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1.12 Application Part13SIERRA BLUFFS FILING 1 LOT 1 RECEPTION NO. 489442 MICHAEL & SHANNON DEIMLER SIERRA BLUFFS FILING 1 LOT 2 RECEPTION NO. 489442 DANIEL T & LAUREN N. SANDERS SIERRA BLUFFS FILING 1 LOT 3 RECEPTION NO. 489442 BROOKE A & MITCHELL McKENZIE SIERRA VISTA RANCH LOT 9 RECEPTION NO. 302518 JEFF RIEKE ET AL DALENE BARTON RECEPTION NOS. 455963 & 943875 DENE & MARY HANGS PARCEL 217927200393 VANGUARD OPERATING LLC RECEPTION NO. 856369 EAGLE SPRINGS ORGANIC LLC RECEPTION NO. 796299 BUTTON FAMILY LIVING TRUST RECEPTION NO. 948132 PATRICIO & ROSALINDA VENZOR RECEPTION NO. 799211 THOMAS A. PALIZZI RECEPTION NO. 911075 MURILLO RECEPTION NO. 899334 FREEARK SUBDIVISION LOT 3RECEPTION NO. 559841 DAVILA ET AL SIERRA BLUFFS FILING 1 LOT 1 RECEPTION NO. 489442 MICHAEL & SHANNON DEIMLER SIERRA BLUFFS FILING 1 LOT 2 RECEPTION NO. 489442 DANIEL T & LAUREN N. SANDERS SIERRA BLUFFS FILING 1 LOT 3 RECEPTION NO. 489442 BROOKE A & MITCHELL McKENZIE SIERRA VISTA RANCH LOT 9 RECEPTION NO. 302518 JEFF RIEKE ET AL DALENE BARTON RECEPTION NOS. 455963 & 943875 DENE & MARY HANGS PARCEL 217927200393 VANGUARD OPERATING LLC RECEPTION NO. 856369 EAGLE SPRINGS ORGANIC LLC RECEPTION NO. 796299 BUTTON FAMILY LIVING TRUST RECEPTION NO. 948132 PATRICIO & ROSALINDA VENZOR RECEPTION NO. 799211 THOMAS A. PALIZZI RECEPTION NO. 911075 MURILLO RECEPTION NO. 899334 FREEARK SUBDIVISION LOT 3RECEPTION NO. 559841 DAVILA ET AL SIERRA BLUFFS FILING 1 LOT 1 RECEPTION NO. 489442 MICHAEL & SHANNON DEIMLER SIERRA BLUFFS FILING 1 LOT 2 RECEPTION NO. 489442 DANIEL T & LAUREN N. SANDERS SIERRA BLUFFS FILING 1 LOT 3 RECEPTION NO. 489442 BROOKE A & MITCHELL McKENZIE SIERRA VISTA RANCH LOT 9 RECEPTION NO. 302518 JEFF RIEKE ET AL DALENE BARTON RECEPTION NOS. 455963 & 943875 DENE & MARY HANGS PARCEL 217927200393 VANGUARD OPERATING LLC RECEPTION NO. 856369 EAGLE SPRINGS ORGANIC LLC RECEPTION NO. 796299 BUTTON FAMILY LIVING TRUST RECEPTION NO. 948132 PATRICIO & ROSALINDA VENZOR RECEPTION NO. 799211 THOMAS A. PALIZZI RECEPTION NO. 911075 MURILLO RECEPTION NO. 899334 FREEARK SUBDIVISION LOT 3RECEPTION NO. 559841 DAVILA ET AL CULVERT B 12" DIA. @ 2.00% CULVERT A 30" DIA. @ 2.00% CULVERT D 30" DIA. @ 2.00% CULVERT C 12" DIA. @ 2.00% 1.2 CULVERT E 24" DIA. @ 2.00% CULVERT F 12" DIA. @ 2.00% 1.1 54 3 2 1 GARFIELD, COLORADO10/07/21 1" = 200' 3704.001 PV CIVILBASIN EXHIBITEX.PEACE BEAR RANCH10/08/21TCRBISSUED FOR 30% REVIEWA-------------------------JOB NO. SCALEDATEREVISIONSNO.DATEDWN.CHK.ELECTRIC POWER ENGINEERING, INC.12600 W. COLFAX AVE, STE. C500LAKEWOOD, CO 80215(303) 431-7895 www.neieng.comPRELIMINARY NOT FOR CONSTRUCTION FOR REVIEW & APPROVAL ONLY SCALE: 200'100'0 200'400'600' 1"=200' N NOTES 1.SURVEY AND TOPOGRAPHY DATA TAKEN FROM "PEACE BEAR RANCH-ALTA SURVEY - ACQUISITION-ISSUED_03-16-2021" BY SGM INC.; DATED MARCH 16, 2021. 2.WETLANDS SHOWN AS PROVIDED IN THE ALTA SURVEY. PROPOSED LIMIT OF DISTURBANCE EXISTING RIGHT-OF-WAY EXISTING PROPERTY LINE EXISTING WETLANDS EXISTING FENCE EXISTING DITCH LEGEND: PROPOSED CULVERT EXISTING CONTOUR MINOR EXISTING CONTOUR MAJOR EXISTING FEATURES PROPOSED FEATURES EXISTING RIGHT-OF-WAY EXISTING PROPERTY LINE EXISTING WETLANDS EXISTING FENCE EXISTING DITCH EXISTING ZONING SETBACK EXISTING DITCH SETBACK EXISTING WETLANDS SETBACK EXISTING UTILITY POLE EXISTING OVERHEAD ELECTRIC EXISTING WATER METER EXISTING COUNTY ROAD 331 EXISTING GATE POST RIPRAP EROSION CONTROL #BASIN ID BASIN BOUNDARY AES Peace Bear Ranch Solar – Land Use Change – Major Impact permit application (11/5/2021) AES Peace Bear Ranch Solar – Garfield County 52 Please see the following pages for proof of receipt from the Colorado Department of Health and Environment a Stormwater Management Plan prepared by NEI Engineering for AES Peace Bear Ranch Solar, LLC and submitted on November 8, 2021. The full stormwater management plan will be provided as separate addenda to this application given its size. STORMWATER MANAGEMENT PLAN – RECEIPT OF SUBMISSION TO CDPHE Appendix C6a A. PERMIT INFORMATION Reason for Application þ NEW CERT ¨RENEW CERT ¨MODIFICATION ¨TRANSFER ¨CHANGE OF CONTACT ¨TERMINATION Existing Cert # B. PERMITTED PROJECT/FACILITY INFORMATION Facility Name:Peace Bear Ranch Original ID: Property Address 1:2714 County Road 331 Property Address 2:County:GARFIELD City:Silt State:CO Zip Code:81652 Latitude :39.5082 Longitude :-107.6637 SIC Code Description 4911 Electric services C. CONTACT INFORMATION 1) *OPERATOR – RESPONSIBLE OFFICIAL - the party that has operation control over day to day activities – may be the same as the Owner Receiving Water Name Receiving Water Type Colorado River Ultimate ASSIGNED PERMIT NUMBER Date Received 11/08/2021 09:26:31 MM DD YYYY HH:MM:SS Revised: 3-2016 STORMWATER DISCHARGE ASSOCIATED WITH CONSTRUCTION ACTIVITIES APPLICATION COLORADO DISCHARGE PERMIT SYSTEM (CDPS) PHOTO COPIES, FAXED COPIES, PDF COPIES OR EMAILS WILL NOT BE ACCEPTED. Any additional information that you would like the Division to consider in developing the permit should be provided with the application. Examples include effluent data and/or modeling and planned pollutant removal strategies. Beginning July 1, 2016, invoices will be based on acres disturbed. DO NOT PAY THE FEES NOW – Invoices will be sent after the receipt of the application. Disturbed Acreage for this application (see page 4) ¨Less than 1 acre ($83 initial fee, $165 annual fee) ¨1-30 acres ($175 initial fee, $350 annual fee) ¨Greater than 30 acres ($270 initial fee, $540 annual fee) 1 OF 4 Responsible Person (Title): EPC Contractor To Be Determined at Later Date First Name:EPC Contractor To Be Determined at Later Date Last Name:EPC Contractor To Be Determined at Later Date Telephone No:7204258768 Email Address:jason.owens@aes.com Organization: EPC Contractor To Be Determined at Later Date Mailing Address:EPC Contractor To Be Determined at Later Date City:EPC Contractor To Be Determined at Later Date State:CO Zip Code:80027 2) *PROPERTY OWNER (CO-PERMITTEE) RESPONSIBLE OFFICIAL Responsible Person (Title): EPC Contractor To Be Determined at Later Date First Name:EPC Contractor To Be Determined at Later Date Last Name:EPC Contractor To Be Determined at Later Date Telephone No:7204258768 Email Address:jason.owens@aes.com Organization: EPC Contractor To Be Determined at Later Date Mailing Address:EPC Contractor To Be Determined at Later Date City:EPC Contractor To Be Determined at Later Date State:CO Zip Code:80027 3) *SITE CONTACT (local contact for questions relating to the facility & discharge authorized by this permit) Responsible Person (Title): EPC Contractor To Be Determined at Later Date First Name:EPC Contractor To Be Determined at Later Date Last Name:EPC Contractor To Be Determined at Later Date Telephone No:7204258768 Email Address:jason.owens@aes.com Organization: EPC Contractor To Be Determined at Later Date Mailing Address:EPC Contractor To Be Determined at Later Date City:EPC Contractor To Be Determined at Later Date State:CO Zip Code:80027 4) *BILLING CONTACT Responsible Person (Title): Project manager First Name:Jason Last Name:Owens Telephone No:7204258768 Email Address:jason.owens@aes.com Organization: AES Clean Energy Mailing Address:282 Century Place Suite 2000 City:Louisville State:CO Zip Code:80027 5) OTHER CONTACT TYPES Title First Name Last Name Phone Email Address City State Zip Contact Type Other 6) Former Permittee (transfer) Responsible Person (Title): First Name:Last Name: Email Address:Company: D. LEGAL DESCRIPTION Legal description: if subdivided, provide the legal description below, or indicate that it is not applicatable. Do not supply Township/Range/Section or metes and bounds description of the site. Subdivision(s): Lot(s):Block(s): OR þ Not applicable (site has not been subdivided) ¨Facility additional description info 2 OF 4 F. NATURE OF CONSTRUCTION ACTIVITY Check the appropriate box(s) or provide a brief description that indicates the general nature of the construction activities. (The full description of activities must be included in the Stormwater Management Plan.) ¨Commercial Development ¨Residential Development ¨Highway and Transportation Development ¨Pipeline and Utilities (including natural gas, electricity, water, and communications) ¨Oil and Gas Exploration and Well Pad Development ¨Non-structural and other development (i.e. parks, trails, stream realignment, bank stabilization, demolition, etc.) þ Other Solar Facility G. ANTICIPATED CONSTRUCTION SCHEDULE Construction Start Date:05/01/2022 Final Stabilization Date:12/31/2022 • Construction Start Date - This is the day you expect to begin ground disturbing activities, including grubbing, stockpiling, excavating, demolition, and grading activities. • Final Stabilization Date - in terms of permit coverage, this is when he site is finally stabilized. This means that all ground surface disturbing activities at the site have been completed and all disturbed areas have either been built on, paved, or a uniform vegetative cover has been established with an individual plant density of at least 70 percent of pre-disturbance levels. • Permit coverage must be maintained until the site is finally stabilized. Even if you are only doing one part of the project, the estimated final stabilization date must be for the overall project. If permit coverage is still required once your part is completed, the permit certification may be transferred to a new responsible operator. SIGNATURE REQUIREMENTS: TERMINATION CERTIFICATION ¨By checking this box I understand that by submitting this notice of termination, I am no longer authorized to discharge stormwater associated with construction activity by the general permit. I understand that discharging pollutants in stormwater associated with construction activities to the waters of the State of Colorado, where such discharges are not authorized by a CDPS permit, is unlawful under the Colorado Water Quality Control Act and the Clean Water Act. þ STORMWATER MANAGEMENT PLAN CERTIFICATION (on new and renewals) By checking this box “I certify under penalty of law that a complete Stormwater Management Plan, has been/or will be completed, prior to the commencement of any construction activity. