to 20MW / 20MWh
capacity, a control building, substation transformers, office and amenities.
• Internal all-weather access tracks and a laydown area.
• Creation of a new access to Benalla-Yarrawonga Road and Lake Mokoan Road.
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• Landscaping and revegetation.
• Removal of 1.891 hectares of native vegetation.
• Security fencing, CCTV and Infra-Red lighting.
• Business identification signage including three signs totalling 3 sqm in display area (1 sqm
each) located at site entrances along Benalla-Yarrawonga Road and Lake Mokoan Road.
• Realignment of easements.

3.4.1 PCUs
Power Conversion Units, or PCUs, house transformers and inverters which will be sited between
the PV Module Arrays, along the solar farm’s internal access tracks. There will be approximately
57 PCUs across the site (12 single inverters and 45 double inverters). The PCUs convert the Direct
Current (DC) to Alternating Current (AC), while the transformers increase the voltage from Low
Voltage to a Medium or High Voltage, as required for the electricity grid connection. PCUs are a
compact, containerised product, with each unit measuring approximately 2.5 metres wide by 2.9
metres high, with a depth of 12.2 metres (equivalent to a 40 foot shipping container for the double
inverter units). Due to potential flooding over parts of the subject site, some of the PCUs will be
elevated 300 mm above the applicable flood level in accordance with GBCMA requirements (refer
to Section 7.2). The exact height of these PCUs will be subject to detailed design. The location of
the PCUs are identified in Appendix C. Figure 3-4 and Figure 3-5 provide examples of typical
PCUs.

Figure 3-4: Typical Single Inverter

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Figure 3-5: Typical Double Inverter

3.4.2 Battery Storage

The proposed BESS will be located within a secure compound within the Project’s utility zone
(adjacent to the substation and O&M facility area). The BESS will enable the solar farm to be a
flexible energy generation source, providing energy when it is required the most. The BESS
converts energy into electrical energy and stores the energy internally. It may also contribute
towards network security Frequency Control Ancillary Services (FCAS) in the Region. A typical
BESS is shown in Figure 3-6 and layout for the BESS are contained in the layout shown in
Appendix C.

Figure 3-6: Typical BESS

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3.5 Quantities of Dangerous Goods Stored and Handled
The DGs stored at the site are for various customers and may fluctuate with customer
requirements. The classes and quantities to be approved in the project are summarised Table 3-1.
The locations of the BESS and transformers are indicated on the drawing provided in Appendix
C.
Table 3-1: Maximum Classes and Quantities of Dangerous Goods Stored
Class Description Quantity

2.2 R-134a* / R-410a* 1,000 L*

9 Lithium Batteries 900 T

C1 Transformer oils 212,000 L

C1 Diesel 5,000 L

*Estimated commodity and quantity based upon similar project.

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4.0 Fire Protection Quantity Assessment
4.1 Introduction
The Victorian Dangerous Goods (Storage and Handling) Regulations (VDGR, Ref. [1]) covers the
storage and handling of materials classified as Dangerous Goods (DGs). This Regulation provides
an assessment of the required documentation to be prepared for a site based upon a threshold
based approach for each class of DG stored at a site. As shown in Section 3.5 a range of products
will be stored as part of site operations which are classified as DGs; hence, the site is subject to
the VDGR. The main purpose of the assessment is to determine whether additional overview is
required from a regulatory perspective in terms of WorkSafe Victoria and Fire & Rescue Victoria
(FRV) involvement. This is determined by the threshold “Fire Protection Quantity” (FPQ) within the
VDGR. Provided in the following section is an assessment of the FPQ and the associated
implications for the site approval process.

4.2 Assessment
As noted, the assessment is based upon thresholds provided in the VDGR. The applicable
thresholds for the site have been extracted from the Regulation to assess where the site will sit
within the regulatory framework for DGs. The results of the assessment are shown in Table 4-1.
Table 4-1: Fire Protection Quantity Assessment
Class Description Quantity Placard Manifest FPQ Determination

2.2 R-134a / R-410a 1,000 L 5,000 L 10,000 L 20,000 L n/a

9 Lithium Batteries 900 T 5T 10 T 20 T FPQ

C1 Transformer oils 212,000 L 10,000 L 100,000 L 100,000 L FPQ

C1 Diesel 5,000 L 10,000 L 100,000 L 100,000 L n/a

Based upon a review of Table 4-1 the site would be classified as a FPQ site.

4.3 Implications
The assessment determined that the site would be classified as a FPQ site which requires referral
to FRV. Typically, this would require a design assessment of the project to demonstrate compliance
with an applicable DG design standard. However, the site is being triggered by the batteries which
are classified as a Class 9 DG which technically only exists during transport and not storage.
Nonetheless, the VDGR include this as an assessable quantity; hence, a submission to the FRV
for written advice is required under the Regulation.
The design standard for Class 9 batteries, AS/NZS 4681:2000 (Ref. [6] is extremely dated and only
covers DGs stored in buildings as the risks for external storage are relatively minor. Furthermore,
the standard was based upon battery designs from 2000 which did not include the protection
incorporated in modern batteries (i.e. temperature and voltage monitoring, cooling, etc.) and were
based upon chemistries more likely to result in thermal decomposition (i.e. lithium metal).
Therefore, there is no real design guidance available for such battery installation (i.e. West Mokoan
BESS) from a DG perspective.
The risks are mitigated via the design of the battery modules themselves and the availability of fire
protection at the site. As per the Guidelines for Renewable Energy Installation published by Country
Fire Brigade (CFA) in 2019, the project is also expected to have some abilities (e.g. presence of
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hydrants, water tanks) to fight a fire at the site should one occur. Discussion with FRV based upon
the remoteness of the project site (i.e. if a site is not within the immediate turnout area of a fire
station) is recommended prior to construction.
Additional implications include those relating to the documentation which is required to be prepared
by the VDGR. Documentation required for a site exceeding manifest levels is as follows:
• Risk assessment
• Register
• Manifest
• Notification to the Regulator
• Emergency Response Plan
• Emergency Services Information Booklet
• Placard schedule
• Site layout
Each of these items have been discussed further in the following subsections in terms of what they
entail and whether they will be submitted to a Regulator (i.e. WorkSafe Victoria) for approval prior
to occupation of the site for the proposed use.

4.3.1 Risk Assessment

A risk assessment is required by Clause 27 of the VDGR which requires the risks associated with
an activity or storage to be controlled. The DG risk assessment is the documentation prepared to
demonstrate the risks have been assessed with the required controls incorporated into the site
design / operation to an acceptable level as required by the Regulation. This document is not
submitted to a Regulator, however it is a requirement of the operator to demonstrate they have
fulfilled their obligations under the VDGR. This document is likely to only be reviewed by a
Regulator if they attend the site as part of an inspection or due to an incident at the site requiring
their involvement.

4.3.2 Register
A register is required under Clause 60 of the VDGR and is a summary of the DGs stored on site
along with the Safety Data Sheets (SDS) for the products stored. The register also links into the
findings of the risk assessment closing the loop from the summary document to the risk
assessment. The register is not submitted to a Regulator for review but is required to fulfil the
operators’ obligations under the VDGR.

