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Home My WebLink About05-24-22 Board of Health Memo CCH Solar PanelsTOWN OF YARMOUTH 1146 ROUTE 28, SOUTH VARMOUTH, MASSACHUSETTS 02664-4451 Telephone (508) 398-2231 ext. 1240, Fax (508) 760-3472 BOARD OF HEALTH MEMORANDUM TO: Zoning Board of Appeals (ZBA) FROM: Carl E. Lawson, Jr., Hazardous Waste Inspector C L� SUBJECT: ZBA Petition Number 4945 (Continued from 3-24-22) ZBA Hearing Date May 26, 2022 Cape Cod Hospital & Winterbury Solar LLC (Next Grid Inc.) 4, 30, 34 and 40 Bayview St. West Yarmouth DATE: May 17, 2022 CC: 1) Mark Grylls, Building Commissioner, Director of Inspectional Services 2) Yarmouth Fire Prevention Summary Based on the information received thus far it appears Next Grid will be able to comply with all aspects of the Town of Yarmouth, Board of Health Regulation: Handling and Storage of Toxic or Hazardous Materials, with additional safeguards beyond the strict scope of the regulation also included. Below please find the process by which this conclusion was determined. Health Dept. Review Since the original ZBA hearing date of March 24, 2022 the Health Dept, participated in a conference call with Mr. Huang IU, Chief Technical Officer of Eneon, the battery supplier and Mr. Daniel Serber, Senior Director of Land Development with Next Grid Inc., the project applicant seeking to construct carports with roof -mounted solar panels above an existing Cape Cod Hospital parking lot. After the call we exchanged several emails over the next couple of weeks during which I learned further details of the project. Information and project details obtained during the conference call and subsequent emails follow below. Proposal The Health Department was informed (initially by Town Site Plan Review notice, later by email from the project attorney and most recently by ZBA Hearing Notice) that Cape Cod Hospital (CCH) seeks to construct car ports with canopy -mounted solar panels over an existing parking lot. The solar panels will generate energy that will be stored by the batteries for return to the electric power grid as electrical demand allows. Two electrical inverters will convert the DC current generated by the solar panels to AC current for return to the electric power grid. Regulator, Items The Board of Health (BOH) Regulation "Handling and Storage of Toxic or Hazardous Materials," effective May 2, 1990, and licensing requirement is applicable to this proposal as the involved quantities of materials exceed the licensing threshold of 10 gallons liquid measure and 5 pounds dry weight. The regulation includes, but is not limited to, 150% volume secondary containment of toxic or hazardous materials. Information Learned Since the ZBA Hearing on March 24 2022 Batteries Single -celled, lithium -ion batteries will be installed for the project. Each lithium -ion battery cell: (1) is contained within a single -walled aluminum housing known as a can; (2) is a fully sealed unit with no venting and (3) contains liquid electrolyte solution in the amount of approximately 1.617 liters or 0.4271 gallons. The batteries are housed within modules. Each module contains 10 batteries. The modules are housed within racks. Each rack can house up to 38 modules and that number is planned at this time. The racks are housed within cabinets. Each cabinet contains one rack and 18 cabinets are planned at this time. A total of 6840 batteries will be in place once the solar installation is complete. 1 battery X 10 batteries per module X 38 modules per rack X 1 rack per cabinet X 18 cabinets = 6840 batteries. 2 Electrical Inverters As mentioned previously two electrical inverters will be installed as part of this project. Each electrical inverters contains 4 liters (L) or approximately 1.096 gallons of antifreeze. Health Dent. Review of Toxic or Hazardous Materials The Health Dept. reviewed Safety Data Sheets (SDS) for each component of the battery electrolyte solution and the electrical inverter antifreeze. None of the materials are nontoxic and nonhazardous, nor was such a claim ever made by the providers of the materials. An SDS for the electrolyte solution is not available because it is a trade secret, however the SDS for the individual components were received and reviewed. Secondary Containment of Toxic or Hazardous Materials Battery Electrolyte As mentioned above 6840 total batteries each containing approximately 0.4271 gallons of electrolyte solution are included in this project. Therefore, approximately 2921 gallons of electrolyte are involved. The primary containment is the single -walled aluminum battery housings referred to as cans. The module housings in which the batteries reside provide secondary containment although short of the 150% required by regulation. As mentioned above the modules are place within racks. The racks have no containment capacity. The cabinets which each house one rack have secondary containment capacity that when coupled with that provided by the modules achieve more than the 150% volume secondary containment required by regulation. Electrical Inverter Antifreeze Each electrical inverters contains 4 liters (L) or approximately 1.096 gallons of antifreeze. The inverters each have secondary containment capacity that far exceeds the 150% volume required by regulation. Solar Panels The solar panels contain no toxic or hazardous liquids or dry materials. Delivery of Toxic and Hazardous Materials The solar array components containing toxic or