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Bomber Heights-BESS Emergency Response Plan-11 1 Bomber Heights Solar PV And Battery Energy Storage System Emergency Response Plan 2 Table of Contents Table of Contents .......................................................................................................................................... 2 1 Introduction ............................................................................................................................................ 3 1.1 Scope and Purpose ..................................................................................................................... 3 1.2 Timeframe .................................................................................................................................... 4 1.3 Activation ..................................................................................................................................... 4 1.4 Agency Jurisdiction ...................................................................................................................... 4 1.5 Operations and Maintenance (O&M) ........................................................................................... 4 1.6 ERP Update Process ................................................................................................................... 4 2 Definitions and Acronyms ..................................................................................................................... 4 2.1 Definitions .................................................................................................................................... 4 2.2 Acronyms ..................................................................................................................................... 6 3 General Site Information ....................................................................................................................... 8 3.1 Owner/Operator Information ........................................................................................................ 8 3.2 Site Overview ............................................................................................................................... 8 3.3 Site Design................................................................................................................................... 9 3.4 Fire Department Access and Staging Area ............................................................................... 10 3.5 Site Security Perimeter .............................................................................................................. 11 3.6 Site Access ................................................................................................................................ 11 3.7 Equipment Access ..................................................................................................................... 11 3.8 Water Supply ............................................................................................................................. 11 3.9 Lock Box Access ....................................................................................................................... 11 3.10 Nearby Exposures ..................................................................................................................... 11 3.11 Site Maintenance ....................................................................................................................... 11 3.12 BESS Product Information ......................................................................................................... 11 3.12.1 BESS Product Features ........................................................................................................ 12 3.12.1.1 Battery Management System (BMS) ..................................................................................... 12 3.12.1.2 Customer Interface Bay ......................................................................................................... 13 3.12.1.3 Thermal Management System .............................................................................................. 13 3.12.1.4 Site Controller and Monitoring ............................................................................................... 13 3.12.1.5 Electrical Fault Protection Devices ........................................................................................ 13 3.13 Fire Protection Systems ............................................................................................................. 14 3.13.1.1 Explosion Control System ..................................................................................................... 14 3.14 Emergency Shutoffs .................................................................................................................. 15 3.15 Fire Detection ............................................................................................................................ 15 3 3.16 Emergency Contacts ................................................................................................................. 15 3.17 Fire Responder Contact Information ......................................................................................... 16 3.18 Other Contact Information ......................................................................................................... 16 3.19 Roles and Responsibilities ......................................................................................................... 17 4 Battery Management System (BMS) .................................................................................................. 20 4.1 Alarm Matrix ............................................................................................................................... 20 5 Notification Matrix ................................................................................................................................ 23 6 Emergency Response Considerations ................................................................................................ 23 6.1 Emergency Contacts ................................................................................................................. 23 6.2 Equipment and Personnel Protective Equipment (PPE) ........................................................... 23 6.3 APIE (Analyze, Plan, Implement, and Evaluate) Framework .................................................... 23 6.4 Scene Size-up – Command and Control ................................................................................... 