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the Stormwater Management Plan is/or will be, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for falsely certifying the completion of said SWMP, including the possibility of fine and imprisonment for knowing violations.” THIS PORTION OF THE SIGNATURE LANGUAGE IS REQUIRED ON ALL SUBMITTALS "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." “I understand that submittal of this application is for coverage under the State of Colorado General Permit for Stormwater Discharges Associated with Construction Activity for the entirety of the construction site/project described and applied for, until such time as the application is amended or the certification is transferred, inactivated, or expired.” E. AREA OF CONSTRUCTION SITE Total area of construction site 199 acres Total area of project disturbance 81 acres 3 OF 4 Signature of Operator Date Signed Name (printed)Title Signature of Owner Date Signed Name (printed)Title Signature: The applicant must be either the owner and operator of the construction site. Refer to Part B of the instructions for additional information. The application must be signed by the applicant to be considered complete. In all cases, it shall be signed as follows: (Regulation 61.4 (1ei) a) In the case of corporations, by the responsible corporate officer is responsible for the overall operation of the facility from which the discharge described in the form originates b) In the case of a partnership, by a general partner. c) In the case of a sole proprietorship, by the proprietor. d) In the case of a municipal, state, or other public facility, by either a principal executive officer, ranking elected official, (a principal executive officer has responsibility for the overall operation of the facility from which the discharge originates). FORMER PERMITTEE used for transfers Signature (Legally Responsible Party)Date Name (printed)Title 4 OF 4 AES Peace Bear Ranch Solar – Land Use Change – Major Impact permit application (11/5/2021) AES Peace Bear Ranch Solar – Garfield County 53 Please see the following pages for the Forge Solar Glare Analysis for AES Peace Bear Ranch Solar, LLC conducted in August 2021. FORGESOLAR GLARE ANALYSIS Appendix C7 FORGESOLAR GLARE ANALYSIS Project: Peace Bear Ranch 10MW PV with BESS Site configuration: PBR 1-temp-0 Analysis conducted by Derrick Worden (Derrick.worden@aes.com) at 17:28 on 20 Aug, 2021. U.S. FAA 2013 Policy Adherence The following table summarizes the policy adherence of the glare analysis based on the 2013 U.S. Federal Aviation Administration Interim Policy 78 FR 63276. This policy requires the following criteria be met for solar energy systems on airport property: • No "yellow" glare (potential for after-image) for any flight path from threshold to 2 miles • No glare of any kind for Air Traffic Control Tower(s) ("ATCT") at cab height. • Default analysis and observer characteristics (see list below) ForgeSolar does not represent or speak officially for the FAA and cannot approve or deny projects. Results are informational only. COMPONENT STATUS DESCRIPTION Analysis parameters PASS Analysis time interval and eye characteristics used are acceptable 2-mile flight path(s) PASS Flight path receptor(s) do not receive yellow glare ATCT(s) N/A No ATCT receptors designated Default glare analysis parameters and observer eye characteristics (for reference only): • Analysis time interval: 1 minute • Ocular transmission coefficient: 0.5 • Pupil diameter: 0.002 meters • Eye focal length: 0.017 meters • Sun subtended angle: 9.3 milliradians FAA Policy 78 FR 63276 can be read at https://www.federalregister.gov/d/2013-24729 SITE CONFIGURATION PV Array(s) Analysis Parameters DNI: peaks at 1,000.0 W/m^2 Time interval: 1 min Ocular transmission coefficient: 0.5 Pupil diameter: 0.002 m Eye focal length: 0.017 m Sun subtended angle: 9.3 mrad Site Config ID: 57670.10307 Name: PV array 1 Axis tracking: Single-axis rotation Tracking axis orientation: 180.0° Tracking axis tilt: 0.0° Tracking axis panel offset: 0.0° Max tracking angle: 60.0° Resting angle: 60.0° Rated power: - Panel material: Smooth glass with AR coating Reflectivity: Vary with sun Slope error: correlate with material Vertex Latitude (°) Longitude (°) Ground elevation (ft)Height above ground (ft) Total elevation (ft) 1 39.512075 -107.666179 5798.44 12.00 5810.44 2 39.512125 -107.669784 5778.61 12.00 5790.62 3 39.511347 -107.671372 5779.89 12.00 5791.89 4 39.510072 -107.671329 5812.82 12.00 5824.82 5 39.508748 -107.671329 5788.56 12.00 5800.56 6 39.508814 -107.667273 5782.57 12.00 5794.58 7 39.509575 -107.667252 5791.26 12.00 5803.26 8 39.510271 -107.667874 5815.52 12.00 5827.52 9 39.510701 -107.665900 5822.02 12.00 5834.02 Flight Path Receptor(s) Name: PV array 2 Axis tracking: Single-axis rotation Tracking axis orientation: 180.0° Tracking axis tilt: 0.0° Tracking axis panel offset: 0.0° Max tracking angle: 60.0° Resting angle: 60.0° Rated power: - Panel material: Smooth glass with AR coating Reflectivity: Vary with sun Slope error: correlate with material Vertex Latitude (°) Longitude (°) Ground elevation (ft)Height above ground (ft) Total elevation (ft) 1 39.508781 -107.666865 5783.78 12.00 5795.78 2 39.506413 -107.666930 5783.84 12.00 5795.84 3 39.506397 -107.666501 5787.19 12.00 5799.19 4 39.506032 -107.666243 5785.93 12.00 5797.93 5 39.505900 -107.665471 5786.97 12.00 5798.97 6 39.506082 -107.665042 5786.96 12.00 5798.96 7 39.506645 -107.665106 5789.04 12.00 5801.04 8 39.506347 -107.661093 5732.93 12.00 5744.93 9 39.509956 -107.661372 5717.59 12.00 5729.59 10 39.510585 -107.662467 5724.29 12.00 5736.29 11 39.509443 -107.664527 5748.42 12.00 5760.42 Name: FP 1 Description: Threshold height: 50 ft Direction: 268.4° Glide slope: 3.0° Pilot view restricted? Yes Vertical view: 30.0° Azimuthal view: 50.0° Point Latitude (°) Longitude (°) Ground elevation (ft)Height above ground (ft) Total elevation (ft) Threshold 39.526872 -107.715609 5532.28 50.00 5582.28 Two-mile 39.527659 -107.678094 5661.46 474.27 6135.73 Discrete Observation Receptors Name ID Latitude (°) Longitude (°)Elevation (ft) Height (ft) OP 1 1 39.512768 -107.663084 5747.55 10.00 OP 2 2 39.513106 -107.667818 5802.21 10.00 OP 3 3 39.510728 -107.672407 5787.28 10.00 OP 4 4 39.503639 -107.661614 5715.80 10.00 OP 5 5 39.503288 -107.657864 5659.19 10.00 OP 6 6 39.504815 -107.658074 5644.12 10.00 OP 7 7 39.510233 -107.657167 5680.03 10.00 OP 8 8 39.511631 -107.656506 5664.97 10.00 OP 9 9 39.512371 -107.656420 5650.34 10.00 OP 10 10 39.513873 -107.660342 5632.41 10.00 OP 11 11 39.514821 -107.659221 5612.69 10.00 OP 12 12 39.514750 -107.658158 5588.22 10.00 OP 13 13 39.517561 -107.667909 5915.29 10.00 Name: FP 2 Description: Threshold height: 50 ft Direction: 88.2° Glide slope: 3.0° Pilot view restricted? Yes Vertical view: 30.0° Azimuthal view: 50.0° Point Latitude (°) Longitude (°) Ground elevation (ft)Height above ground (ft) Total elevation (ft) Threshold 39.526357 -107.740397 5465.38 50.00 5515.39 Two-mile 39.525474 -107.777908 5308.97 759.87 6068.84 Route Receptor(s) Name: Route 1 Path type: Two-way Observer view angle: 50.0° Note: Route receptors are excluded from this FAA policy review. Use the 2-mile flight path receptor to simulate flight paths according to FAA guidelines. Vertex Latitude (°) Longitude (°) Ground elevation (ft)Height above ground (ft) Total elevation (ft) 1 39.517130 -107.658015 5577.40 6.00 5583.40 2 39.516919 -107.658036 5577.77 6.00 5583.77 3 39.516217 -107.658229 5582.58 6.00 5588.58 4 39.514941 -107.658592 5590.59 6.00 5596.59 5 39.513583 -107.659069 5598.80 6.00 5604.80 6 39.513240 -107.659192 