4.3.3 Manifest
The manifest is required under Clause 45 of the VDGR. The document is another summary
document which is submitted along with the notification to the Regulator. The purpose of the
manifest is to provide information about the types and quantities of DG stored to FRV should an
incident occur at the site.
While the document is submitted to the Regulator it is typically for information purposes and does
not require approval by them.

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4.3.4 Notification to the Regulator
The notification is required by Clause 66 of the VDGR and is the driving link between the manifest
and the Regulator. It is a form which details the specifics of the DG depots at a site and how they
interlink with the manifest. The notification is used to form a database of sites which store DGs
exceeding the manifest level. While the notification is not typically reviewed, the operator will
receive an acknowledgement from the Regulator which they use to demonstrate they have notified
the Regulator as required by the VDGR.

4.3.5 Emergency Response Plan

The Emergency Response Plan (ERP) is required by Clause 55. The purpose is to outline the
potential emergencies (i.e. fire, bush fire, natural disaster, etc.) and the associated mitigation and
response measures. The document is site specific and is submitted to the FRV for review and
approval.

4.3.6 Emergency Services Information Booklet

The Emergency Services Information Booklet (ESIB) is an accompanying document to the ERP
and is essentially a summary document of the ERP. This is submitted to the FRV for review and
approval.

4.3.7 Placard Schedule

The site is required to be placarded under Clause 47 and the placard schedule is a document which
details where the placards are required to achieve compliance with the VDGR. The placard
schedule is not submitted to the Regulator but is used to ensure the correct placards have been
installed.

4.3.8 Site Layout

The site layout is required by Clause 8 of Schedule 3 of the VDGR and accompanies both the
manifest and the notification. The purpose of the layout is to show where the DGs are stored around
the site along with other points of interest to FRV including; power isolation points, valve isolation
points, drains, etc. to assist them in coordinating a response (i.e. isolate power prior to attacking a
fire) or prevent contaminated water from being discharged from the site.

4.3.9 General
The documentation listed above is not required prior to construction but would be required to be in
place 2 weeks prior to occupation.

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5.0 Hazard Identification
5.1 Introduction
A hazard identification table has been developed and is presented at Appendix A. This table has
been developed following the recommended approach in Hazardous Industry Planning Advisory
Paper No .6, Hazard Analysis Guidelines (Ref. [2]). The Hazard Identification Table provides a
summary of the potential hazards, consequences and safeguards at the site. The table has been
used to identify the hazards for further assessment in this section of the study. Each hazard is
identified in detail and no hazards have been eliminated from assessment by qualitative risk
assessment prior to detailed hazard assessment in this section of the study.
In order to determine acceptable impact criteria for incidents that would not be considered for
further analysis, due to limited impact offsite, the following approach has been applied:
• Fire Impacts - It is noted in Hazardous Industry Planning Advisory Paper (HIPAP) No. 4 (Ref.
[3]) that a criterion is provided for the maximum permissible heat radiation at the site boundary
(4.7 kW/m2) above which the risk of injury may occur and therefore the risk must be assessed.
Hence, to assist in screening those incidents that do not pose a significant risk, for this study,
incidents that result in a heat radiation less that at 4.7 kW/m2, at the site boundary, are screened
from further assessment.
Those incidents exceeding 4.7 kW/m2 at the site boundary are carried forward for further
assessment (i.e. frequency and risk). This is a conservative approach, as HIPAP No. 4 (Ref.
[3]) indicates that values of heat radiation of 4.7 kW/m2 should not exceed 50 chances per
million per year at sensitive land uses (e.g. residential). It is noted that the closest residential
area is approximately 70 m from the site, hence, by selecting 4.7 kW/m2 as the consequence
impact criteria (at the adjacent industrial site boundary) the assessment is considered
conservative.
• Explosion - It is noted in HIPAP No. 4 (Ref. [3]) that a criterion is provided for the maximum
permissible explosion over pressure at the site boundary (7 kPa) above which the risk of injury
may occur and therefore the risk must be assessed. Hence, to assist in screening those
incidents that do not pose a significant risk, for this study, incidents that result in an explosion
overpressure less than 7 kPa, at the site boundary, are screened from further assessment.
Those incidents exceeding 7 kPa, at the site boundary, are carried forward for further
assessment (i.e. frequency and risk). Similarly, to the heat radiation impact discussed above,
this is conservative as the 7 kPa value listed in HIPAP No. 4 relates to residential areas, which
are over approximately 70 m from the site.
• Toxicity – Toxic substances have been proposed to be stored at the site; hence, toxicity has
been assessed.
• Property Damage and Accident Propagation - It is noted in HIPAP No. 4 (Ref. [3]) that a criterion
is provided for the maximum permissible heat radiation/explosion overpressure at the site
boundary (23 kW/m2/14 kPa) above which the risk of property damage and accident
propagation to neighbouring sites must be assessed. Hence, to assist in screening those
incidents that do not pose a significant risk to incident propagation, for this study, incidents that
result in a heat radiation heat radiation less than 23 kW/m2 and explosion over pressure less
than 14 kPa, at the site boundary, are screened from further assessment. Those incidents

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 exceeding 23 kW/m2 at the site boundary are carried forward for further assessment with
respect to incident propagation (i.e. frequency and risk).
• Societal Risk – HIPAP No. 4 (Ref. [3]) discusses the application of societal risk to populations
surrounding the proposed project. It is noted that HIPAP No. 4 indicates that where a
development proposal involves a significant intensification of population, in the vicinity of such
a project, the change in societal risk needs to be taken into account. In the case of the project,
there is currently no significant intensification of population around the proposed site; hence,
societal risk has not been considered in this assessment.

5.2 Properties of Dangerous Goods

The type of DGs and quantities stored and used at the site has been described in Section 3. Table
5-1 provides a description of the DGs to be stored and handled at the site, including the Class and
the hazardous material properties of the DG Class.
Table 5-1: Properties* of the Dangerous Goods and Materials Stored at the Site
Class Hazardous Properties

Non-flammable, non-toxic gases are those which do not pose a flammable or

2.2 – Non-
toxicity risk and are therefore relatively benign. However, such gases may pose
Flammable, Non-
asphyxiation risks as they can exclude oxygen at the point of release creating an
Toxic Gas
oxygen deficient environment.

9 – Miscellaneous Class 9 substances and articles (miscellaneous dangerous substances and

DGs articles) are substances and articles which, during transport present a danger not
covered by other classes. Releases to the environment may cause damage to
sensitive receptors within the environment. It is noted that the Class 9s stored
within this project are lithium ion batteries which may undergo thermal runaway (i.e.
escalating reaction resulting in heat which ultimately leads to failure of the battery
and a fire).

Combustible liquids are typically long chain hydrocarbons with flash points
exceeding 60.5oC. Combustible liquids are difficult to ignite as the temperature of
Combustible
the liquid must be heated to above the flash point such that vapours are generated
Liquids
which can then ignite. This process requires either sustained heating or a high-
energy ignition source.

* The Australian Code for the Transport of Dangerous Goods by Road and Rail (Ref. [7]

5.3 Hazard Identification

Based on the hazard identification table presented in Appendix A, the following hazardous
scenarios have been developed:
• Li-ion battery fault, thermal runaway and fire.
• Electrical equipment failure and fire.
• Transformer internal arcing, oil spill, ignition and bund fire.
• Refrigerant gas release and asphyxiation hazard.
• Release of diesel, ignition and pool fire.
Each identified scenario is discussed in further detail in the following sections.

