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4 Environmental Analysis 4.18 Wildfire ignition. Fire detection measures would be incorporated in the Project design in accordance with NFPA safety standards. The Project will also comply with applicable local and state fire code requirements, standards from Underwrites Laboratories (UL; safety organization), and the NFPA. Specifically, the selected battery technology for the Project will comply with UL 9540A testing. UL 9540A testing is performed by the battery manufacturer/vendor to prevent thermal runaway and mitigate fire risk. Some of the measures to mitigate fire risk include heating, ventilation, air conditioning, sprinkler system, early smoke detection, alarms, and remote monitoring. The latest UL 9540A testing criteria for battery units such as those proposed for the Project specifically test for the potential for thermal runaway to prevent a thermal runaway event. The latest technology in battery storage has established a design such that in the unlikely event a combustion episode occurs, the combustion would be contained to a single battery container and not result in thermal runaway that could affect neighboring units. The fire protection and prevention technology employed in battery storage units based on battery models available on the current market is specifically designed to prevent a combustion event, and then subsequently put through UL9540A testing to confirm a combustion event that could result in a fire hazard would not occur. In fact, a recent study conducted by the Fire Protection Research Foundation titled "Hazard Assessment of Lithium-Ion Battery Energy Storage Systems" tested an older model of battery in an attempt to intentionally cause a thermal runaway event to determine the potential for thermal runaway, and the attempt failed, demonstrating the fire prevention integrity of such units to prevent combustion and thermal runaway from occurring (NFPA 2016). Compliance with these standards and certification includes a Battery Management System (BMS) design that detects high temperatures at the battery cell or battery module level and automatically shuts down the battery rack. Furthermore, installation of battery units would follow manufacturer specifications for the spacing of batteries and clearance distances to further prevent a thermal runaway event. Each unit would also be equipped with thermal management systems for thermal management of the batteries. Power to the thermal management system and lighting would be provided through a connection to the on-site station service transformer with connection lines installed above and/or below ground. Cabinets housing batteries are designed with adequate ventilation and will also be equipped with carbon monoxide (CO) detection that would alert the remote monitoring facility that the sensor has been activated. The Project would require water for dust suppression during construction and decommissioning activities, and operational water use would be nominal. The Project would also include firebreaks around the site boundary in the form of access roads subject to the standards of each County. Combustible vegetation or agricultural products on and around the Project boundary would be actively managed by the Project owner or its affiliates during the construction, operation, and decommissioning phases of the Project to minimize fire risk. Combustible products would be either limited in height or removed. These measures (i.e., dust suppression) and Project components (i.e., batteries) are considered to be part of the Project. Accordingly, the environmental impacts that could result from Project measures and components have been analyzed throughout this Draft EIR, and no additional impacts (beyond those that are identified in this Draft EIR) would occur. The Project would not require the installation or maintenance of associated infrastructure outside of these Project measures and components included as part of the Project and analyzed in this Draft EIR. Therefore, the Project would have a less-than- Griffith Energy Storage Project 4.18-16 Tetra Tech/SCH 2022120675 Draft Environmental Impact Report August 2023