5599.88 6.00 5605.88 7 39.512714 -107.659514 5599.86 6.00 5605.86 8 39.512565 -107.659589 5597.80 6.00 5603.80 9 39.512321 -107.659681 5600.39 6.00 5606.39 10 39.511986 -107.659713 5602.64 6.00 5608.64 11 39.511518 -107.659734 5607.42 6.00 5613.42 12 39.510769 -107.659686 5610.45 6.00 5616.45 13 39.510264 -107.659723 5614.12 6.00 5620.12 14 39.509883 -107.659740 5616.31 6.00 5622.31 15 39.509635 -107.659654 5616.62 6.00 5622.62 16 39.509126 -107.659208 5622.52 6.00 5628.52 17 39.508778 -107.658919 5628.44 6.00 5634.44 18 39.507669 -107.658243 5636.02 6.00 5642.02 19 39.507454 -107.658152 5638.42 6.00 5644.42 20 39.507131 -107.658146 5640.83 6.00 5646.83 21 39.506638 -107.658211 5638.94 6.00 5644.94 22 39.505724 -107.658318 5644.21 6.00 5650.21 23 39.505003 -107.658436 5646.56 6.00 5652.56 24 39.504271 -107.658474 5647.81 6.00 5653.81 25 39.503588 -107.658398 5666.04 6.00 5672.04 26 39.503195 -107.658345 5669.11 6.00 5675.11 27 39.502661 -107.658382 5669.97 6.00 5675.97 28 39.501895 -107.658479 5667.74 6.00 5673.74 29 39.501634 -107.658500 5663.96 6.00 5669.96 Name: Route 2 Path type: Two-way Observer view angle: 50.0° Note: Route receptors are excluded from this FAA policy review. Use the 2-mile flight path receptor to simulate flight paths according to FAA guidelines. Vertex Latitude (°) Longitude (°) Ground elevation (ft)Height above ground (ft) Total elevation (ft) 1 39.514473 -107.658841 5592.49 6.00 5598.49 2 39.514535 -107.659163 5597.74 6.00 5603.74 3 39.514473 -107.659543 5603.76 6.00 5609.76 4 39.514427 -107.659656 5606.02 6.00 5612.02 5 39.514402 -107.660863 5624.97 6.00 5630.97 6 39.514303 -107.661244 5631.83 6.00 5637.83 7 39.513769 -107.662269 5667.44 6.00 5673.44 8 39.513711 -107.662489 5675.31 6.00 5681.31 9 39.513757 -107.662725 5685.33 6.00 5691.33 10 39.513910 -107.662880 5694.56 6.00 5700.56 11 39.514195 -107.663036 5707.19 6.00 5713.19 12 39.514394 -107.663036 5708.62 6.00 5714.62 13 39.514796 -107.662649 5703.46 6.00 5709.46 14 39.514957 -107.662585 5702.86 6.00 5708.86 15 39.515131 -107.662644 5700.93 6.00 5706.94 16 39.515242 -107.662746 5702.60 6.00 5708.60 17 39.515731 -107.664345 5734.14 6.00 5740.14 18 39.515739 -107.664575 5739.09 6.00 5745.09 19 39.515698 -107.664790 5744.09 6.00 5750.09 20 39.515214 -107.666158 5761.70 6.00 5767.70 21 39.515234 -107.666378 5762.47 6.00 5768.47 22 39.515321 -107.666635 5766.17 6.00 5772.17 23 39.515534 -107.667247 5772.91 6.00 5778.91 24 39.515840 -107.668186 5774.02 6.00 5780.02 25 39.516088 -107.669221 5768.79 6.00 5774.79 26 39.516063 -107.669435 5767.92 6.00 5773.92 27 39.515956 -107.669736 5761.05 6.00 5767.05 28 39.515985 -107.670186 5754.36 6.00 5760.36 29 39.516084 -107.670723 5750.01 6.00 5756.01 30 39.516274 -107.671066 5746.69 6.00 5752.69 31 39.516523 -107.671436 5747.91 6.00 5753.91 32 39.516701 -107.671721 5748.25 6.00 5754.25 33 39.516850 -107.672230 5745.84 6.00 5751.84 34 39.517110 -107.672676 5740.90 6.00 5746.90 35 39.517781 -107.673529 5738.50 6.00 5744.50 36 39.518037 -107.673807 5738.57 6.00 5744.57 37 39.518368 -107.674140 5737.59 6.00 5743.59 38 39.519279 -107.674784 5749.13 6.00 5755.13 GLARE ANALYSIS RESULTS Summary of Glare PV Array Name Tilt Orient "Green" Glare "Yellow" Glare Energy (°) (°) min min kWh PV array 1 SA tracking SA tracking 0 0 - PV array 2 SA tracking SA tracking 0 0 - Total annual glare received by each receptor Receptor Annual Green Glare (min) Annual Yellow Glare (min) FP 1 0 0 FP 2 0 0 OP 1 0 0 OP 2 0 0 OP 3 0 0 OP 4 0 0 OP 5 0 0 OP 6 0 0 OP 7 0 0 OP 8 0 0 OP 9 0 0 OP 10 0 0 OP 11 0 0 OP 12 0 0 OP 13 0 0 Route 1 0 0 Route 2 0 0 Results for: PV array 1 Receptor Green Glare (min) Yellow Glare (min) FP 1 0 0 FP 2 0 0 OP 1 0 0 Receptor Green Glare (min) Yellow Glare (min) OP 2 0 0 OP 3 0 0 OP 4 0 0 OP 5 0 0 OP 6 0 0 OP 7 0 0 OP 8 0 0 OP 9 0 0 OP 10 0 0 OP 11 0 0 OP 12 0 0 OP 13 0 0 Route 1 0 0 Route 2 0 0 Flight Path: FP 1 0 minutes of yellow glare 0 minutes of green glare Flight Path: FP 2 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 1 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 2 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 3 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 4 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 5 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 6 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 7 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 8 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 9 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 10 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 11 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 12 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 13 0 minutes of yellow glare 0 minutes of green glare Route: Route 1 0 minutes of yellow glare 0 minutes of green glare Route: Route 2 0 minutes of yellow glare 0 minutes of green glare Results for: PV array 2 Receptor Green Glare (min) Yellow Glare (min) FP 1 0 0 FP 2 0 0 OP 1 0 0 OP 2 0 0 OP 3 0 0 OP 4 0 0 OP 5 0 0 OP 6 0 0 OP 7 0 0 OP 8 0 0 OP 9 0 0 OP 10 0 0 OP 11 0 0 OP 12 0 0 OP 13 0 0 Route 1 0 0 Route 2 0 0 Flight Path: FP 1 0 minutes of yellow glare 0 minutes of green glare Flight Path: FP 2 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 1 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 2 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 3 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 4 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 5 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 6 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 7 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 8 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 9 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 10 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 11 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 12 0 minutes of yellow glare 0 minutes of green glare Point Receptor: OP 13 0 minutes of yellow glare 0 minutes of green glare Route: Route 1 0 minutes of yellow glare 0 minutes of green glare Route: Route 2 0 minutes of yellow glare 0 minutes of green glare Assumptions 2016 © Sims Industries d/b/a ForgeSolar, All Rights Reserved. "Green" glare is glare with low potential to cause an after-image (flash blindness) when observed prior to a typical blink response time. "Yellow" glare is glare with potential to cause an after-image (flash blindness) when observed prior to a typical blink response time. Times associated with glare are denoted in Standard time. For Daylight Savings, add one hour. Glare analyses do not account for physical obstructions between reflectors and receptors. This includes buildings, tree cover and geographic obstructions. Several calculations utilize the PV array centroid, rather than the actual glare spot location, due to V1 algorithm limitations. This may affect results for large PV footprints. Additional analyses of array sub-sections can provide additional information on expected glare. The subtended source angle (glare spot size) is constrained by the PV array footprint size. Partitioning large arrays into smaller sections will reduce the maximum potential subtended angle, potentially impacting results if actual glare spots are larger than the sub-array size. Additional analyses of the combined area of adjacent sub-arrays can provide more information on potential glare hazards. (See previous point on related limitations.) Glare locations displayed on receptor plots are approximate. Actual glare-spot locations may differ. Glare vector plots are simplified representations of analysis data. Actual glare emanations and results may differ. The glare hazard determination relies on several approximations including observer eye characteristics, angle of view, and typical blink response time. Actual results and glare occurrence may differ. Hazard zone boundaries shown in the Glare Hazard plot are an approximation and visual aid based on aggregated research data. Actual ocular impact outcomes encompass a continuous, not discrete, spectrum. Refer to the Help page at www.forgesolar.com/help/ for assumptions and limitations not listed here. AES Peace Bear Ranch Solar – Land Use Change – Major Impact permit application (11/5/2021) AES Peace Bear Ranch Solar – Garfield County 54 Please see the following pages for a Letter of Attestation from Holy Cross Energy in support for AES Peace Bear Ranch Solar, LLC provided in August 2021. HOLY CROSS ENERGY LETTER OF ATTESTATION Appendix C8 3799 HIGHWAY 82∙P.O. DRAWER 2150 GLENWOOD SPRINGS, COLORADO 81602 (970) 945-5491∙FAX (970) 947-5480 August 5, 2021 AES Clean Energy 282 Century Place, Suite 2000 Louisville, CO 80027 RE: Letter of Support Dear Mr. Mayer, Please let this letter serve as an attestation that Holy Cross Energy (HCE) is supportive of AES’s High Mesa and Peace Bear Ranch projects in development in Garfield County. HCE confirms there is a Power Purchase Agreement in place with