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5.4 Li-Ion Battery Fault, Thermal Runaway and Fire
Lithium ion (Li-ion) batteries are composed of a metallic anode and cathode which allows for
electrons released from the anode to travel to the cathode where positively charged ions in the
solute migrate to the cathode and are reduced. The flow of electrons provides the source of energy
which is discharged from a battery and used for work. In a Li-ion battery, the lithium metal
composites (a composite of lithium with other metals such as cobalt, manganese, nickel, or any
combination of these metals) oxidises (loses an electron) becoming a positively charged ion in
solution which migrates through the battery separator to the cathode. At the same time, the lost
electron travels through the circuit to the cathode. The lithium ions in solution then recombine with
the electron at the cathode forming lithium metal within the cathodic metal composite. This process
is shown in Figure 5-1.

Figure 5-1: Cathode and Anode of a Battery (Source Research Gate)

Initial lithium batteries were designed around lithium metal (i.e. no composite structure) due to the
high energy density yielded by the metal. However, when overcharging a battery, lithium ions can
begin to plate on the anode in the form of lithium dendrites. Eventually, the dendrites pierce the
separator within the battery resulting in a short of the battery which could result in heat, fire, or
explosion of the battery. The technology evolved to move away from lithium metal to lithium ions
(held within composite materials) which reduced the incidence of lithium dendrites forming resulting
in an overall safer battery.
Despite the improvement in battery technology, there are several degradation mechanisms that
are still present within the battery which can result in thermal runaway. These include:
• Chemical reduction of the electrolyte at the anode
• Thermal decomposition of the electrolyte
• Chemical reduction of the electrolyte at the cathode
• Thermal decomposition by the cathode and the anode
• Internal short circuit by charge effects

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These effects arise primarily as a result of high discharge, overcharging, or water ingress into the
battery which results in a host of bi-products being formed within the battery during charge and
discharge cycles.
As a result, lithium ion batteries are equipped with several safety features to prevent the batteries
from charging or discharging at voltages which result in battery degradation which lead to shorting
of the battery and thermal runaway. Safety features generally include:
• Shut-down separator (for overheating)
• Tear-away tab (for internal pressure relief)
• Vent (pressure relief in case of severe outgassing)
• Thermal interrupt (overcurrent/overcharging/environmental exposure)
These features are designed to prevent overcharging or excessive discharge, pressurisation
arising from heat generated at the anode or from battery contamination. Protection techniques for
Li-ion batteries are standard; hence, the potential for thermal runaway to occur in normal operation
is incredibly low with the only exceptions being where batteries are manufactured poorly or due to
manufacturing faults, or battery damage (i.e. battery cell is ruptured as this can short circuit the
battery resulting in thermal runaway).
Given the ubiquitous nature of lithium ion batteries, thermal runaway is not considered a credible
threat when used in a battery storage. In terms of physical damage, the batteries are contained
within in modules which are located within a fenced area; therefore, there is a low potential for
damage to occur to the batteries which may initiate an incident.
Notwithstanding this, there is the potential for thermal runaway to occur which may consume the
whole battery module which may result in offsite impacts or propagation risks to adjacent modules.
Therefore, this incident has been carried forward for further analysis.

5.5 Electrical Equipment Failure and Fire

Electrical equipment is located within the switch room which may fail resulting in overheating,
arcing, etc. which could initiate a fire. In the event of a fire, it may begin to propagate to adjacent
combustible materials (i.e. wiring). It is noted that electrical equipment fires typically start by
smouldering before flame ignition occurs resulting in a slow fire development.
The type of equipment used within the project is ubiquitous throughout the world and across
industry segments and is therefore not a unique fire scenario. Based upon fire development within
switch rooms the fire would be considered to be relatively slow in growth and would be unlikely to
result in substantial impacts in terms of offsite impact or incident propagation. Therefore, this
incident has not been carried forward for further analysis.

5.6 Transformer Internal Arcing, Oil Spill, Ignition and Bund Fire
Transformers contain oil which is used to cool the units during operation. If arcing occurs within the
transformer (e.g. due to a low oil level), the high energy passing through the coolant vaporises the
oil into light hydrocarbons (methane, ethane, acetylene, etc.) resulting in rapid pressurisation within
the reservoir. To minimise the likelihood of such occurrence, transformers are fitted with a low oil
pressure switches and a pressure surge switch (Buckholtz relay). These devices identify potential
oil and pressure events within the transformer, isolating power and alarming operators.

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Notwithstanding the protection systems, if the pressure rise exceeds the structural integrity of the
reservoir, and the installed pressure relief devices, the reservoir can rupture allowing the release
of oil into the bund. The rupture also allows oxygen to enter the reservoir. The temperature of the
gases is above the auto ignition point, but this does not occur until oxygen is present. When oxygen
enters the reservoir, the gases auto ignite which generates sufficient heat to ignite the oil in the
bund.
As there is the potential for a fire to occur within the substation transformers, this incident has been
carried forward for further analysis.
The transformers haven’t been subject to detailed design at this stage; hence, the following
recommendation has been made:
• The transformers shall be designed according to the requirements detailed in AS 1940-2017
“The storage and handling of flammable and combustible liquids” to minimise the potential for
fire or explosion to occur within the transformers.

5.7 Refrigerant Gas Release and Asphyxiation Hazard

The refrigeration system will be used to providing air conditioning and temperature control in the
control room and other areas requiring temperature control. A simplified explanation of how a
refrigeration system operates to cool an area is provided below.
A refrigeration system contains four essential components:
1. Compressor
2. Expansion valve
3. Refrigerant
4. Heat exchanging pipework
Figure 5-2 has been provided to aid in the description of how the refrigeration system operates to
cool a specific area. The refrigeration system cycles the refrigerant gas through the system.

Figure 5-2: Refrigeration Flow Diagram

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1. Refrigerant gas from the evaporator enters the compressor where it is pressurised (red) which
increases the temperature of the gas. The gas travels along the pipework to the condenser.
2. The condenser is coiled to provide a large surface area to allow the hot gas to dissipate heat.
As the gas releases heat through the coils, the gas condenses into a pressurised liquid (dark
blue).
3. The pressurised liquid enters the thermostatic expansion valve where it expands across the
valve seat, resulting in a sudden drop of pressure of the liquid refrigerant and rapid expansion
which cools the liquid (light blue).
4. The cooled refrigerant enters the evaporator which is coiled to provide a large surface area to
facilitate exchange of heat from the area to be cooled into the refrigerant. As the refrigerant
absorbs heat it boils into a gaseous state.
5. On completion of the cycle, the refrigerant is drawn into the compressor and the cycle repeats.
Refrigeration systems are commonly used in all air conditioning systems which are not subject to
frequent releases and if they do occur the leaks are minor resulting in minimal amounts of escaped
gas. Therefore, a rupture release would not be considered to be a credible scenario given the
ubiquitous nature of these systems. In the event a small release occurs it will be dissipated quickly
via wind movement around the refrigeration unit prevent accumulation. Furthermore, such a
release would be insufficient to impact offsite; hence, this incident has not been carried forward for
further analysis.