24 6.5 Determine Fire Protection Approach ......................................................................................... 24 6.6 Incident Monitoring and Evaluation ........................................................................................... 25 7 Post Incident Operations ..................................................................................................................... 25 8 Training and Exercises ........................................................................................................................ 25 9 Revision Tracking ................................................................................................................................ 26 Disclaimer: This drafted Emergency Response Plan (ERP) is provided for information and guidance purposes only and establishes a suggested format. The ERP requires regular updates with sufficient detail to enable personnel to implement necessary emergency procedures without question or delay to ensure the continuity of operations. 1 Introduction 1.1 Scope and Purpose This Emergency Response Plan (ERP) or Emergency Operations Plan (EOP) has been developed for the Bomber Heights Solar + Battery Energy Storage System (BESS) located at 115 Troy Rd., Ithaca, NY 14850. The purpose of this document is to provide guidance and pertinent information regarding the roles, responsibilities, and chain of communication and command of the System Owner/Operator, Property Owner, Emergency Responders, and other required Subject Matter Experts (SMEs) for preparing for, and safely responding to, a fire, explosion, or other battery-related incident requiring a public safety response at the energy storage facility. The Operations and Maintenance (O&M) Manager for the project is an employee of Nexamp. “On- site personnel” include all individuals on the facility property who are direct employees of the Owner/Operator or affiliated contractors. The Owner/Operator and contractors are similarly responsible for establishing and maintaining contractor-specific Emergency Management Plans and reporting procedures that will work in conjunction with the overall energy storage facility plan. 4 Life safety shall be the highest priority during any event type associated with this energy storage facility. 1.2 Timeframe This ERP covers the timeframe beginning at the final approval of the Ithaca Fire Department to the beginning of decommissioning and removal of the energy storage system. 1.3 Activation This ERP shall be activated during any emergency response to energy storage facility-related incident on site. 1.4 Agency Jurisdiction This plan has been strictly developed for the Ithaca Fire Department and does not cover multi- agency response. 1.5 Operations and Maintenance (O&M) Operations and maintenance procedures for the energy storage facility and associated equipment are outside the scope of this document. Procedures for inspection and testing of associated alarms, interlocks, and controls are provided in the O&M plan. Please refer to manufacturer Operations and Maintenance (O&M) manuals for all associated equipment and protocols related to the site prior to beginning any maintenance work on this facility. 1.6 ERP Update Process Dates for draft issuance, revisions and final issuance of this ERP are provided in Section 14 of the document. A review of this emergency response plan shall be conducted and documented:  at minimum on an annual basis; or  if there is a change in design, construction, operation, or maintenance that affects emergency response planning. Ensure all relevant stakeholders receive a complete copy of this Emergency Response Plan. Plan retirement will coincide with decommissioning of the facility. All decommissioning procedures shall be performed by trained and knowledgeable people in alignment with the Decommissioning Plan provided for this installation. Decommissioning shall be performed under the supervision of the System Owner/Operator and manufacturer. 2 Definitions and Acronyms 2.1 Definitions Approved – Acceptable to the authority having jurisdiction Battery – A single cell or a group of cells connected electrically in series, in parallel, or a combination of both. Battery cell - The basic electrochemical unit, characterized by an anode and a cathode, used to receive, store, and deliver electrical energy. 5 Battery management system (BMS) - A system that monitors and controls performance of an energy storage system and can have the ability to disconnect the energy storage unit from the system in the event abnormal or hazardous conditions are detected. Battery module – A subset of battery cells, connected in series, parallel, or a combination of both, with some amount of monitoring and passive disconnect capabilities Battery rack – A subset of interconnected modules, typically in series, which typically includes switchgear, BMS, and active disconnect capabilities Certifications – In this context, certifications address primarily Underwriters Laboratory standards, including UL (Underwriters Laboratories) 1642, UL 1973, UL 1741, and UL 9540. Also, UL 9540A testing will be included in this context. Deflagration – Combustion event which propagates through explosive gases released by batteries during abnormal failure events at subsonic speeds. In this context, deflagration risk may be managed through a variety of mitigative measures, such as vent design, exhaust, or suppression systems. Electrical Event - Internal short circuit due to internal cell defects, overvoltage charging or a defect on internal resistance. Energy storage system - One or more devices, assembled, capable of storing energy to supply electrical energy at a future time. Battery energy storages system is called a BESS (Battery Energy Storage System). Energy Storage Management System (ESMS) - A system that monitors, controls, and optimizes the performance of an energy storage system and can control the disconnection of the energy storage system in the event of abnormal conditions. Fire Command Center - The principal attended or unattended room or area where the status of the detection, alarm communications, control systems, and other emergency systems is displayed and from which the system(s) can be manually controlled. Incident Action Plan (IAP) – IAP formally documents incident goals/control objectives, operation period objectives, and the response strategy defined by incident command during response planning. Inverter – A piece of electrical equipment which converts DC (Direct Current) energy of the batteries into AC (Alternating Current) energy of the grid and vice versa Monitoring Company – alerted in the event of activation of Nexamp’s aspirating smoke