hazardous materials will be delivered to the site for installation by the contractor. After construction is complete there are no further deliveries planned unless components need replacement. Storage of Toxic and Hazardous Materials All electrolyte solution is contained inside the batteries. The batteries are housed within modules that are placed within racks which will reside inside cabinets placed outside on concrete equipment pads which will be surrounded by protective bollards. All antifreeze is contained inside the electrical inverters which will also be placed outside on a concrete equipment pad also surrounded by protective bollards. Use of Toxic and Hazardous Materials All the toxic and hazardous materials will be used within the listed components (batteries and electrical inverters) in the process of solar energy generation and storage. Disposal of Toxic and Hazardous Materials No hazardous wastes will be generated on a regular basis. The service life of the batteries is 10 to 20 years. Yarmouth Board of Health Regulation Yarmouth Health Regulation requires the following regarding toxic or hazardous materials handling and storage which apply to the proposal from Next Grid. 1) The business must register annually for a Yarmouth Board of Health Handling and Storage of Toxic or Hazardous Materials License. Next Grid has confirmed they will apply. 2) No materials may be discharged to the environment. Next Grid understands and has no plan to do so, nor need for such. 3) No outdoor storage of materials is allowed. The batteries and each of the two inverters will be inside cabinets intended for outdoor use. 4) All materials must be protected from vandalism. The cabinets for all materials will be locked. 5) Materials must be stored in covered product -tight containers. 4 The toxic and hazardous materials are all contained within solar array system components. 6) All materials must be stored inside secondary containment of 150% volume of the total amount of materials stored. The toxic and hazardous materials will have secondary containment that meets this requirement. 7) Any waste material must be properly disposed by a licensed hazardous waste hauler with removal documentation in the form of hazardous waste manifests retained. There will be no regular generation of toxic or hazardous waste. The only disposal will be the removal of batteries at the end of their service life which is expected to be 10 to 20 years. 8) Safety Data Sheets (SDS) for each toxic or hazardous material must be maintained onsite and be readily available. Next Grid, the owner of the solar array equipment will have no physical office onsite in which to house SDS hard copy or electronic files. The SDS should be provided to CCH, the property owner. 9) No vehicle repair or washing is allowed onsite. No operations involving the above is proposed. 10)A sufficient supply of absorbent material must be kept onsite for use in the event of a release of toxic or hazardous materials. The initial response to mitigate a release of material was discussed on May 19, 2022 during a site visit at the project location. CCH, Yarmouth Fire Dept. (YFD), Health Dept. and Down Cape Engineering staff attended. Daniel Serber of Next Grid participated by phone during the discussion of this topic. Due to the hazardous nature of the involved materials it was discussed that CCH personnel will not play a role in containing or absorbing any released materials. Instead CCH personnel will notify YFD and establish a boundary around the solar installation, within which no CCH staff or members of the public will be permitted. The delineation of such boundary will be determined through further discussion between the Fire Dept. Next Grid, and CCH. A completed spill plan has yet to be completed. Following YFD response and assessment, Clean Harbors, an environmental services company contracted by Next Grid, will complete remediation of released materials once the impacted area is deemed safe by YFD for such work. 5 _Additional Safeguards Beyond Secondary Containment and the Strict Scope of the Board of Health Regulation Monitoring The batteries are electronically monitored on a continuous basis for both safe operation and performance. Performance issues automatically generate an email to Next Grid for evaluation. Safety issues generate an immediate, automatic notification to a Massachusetts -based monitoring firm. Depending upon the level of severity of the safety issue: (1) the Fire Dept. is notified; (2) the system automatically shuts down; and/or (3) the automatic water injection fire suppression system disperses water onto the battery array. The fire suppression system will be supplied by an onsite 300-gallon water tank that the service contractor will keep filled. The system will operate until the water supply is exhausted with continued response and application of water by YFD. Physical Protection The battery cabinets and electrical inverters will be protected by bollards from potential vehicle strikes. Protection from Vandalism The battery cabinets and electrical inverters will be locked. Summary In reiteration of the summary presented at the beginning of this memorandum and based on the information received thus far it appears Next Grid will be able to comply with all aspects of the Town of Yarmouth, Board of Health Regulation: Handling and Storage of Toxic or Hazardous Materials, with additional safeguards beyond the strict scope of the regulation also included. C: