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4 Environmental Analysis
<br /> 4.9 Hazards and Hazardous Materials
<br /> Motor Vehicles. Lithium-ion batteries are classified as a Class 9 hazardous material, and therefore
<br /> must meet DOT Hazardous Material Regulations (49 CFR 171-180). In addition, under UN3536
<br /> "Lithium batteries installed in cargo transport units" (United Nations 2019), the batteries must be
<br /> securely attached to the interior structure of the cargo unit (e.g., Conex-type shipping container),
<br /> the batteries must pass UN38.3 tests that prevent overcharge and over discharge between
<br /> batteries, and no additional hazardous cargo is allowed that is not directly related to the transport
<br /> of the batteries. UN38.3 compliance allows certification for safe transport by air, land, or sea.
<br /> According to the study"Comparative Risks of Hazardous Materials and Non-hazardous Materials
<br /> Truck Shipment Accidents/Incidents" by Battelle (2001), the hazardous material accident/incident
<br /> rate per mile (road miles only)for all Class 9 hazardous materials is 1.09 in 1 million. This statistic
<br /> includes en route incidents, and includes all Class 9 hazardous materials, of which lithium-ion
<br /> batteries make up only a portion. This indicates the worst-case probability of an accident occurring
<br /> during lithium battery transportation to the Project site would be approximately 1 accident per 1
<br /> million miles traveled. There will be a one-time transport of batteries to the Project site, then very
<br /> infrequent transport of batteries for the lifetime of the Project. Thus, the infrequent shipping,
<br /> containerized shipping, low probability of accident/incident, and multiple regulations that control
<br /> the shipping of lithium-ion batteries would make impacts associated with routine transport and
<br /> foreseeable upset or accidents involving the release of hazardous materials less than significant.
<br /> With these protections in place, Project construction would have a less than significant impact
<br /> due to creation of a potential significant hazard to the public or the environment through the routine
<br /> transport, use, or disposal of hazardous materials.
<br /> Operation
<br /> Project operations and maintenance (O&M) activities may involve the transportation, use, or
<br /> temporary storage of a variety of hazardous materials, such as batteries, hydraulic fluid, diesel
<br /> fuel, insulation oil for the transformers, grease, lubricants, paints, solvents, and adhesives. The
<br /> Project substation would include transformers, breakers, switches, meters, and related
<br /> equipment.
<br /> O&M activities associated with a battery energy storage facility are relatively limited when
<br /> compared to other industrial land uses. During operation, the Project would require one or two
<br /> workers in a light utility truck to visit the facility on a weekly basis. O&M staff would visit the site
<br /> for switching and other operation activities. Maintenance trucks would be used to perform routine
<br /> maintenance, including, but not limited to, equipment testing, monitoring, repair, routine
<br /> procedures to ensure service continuity, and standard preventative maintenance. Long-term
<br /> maintenance and equipment replacement would be scheduled in accordance with manufacturer
<br /> recommendations to ensure equipment integrity is maintained. Typically, one major maintenance
<br /> inspection would take place annually.
<br /> The Project would generate a small amount of waste during operation, such as broken or rusted
<br /> metal, defective or malfunctioning equipment, electrical materials, empty containers, other
<br /> miscellaneous solid waste, and typical refuse from the O&M staff. Additionally, limited amounts
<br /> of hazardous materials would be stored or used onsite during Project operation, including diesel
<br /> fuel, gasoline, and motor oil for vehicles; mineral oil to be sealed within the transformers; and
<br /> lead-acid-based or lithium-ion-based batteries for emergency backup. Appropriate spill
<br /> containment and cleanup kits would be maintained during operation of the Project. The Project
<br /> Griffith Energy Storage Project 4.9-13 Tetra Tech/SCH 2022120675
<br /> Draft Environmental Impact Report August 2023
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