detection (ASD) system. Mechanical Failures - Physical damage to a cell which may have occurred during the manufacturing or installation process, as well as damage caused by vibration or expansion. Off-gassing – Gases released by batteries during abnormal events prior to thermal runaway Subject matter expert (SME) – One or more parties who have skills and knowledge related to the operation of the electrical equipment and installations and has received safety training to recognize and avoid the hazards involved. These parties will be responsible for communication during failures with facility personnel, system operators, and emergency personnel. The SME will be qualified in workplace and electrical safety in local jurisdiction of the system. Thermal Event - A chemical process where self-heating in a battery exceeds the rate of cooling causing high internal temperatures, melting, off-gassing/venting, and in some cases, fire, or explosion. Thermal, 6 mechanical, and electrical abuse can lead to thermal runaway; internal short circuit from manufacturing defects; or the development of metallic dendrites that form an internal short over time. Lithium-ion batteries undergoing thermal runaway can vent their internal contents in the form of gas. Without proper ventilation a combination of gases can build up in an enclosed space. The Lower Explosive Limit (LEL) for this mixture can vary. Oxygen starvation fire suppression in lithium-ion battery systems is not recommended. Smoke can be toxic and smoke from batteries is no exception. Use of a positive pressure breathing apparatus is recommended whenever responding to battery system fires. Thermal runaway - The condition when an electrochemical cell increases its temperature through self- heating in an uncontrollable fashion and progresses when the cell’s heat generation is at a higher rate than can dissipate leading to fire, explosion, and gassing. 2.2 Acronyms Abbreviation / Acronym Description AR Arc-Rated BESS / ESS Battery Energy Storage System – the complete facility including bidirectional inverter(s), step- up transformer(s), protection devices, HVAC system(s) and control systems. BMS Battery Management System – the electronic control system that manages the battery installation, maintaining operation within safe limits and monitoring and reporting status to the PPC (Power Plant Controller). DAS Data Acquisition System (synonymous with SCADA) E-Stop/EPO Emergency Stop / Emergency Power Off ERP Emergency Response Plan EMS Energy Management System – The system running the PPC and providing an HMI for the user interface FACP Fire Alarm Control Panel FDC Fire Department Connection FSS Fire Suppression System HVAC Heating, Ventilation, Air Conditioning system 7 Abbreviation / Acronym Description IC Incident Commander ICS Incident Command System kW Kilowatt(s) kWh Kilowatt-hour(s) LFL/LEL Lower Flammability Limit / Lower Explosive Limit MW Megawatt(s) MWh Megawatt-hour(s) O&M Operations and Maintenance SCBA Self-Contained Breathing Apparatus SDS Safety Data Sheets – a document that contains information on the potential hazards (health, fire, reactivity and environmental) and how to work safely with the chemical product. PCS Power Conversion System – Includes bidirectional inverter and integrated control system PPC Power Plant Controller – The main BESS computer that provides user interaction for all available systems via the EMS HMI. SCADA Supervisory Control and Data Acquisition – Control system architecture that provides an interface for monitoring and issuing commands to the BESS via the RTUs (Remote Telemetry Unit). 8 Abbreviation / Acronym Description SME Subject Matter Expert SOC State of Charge – The percent level of charge of the batteries relative to their capacity. SOH State of Health – The percent merit of condition of the batteries relative to ideal conditions. Will decrease over time with use. UICS Unified Incident Command System UFL / UEL Upper Flammability Limit / Upper Explosive Limit 3 General Site Information 3.1 Owner/Operator Information The owner of the BESS is Bomber Heights Solar PV, which is an LLC of Nexamp. The Operator of the BESS is Nexamp. Nexamp is a vertically integrated Independent Power Producer (IPP) based in Boston that has constructed, owns, and operates 200+MWh of energy storage across Massachusetts and New York. Nexamp also operates over 1GW of solar across the United States, and continues to develop and construct a multi-GW pipeline of energy storage and solar projects across the U.S. More information about Nexamp can be found here: https://www.nexamp.com/ 3.2 Site Overview The Bomber Heights Solar and Energy Storage facility is located at 115 Troy Rd., Ithaca, NY 14850. The Bomber Heights Solar and Energy Storage facility consists of Four (4) Megapack 2XL rated at 979.2 kW / 3,916.8 kWh (4-hour duration) with a total BESS capacity of 3,916.8 kW / 15,667.2 kWh. The BESS is AC-coupled with a Solar PV array spread across the property. The PV capacity is 4,500 kWac. 9 Figure 1 Site Layout 3.3 Site Design The BESS is located on the southern portion of the property as shown in Figure 2. The BESS is adjacent to the access road and provides fire apparatus access. Figure 2 BESS Layout - zoomed in In the event of an emergency, all site personnel, visitors, Nexamp, and emergency response personnel (including the fire department) should remain outside the 100ft radius seen below. In the event of an emergency, the neighboring property owners should be notified of the event and provided updates throughout the duration of the event. 10 Figure 3 - 100 ft radius Electrical equipment including metering enclosures, transformers, Data Acquisitions System cabinets are located within the BESS area, with at least a 10 ft setback between the BESS unit, the equipment, the solar array, and the access road. The BESS enclosure is installed on a concrete pad, elevated above the flood plain with the surrounding area noted as gravel. The gravel will extend to the access road and between the BESS and the PV array towards the east. 3.4 Fire Department Access and Staging Area An entrance point is located on the northwest end of the property. Staging areas are recommended to be conducted at the access road just at the entrance gate of the site facility as shown in Figure 3. Staging areas should be based on the IC and the initial size-up. The Fire Department should not attempt to enter the site fence line unless there is a clear threat to life safety. Figure 3 Fire Department Access and Staging Area 11 3.5 Site Security Perimeter The site is enclosed with a locked gate as the primary entrance to the facility and is surrounded by a fence. The BESS units are each individually locked. As noted above, the Fire Department should not attempt to enter the BESS area unless there is a clear threat to life safety. 