AES for both projects, with scheduled Commercial Operation dates of December 31, 2022. While this letter serves to support AES’s permit efforts with Garfield County, it does not constitute permission to operate in parallel with HCE’s electric distribution system. HCE and AES will continue to coordinate to ensure the requirements of the Power Purchase Agreement are met, a Generator Interconnection Agreement is signed by both parties, and the requirements of that Generator Interconnection Agreement are met prior to the facility operating in parallel with HCE’s electric distribution system. The Peace Bear Ranch project is additionally contingent on results from Public Service Company of Colorado’s Affected System Study. Please contact me with any questions and concerns. Sincerely, HOLY CROSS ENERGY Sam Whelan Manager, Power Supply AES Peace Bear Ranch Solar – Land Use Change – Major Impact permit application (11/5/2021) AES Peace Bear Ranch Solar – Garfield County 55 Please see the following pages for AES’ Fire Risk Assessment of Battery Storage Systems similar to those designed and specified for AES Peace Bear Ranch Solar, LLC. AES BATTERTY STORAGE SYSTEM FIRE RISK ASSESSMENT Appendix C9 AES Distributed Energy Contains Proprietary Information Page 1 of 18 Fire Risk Assessment for Outdoor, Remote, Non-Walk-in BESS Enclosures 26 Nov 2019 Rev 1 for SMART Projects 10 April 2020 Rev 2 Modified for NY DER Projects 1 May 2020, Rev 2. Part 3 Covering NFPA 1 Ch 52 Added AES Distributed Energy Contains Proprietary Information Page 2 of 18 Contents Purpose ......................................................................................................................................................... 4 Part 1. Fire Safety Analysis Based on NFPA 551 and NFPA 550 .................................................................... 4 1. Fire Safety Objectives ............................................................................................................................ 4 Risk Criteria ........................................................................................................................................... 4 Protection of Human Life ...................................................................................................................... 4 Protection of Property .......................................................................................................................... 5 Protection of Business .......................................................................................................................... 5 Fire Scenarios ........................................................................................................................................ 5 2. Prevent Fire Ignition .............................................................................................................................. 6 Combustible Materials and Mitigation ................................................................................................. 6 Potential Causes of Ignition and Mitigation .......................................................................................... 6 3. Manage Fire Impact .............................................................................................................................. 7 Fire Detection ........................................................................................................................................ 7 Fire Control ........................................................................................................................................... 8 Fire Emergency Response ..................................................................................................................... 9 Part 2. Fire Safety Analysis Based on NFPA 855.......................................................................................... 10 Chapter 4 ................................................................................................................................................. 10 Section 4.1 General and 4.14 Hazard Mitigation Analysis ...................................................................... 10 Section 4.2 Equipment ............................................................................................................................ 12 Section 4.3 and 4.4 Installation Requirements and Location ................................................................. 12 Sections 4.5 4.6, 4.7, 4.8, & 4.9 ............................................................................................................... 13 Section 4.10 Smoke and Fire Detection .................................................................................................. 13 Section 4.11 Fire Control and Suppression ............................................................................................. 13 Section 4.12 Explosion Control ............................................................................................................... 13 Section 4.13 Water Supply ...................................................................................................................... 13 Sections 4.14, 4.15 .................................................................................................................................. 14 Section 4.16 Remediation Measures ...................................................................................................... 14 Chapter 5. System Interconnections ...................................................................................................... 14 Chapter 6, 7 & 8 ...................................................................................................................................... 14 Chapter 9 Electrochemical Energy Storage Systems .............................................................................. 14 Chapters 10, 11, 12, 13, 14, & 15 ............................................................................................................ 14 Part 3. Fire Safety Analysis Based on NFPA 1 Chapter 52 ........................................................................... 15 AES Distributed Energy Contains Proprietary Information Page 3 of 18 Section 52.1 General and 52.2 Permits................................................................................................... 15 Section 52.2 PdAcid & NiCd, Section 52.3.3 Capacitors ......................................................................... 15 Section 52.3.2.1 Location ........................................................................................................................ 15 Section 52.3.2.2 and 3 Max Allowable Quantities, Battery Arrays ......................................................... 15 Section 52.3.2.4 Hazard Mitigation Analysis ........................................................................................... 15 Section 52.3.2.5 Listings .......................................................................................................................... 15 Section 52.3.2.6 Installation ................................................................................................................... 16 Sections 52.3.2.6. 6, 7 & 8. Seismic, Caps and Mixed Batteries............................................................. 16 Section 52.3.2.7 Fire Suppression and Detection ................................................................................... 16 Section 52.3.2.8 & 9 Ventilation and Spill Control .................................................................................. 16 Section 52.3.2.10 and 11 Thermal Runaway for Lithium Ion Batteries .................................................. 16 Section 52.3.2.12 Testing, Maintenance, and Repairs. ........................................................................... 16 Definitions ................................................................................................................................................... 17 Reference Documents ................................................................................................................................. 17 AES Distributed Energy Contains Proprietary Information Page 4 of 18 Purpose This assessment provides justification and explanation for the Fire Safety Design, Implementation and Operation of the AES BESS enclosure for outdoor, remote, non-walk-in type enclosures for energy storage facilities owned and operated by AES in an area under access control to only qualified individuals. Part 1. Fire Safety Analysis Based on NFPA 551 and NFPA 550 This part of the analysis uses the concepts outlined in NFPA 551 on Evaluation of Fire Risk Assessments, and NFPA 550 on a Fire Safety Concepts Tree (Figure 1). First, the fire safety objectives are defined. Then, there is an examination on preventing a fire, and how to manage the impact of the fire if one does occur. Figure 1 Fire Safety Concepts Tree 1. Fire Safety Objectives The fire safety objectives for this product are: 1. No harm to personnel, including operators, first responders and bystanders outside the project boundary. 