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Project Dune
Preliminary Hazard Analysis and Fire Risk Assessment
Zerra DC
Reference: 529578
Revision: 0
2026-04-10
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Document
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Report title Preliminary Hazard Analysis and Fire Risk Assessment
Document code Project number 529578
File path Https://aurecongroup.sharepoint.com/sites/529578/5_WorkingFiles/501 Engineering/17 Process Safety/1 PHA
and FRA/Project Dune PHA and FRA Rev 0.docx
Client Zerra DC
Client contact Client reference
Rev Date Revision details/status Author Reviewer Verifier Approver
(if required)
A 2026-02-04 First draft Harini Weerakoon Olivia King Delene Kock Melanie Misiurak
Sam Grayson
B 2026-02-06 Second draft Harini Weerakoon Olivia King Delene Kock Melanie Misiurak
Sam Grayson
C 2026-02-13 Issued for review Harini Weerakoon Olivia King Delene Kock Melanie Misiurak
D 2026-02-27 Updated with client comments Harini Weerakoon Olivia King Delene Kock Melanie Misiurak
E 2026-03-02 Updated with client comments Angelyn Wu Lauren Melanie Misiurak
Landers
0 2026-04-10 Final Harini Weerakoon Delene Kock Melanie Misiurak
Current revision 0
Approval
Author signature Approver signature
Name Angelyn Wu Name Melanie Misiurak
Harini Weerakoon
Title Senior Consultant, Asset Title Project Manager
Management and
Performance
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Contents
1 Introduction .................................................................................................................................................. 5
1.1 Overview ................................................................................................................................... 5
1.2 Purpose .................................................................................................................................... 5
1.3 Key Assumptions ...................................................................................................................... 5
2 Facility Overview ......................................................................................................................................... 7
2.1 Project Description ................................................................................................................... 7
2.2 Site Location and Surrounding Land Uses ............................................................................. 13
3 Legislative and Policy Context ................................................................................................................ 15
4 Methodology .............................................................................................................................................. 17
4.1 Preliminary Hazard Analysis .................................................................................................. 17
4.1.1 Task 1: Regulation Screening Assessment ............................................................ 17
4.1.2 Task 2: Preliminary Hazard Analysis ....................................................................... 17
4.2 Fire Risk Analysis ................................................................................................................... 18
4.3 Recommendations.................................................................................................................. 18
5 Task 1A: Regulation Screening Assessment for Datacentres (Lot 6 and the northern extremity of
Lot 5) ................................................................................................................................................... 19
5.1 Storage Details of Dangerous Goods on Site ........................................................................ 19
5.1.1 Lithium-ion Batteries ................................................................................................ 19
5.1.2 Diesel Fuel and Generators .................................................................................... 19
5.1.3 Generator Lube Oil .................................................................................................. 19
5.1.4 Chilled Water Treatment Chemicals ........................................................................ 19
5.1.5 Sulphur Hexafluoride ............................................................................................... 19
5.1.6 Transformers ........................................................................................................... 19
5.2 Summary of Dangerous Goods Locations ............................................................................. 20
5.3 Dangerous Goods Storage and Handling Requirements ....................................................... 22
5.3.1 The OHS Act and OHS Requirements .................................................................... 22
5.3.2 The Dangerous Goods Regulations ........................................................................ 23
5.3.3 Diesel Fuel ............................................................................................................... 25
5.3.4 Chilled Water Treatment Chemicals (Class 8 DGs) ................................................ 26
6 Task 1B: Regulation Screening Assessment for BESS zone ............................................................... 27
6.1 Storage Details of Dangerous Goods in BESS Zone ............................................................. 27
6.2 Summary of Dangerous Goods Locations ............................................................................. 27
6.3 Dangerous Goods Storage and Handling Requirements ....................................................... 27
6.3.1 The OHS Act and OHS Requirements .................................................................... 27
6.3.2 The Dangerous Goods Regulations ........................................................................ 28
7 Task 2: Preliminary Hazard Analysis ...................................................................................................... 30
7.1 Lithium-ion Battery Hazards ................................................................................................... 30
7.2 Combustible Liquid Hazards .................................................................................................. 30
7.3 Combustion Emissions ........................................................................................................... 30
7.4 Chilled Water Treatment Chemicals ....................................................................................... 30
7.5 Natural Hazards ...................................................................................................................... 30
7.6 Risk Analysis .......................................................................................................................... 31
7.6.1 Risk Analysis Methodology ..................................................................................... 31
7.6.2 Risk Controls ........................................................................................................... 33