3.6 Site Access The site is enclosed within protective steel fencing with a 10-ft gated entrance located at the northern side of the site. As noted above, the Fire Department should not attempt to enter the site fence unless there is a clear threat to life safety. 3.7 44Equipment Access The Tesla Megapack enclosures are only accessible for maintenance purposes via cabinet-style enclosure doors and cannot be physically entered by personnel at any time. The Fire Department should not attempt to open the enclosure doors at any time. 3.8 Water Supply Primary water source to be confirmed with fire department. 3.9 Lock Box Access A lock box openable by a standard key (Fire Department approved) containing a physical copy of the EPRP, operational permits, O&M logs, product manuals, etc., is provided at the site entrance shown in Figure 3. 3.10 Nearby Exposures The following nearby exposures are in the immediate area, as shown in Figure 1 above. 1. Residences to North, South, East, and West a. Location: ~750 – 1,500 ft from BESS b. Construction: To be identified 2. PV Array a. Location: Surrounding the BESS, with ~50 ft clearance to the South (closest location) b. Construction: Steel and PV modules 3.11 Site Maintenance The facility’s interior access roads should be maintained to guarantee accessibility to the site by emergency personnel, especially during inclement weather. Nexamp shall ensure snow removal, landscaping, and other ongoing upkeep activities are in place prior to construction. 3.12 BESS Product Information The BESS Technology/Product incorporated into the design of this project is the Tesla Megapack 2XL (MP2XL). The Megapack 2XL is a pre-engineered and integrated energy storage unit that utilizes Lithium-ion batteries to store and discharge power/energy. More specifically, the batteries use lithium Iron Phosphate (LFP) battery cell chemistry where battery cells are configured into battery modules, which are then integrated into battery racks that are housed in the enclosure/container as shown Figure 56. The Megapack 2XL is offered in various configurations of varying power/energy capacities. The MP2XL arrives at the site fully assembled needing just the alternate current (AC) connection and communications cable to be connected on site. The MP2XL is approximately 28.9 ft in length, 12 5.4ft deep, and 9.2ft in height. The MP2XL is intended for outdoor installations, ground-mounted to a foundation or base strong enough to support the weight of the equipment and anchor loads (including concrete pads, grade beams, etc.). The thermal roof (part of the thermal management system) is enclosed within an IP20 enclosure that sits above the battery module bays. The lithium- ion batteries are housed inside an IP66 steel enclosure (battery module bay) that provides protection against particles and water ingress. Figure 5 Tesla Megapack 2XL Overview Megapack 2XL is listed to the following standards by OSHA-recognized Nationally Recognized Testing Laboratories:  UL 1642 (cell-level certification)  UL 1973 and IEC 62619 (battery module-level certification)  UL 9540, IEC 62933-5-2, IEC 62109-1 (System-level certification)  UL 1741, CSA C22.2 #107.1 (power electronics)  UL 1998 and IEC 60730 Annex H (functional safety of software)  IEC 61000-6-2, and EN 55011 (EMC)  UN 38.3 (transportation, self-certified)  IEEE 693 (seismic safety)  UL 9540A (large-scale fire testing): Tested the cell, module, and unit level The Megapack 2XL is designed to comply with major installation codes for energy storage systems, including NFPA 855, IFC 2018 and 2021, and NEC 2020. The Megapack 2XL has been reviewed and validated by an Independent Engineer, both at the product level and for the results of large-scale fire testing. 3.12.1 BESS Product Features 3.12.1.1 Battery Management System (BMS) See Section 4. 13 3.12.1.2 Customer Interface Bay The Customer Interface Bay (CIB) is a user-accessible area designed for operation and service. The CIB includes the main AC breaker, a status panel and controller area network (CAN) interface for service personnel, customer input/output (I/O) terminals, and the keylock switch (a “Lock Out/Tag Out” switch), which shuts down the AC bus to permit MP2XL maintenance by service personnel. 3.12.1.3 Thermal Management System The thermal management system (TMS) provides suitable operating temperature for the MP2XL. The thermal bay and thermal rood house the components of the TMS. The TMS contains a closed-loop liquid cooling system that circulates a 50/50 mixture of ethylene glycol and water throughout the battery modules and power electronics to maintain an optimum battery operating temperature. The TMS works autonomously and does not require user feedback or controls to turn the system on when needed or to adjust temperature settings. The thermal cabinet includes pumps that circulate the liquid coolant through the MP2XL, an in-line heater that can warm the coolant and a compressor that maintains control for the cabinet. The thermal roof, located above the battery bays within its own IP20 enclosure, provides a ventilation airspace for the MP2XL. It contains fans and radiators that cool the ethylene glycol-water resolution. Cool air enters the thermal roof through the grates on the front of the MP2XL. The cool air then passes over the radiators, absorbing heat, and then is exhausted out of the top of the thermal roof via fans. 3.12.1.4 Site Controller and Monitoring Beyond the built-in safeguards of the BMS described in Section 5, the MP2XL is supported by a Tesla Local Operations Center (LOC). The MP2XL has 24/7 remote monitoring by Tesla’s LOC, but also Nexamp’ s Network Operating Center (NOC) located in Lawrence, MA. The 24/7 remote monitoring is accompanied by 24/7 diagnostics and troubleshooting capabilities, without needing a technician on site. All faults are transmitted to the LOC and NOC, alerting Tesla and the Operator abnormal conditions that may require corrective action, either through remote means or an in-person field service. This communication link is accomplished via the Tesla Site Controller (TSC). The TSC provides the single point of interface for the Utility, network operator, and/or the System Owner/Operator’s SCADA systems to control and monitor the entire energy storage facility. 