2. Minimize impact to the environment. 3. Minimize the fire risk to assets. Risk Criteria • No harm to personnel is acceptable • Negligible harm to assets with an Occasional probability • Marginal harm to assets with a Remote probability • Critical and Catastrophic harm to assets should be Improbable Protection of Human Life Since these enclosures are non-walk-in, and access is restricted, the fire hazard harm to people would be the result of a fire, or explosion that escapes the boundary of the enclosure to a person in the vicinity. Fire Safety Objectives Prevent Fire Ignition Manage Fire Impact Control Heat- Energy Sources Control Source- Fuel Interactions Control Fuel Manage Fire Manage Exposed AES Distributed Energy Contains Proprietary Information Page 5 of 18 Thus, if a fire were to occur, containing it, preventing an explosion, and making sure people are not in the vicinity during a fire is the priority. Protection of Property There is a significant investment in the assets within the enclosure. The priority for protecting these assets from fire damage is preventing the fire in the first place. If there is a fire of any significance, it would be undesirable to re-use the batteries and equipment. After a fire event, the probability of a compromised material that could due further damage to the system is high. Therefore, there is no value is preserving the equipment in the enclosure if a fire event happens. There is value in preserving the property assets within the vicinity of the BESS enclosure, such as the PCS and transformers. Thus, if a fire were to occur, containing it and preventing an explosion are the asset protection priorities. Protection of Business Any fire event would negatively impact the business in terms of operating revenue, reputation, and the ability to execute additional projects. Again, the priority is not to have a fire in the first place. Any fire that did occur would require the replacement of the BESS equipment. The generating plant would not be operational, which would result in lost revenue. Fire Scenarios The fire assessment considers the following Fire Scenarios, as described in NFPA 551: (1) Fire ignition. Often based on the most probable event in a particular setting, for example, cigarette ignition of a couch in a living room. Prevention education would reduce the probability of occurrence of this event and the consequential risks. (2) Fire growth. Based on all probable developments of a fire, from smoldering to flashover fires. Fire protection systems such as sprinklers, compartmentation, and door closers may help to contain these fires and to reduce their consequential risks. The reduction in risk depends on the reliability and effectiveness of the fire control systems. (3) Smoke spread. Based on smoke spread to critical egress routes and other parts in a building. Fire protection systems such as smoke control and stairwell pressurization may help to contain the smoke and to reduce its consequential risks. The reduction in risk depends on d1e reliability and effectiveness of the smoke control systems. (4) Exposure of occupants. Based on smoke and fire blocking egress routes. Fire protection systems such as fire alarms, voice communication, clear egress routes, and refuge areas may help to provide early warning to occupants and to direct them either to evacuate the building or to seek refuge in certain areas. The reduction in risk depends on the reliability and effectiveness of the warning and evacuation systems. (5) Failure of fire department to respond. Based on no response or late response. Proper notification procedure and adequate fire department resources would help to rescue the trapped occupants or to control the fire. The reduction in risk depends on the reliability of the notification procedure and the adequacy of fire department resources. AES Distributed Energy Contains Proprietary Information Page 6 of 18 2. Prevent Fire Ignition Combustible Materials and Mitigation The BESS enclosure structural elements are mostly metal, or other non-combustible materials. Combustible materials in the BESS enclosure include: 1. Electrochemical components of the batteries, namely the electrolyte, o The combustion properties of the Samsung batteries have been studied and tested according to UL9540A. Although most of the report is confidential, a redacted portion of that report is submitted as a reference in this report, which includes gas compositions and flame spread properties. In a multi-rack test, fire that was initiated in one rack did not spread to the adjacent racks. 2. Plastic in the housing of the battery modules, o The effects of the plastic housing are included Samsung’s UL9540A findings. 3. Some enclosure barrier walls to control air flow, o The material is a construction grade polycarbonate and contains a Flame Retardant, listed as an ASTM E84-01 Class A material. 4. Some auxiliary component housings o Minimal material in the form of plastic fittings and covers. 5. Polyurethane spray foam under the steel floor o Contains fire retardant to meet E-84 Class 1 approvals. 6. Electrical cable insulation o All cables are rated for the voltage and installation location, according to the NFPA 70E type and UL listing. o Most common conductor insulation types are NFPA 70E types MTW and RHW-2. 7. Potential unwarranted combustible materials not part of the system that would be placed inside the container counter to signage, policy, and training. o The site is fenced and monitored. The container is locked. Door switches alarm if a door is opened and the system shuts down automatically if a door is opened during operation. Potential Causes of Ignition and Mitigation The most common ignition of fires in BESS containers are: 1) Electrical fires caused by resistance heating due to: a) Conductors sized too small; o The design has been reviewed and all conductor sizes are sufficient to prevent overheating b) Conductors with loose interconnections connections. o All electrical connections require torque marks to be checked during QC steps o All electrical connections require lock-nuts or spring washers to ensure tight connections o Annual Maintenance checks review major electrical connections to ensure connections remain tight over the life of the project 2) Chemical fires caused by heating of the batteries due to: a) Exceeding State of Charge (SOC) limits by over-charging or discharging the batteries AES Distributed Energy Contains Proprietary Information Page 7 of 18 o The SOC is managed and tracked by the BMS. Alarms and automatic shutdowns occur if the SOC limits are exceeded. b) Exceeding Rate of Charge/Discharge (C-rate) limits o The C-rate is managed and tracked by the BMS. Alarms and automatic shutdowns occur if the SOC limits are exceeded. c) Poor State of Health (SOH) due to degradation of the batteries o The SOH is managed and tracked by the BMS. Alarms and automatic shutdowns occur if the SOH drops below a minimum threshold. d) Exceeding acceptable interior environmental controls, hot air temperature or condensation o An HVAC system controls the interior environment. This system in monitored by the PPC against lockouts, high or low air temperatures, and high humidity. Alarms and automatic shutdowns occur if the temperature or humidity threshold limits are exceeded. e) Failure of a battery component o Component failures would result in temperature and/or voltage variances. Temperatures and voltages of all cells are monitored at 1 second intervals by the BMS. Alarms and automatic shutdowns occur if the temperatures or temperature variations exceed safe thresholds. Alarms and automatic shutdowns occur if the voltages or voltage variations exceed safe thresholds. Alarms detected by the BMS are watched by the PPC and SCADA to alert operational staff of hazards, and the PPC has a watchdog timer to monitor communication status to the BMS. The PPC has additional redundant protection measures based on temperatures and voltages that it monitors. 3) Arson a) The container is set fire due to criminal activity. o The site is fenced and monitored. The container is locked. Door switches alarm if a door is opened and the system shuts down automatically if a door is opened during operation. 