5.8 Release of Diesel, Ignition and Pool Fire

Diesel will be used on site equipment primarily during construction but may be present during
operations where equipment needs to be moved / relocated / site vehicles. The diesel will likely be
stored in a portable refuelling tank which typically are double skinned (i.e. integrally bunded) tanks
complying with AS 1940-2017 (Ref. [8]). The presence of two tanks (i.e. inner and outer tank)
results in the potential for external leakage to be incredibly low as this requires the failure of both
tanks simultaneously. Therefore, a full release of diesel fuel from the tanks would not be expected
to occur.
Nonetheless, if a substantial release did occur, combustible liquids do not emit flammable vapours
which results in the ignition probability being incredibly. To ignite the spill, a sustained ignition
source with sufficient energy would be required to be exposed to create sufficient heat to vapourise
the liquid to initiate combustion. Should this occur, the fire would grow to the dimensions of the spill
which would be unlikely to be sufficient to result in an offsite impact.
Due to the low likelihood of release, ignition and consequences impacts from a diesel pool fire an
offsite impact is not considered to be a credible scenario; hence, this incident has not been carried
forward for further analysis.

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 6.0 Consequence Analysis
6.1 Incidents Carried Forward for Consequence Analysis
The following incidents were identified to have potential to impact off site:
• Li-ion battery fault, thermal runaway and fire.
• Transformer internal arcing, oil spill, ignition and bund fire.
Each incident has been assessed in the following sections.

6.2 Li-Ion Battery Fault, Thermal Runaway and Fire

There is potential that a Li-Ion battery may fault resulting in thermal decomposition and fire which
may spread throughout the whole fire unit if not isolated / protected. A detailed analysis has been
conducted in Appendix B and the radiant heat impact distances estimated for this scenario are
shown in Table 6-1. The radiant heat contours associated with a fire occurring within a Li-Ion
battery module are shown in Figure 6-1. It is noted the contours are located at units in the worst
case location with respect to the site boundary.
Table 6-1: Radiant Heat from a Li-Ion Battery Fire
Heat Radiation (KW/m2) Distance (m)

35 2.3

23 3.1

12.6 4.6

4.7 8.2

Figure 6-1 is based upon the O&M area which is centrally located within the overall site layout. As
can be seen in Figure 6-1 the radiant heat contours at 4.7 kW/m2 do not impact over the O&M
boundary and by extension would therefore not extend over the site boundary; hence, the potential
for a fatality to occur offsite would not be expected to occur.
The 23 kW/m2 contour is associated with incident propagation which also does not impact over the
O&M boundary nor the site boundary. Therefore, incident propagation offsite would not be
expected to occur from a Li-Ion battery module fire. It is noted that the contour may impact the
adjacent Li-Ion battery units; however, it is noted the analysis is incredibly conservative as it
assumes the whole area of a unit is on fire which ignores the gaps between individual units within
the module cluster. Furthermore, it doesn’t take into account the barrier to direct radiant heat
exposure as the units are enclosed and typically have temperature control. Therefore, incident
propagation between units would also not be expected to occur.
In the event radiant heat did impact the battery enclosure the protection systems present within the
battery units (i.e. temperature and voltage monitoring and isolations) would activate preventing
propagation of the incident into adjacent units.
As the contours for fatality and incident propagation do not impact over the site boundaries this
incident has not been carried forward for further analysis.

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 Figure 6-1: Li-Ion Battery Module Fire Radiant Heat Contours

6.3 Transformer Internal Arcing, Oil Spill, Ignition and Bund Fire
There is potential that arcing may occur within the transformers which may lead to generation of
gases and pressure above the structural integrity of the oil reservoir which may rupture leaking oil
into the bund. As a result of the arcing and rupture, the oil may ignite leading to a bund fire within
the dimensions of the bund. A detailed analysis has been conducted in Appendix B and the radiant
heat impact distances estimated for this scenario are shown in Table 6-2. The radiant heat contours
associated with a fire occurring within a transformer bund are shown in Figure 6-2. It is noted the
contours are located at the worst-case location within the substation with respect to the site
boundary.
Table 6-2: Radiant Heat from a Transformer Bund Fire
Heat Radiation (KW/m2) Distance (m)

35 1.6

23 2.2

12.6 3.2

4.7 5.6

Figure 6-2 is based upon the O&M area which is centrally located within the overall site layout. As
can be seen in Figure 6-2 the radiant heat contours at 4.7 kW/m2 do not impact over the O&M
boundary and by extension would therefore not extend over the site boundary; hence, the potential
for a fatality to occur offsite would not be expected to occur.
The 23 kW/m2 contour is associated with incident propagation which also does not impact over the
O&M boundary nor the site boundary. Therefore, incident propagation offsite would not be
expected to occur from transformer bund fire.
It is noted that there are other transformer locations around the site along the PV arrays; however,
these are located >20 m from the site boundary and therefore would not result in impacts off site.
As the contours for fatality and incident propagation do not impact over the site boundaries this
incident has not been carried forward for further analysis.

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 Figure 6-2: Transformer Bund Fire Radiant Heat Contours

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 7.0 Frequency Analysis
7.1 Incidents Carried Forward for Frequency Analysis
No incidents were identified to have an offsite impact; hence, no frequency analysis has been
conducted as the offsite impact would be zero (0).

7.2 Total Fatality Risk

As noted, there is no potential for offsite impact in terms of incident propagation or fatality; hence,
the fatality risk would be zero (0); nonetheless, the results have been summarised in Table 7-1.
Table 7-1: Total Fatality Risk
Incident Fatality Risk

Li-Ion Fire 0

Transformer Fire 0

Total 0

7.3 Comparison Against Risk Criteria

The acceptable criteria have been taken from the NSW Department of Planning, Industry and
Environment Hazardous Industry Planning Advisory Paper No. 4 – Risk Criteria for Land Use Safety
Planning (Ref. [3]) and used for guidance as Victoria does not have any published criteria for offsite
risk. The acceptable risk criteria published in the guideline relates to injury, fatality and property
damage. The values in the guideline present the maximum levels of risk that are permissible at the
land use under assessment.
The adjacent land use is classified as an industrial site (under the guidelines). For industrial
facilities, the maximum permissible fatality risk is 50 chances per million per year (pmpy). The
assessed highest fatality risk is 0 pmpy at the closest site boundary; hence, the highest risk is within
the permissible criteria and therefore all other risk points beyond the boundary would be within the
acceptable criteria.
Based on the estimated injury risk, conducted in the analysis above, the risks associated with injury
and nuisances at the closest residential area are not considered to be exceeded.

7.4 Incident Propagation

The same guidelines provide acceptable risk criteria (Ref. [3]) for incident propagation as 50
chances pmpy. A review of the scenarios that may lead to incident propagation shows that the 23
kW/m2 contour was not observed to impact offsite; hence, the potential for incident propagation is
zero (0) which is less than the acceptable risk criteria for incident propagation.