3.12.1.5 Electrical Fault Protection Devices The MP2XL has several passive and active safety control mechanisms installed within the battery module circuit and distribution circuit that would be available to interrupt a fault condition. At a high level, these electrical fault protection features include:  Battery module overcurrent protection: The battery modules contain DC single-use fusible links mounted directly on the battery modules. These fuses are one-time-use safety devices that can interrupt the flow of an overcurrent in the battery module during an off-normal electrical event.  Inverter DC protection: The inverter modules, which are installed at each of the battery modules, are equipped with a high-speed pyrotechnic fuse that can isolate the battery module passively or actively during an off-normal event.  Inverter AC protection: In addition, each inverter module is equipped with its own AC contactor and AC fuses should an off-normal electrical event occur at the inverter module on the AC side of the circuit.  Ground fault protection: Finally, the MP2XL is also provided with a DC ground fault detection system. It measures insulation resistance prior to operation and looks for excessive leakage current during operation. Additionally, the MP2XL also contains an AC 14 circuit breaker, with ground-fault trip settings, which is installed within the CIB to provide distribution system protection 3.13 Fire Protection Systems 3.13.1.1 Explosion Control System The MP2XL includes an explosion control system to mitigate the risk of an uncontrolled deflagration. The system includes pressure-sensitive vents (overpressure vents), and sparkers installed throughout the battery module bay. The sparkers are designed to ignite flammable gases exceedingly early in a thermal runaway event before they accumulate within the enclosure and become an explosion hazard. They are installed at a variety of locations and heights throughout the battery module bays to ensure the flammable gases released during thermal runaway quickly meet an ignition source. Note, this explosion control system is the same approach that Tesla has utilized in previous versions of the Megapack (Megapack 1 and Megapack 2) and is not a new concept. It has been extensively validated through installation level testing for these previous Megapack versions as well as the MP2XL and its performance has been demonstrated in the field during thermal events involving Megapacks. The overpressure vents are installed in the roof of the sealed battery bay’s IP66 enclosure, as shown in Figure 6. When activated, the overpressure vents open into the enclosed thermal roof, ensuring that the release of the overpressure vents does not create a projectile hazard. In addition, since they are installed in between the battery module bays and the thermal roof, the overpressure vents are not exposed to the environment, which means they are protected from the elements, such as falling tree limbs or snow, which could impact their functionality. Figure 6 MP2XL Overpressure vent overview Once opened, the overpressure vents permit gases, products of combustion, and flames to safely exhaust through the roof of the MP2XL during a thermal event. By designing this natural ventilation flow path, flammable gases are not permitted to accumulate within the MP2XL cabinet, reducing the risk of a deflagration or explosion that could compromise the cabinet’s integrity, push open the front doors, or expel projectiles from the cabinet. In addition, the ventilation path creates a controlled fire condition, should one occur, out the top of the MP2XL cabinet. By maintaining the MP2XL cabinet’s integrity, keeping all the doors shut during a fire event, reducing the risk of projectiles, and creating a controlled path for flames to exit the top of the MP2XL cabinet, the likelihood of a thermal event having an impact on life safety, site personnel or first responders, is reduced. In addition, by maintaining these features, the likelihood of a fire propagating to adjacent MP2XL cabinets, electrical equipment, or other exposures is also reduced. 15 The overpressure vents themselves are passive and are not actuated or controlled by another device. They are designed to release during an overpressure event, such as the rapid ignition of flammable gases by a sparker. The number and total area of overpressure vents were sized following the guidance of NFPA 68 with a safety factor of two times the enclosure’s strength, including the front doors. Tesla developed the overpressure vents and sparker system because the direct application of NFPA 68 or NFPA 69 is not suitable for the MP2XL cabinet, which does not have large volumes of open-air space. This engineered approach is permitted by NFPA 855 §9.7.6.7.3.3 provided it is validated by installation-level fire and explosion testing and an engineering evaluation, which Tesla has performed. 3.14 Emergency Shutoffs Emergency shut-offs are provided at multiple levels, though the Fire Department should not engage with E-Stops, as BESS shutdown may adversely affect the electrical grid. The Fire Department should not engage with E-Stops, as BESS shutdown may adversely affect the electrical grid. Any interaction with E-Stops should only be initiated in coordination with Nexamp, and other SMEs as is deemed necessary. Automatic E-Stop Automatic shutdown is provided at different levels for the Tesla Megapack battery modules, depending on the type of failure:  For major faults within battery module(s) – such overtemperature, overcharge, or ground fault – the failed module(s) will be isolated by DC-DC converters, disconnects, and/or DC fuses, and an alarm will be generated. This may not result in complete shutdown of the system.  If a large propagating thermal runaway occurs, the faulted Megapack is isolated by opening its AC contactors and over temperature loss faults will be sent to the service team. Enclosure-Level E-Stop Each Megapack unit is equipped with an AC circuit breaker located within the Megapack Customer Interface Bay door and is to be used only by authorized maintenance or operations personnel. In the event of a battery-related failure, the Fire Department should not approach any battery enclosures or engage with any enclosure E-Stops. 3.15 Fire Detection The MP2XL does not have an internal fire detection system or one that is integral to its design/construction. Temperature and voltage sensors and alarms will indicate a potential hazard before a fire can begin. As such, Nexamp can shut down the system before a fire can begin or escalate. 3.16 Emergency Contacts  Local Fire Department: Ithaca Fire Department o Address: 310 W. Green St, Ithaca, NY 14850 o Emergency: 9-1-1 (if dialing locally from BESS location)  Local Hospital: TBD with Fire Department o Address: o Emergency: 9-1-1 (if dialing locally from BESS location) 16  Nexamp Emergency Response Coordinator: o Sean Banaee, 757-971-7732  Nexamp Emergency Line - (857) 239-0057 3.17 Fire Responder Contact Information  Local Fire Department: Ithaca Fire Department o Address: 310 W. Green St, Ithaca, NY 14850 o Emergency: 9-1-1 (if dialing locally from BESS location) o Non-Emergency: (607) 272-1234  Local Hospital: To be updated o Address: To be updated o Emergency: 9-1-1 (if dialing locally from BESS location) o Emergency Room: To be updated o Non-Emergency: To be updated 3.18 Other Contact Information Nexamp Site Contacts Name Role Phone Number Nexamp Emergency Call Center 857-239-0057 Bomber Heights Solar PV BESS Owner 617-431-1440 Sean Banaee Emergency Response Coordinator 752-971-7732 Mohamed Kassamali BESS SME 516-355-1466 Nexamp/BESS Vendor Subject Matter Expert Name Role Phone Number Nexamp BESS Operator 857-239-0057 Back up: 617-431-1440 Tesla BESS Manufacturer 650-681-6060 Chemtrec HAZMAT Remediation 800-424-9300 17 3.19 Roles and Responsibilities The following table provides a high-level summary of key stakeholders’ responsibilities regarding emergency preparedness and response. The BESS Owner and Operator will assist in the implementation of this plan by knowing and communicating evacuation routes to work during emergency evacuation and reporting the status of the incident and evacuation to the Ithaca Fire Department. All facility personnel have a responsibility to immediately report any emergencies to the SME and/or BESS Operator or local emergency responders when appropriate. No delay to report emergency events that require the local emergency responders. The SME and designated alternative will be always contactable by telephone; be readily available to first responders in the event of an emergency. The SME shall be well versed in battery failure modes and hazards. If SME is not available, a toll-free phone number for first responders to call at any time shall be provided. Additionally, first responders shall be given operational data on the system, including the current state of health, system alarm notifications and advice on how to proceed during an emergency event shall be provided. BESS Owner Identity Bomber Heights Solar PV (Nexamp) Responsibilities Shall coordinate with the Emergency Response Coordinator and/or its contractors with access to the site, as necessary, for them to perform their duties and obligations. Emergency Response Coordinator Identity Sean Banaee (Nexamp) Responsibilities Shall provide a site-specific Emergency Response Plan for each site that was developed during the engineering, construction, and commissioning phases of the projects. The Emergency Response Plan should be submitted to the local fire department, the BESS Operators, and the BESS Maintenance Contractors prior to going live. The Emergency Response Coordinator will also be responsible for introductory training of the ERP, the BESS project site, and introduction amongst all emergency response stakeholders listed in this table. BESS SME Identity Mohamed Kassamali and Nickole Gagne (Nexamp) 18 Responsibilities The BESS SME role consists of at least two people, one of which is the battery technology expert, and the other being a qualified electrical expert. The two parties are responsible for communicating with each other, the BESS operator, and the Local Fire Department. The description of these two parties and their respective responsibilities are listed below. Qualified Electrical Expert (Nexamp) One person employed by the BESS Owner has the skills and knowledge related to the operation of the electrical equipment and installations and has received safety training to recognize and avoid the hazards involved. This party will be qualified in the workplace and electrical safety in local jurisdiction of the system. This party will be responsible for the following during an emergency or failure: - Prepare for and conduct exchange of information with battery technology experts (BESS SME), Emergency Response Coordinator, Local Fire Department, and BESS operators - Communicate proper methods for isolation and shutdown the system based on available information on the emergency event - Determine electrical hazards and failures and communicate them to the Local Fire Department Battery Technology Expert (Nexamp) One person employed by the BESS Owner has knowledge of the normal and abnormal operation of the BESS and associated equipment. This person will have a deep understanding of the BESS failure modes, automatic and passive safety systems associated with the BESS, and correct emergency response procedures and action plans. This party will be responsible for the following during an emergency of failure: - Communicating with the Qualified Electrical Expert (BESS SME), Emergency Response Coordinator, Local Fire Department, and BESS Operator. - Communicating the required setbacks and evacuation points that the Local Fire Department should maintain to the Local Fire Department - Collecting information from the BESS Operator regarding the BESS status and its alarms - Direct communication will be made from BESS SME to the BESS manufacturer following an emergency event. BESS Operator Identity Nexamp 19 Responsibilities The following responsibilities fall under the BESS Operator’s scope during an emergency event: - Actively monitor and control the BESS during its normal and abnormal operations to the best of their ability. All monitoring and controlling will be performed in line with the BESS Manufacturer’s recommendations. - Directly communicate with the Local Fire Department, Emergency Response Coordinator, and BESS SME at the onset of the emergency event and for the remainder of the emergency event. - Dispatching qualified personnel to the site Local Fire Department / Emergency Response Personnel Identity Ithaca Fire Department Responsibilities Will receive and review a copy of the Emergency Response Plan (ERP) for each site and approve of the ERP prior to the BESS Owner sharing the document with all stakeholders and conducting training. Upon alarm, will coordinate with the Emergency Response Coordinator, and BESS SME to receive an update on the emergency and ensure the BESS site is safe to approach prior to engaging. Will be required to maintain training for new members of the FD and maintaining a copy of the ERP accessible to all members of the FD. Incident Commander (IC) Identity Ithaca Fire Department Responsibilities The party responsible for overall management of the incident and determines which Command or General Staff position is to maintain a manageable span of control and ensure appropriate attention to the necessary incident management functions. Site Owner Identity Troy Heights, LLC 20 4 Battery Management System (BMS) MP2XL has