3. Manage Fire Impact Fire Detection In addition to fire detection, strategies also include detection of flammable gases that could increase the chance of a fire. 1) Smoke Detectors. There are four detectors in the enclosure at locations to meet the design guidelines of NFPA 72. The detectors are tied to the Fire Control Panel, which provides alarm signals to the PPC through the enclosure PLC. 2) Air Temperature Sensors. There are 6 temperature sensors located in the enclosure. Heat from a fire could be detected by these sensors. High temperature alarms are handled by the PPC. 3) Battery Cell Temperature Sensors. There are 3 temperature sensors in every module. These temperature sensors would capture off-gassing threshold temperature and run-away temperature thresholds. Temperatures and alarms are monitored by the BMS and PPC. AES Distributed Energy Contains Proprietary Information Page 8 of 18 Fire Control 1) Fire Suppression A Fire Suppression System with NOVEC 1230 is included in these containers. Although NFPA 2001 is intended for occupied buildings and this BESS container is not occupied, the design of the fire suppression system complies with the relevant parts of that standard. Cup burner tests on the electrolyte in the Samsung batteries resulted in a 5.6% Novec 1230 concentration to extinguish the fire. Even though other studies and actual events have shown that large scale lithium battery fires were not able to be put out by a clean agent fire suppression system, the suppression system in these containers will suppress a smaller fire from a non-battery source and prevent it from becoming a larger fire. 2) Explosion Control, NFPA 68 and 69 NFPA 69: Explosion Control There is no flammable gas released during the normal operation of the unit. Therefore, a continuous or intermittent ventilation system is not required, nor desirable. If several operational safety stops fail, and a hazard occurs that brings the batteries to exceed 160 °C, then thermal decomposition could occur, during which flammable gas could be released from the batteries. The first method for predicting a potential flammable gas condition checks for excessive battery temperature and voltage readings. This method is the most reliable. If excessive voltage and temperatures are detected by the rBMS, sBMS, or PCS controller, the system is automatically shut down, and AES operators are notified. As a secondary detection method, gas detectors for Hydrogen (H2), Carbon Monoxide, (CO), and/or methane (CH4), can be added and connected to an active exhaust system. Based on testing of the gases vented from a battery, these three have the highest fraction as shown in Table 1. When one of these flammable gasses are detected, the exhaust system activates. The exhaust system blows at about 3000 cfm, so for a 40’ HC container size enclosure, the turnover time is about 1 minute. Table 1. Measured Gas Composition of a Vented Cell (SDI Confidential Information) Gas Measured v/v% Component LFL Hydrogen 31.8% 4.0% Carbon Monoxide 19.4% 10% Methane 9.2% 4.4% Other Various HC Gasses* 11% ~2% Non-Flammable CO2 28.6% N/A *Various C2-C5 hydrocarbons released, but none > 5.5% and most > 1%. NFPA 68: Deflagration Venting Because the system has a flammable gas detection and active exhaust system, deflagration protection is not required. Even so, the calculations per NFPA 68 were calculated for informative purposes. AES Distributed Energy Contains Proprietary Information Page 9 of 18 Deflagration venting using the off-gassing data from Samsung’s UL9540A tests would require a rupture area of 14 m2 to prevent the internal pressure from rising above the safe requirements of a low strength structure (<0.5 bar-g rise). There are 105 meters of linear door seal area with a width of 2 cm (2 m2) that would also blow out in an explosive event. In an explosive event the pressure inside the container could reach 3.5 bar-g with the rupture vents and doors seals release according to high strength structure calculations. Such a deflagration event could only occur upon the failure of all four levels of protection that are in place. 3) Fire Spread and Exposures Containers are spaced a minimum of 8 feet from other electrical equipment, and at least 16 feet from any combustible materials. This separation reduces the likelihood that a fire originating in the battery container will spread to other equipment, or that fire originating outside the battery container will spread to the container. Fire Emergency Response First responders should not approach the container if there is a fire in the BESS. Fire control management should be restricted to protect property surrounding the site and prevent the fire from spreading beyond the site. AES will provide a Fire Mitigation Person in the event there is a fire. This person will be one of the AES operations members in the area and assigned to that site. AES Distributed Energy Contains Proprietary Information Page 10 of 18 Part 2. Fire Safety Analysis Based on NFPA 855 NFPA 855 is the newest Fire Code specifically written to address safety for large stationary battery systems. This assessment reviews NFPA 855 for the sections specific to the Hazard Analysis. Adherence to requirements of NFPA 855 regarding the general design, construction and operation are incorporated in the project design documents. Chapters 1, 2 and 3 are informative. Chapter 4 The design, construction, and operation of the system complies with the relevant sections of Chapter 4. Section 4.1 General and 4.14 Hazard Mitigation Analysis The General requirement in Section 4.1 have been followed for this system. The following responds to NFPA 855, Section 4.1.4 Hazard Mitigation Analysis. 4.1.4.1* A hazard mitigation analysis shall be provided to the AHJ for review and approval when any of the following conditions are present: (1) When technologies not specifically addressed in Table 1.3 are provided. (2) More than one ESS technology is provided in a room or indoor area where adverse interaction between the technologies is possible. (3) When allowed as a basis for increasing maximum stored energy as specified in 4.8.1 and 4.8.2. Items 1 and 2 do not apply. Item 3 applies as the Max Stored energy in Table 4.8 is 600 kWh and this project stores up to 4240 kWh in an enclosure. 4.1.4.2 The analysis shall evaluate the consequences of the following failure modes and others deemed necessary by the AHJ: (1) Thermal runaway condition in a single module, array, or unit (2) Failure of an energy storage management system (3) Failure of a required ventilation or exhaust system (4) Failure of a required smoke detection, fire detection, fire suppression, or gas detection system 4.1.4.2.1 Only single failure modes shall be considered for each mode given in 4.1.4.2. These 4 items have been included in the FMEA: 1) Thermal runaway conditions in a single module, array and rack have been evaluated and reported by Samsung in their UL 9540A report. In summary, it was found that off gassing of a cell occurs at temperature greater than 160 °C, thermal runaway occurs and temperature greater than 168 °C. A thermal runaway propagated to other cells in a single module but did not propagate to other modules. And, a thermal runaway in one rack did not propagate to another rack. There were no re- ignitions after the initial event and no flaming occurred during the test. Each cell can release up to 144L of gas during complete thermal decomposition. To reach the LFL (5.5%) during off-gassing, every cell in at least 1.3 modules would need to vent. AES Distributed Energy Contains Proprietary Information Page 11 of 18 2) A failure of power or communications of the BMS or PPC results in the automatic shut down of the system and disconnection of strings from the DC bus. This puts the system in a safe condition from electrical fires caused by faults, overcharging, or undercharging. a) The BMS protection map is found in Section 2 of the Samsung O&M Manual. b) The PPC protection map is found in the GPTech PPC Signal List, v0.5.1 or newer. 3) There is no continuous exhaust ventilation required for this system. A failure of the flammable gas detection and ventilation system could result in a combustible gas mixture in the enclosure, which could result in an explosion, ONLY IF THE FOLLOWING ADDITIONAL FAILURES TAKE PLACE: a) The PPC fails to detect and act on an over or undercharging condition; and b) The BMS fails to detect and act on an over or undercharging condition; and c) The PPC and BMS fail to detect cell temperatures that exceed the off-gassing limits; and d) A significant number of cells simultaneously reach the critical temperature for off gassing such that the Flammability Limits are reached; and e) An ignition source is available that initiates combustion of the gasses. The probability that all these failure events would occur is considered improbable and is not necessary to consider according to 4.1.4.2.1. One condition where such simultaneous failures could take place would be a large site fire that started externally and engulfed the battery enclosure, which is made unlikely through the separation from combustible materials. 4) The fire suppression system installed in the container is primarily to limit the possible spread of an electrical or other non-battery fire. The fire suppression system is monitored by the PPC, which will shut down the system if communication is lost or the fire suppression system triggers a system lockout as a result of an internal error. 4.1.4.3 The AHJ shall be permitted to approve the hazardous mitigation analysis as documentation of the safety of the ESS installation provided the consequences of the analysis demonstrate the following: (1) Fires will be contained within unoccupied ESS rooms for the minimum duration of the fire resistance rating specified in 4.3.6. (2) Suitable deflagration protection is provided where required. (3) ESS cabinets in occupied work centers allow occupants to safely evacuate in fire conditions. (4) Toxic and highly toxic gases released during normal charging, discharging, and operation will not exceed the PEL in the area where the ESS is contained. (5) Toxic and highly toxic gases released during fires and other fault conditions will not reach concentrations in excess of immediately dangerous to life or health (IDLH) level in the building or adjacent means of egress routes during the time deemed necessary to evacuate from that area. (6) Flammable gases released during charging, discharging, and normal operation will not exceed 25 percent of the LFL. 1) This requirement is not applicable as the BESS enclosure is not in the vicinity of any occupied building or structure. AES Distributed Energy Contains Proprietary Information Page 12 of 18 2) Deflagration protection is provided by prevention and detection of flammable gases, and finally the failure of the door seals and rupture vents. See the section below on deflagration analysis. 3) This requirement is not applicable as the BESS enclosure is unoccupied. 4) There are no toxic gases released during normal operation. 5) Since the enclosure is non-occupied, this section does not apply. The hazard was investigated for personnel that may be in the vicinity, external to the enclosure. During nail penetration tests, thermal off gassing and combustion of the Samsung batteries, there was minimal toxic gases produced, the most abundant being carbon monoxide as shown in Figure 2 and Figure 3. 6) There are no flammable gasses released during normal operation. Figure 2 – Gas evolved from two nail penetration tests of a Samsung Battery Cell (94Ah). Figure 3 – Gas evolved from thermal run-away tests of a Samsung Battery Cell (94Ah). 4.1.4.4 The hazard mitigation analysis shall be documented and made available to the AHJ and those authorized to design the operate the system. This report will be made available as required. 4.1.4.5* Construction, equipment, and systems that are required for the ESS to comply with the hazardous mitigation analysis shall be installed, tested, and maintained in accordance with this standard and the manufacturer's instructions. This requirement is met by the Quality Control procedure and documents as part of the system commissioning. The overall site Operations and Maintenance manual includes all necessary commissioning tests, which may be repeated from time to time to ensure ongoing safe operation of the system. Section 4.2 Equipment The section relates to the design and operation of the system. The system complies to the applicable requirements. Section 4.3 and 4.4 Installation Requirements and Location The BESS facilities assessed are considered Outdoor, Remote, and Non-occupied. As a result, many of the requirements in Section 4.3 and 4.4 do not apply Gas H2 CO CO2 CH4 C2H6 C2H4 C3H8 C3H6 C3H4 C4's C5's Sample 31.8%19.4%28.6%9.2%0.52%5.5%0.20%3.4%0.03%1.3%0.053% AES Distributed Energy Contains Proprietary Information Page 13 of 18 4.4.3.1 Remote outdoor locations include ESS located more than 100 ft (30.5 m) from buildings, lot lines that can be built upon, public ways, stored combustible materials, hazardous materials, high-piled stock, and other exposure hazards not associated with electrical grid infrastructure. Sections 4.5 4.6, 4.7, 4.8, & 4.9 Section 4.5 on Mobile systems does not apply. Section 4.6. Per 4.6.1, Size and Separation restrictions do not apply for this system. Section 4.7 Occupied Work Center restrictions does not apply. Section 4.8 Maximum stored energy restrictions do not apply. Section 4.9 Exhaust Ventilation does not apply. Section 4.10 Smoke and Fire Detection 4.10.1 All fire areas containing ESS systems located within buildings or structures shall be provided with a smoke detection system in accordance with NFPA 72. Smoke detectors are included in the design per NFPA 72 Sections 17.7. Section 4.11 Fire Control and Suppression Fire Suppression systems are not required for this system (outdoor, remote, non-walk-in) according to 4.11.1, as it is not required elsewhere in the standard. Chapter 9 requires thermal runaway mitigation, which can be addressed through other means. Section 4.11.4-9 specifically exempt several types of systems, namely 4.11.9: 4.11.9 When approved by the AHJ, ESS shall be permitted to be installed in outdoor walk-in enclosures without the protection of an automatic fire control and suppression system where large-scale fire testing conducted in accordance with 4.1.5 documents that an ESS fire does not compromise the means of egress and does not present an exposure hazard in accordance with 4.4.3.3 and 4.4.3.4. There seems to be a section missing that exempts outdoor non-walk-in enclosures, in which the hazard is significantly less. Although not required, the BESS system includes a clean-agent fire suppression system. Section 4.12 Explosion Control Explosion control is required from Chapter 9. Explosion Control involves 1) explosion prevention and 2) deflagration venting. 4.12.2 Explosion prevention and deflagration venting shall not be required where approved by the AHJ based on largescale fire testing in accordance with 4.1.5 that demonstrates that flammable gas concentrations in the room, building, or walk-in unit cannot exceed 25 percent of the LFL in locations where the gas is likely to accumulate. The BESS system addresses explosion control as described in Section 3 of Part 1 of this document. Section 4.13 Water Supply Water is not supplied for these systems, so requirements of NFPA 1142 apply. AES Distributed Energy Contains Proprietary Information Page 14 of 18 Sections 4.14, 4.15 Section 4.14 Spill Control does not apply to this system, as it does not employ a liquid electrolyte. Section 4.15 Neutralization does not apply to this system. Section 4.16 Remediation Measures 4.16.2.1 When, in the opinion of the AHJ, it is essential for public safety that trained personnel be on site to respond to possible ignition or reignition of damaged the ESS, the owner, agent, or lessee shall provide one or more fire mitigation personnel, as required and approved, at their expense. 4.16.2.2 These personnel shall remain on duty continuously after the fire department leaves the premises until the damaged ESS is removed from the premises or the AHJ indicates they can leave. 4.16.2.3 On-duty fire mitigation personnel shall have the following responsibilities: (1) Keep diligent watch for fires, obstructions to means of egress, and other hazards (2) Immediately contact the fire department if their assistance is needed to mitigate any hazards (3) Take prompt measures for remediation of hazards and extinguishment of fires that occur (4) Take prompt measures to assist in the evacuation of the public from the structures Section 4.16 specifies that AES is to provide trained personnel to respond and be on site in the event there is a fire. AES has an operations crew in the area for this purpose. Chapter 5. System Interconnections 5.1* General. All electrical connections and wiring to and from an ESS or the components of an ESS shall be in accordance with NFPA 70 or IEEE C2 based on the location of the ESS in relation to and its interaction with the electrical grid. The system design meets the specifications of Section 5 where applicable. Chapter 6, 7 & 8 Chapter 6 Commissioning, Chapter 7 on Operation and Maintenance, and Chapter 8 on Decommissioning does not contain material for the Hazard Analysis. These elements are addressed in the BESS O&M Manual. Chapter 9 Electrochemical Energy Storage Systems Chapter 9 specifies that Lithium-Ion ESS need compliance with thermal runaway, explosion control and size and separation, but do not need exhaust ventilation, spill control, neutralization, or safety caps. Chapters 10, 11, 12, 13, 14, & 15 These chapters do not apply to this system. AES Distributed Energy Contains Proprietary Information Page 15 of 18 Part 3. Fire Safety Analysis Based on NFPA 1 Chapter 52 Chapter 52 of NFPA 1 up until 2018 was a code addressing safety of battery systems in buildings, specifically for facility standby power, emergency power, or uninterrupted power supplies. The 2018 version was expanded to include stationary battery systems of all types; however, still heavily focused on batteries in or associated with occupied buildings, so most of this code is not applicable