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 8.0 Conclusion and Recommendations
8.1 Conclusions
A hazard identification table was developed for the West Mokoan Solar Farm PV & BESS project
to identify potential hazards that may be present at the site as a result of operations or storage of
materials. Based on the identified hazards, scenarios were postulated that may result in an incident
with a potential for offsite impacts. Postulated scenarios were discussed qualitatively and any
scenarios that would not impact offsite were eliminated from further assessment. Scenarios not
eliminated were then carried forward for consequence analysis.
Incidents carried forward for consequence analysis were assessed in detail to estimate the impact
distances. Impact distances were developed into scenario contours and overlaid onto the site
layout diagram to determine if an offsite impact would occur. The consequence analysis showed
that no scenarios would have the potential to impact off site; hence, no incidents were carried
forward for detailed frequency analysis.
Notwithstanding this, a frequency assessment was prepared to highlight that the risk at the site
boundary would be zero (0) as the consequence contours would not impact over the site boundary.
As the risk was calculated to be zero (0) it would be below the acceptable criteria and would be
considered a permissible development.
In addition, incidents exceeding 23 kW/m2 were reviewed which indicated that the contours from
such incidents would not impact over the site boundary and therefore incident propagation would
not be expected to occur and would be below the acceptable criteria.
Based on the analysis conducted, it is concluded that the risks at the site boundary are not
considered to exceed the acceptable risk criteria; hence, the project would only be classified as
potentially hazardous and would be permitted within the current land zoning for the site.

8.2 Recommendations
Notwithstanding the conclusions drawn, the following recommendations have been made and
should be undertaken to cover the battery and inverter equipment as well as common hazards for
a mechanical site prior to the commencement of operations at the Solar PV and BESS project to
the extent dangerous goods exceed any thresholds:
• A submission to FRV shall be made for written advice in accordance with the VDGR.
• A Dangerous Goods (DG) risk assessment shall be prepared for the site.
• A DG register shall be prepared for the site.
• A site manifest shall be prepared at the site in accordance with Schedule 3 of the Victorian
Dangerous Goods Regulation (VDGR).
• The site shall notify the Regulator (i.e. WorkSafe Victoria) of the presence of DGs.
• A site layout shall be prepared for the site in accordance with Schedule 3 of the VDGR.
• A placard schedule shall be prepared for the site to ensure the correct placards are installed.
• An Emergency Response Plan (ERP) shall be prepared for the site and submitted to the Fire &
Rescue Victoria (FRV).

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 • An Emergency Services Information Booklet (ESIB) shall be prepared for the site and submitted
to the FRV.
• The transformers shall be designed according to the requirements detailed in AS 1940-2017
“The storage and handling of flammable and combustible liquids” to minimise the potential for
fire or explosion to occur within the transformers.

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 9.0 References

[1] WorkSafe Victoria, “Victoria Dangerous Goods Regulation 2012 under the Victoria
Occupational Health and Safety Regulation 2017,” WorkSafe Victoria, Melbourne, 2012.

[2] Department of Planning, Industry and Environment, “Hazardous Industry Planning Advisory
Paper No. 6 - Guidelines for Hazard Analysis,” Department of Planning, Industry and
Environment, Sydney, 2011.

[3] Department of Planning, Industry and Environment, “Hazardous Industry Planning Advisory
Paper No. 4 - Risk Criteria for Land Use Safety Planning,” Department of Planning, Industry
and Environment, Sydney, 2011.

[4] WorkSafe Victoria, “Occupational Health and Safety Regulation,” WorkSafe Victoria,
Melbourne, 2017.

[5] Department of Planning, Industry and Environment, Multi-Level Risk Assessment, Sydney:
Department of Planning, Industry and Environment, 2011.

[6] Standards Australia, “AS/NZS 4681:2000 - The Storage and Handling of Class 9
(Miscellaneous) Dangerous Goods and Articles,” Standards Australia, Sydney, 2000.

[7] National Transport Commission (NTC), “Australian Code for the Transport of Dangerous
Goods by Road & Rail, 7th Edition,” 2011.

[8] Standards Australia, AS 1940-2017 - Storage and Handling of Flammable and Combustible
Liquids, Sydney: Standards Australia, 2017.

[9] Standards Australia, “AS/NZS 3000:2007 - Wiring Rules,” Standards Australia, Sydney, 2007.

[10] I. Cameron and R. Raman, Process Systems Risk Management, San Diego: Elsevier, 2005.

[11] F. P. Lees, Loss Prevention in the Process Industries, London: Butterworth-Heinemann, 2005.

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 Appendix A
Hazard Identification Table

Hazard Identification Table

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 A1. Hazard Identification Table
Area/Operation Hazard Cause Hazard Consequence Safeguards

Battery Storage • Failure of lithium ion • Thermal runaway resulting in fire • Batteries are tested by manufacturer prior to sale /
battery protection systems or explosion installation
• Incident propagation through • Overcharging and electrical circuit protection
battery cells • Battery monitoring systems
• Thermal and smoke detection
• Batteries composed of subcomponents (i.e. BBU, cells)
reducing risk of substantial component failure
• Batteries are not located in areas where damage could
easily occur (i.e. within the fenced property)
• Hydrant protection
• Electrical systems designed per AS/NZS 3000:2007 (Ref.
[9])

Switch rooms, • Arcing, overheating, • Ignition of processors and other • Hydrant protection
MMR rooms, sparking, etc. of electrical combustible material within servers • Fires tend to smoulder rather than burn
communications, systems and subsequent fire
data halls, etc. • Isolated location
• Switch room contained within a structure

Substation • Arcing within transformer, • Transformer oil spill into bund and • Bunded
vaporisation of oil and bund fire • Fire protection (hydrants, extinguishers)
rupture of oil reservoir
• Isolated location

Refrigerant gases • Failure of flanges, valves, • Non-flammable, non-toxic gases • Relatively low volume of gas used
compressors, etc. and pose no fire issue • Robust and commonly used systems which are not prone to
release of gas • Potential oxygen exclusion and large leaks
asphyxiation risk

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 Area/Operation Hazard Cause Hazard Consequence Safeguards
• Open outdoor area provides natural ventilation preventing
accumulation of gases

Diesel • Release of combustible • Pool fire at the point of release • Combustible liquids do not give off flammable vapours at
liquid and ignition atmospheric conditions
• Low ignition probability
• Relatively small release of diesel
• AS 1940-2017 compliant storages

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28 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 Appendix B
Consequence Analysis

Consequence Analysis

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29 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 B1. Incidents Assessed in Detailed Consequence Analysis
The following incidents are assessed for consequence impacts.
• Li-ion battery fault, thermal runaway and fire.
• Transformer internal arcing, oil spill, ignition and bund fire.
Each incident has been assessed in the sections below.
B2. Spreadsheet Calculator (SSC)
The SSC is designed on the basis of finite elements. The liquid flame area is calculated as if it is a
circle to find the radius for input into the SSC model.
The SSC is designed on the basis of finite elements. The liquid flame area is calculated as if it is a
circle to find the radius for input into the SSC model. Appendix Figure B-1 shows a typical pool
fire, indicating the target and fire impact details.