an integrated battery management system (BMS) that tracks the performance, voltage, current, and state of charge of the cells (among many other datapoints). The BMS is a layered system, where each battery module has its own BMS and the MP2XL itself has a bus controller supervising the output of all the battery modules at the AC bus level. The BMS is engineered to react to fault conditions in an autonomous manner, with safeguards built into firmware. These fault conditions include, but are not limited to, over-temperature, loss of communication, over-voltage, and isolation. For instance, to prevent a cell over-temperature the TMS is enabled by the BMS to cool the cells/module. This action by the BMS (which is just one example of many ways the BMS can respond to a fault condition) can either prevent thermal runaway from occurring in the cell or prohibit the propagation of thermal runaway to adjacent cells. Depending on the severity of the fault condition, the BMS can automatically isolate the affected battery module temporarily (less severe fault) or it can permanently disconnect the module. The BMS is the brain behind the energy storage system. Like how the Chief Officer will locate a residential or commercial facility FACP to allow them to begin their basic size-up, the BMS alongside the Site Controller will provide similar insight into the type of alarm, location and how much of the energy storage system may be involved. As such, BMS data should be leveraged to make informed decisions. The BESS SME will provide an interpretation of the BMS data and convey the data to the Chief Officer. 4.1 Alarm Matrix List of Alarm Conditions Requiring Ithaca Fire Department Response An alarm matrix that explains the alarm, alarm description, and the resulting action from the BMS is provided in Table 1. However, there may be additional indicators or information communicated directly from Tesla to Nexamp that may be shared with the Ithaca Fire Department. Responsibilities The owner of the premises upon which the battery system is installed. 21 Table 1 Alarms Matrix Alarm Name/Code Alarm description Alarm Response Maximum Battery Temperature Maximum battery cell temperatures across all battery modules within a Megapack If this alarm occurs, Tesla will immediately contact Nexamp and provide the system diagnosis. Simultaneously, Nexamp’ s NOC will be seeing alarms which will trigger an immediate call to the Ithaca Fire Department. Nexamp will request that the Ithaca Fire Department is dispatched, and Nexamp will dispatch their EH&S and Asset Management personnel. Upon further diagnosis, additional action may be administered. If this alarm results in a battery fire, the Emergency Response Plan (ERP) will be in effect. Megapack Inverter Fault All inverters in the Megapack are faulted If this alarm occurs, Tesla will immediately contact Nexamp and provide the system diagnosis. Simultaneously, Nexamp’ s NOC will be seeing alarms which will trigger an immediate call to the Ithaca Fire Department. Nexamp will notify Ithaca Fire Department of the alarm and provide a diagnosis (if available). Nexamp will communicate that they will update the fire department on the conditions of the BESS. Tesla and Nexamp will shut down the BESS to troubleshoot the issue. Personnel will be dispatched if the issue cannot be resolved remotely. 22 Extreme Temperature Warning Battery cells have reached a temperature above the cell temperature warning threshold If this alarm occurs, Tesla will immediately contact Nexamp and provide the system diagnosis. Simultaneously, Nexamp’ s NOC will be seeing alarms which will trigger an immediate call to the Ithaca Fire Department. Nexamp will notify Ithaca Fire Department of the alarm and provide a diagnosis (if available). Nexamp will communicate that they will update the fire department on the conditions of the BESS. Tesla and Nexamp will shut down the BESS to troubleshoot the issue. Personnel will be dispatched if the issue cannot be resolved remotely. Extreme Temperature Fault Battery cells have reached a temperature above the cell temperature fault threshold If this alarm occurs, Tesla will immediately contact Nexamp and provide the system diagnosis. Simultaneously, Nexamp’ s NOC will be seeing alarms which will trigger an immediate call to the Ithaca Fire Department. Nexamp will ask that Ithaca Fire Department is dispatched, and Nexamp will dispatch their EH&S and Asset Management personnel. Upon further diagnosis, added action may be administered. If this alarm results in a battery fire, the Emergency Response Plan (ERP) will be in effect. Power Electronics Over Temperature Megapack Power Electronics are experiencing an overtemperature If this alarm occurs, Tesla will immediately contact Nexamp and provide the system diagnosis. Simultaneously, Nexamp’ s NOC will be seeing alarms which will trigger an immediate call to the Ithaca Fire Department. Nexamp will notify Ithaca Fire Department of the alarm and provide a diagnosis (if available). Nexamp will communicate that 23 they will update the fire department on the conditions of the BESS. Tesla and Nexamp will shut down the BESS to troubleshoot the issue. Personnel will be dispatched if the issue cannot be resolved remotely. A safe start up procedure following an alarm event is covered in the O&M manual and Tesla emergency response guide included in Nexamp’s supporting documentation package. 5 Notification Matrix To be updated upon discussion with Ithaca Fire Department 6 Emergency Response Considerations 6.1 Emergency Contacts A list of emergency contacts associated with this installation is provided in Section 3.15. 6.2 Equipment and Personnel Protective Equipment (PPE) Full firefighter protective gear shall be worn in any response to a fire and/or explosion event or if there is any sign a fire may be present or likely to be present at any time during the event. The Officer in Charge should have a 4/5 gas meter available, along with a thermal imaging camera (TIC). If there is no risk of fire or explosion present, arc-related (AR) protective clothing to protect against arc flash and electrical shock shall be worn. Jewelry such as necklaces, rings, bracelets, etc. shall be removed to avoid contact with any electrical hazard Proper PPE shall include use of Self-Contained Breathing Apparatus (SCBA). 6.3 APIE (Analyze, Plan, Implement, and Evaluate) Framework APIE is a framework commonly used for emergency incident preparation and development of proper response protocol(s). The four elements of the framework are Analyze, Plan, Implement, and Evaluate. An example of APIE framework with simplified sample details pertaining to an emergency incident is as follows:  Analyze: Provide signs and monitoring signals that indicate incident escalation (e.g., fire or explosion) may take place which first responders should be aware of. 24  Plan: Delineate the danger zone to mitigate first responders and bystanders (pedestrians, vehicular traffic, residents, etc.)  