to this BESS project system. The requirements of NFPA 1 Chaper 52 are compatible, although less specific for this type of project, than the requirements in NFPA 855. The following addresses each part of Chapter 52. Section 52.1 General and 52.2 Permits Energy storage systems shall comply with Chapter 52. Permits, where required, shall comply with Section 1.12 of NFPA 1, which provides requirements for AHJ permitting. Section 52.2 PdAcid & NiCd, Section 52.3.3 Capacitors Lead-Acid, NiCd, and Capacitors – Not applicable to this project. Section 52.3.2.1 Location This section specifies requirements for outdoor, non-walk in systems to be in noncombustible enclosures that are locked and accessible only to authorized persons. The enclosure shall be separated from other buildings, lot lines by at least 5’; and separate from any means of egress from other buildings by 10’. Section 52.3.2.2 and 3 Max Allowable Quantities, Battery Arrays Section *.2 addresses batteries in occupied buildings or rooms and does not apply. In addition, the BESS system for this study has undergone a hazardous mitigation analysis and the battery system has large scale fire and fault testing performed (UL9540A) by the battery manufacturer. Per this section *.3, the BESS system studied here should be permitted to exceed the capacity limits of table 52.3.2.2.1 because a the system has undergone large-scale fire and fault conditions testing showing that a fire involving one array will not propagate to an adjacent array, and be contained within the room per 53.3.2.1.3 (which does not apply because it is for inhabited buildings). Section 52.3.2.4 Hazard Mitigation Analysis An FMEA has been performed for the BESS system studied in this report, and thus provides further allowance to increase the quantities specified in Tabel 52.3.2.2.1. Most of this section refers to occupied buildings, which is not applicable to this project. There are no toxic or flammable gasses released during charging, discharging, or normal operation. Equipment and Systems required to comply with the hazard mitigation analysis shall be installed, maintained, and tested per national standards. The BESS system studied here complies as all components of the safety systems are UL listed. Section 52.3.2.5 Listings The batteries in this BESS project are UL 1973 listed. The project system studied here is a custom design by Professional Engineers and sealed accordingly; it is not a prepackaged or pre-engineered system. The AES Distributed Energy Contains Proprietary Information Page 16 of 18 battery enclosure includes environmental control to meet conditions within the battery manufacturers specifications. Section 52.3.2.6 Installation The project system contains an advanced BMS and SCADA that addresses requirements of article *.1. The charger is the PCS, a UL listed pre-engineered component meeting article *.2. The battery system is protected from vehicle impacts per article *.3. There is no combustibles stored in the container, which meets article *.4. Signage for the project system is included in the design set and has been reviewed to meet article *.5. Sections 52.3.2.6. 6, 7 & 8. Seismic, Caps and Mixed Batteries. The project system is designed per seismic code. Vented caps are not required for Li-Ion systems. There are small Lead Acid back-up batteries for the controls and Fire Safety System in the enclosure with the Lithium Ion batteries, and there is no unsafe interaction between them. Section 52.3.2.7 Fire Suppression and Detection The project system is not a building or habitable room so an automatic sprinkler system is not required. The system contains a Clean Agent Fire Suppression system with a design based on NFPA 2001 (although that code is for habitable rooms, and so is not completely applicable) and fire and fault testing. The project system contains a Fire Safety System with detection, alarms and monitoring meeting article *.2. Section 52.3.2.8 & 9 Ventilation and Spill Control For the Project System, Ventilation is not required for lithium ion systems per 52.3.2.11.1. Spill Control and Neutralization is not require for Lithium ion systems per 52.3.2.11.1. Section 52.3.2.10 and 11 Thermal Runaway for Lithium Ion Batteries A device or method shall be provided to preclude, detect, and control thermal runaway is required per 52.3.2.11.1. The FMEA analysis and the accompanying Alarm and Protection tables for the SCADA, BMS, physical design and Fire Safety System describe this compliance. Section 52.3.2.12 Testing, Maintenance, and Repairs. This section states testing and maintenance shall be in accordance with the manufactures instructions, by which the compliance is explained in the project design and operation documentation. AES Distributed Energy Contains Proprietary Information Page 17 of 18 Definitions • BESS – Battery Energy Storage System – Overall system for storing electrical energy, including the battery modules, containers, power converters, controls, and protection devices. • BMS – Battery Management System – Controller responsible for management of the battery bank, including module-level data such as voltage and temperature, rack-level data such as min/max temperature and state of charge, and bank-level data such as # of racks connected, state of health, and alarms. • PLC – Programmable Logic Controller • PPC – Power Plant Controller – Controller responsible for closed-loop power control at the point of interconnection. Manages inverter and power converter power levels, and site-level alarms. • SOC – State of Charge – Current charge of the battery bank, from 0-100%. SOH – State of Health – Current battery capacity as a percentage of the beginning of life value. *Table A.5.2.5(a) of NFPA551 Severity Impact Negligible The impact of loss will be so minor that it would have no discernible effect on the facility, its operations, or the environment. Marginal The loss will have an impact on the facility, which may have to suspend some operations briefly. Some monetary investments may be necessary to restore the facility to full operations. Minor personal injury may be involved. The fire could cause localized environmental damage. Critical The loss will have a high impact on the facility, which may have to suspend operations. Significant monetary investments may be necessary to restore to fulfill operations. Personal injury and possibly deaths may be involved. The fire could cause significant reversible environmental damage. Catastrophic The fire will produce death or multiple deaths or injuries, or the impact on operations will be disastrous, resulting in long-term or permanent closing. The facility would cease to operate immediately after the fire occurred. The fire could cause significant irreversible environmental damage. *Table A.5.2.5(a) of NFPA551 Probability Description Frequent Likely to occur frequently, experienced (P>0.1) Probable Will occur several times during system life (P>0.001) Occasional Unlikely to occur in a given system operation (P>10-6) Remote So improbable, may be assumed this hazard will not be experienced (P<10-6) Improbable Probability of occurrence not distinguishable from zero (P ~ 0) Reference Documents Codes and Standards: AES Distributed Energy Contains Proprietary Information Page 18 of 18 • UL 9540 Energy Storage Systems and Equipment • UL 9540A Test Method for Evaluating Thermal Runaway Fire Propagation in Battery Energy Storage Systems (BESSs) • UL 1973 Standard for Batteries for Use in Stationary, Vehicle Auxiliary Power and Light Electric Rail (LER) Applications • NFPA 1 Fire Code, Ch 52, Stationary Storage Battery Systems • NFPA 68 Explosion Protection by Deflagration Venting • NFPA 69 Explosion Prevention Systems • NFPA 70/NEC Article 706 • NFPA 550 Fire Safety Concepts Tree • NFPA 551 Evaluation of Fire Risk Assessments • NFPA 855 Stationary Energy Storage Systems • NFPA 2001 Clean Agent Fire Extinguishing Systems • IEEE/ASHRAE 1635 Guideline 21 Guide for the Ventilation and Thermal Management of Batteries for Stationary Applications • IFC Chapter 12 Energy Systems, Section 1206 Electrical Energy Storage Systems • FM Global Property Loss Prevention Data Sheet # 5-33, Electrical Energy Storage Systems Publications: • DOE OE Energy Storage Systems Safety Roadmap, PNNL-SA-126115, SAND2017-5140 R o Codes and Standards Update, March 2019, SNL. • Energy Storage Safety: 2016, EPRI, SAND2016-6297R Equipment Specific Information • Samsung O&M Manual • Samsung UL9540A report • GPTech Operations Manual • GPTech PPC Signals List • Notifier Fire Control Panel Manual • Siex Fire Suppression Design AES Peace Bear Ranch Solar – Land Use Change – Major Impact permit application (11/5/2021) AES Peace Bear Ranch Solar – Garfield County 56 Please see the following pages for the Garfield County Wildfire Susceptibility Map in the area of the AES Peace Bear Ranch Solar project. GARFIELD COUNTY WILDFIRE SUSCEPTIBILITY MAP Appendix C10