Appendix Figure B-1: Heat Radiation on a Target from a Cylindrical Flame

A fire in a bund or at a tank roof will act as a cylinder with the heat from the cylindrical flame
radiating to the surrounding area. A number of mathematical models may be used for estimating
the heat radiation impacts at various distances from the fire. The point source method is adequate
for assessing impacts in the far field; however, a more effective approach is the view factor method,
which uses the flame shape to determine the fraction of heat radiated from the flame to a target.
The radiated heat is also reduced by the presence of water vapour and the amount of carbon
dioxide in air. The formula for estimating the heat radiation impact at a set distance is shown in
Equation B-1 (Ref. [10]).

𝑄 = 𝐸𝐹𝜏 Equation B-1

Where:
• Q = incident heat flux at the receiver (kW/m2)
• E = surface emissive power of the flame (kW/m2)
• F = view factor between the flame and the receiver
• 𝜏 = atmospheric transmissivity
The calculation of the view factor (F) in Equation B-1 depends upon the shape of the flame and
the location of the flame to the receiver. F is calculated using an integral over the surface of the
flame, S (Ref. [10]). The formula can be shown as:

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30 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 cos 𝛽1 cos 𝛽2 Equation B-2
𝐹 = ∫∫𝑠
𝜋𝑑2

Equation B-2 may be solved using the double integral or using a numerical integration method in
spread sheet form. This is explained below.
For the assessment of pool fires, a Spread Sheet Calculator (SCC) has been developed, which is
designed on the basis of finite elements. The liquid flame area is calculated as if the fire is a vertical
cylinder, for which the flame diameter is estimated based on the fire characteristics (e.g. contained
within a bund). Once the flame cylindrical diameter is estimated, it is input into the SSC model. The
model then estimates the flame height, based on diameter, and develops a flame geometric shape
(cylinder) on which is performed the finite element analysis to estimate the view factor of the flame.
Appendix Figure B-1 shows a typical pool fire, indicating the target and fire impact details.
The SSC integrates the element dA1 by varying the angle theta 𝜃 (the angle from the centre of the
circle to the element) from zero to 90o in intervals of 2.5 degrees. Zero degrees represents the
straight line joining the centre of the cylinder to the target (x0, x1, x2) while 90 o is the point at the
extreme left hand side of the fire base. In this way the fire surface is divided up into elements of
the same angular displacement. Note the tangent to the circle in plan. This tangent lies at an angle,
gamma, with the line joining the target to where the tangent touches the circle (x4). This angle
varies from 90o at the closest distance between the liquid flame (circle) and the target (x0) and gets
progressively smaller as 𝜃 increases. As 𝜃 increases, the line x4 subtends an angle phi Φ with x0.
By similar triangles we see that the angle gamma 𝛾 is equal to 90- 𝜃 - Φ . This angle is important
because the sine of the angle give us the proportion of the projected area of the plane. When 𝛾 is
90o, sin(𝛾) is 1.0, meaning that the projected area is 100% of the actual area.
Before the value of 𝜃 reaches 90o the line x4 becomes tangential to the circle. The fire cannot be
seen from the rear and negative values appear in the view factors to reflect this. The SSC filters
out all negative contributions.
For the simple case, where the fire is of unit height, the view factor of an element is simply given
by the expression in Equation B-3 (Derived from Equation B-2):
sin 𝛾
𝑉𝐹 = ∆𝐴 Equation B-3
𝜋 × 𝑋4 × 𝑋4
Where ∆A is the area of an individual element at ground level.
Note: the denominator (π. x4. x4) is a term that describes the inverse square law for radiation
assumed to be distributed evenly over the surface of a sphere.
Applying the above approach, we see the value of x4 increase as 𝜃 increase, and the value of
sin(𝛾) decreases as 𝜃 increase. This means that the contribution of the radiation from the edge of
the circular fire drops off quite suddenly compared to a view normal to the fire. Note that the SSC
adds up the separate contributions of Equation B-3 for values of 𝜃 between zero until x4 makes a
tangent to the circle.
It is now necessary to do two things: (i) to regard the actual fire as occurring on top of a fire wall
(store) and (ii) to calculate and sum all of the view factors over the surface of the fire from its base
to its top. The overall height of the flame is divided into 10 equal segments. The same geometric
technique is used. The value of x4 is used as the base of the triangle and the height of the flame,
as the height. The hypotenuse is the distance from target to the face of the flame (called X4’). The

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31 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 angle of elevation to the element of the fire (alpha 𝛼) is the arctangent of the height over the ground
distance. From the cos(𝛼) we get the projected area for radiation. Thus there is a new combined
distance and an overall equation becomes in Equation B-4 ((Derived from Equation B-3):
sin 𝛾 × cos 𝛼
𝑉𝐹 = ∆𝐴 Equation B-4
𝜋 × 𝑋4 × 𝑋4
The SCC now turns three dimensional. The vertical axis represents the variation in 𝜃 from 0 to 90o
representing half a projected circle. The horizontal axis represents increasing values of flame
height in increments of 10%. The average of the extremes is used (e.g. if the fire were 10 m high
then the first point would be the average of 0 and 1 i.e. 0.5 m), the next point would be 1.5 m and
so on).
Thus the surface of the flame is divided into 360 equal area increments per half cylinder making
720 increments for the whole cylinder. Some of these go negative as described above and are not
counted because they are not visible. Negative values are removed automatically.
The sum is taken of the View Factors in Equation B-3. Actually the sum is taken without the ∆A
term. This sum is then multiplied by ∆A which is constant. The value is then multiplied by 2 to give
both sides of the cylinder. This is now the integral of the incremental view factors. It is
dimensionless so when we multiply by the emissivity at the “face” of the flame (or surface emissive
power, SEP), which occurs at the same diameter as the fire base (pool), we get the radiation flux
at the target.
The SEP is calculated using the work by Mudan & Croche (Ref. [11] & Ref. [10]) which uses a
weighted value based on the luminous and non-luminous parts of the flame. The weighting is based
on the diameter and uses the flame optical thickness ratio where the flame has a propensity to
extinguish the radiation within the flame itself. The formula is shown in Equation B-5.

𝑆𝐸𝑃 = 𝐸𝑚𝑎𝑥 𝑒 −𝑠𝐷 + 𝐸𝑠 (1 − 𝑒 −𝑠𝐷 ) Equation B-5

Where;
Emax = 140
S = 0.12
Es = 20
D = pool diameter
The only input that is required is the diameter of the pool fire and then estimation for the SEP is
produced for input into the SSC.
The flame height is estimated using the Thomas Correlation (Ref. [10]) which is shown in Equation
B-6.
0.61
𝑚̇
𝐻 = 42𝑑𝑝 [ ] Equation B-6
𝜌𝑎 √𝑔𝑑𝑝

Where;
𝑑𝑝 = pool diameter (m)

𝜌𝑎 = density of air (1.2 kg/m3 at 20oC)

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32 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 𝑚̇ = burning rate (kg/m2.s)
g = 9.81 m/s2
The transmissivity is estimated using Equation B-7 (Ref. [10]).