Implement: Enforce evacuations, street closures, reduced pedestrian, and first responder exposure, and other impact areas that have a life safety concern, as applicable.  Evaluate: Provide continuous monitoring and feedback of the incident and adjust accordingly to ensure ongoing safety of any bystander or responder in the impact area. 6.4 Scene Size-up – Command and Control  Initiation of emergency response shall be activated as per the current protocol. If there is any threat or potential threat to life safety, 911 shall immediately be called to the aid of public safety responders. An initial scene assessment shall be conducted from all sides (360-degree scene size up) if possible, and a concise assessment shall be given to incoming responders. Hazards and facility safety concerns such as high voltage areas or electrical concerns shall be announced to all responders. The scene assessment shall include the following in plain language (no codes, abbreviations, acronyms, etc.):  Location of the incident (Where)  What has happened  What is currently happening  Whether there are any injuries or unaccounted for individuals  What needs or other resources should be requested or brought to site An Incident Command System (ICS) should be established immediately and should include the designation of roles. The primary command post location shall be located at the Fire Department Staging Area. If public safety is summoned to the incident, the ICS shall be a Unified Incident Command System (ICS). One-site staff (if applicable) shall immediately go to the designated muster point(s), which will be the command post location unless designated differently by the Incident Commander. Incident Command shall designate the individual in charge of accountability. Accountability should be reported as soon as possible. If available and able, another individual shall control any traffic and guide first responders to the scene. At the same time as these activities are occurring, the Emergency Response Coordinator or other designated SME shall immediately contact the 24/7 Networks Operations Center to establish available data from the BMS and communicate this to the Incident Commander or other appropriate individuals. 6.5 Determine Fire Protection Approach The decision to utilize water spray or to provide thermal cooling via hose lines should be made in coordination with System Owner / Operator, and any other required SMEs. Caution should be exercised if water is applied directly to the exterior of an affected Energy Storage System enclosure, as this will not stop a thermal runaway event and may potentially delay combustion. Defensive firefighting tactics are generally recommended, with water being applied to nearby exposures for cooling, as necessary. Any hose line operations should be limited to hose and master stream application from outside of the BESS area at least 100ft away from the BESS, and as far back as hose and stream range allow. A fog pattern from a handline or monitor nozzle may potentially be utilized to control smoke and gas released from the affected enclosure and prevent them from moving to unwanted areas. 25 In all instances, power shutdown and isolation involving any high voltage feeder lines must be confirmed before any defensive measures are taken involving application of water to the site. 6.6 Incident Monitoring and Evaluation Continuous monitoring and feedback on the incident should be provided as the situation evolves. Consultation with the System Owner/ Operator, and any other required SMEs should be held to guide incident response and determine appropriate next steps. If available, real-time BMS data from the 24/7 Networks Operations Center should be utilized (e.g., temperature, voltage, or other critical measurements) to monitor the spread of failure and assess the health the ESS to help guide response procedures as the event unfolds. 7 Post Incident Operations Handoff Procedures Upon determination by Ithaca Fire Department Incident Commander, when the energy storage system is deemed safe, the System Operator shall ensure that the site is safeguarded until the damaged system is removed, repaired, or replaced based on the approved Decommissioning Plan filed with the building permit. Activation of Decommissioning Plan Decommissioning of the system shall take place in accordance with the Decommissioning Plan filed with the building permit. Deactivation, de-energizing, dismantling and removal of the system shall be conducted by trained and knowledgeable people in accordance with manufacturer’s specifications. 8 Training and Exercises The ERP serves as the platform for the training program and includes the following:  System Overview  Equipment  BMS  Detection and Suppression  Emergency System Shutdown  Hazards  Suppression agents and exposure control  Response tactics  Post-fire operations Initial training for all stakeholders included in this ERP shall be undertaken before the construction of the BESS facility. Refreshment training of the ERP will be offered at least one time annually However, Nexamp will provide additional training at the request of any stakeholders included in the ERP, particularly the Ithaca Fire Department. In accordance with best practices such as NFPA 855, drills should be conducted regularly to exercise knowledge of the ERP and prepare stakeholders for a potential emergency. Over a three-year cycle, drills will grow in complexity and will be evaluated to ensure the ERP can be executed as written. 26 Drills may be desktop, functional, or full-scale and will follow the FEMA/HSEEP doctrine (Link provided below).  Plan Cycle 1 o Cycle 1 drills will be basic in nature and consider the reasonable conditions that may cause the Fire Service to respond to the Facility.  Plan Cycle 2 o Cycle 2 will begin to evaluate more complex equipment failures where facility personnel will collaborate with members of the first response community to mitigate and contain the event.  Plan Cycle 3 o Cycle 3 will represent the most complex scenario that can impact major system components, neighbors, and the environment. https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep 9 Revision Tracking Rev Author(s) Effective Date Description of Revision(s) 0 Mohamed Kassamali, Eli Shandelman 03/12/2026 First Draft of Emergency Response Plan –Technology, Site, and Contact information included 1 2 3 4 5