𝜏 = 1.006 − 0.01171(log10 𝑋(𝐻2 𝑂) − 0.02368(log10 𝑋(𝐻2 𝑂))2

Equation B-7
− 0.03188(log10 𝑋(𝐶𝑂2 ) + 0.001164(log10 𝑋(𝐶𝑂2 ))2

Where:
• 𝜏 = Transmissivity (%)
𝑅𝐻 ×𝐿×𝑆𝑚𝑚 ×2.88651×102
• X(H2O) =
𝑇
𝐿×273
• X(CO2) = 𝑇

and
• RH = Relative humidity (% expressed as a decimal)
• L = Distance to target (m)
• Smm = saturated water vapour pressure in mm of mercury at temperature (at 25oC Smm = 23.756)
• T = Atmospheric temperature (K)
B3. Radiant Heat Physical Impacts
Appendix Table B-1 provides noteworthy heat radiation values and the corresponding physical
effects of an observer exposed to these values (Ref. [3]).
Appendix Table B-1: Heat Radiation and Associated Physical Impacts
Heat Radiation Impact
(kW/m2)

35 • Cellulosic material will pilot ignite within one minute’s exposure

• Significant chance of a fatality for people exposed instantaneously

23 • Likely fatality for extended exposure and chance of a fatality for instantaneous
exposure
• Spontaneous ignition of wood after long exposure
• Unprotected steel will reach thermal stress temperatures which can cause failure
• Pressure vessel needs to be relieved or failure would occur

12.6 • Significant chance of a fatality for extended exposure. High chance of injury
• Causes the temperature of wood to rise to a point where it can be ignited by a
naked flame after long exposure
• Thin steel with insulation on the side away from the fire may reach a thermal stress
level high enough to cause structural failure

4.7 • Will cause pain in 15-20 seconds and injury after 30 seconds exposure (at least
second degree burns will occur)

2.1 • Minimum to cause pain after 1 minute

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33 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 B4. Li-Ion Battery Fault, Thermal Runaway and Fire
The battery units are spaced out throughout the site to provide energy storage when drawing
energy from the grid and discharging back to the grid. For conservatism, a Li-Ion battery fire has
been based upon a fire originating within a battery pack and propagating to the closest batteries
resulting in a full container fire. The area covered by a full battery module is approximately 29 m2.
This area has been used as an input for the fire dimensions and converted to a circular diameter
to input into the SEP and SSC models.

4 × 29
𝐷=√ = 3.4 𝑚
𝜋

The following data was input into the SSC:

• Fire diameter – 3.4 m
• Burning rate – 0.022 kg/m2.s (selected to model combustible materials)
The above information was put into the spreadsheet calculator which calculated the following
outputs:
• SEP – 99.5 kW/m2
• Flame height – 4.3 m
The results of the analysis are shown in Appendix Table B-2.
Appendix Table B-2: Heat Radiation Impacts from a Li-Ion Battery Fire
Heat Radiation (KW/m2) Distance (m)

35 2.3

23 3.1

12.6 4.6

4.7 8.2

B5. Transformer Internal Arcing, Oil Spill, Ignition and Bund Fire
Transformers contain oil to provide cooling and insulation. If arcing occurs within the transformer,
the oil will rapidly heat generating gases above their auto ignition point. The pressure of the gases
may rupture the reservoir allowing oxygen to enter resulting in the gases auto igniting. The oil is
released from the reservoir and is ignited by the burning gases.
It has been assumed that the transformer has bund dimensions of approximately 12.5 m x 9 m
which is based upon similar projects; hence, if a spill from the transformer was to occur it would fill
the base of the bund resulting in a pool fire with the dimensions of the bund. These dimensions
have been used to calculate a circular diameter to input into the SEP and SSC models.
𝐴 = 𝐿 × 𝑊 = 3 × 3 = 9 𝑚2

4×9
𝐷=√ = 1.9 𝑚
𝜋

The following data was input into the SSC;

• Fire diameter – 1.9 m

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34 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 • Burning rate – 0.022 kg/m2.s (combustible liquid, Ref. [11])
The above information was put into the spreadsheet calculator which calculated the following
outputs:
• SEP – 115 kW/m2
• Flame height – 2.9 m
The results of the analysis are shown in Appendix Table B-3.
Appendix Table B-3: Heat Radiation Impacts from a Transformer Bund Fire
Heat Radiation (KW/m2) Distance (m)

35 1.6

23 2.2

12.6 3.2

4.7 5.6

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35 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 Appendix C
Site Layout

Site Layout

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36 Document No. RCE-21046_SE_PHA_Final_15Jun21_Rev(1)
Date 15/06/2021
 ISO A0 841mm x 1189mm

LEGEND

FA
N

RN
10m WIDE SCREEN PLANTING ZONE PROJECT

LE
TRUE NORTH

Y
WEST MOKOAN

RO
5m WIDE SCREEN PLANTING ZONE

AD
37m
SOLAR FARM
EXISTING BOUNDARY VEGETATION
TO BE RETAINED
EXISTING DWELLING CONCEPT DESIGN

30

W
ENVIRONMENTAL VALUE (EVC

m
BENALLA

W
HABITAT ZONES) TO BE RETAINED 10m Victoria

W
NATIVE VEGETATION ENHANCEMENT CHESNEY VALE CFA

W
FIRE STATION CLIENT
AREA - PROJECT AREA

W
W
NATIVE VEGETATION ENHANCEMENT 892 YARRAWONGA

W
AREA - CROWN LAND NOTE 1 LAKE MOKOAN ROAD

W
DEVELOPMENT Pty Ltd

W
VEGETATION MANAGEMENT AREA -

39
34

W
Level 19, 303 Collins Street
PROJECT AREA

5m
m
Melbourne, VIC 3000

W
VEGETATION MANAGEMENT AREA -

W
W
CROWN LAND m
23

W
E

TRANSMISSION LINE EASEMENT E

W
E

W E

7m
EXISTING DWELLING

W
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31
E

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E

POWERLINE EASEMENT

m
m
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.65
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10
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DESIGNATED WATERWAYS 11.80m
E

W W

14
E

8m

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E
W

W
W

2m
E

2 SITE ENTRANCE E

E
PROPOSED 220kV EASEMENT
E

GATE. NOTE 10. CONSULTANT

E

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E

REALIGNMENT
W

W
E

41m

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S AECOM Australia Pty Ltd
E

W
S

E
E

SITE BOUNDARY FENCE m E

A.B.N 20 093 846 925

24 14.05m

W
E

E
5m COLLINS SQUARE, LEVEL 10, TOWER TWO
E

4
E

W
.

E
0 727 COLLINS STREET, MELBOURNE, VIC 3008
E

10m FIREBREAK OFFSET 1 E

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E

E
E
613 9653 1234 tel 613 9654 7117 fax

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www.aecom.com

E
E

PROPOSED 4m WIDE ACCESS ROADS E

E
E

BE

E
SENSITIVE AREAS

NA
NOTE 2

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W
LL

E
SCATTERED TREES TO BE RETAINED

A-Y

E
(INCLUDING 15m TPZ)

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PROPOSED MV OVERHEAD LINE CONNECTIONS

AR

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BETWEEN NORTH AND SOUTH SITE

E
RA
SCATTERED TREES TO BE REMOVED

W
(INDICATIVE ONLY - REFER TO NOTE 11)

E
WO

12

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'SITE ENTRANCE' AND 'DANGER' &

5m
W
S ION

NG
S S S AT BESS

E
T
SIGNAGE BS & NATIVE VEGETATION

AR
SU REA

E
ED A
ENHANCEMENT AREA.

44
AT ITY A
BUSINESS IDENTIFICATION IGN ACIL ARE

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OA
S M
S

m
DE M F MWW-O REFER TO WOODLAND

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SIGNAGE (NOTE 9) O&

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D
-O HW
Approved: R.H.

HW MANAGEMENT PLAN
S
5m

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20

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4.6 MVA PCU M FOR DETAILS

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MWW-O

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-O HW
HW
21m

13
2.3 MVA PCU

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21m

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Checked: A.S.

ELEVATED 4.6 MVA PCU

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m

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5
3.7

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ELEVATED 2.3 MVA PCU

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SOLAR PANELS INSTALLED ON SINGLE AXIS SITE ENTRANCE GATES W

E
Designer: J.C.

TRACKER TABLES. EACH TABLE SUPPORTS NOTE 10. 15m W

25
W

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EK

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84 PANELS IN 3 STRINGS OF 28. E

E
CR
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52m
W

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CK

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m
ELEVATED SOLAR PANELS INSTALLED ON 25
W

27m
MINIMUM 15m SETBACK FROM THE ST

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Project Management Initials:

SINGLE AXIS TRACKER TABLES. EACH TABLE

E
CENTRELINE OF WATERWAYS

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SUPPORTS 84 PANELS IN 3 STRINGS OF 28. NOTE 1

This drawing is confidential and shall only be used for the purpose of this project. The signing of this title block confirms the design and drafting of this project have been prepared and checked in accordance with the AECOM quality assurance system to ISO 9001-2008.
E
W

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39

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SYSTEM PARAMETERS

E
E
ITEM TOTAL

E
NAMEPLATE AC CAPACITY (MVA) @35°C 234.6

E E
MAXIMUM AC CAPACITY (MW) @ 35°C (PF 0.82) 192.37

E
DC CAPACITY (MW) @ STC

E
233.74

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AVERAGE DC/AC RATIO 1.22

E
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NUMBER OF PCUs (4.6MVA) 45

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3 m
NUMBER OF PCUs (2.3MVA) 7.3

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12

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STRINGS PER 4.6MVA PCU 372

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STRINGS PER 2.3MVA PCU 186

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m
16

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MODULES PER 4.6MVA PCU 10,416

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MODULES PER 2.3MVA PCU 5,208 m

E
9
8.2
S

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TOTAL NUMBER OF TRACKERS 6,324
SITE ENTRANCE GATE.

E
18,972 NOTE 10.

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TOTAL STRINGS

E
38.64m
TOTAL MODULES 531,216

E
E
m
15

E
SYSTEM CONFIGURATION

E
W

E
ITEM SYSTEM SIZE
W

E
W

440W, 144 CELLS MONOCRYSTALLINE, 1500VDC

W

SOLAR MODULE W

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MODULE DIMENSIONS 2115mm x 1052mm W

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34.52m
W

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STRING CONFIGURATION 28 MODULES PER STRING

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W

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SINGLE AXIS TRACKING, 2 MODULE IN PORTRAIT W

TRACKER SYSTEM MAKE/MODEL

E
3 STRINGS PER TRACKER
W

E
W

4.6 MVA (2 X 2.3 MVA INVERTERS @ 35°C)

E
PCU (NAMEPLATE CAPACITY)
W

& 2.3 MVA (1 x 2.3 MVA INVERTER @ 35°C)

E
W

E
3.77 MW (PF 0.82)
W

PCU (DERATED CAPACITY)

E
W

& 1.886 MW (PF 0.82)

m

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W

21
TRACKER AXIS AZIMUTH ANGLE 0°

E
W

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ROW SPACING (CENTRE TO CENTRE) 7.5 m
Filename: P:\605X\60597809\900_CAD_GIS\910_CAD\20_SHEETS\60597809-DWG-EL-0003.DWG

36m

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ISSUE/REVISION

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GCR - GROUND COVERAGE RATIO 0.565 0 m
13
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EXISTING DWELLING 7m

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8.8
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DC SYSTEM VOLTAGE 1500V 11 03/06/2021 REVISED ISSUE

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NOTES:
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8 29/09/2020 REVISED PER CLIENT REVIEW

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7 28/09/2020 REVISED ISSUE

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1. E-1, E-2 AND E-5 TRANSMISSION LINE EASEMENT. WIDTH OF EASEMENT RANGING BETWEEN 61m - 74m.
E

.89
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6 18/08/2020 REVISED PER CLIENT REVIEW

Last saved by: HENWOODE(2021-06-03) Last Plotted: 2021-06-04

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2. EASEMENT E-3, E-4 AND E-5. 14m WIDE DISTRIBUTION LINE EASEMENT.
W

I/R DATE DESCRIPTION

E

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3. LOCATION OF INVERTERS TO BE CONFIRMED DURING DETAILED DESIGN.

E

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4. ACCESS TRACK DESIGN TO BE UNDERTAKEN DURING THE DETAILED DESIGN PHASE. ACCESS TRACKS
E

SHOWN ARE INDICATIVE ONLY.

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5. SITE ENTRANCE GATES TO BE CONFIRMED DURING DETAILED DESIGN. 0 125 250

m
W

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6. SUBSTATION DIMENSIONS APPROXIMATE ONLY. m

W

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m
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7. DIMENSIONS ARE IN METRES UNLESS NOTED OTHERWISE. 31 m S

W

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25

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4 S
0.1
S
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8. NATIVE VEGETATION THAT HAS NOT BEEN IDENTIFIED TO BE RETAINED MAY BE REMOVED WHERE PROJECT NUMBER
m

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1:5000
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NECESSARY, SUBJECT TO DELWP NATIVE VEGETATION REMOVAL PERMIT APPROVAL. NATIVE

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60597809
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SITE ENTRANCE GATE.

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VEGETATION SHOULD BE RETAINED WHERE PRACTICABLE. E E

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EXISTING DWELLING NOTE 10.

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9. BUSINESS IDENTIFICATION SIGNAGE (1m (L) x 1m (W)) SHALL BE LOCATED AT THE DESIGNATED MAIN E

SHEET TITLE
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EXISTING DWELLING
ENTRANCE OF EACH MAIN PROPERTY.
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10. ENTRY/ACCESS POINTS TO BE DESIGNED IN ACCORDANCE WITH VICROADS STANDARD DRAWING

E

WEST MOKOAN
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SOLAR FARM
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GD4010 - TYPICAL ACCESS TO RURAL PROPERTIES.

FOR DISCUSSION PURPOSE ONLY
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CONCEPT LAYOUT
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11. PROPOSED OVERHEAD LINE ROUTES AND LOCATIONS ARE INDICATIVE ONLY AND SHALL BE
SOLAR PV PLANT
E
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CONFIRMED DURING DETAILED DESIGN. THE OVERHEAD LINE INFRASTRUCTURE SHALL BE DESIGNED E

SHEET NUMBER
W

E PLEASE NOTE THE ENCLOSED DRAWINGS ARE ONLY PRELIMINARY AND NOT FOR CONSTRUCTION, AND THEREFORE
AND CONSTRUCTED TO ENSURE NO IMPACT ON NATIVE VEGETATION. ARE LIKELY TO BE SUBJECT TO CHANGE.
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SCALE 1:5000
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60597809-DWG-EL-0003
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