7.6.3 Risk Register ........................................................................................................... 33
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8 Fire Risk Analysis ..................................................................................................................................... 34
8.1 Battery Fires ........................................................................................................................... 34
8.1.1 Multi-Point Source Radiation Model ........................................................................ 34
8.1.2 Summary of Inputs for Battery Fire Modelling ......................................................... 35
8.2 Battery Thermal Runaway Off-Gassing.................................................................................. 35
8.2.1 Outdoor Dispersion Model ....................................................................................... 35
8.2.2 Flammable Gas Modelling Inputs ............................................................................ 36
8.2.3 Toxic Gas Modelling Inputs ..................................................................................... 36
8.3 Diesel Pool Fires .................................................................................................................... 37
8.4 Consequence Criteria ............................................................................................................. 37
8.4.1 Heat Radiation Impacts ........................................................................................... 37
8.4.2 Flammable Gas Release Impacts ........................................................................... 38
8.4.3 Toxic Gas Release Impacts .................................................................................... 38
8.5 Results .................................................................................................................................... 38
8.5.1 Battery Fires ............................................................................................................ 38
8.5.2 Battery Thermal Runaway Off-Gassing................................................................... 39
9 Recommendations .................................................................................................................................... 40
9.1 Lithium-ion Battery Safeguards .............................................................................................. 40
9.2 Combustible Liquid Safeguards ............................................................................................. 41
9.3 Chilled Water Treatment Chemicals Safeguards ................................................................... 41
9.4 Natural Hazards Safeguards .................................................................................................. 42
9.5 Additional Supporting Documentation Recommendations ..................................................... 42
9.5.1 Fire Safety Study ..................................................................................................... 42
9.5.2 Emergency Response Plan ..................................................................................... 42
9.5.3 Emergency Information Book .................................................................................. 43
10 References ................................................................................................................................................. 44
Appendices
Appendix A
Risk Register
Appendix B
Lithium-Ion Battery Fire Modelling Approach
Appendix C
Side View Profiles of Off-Gas Modelling
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Figures
Figure 2-1 Overall site plan
Figure 2-2 Stages of the project
Figure 2-3 General arrangement layout - Ground floor
Figure 2-4 General arrangement layout - Level 1
Figure 2-5 General arrangement layout - Roof
Figure 2-6 Map of surrounding land uses (existing parent lot boundaries; to be updated after
subdivision).
Figure 3-1 Required documentation and consultation to comply with FRV GL-55 requirements [9]
Figure 5-1 Generator belly tanks and day tanks locations on the ground floor layout
Figure 5-2 Diesel and Fire Asset Locations
Figure 5-3 PTU locations on the Level 1 layout
Figure 5-4 Form and dimensions of outer warning placard
Figure 5-5 Placard for C1 combustible liquids
Figure 5-6 Placard for Class 8 DGs
Figure 6-1 BESS zone location on overall site layout
Figure 8-1 Visual representation of multi-point source radiation model
Figure 10-1 Visual representation of multi-point source radiation model
Figure 10-2 LFP battery chemistry – 25% LFL side view profile
Figure 10-3 NMC battery chemistry – 25% LFL side view profile
Figure 10-4 LFP battery chemistry – CO IDLH concentration side view profile
Figure 10-5 NMC battery chemistry – CO IDLH concentration side view profile
Figure 10-6 LFP battery chemistry – HF IDLH concentration side view profile
Figure 10-7 NMC battery chemistry – HF IDLH concentration side view profile
Tables
Table 1 Approximate distances of BESS, Lot 6, and future stage development to sensitive receivers
Table 2 Approximate distances of BESS, Lot 6, and future stage development to industrial receivers
Table 3 Lot 6 (and the northern extremity of Lot 5) hazardous/dangerous goods and their threshold
quantities
Table 4 BESS zone hazardous goods and their threshold quantities
Table 5 Natural hazards
Table 6 Hazard consequence assessment matrix
Table 7 Hazard likelihood assessment matrix
Table 8 Risk rating matrix
Table 9 Inputs for battery fire modelling
Table 10 Estimated off-gas component volumes generated from a 13.89 kWh battery rack undergoing
thermal runaway
Table 11 Generation rates used in toxic modelling
Table 12 Heat radiation consequence criteria
Table 13 Battery off-gas LFL values
Table 14 Heat Radiation Distances for Representative PTU/BESS Battery Fire
Table 15 Natural hazards safeguards
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Abbreviations
Abbreviation Definition
AEP Annual Exceedance Probability
HF Hydrogen Fluoride
IDLH Immediately Dangerous to Life and Health
LFL Lower Flammable Limit
SF6 Sulphur Hexafluoride
SOC State of Charge
BMS Battery Management System
BESS Battery Energy Storage Systems
CBD Central Business District
DG Dangerous Good
DG Act Dangerous Goods Act 1985
DG Regulations Dangerous Goods (Storage and Handling) Regulations 2022
EIB Emergency Information Book
EIC Emergency Information Container
ELO Emergency Liaison Officer
ERP Emergency Response Plan
FSS Fire Safety Study
FRA Fire Risk Assessment
FRV Fire Rescue Victoria
IN1Z Industrial 1 Zone
IT Information Technology
LFP Lithium Iron Phosphate
MW Mega Watt
OHS Act Occupational Health and Safety Act 2004
OHS Regulations Occupational Health and Safety Regulations 2017
PHA Preliminary Hazard Analysis
PPF Planning Policy Framework
PTU Power Train Unit
VAD Visual alarm device
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1 Introduction
1.1 Overview
Zerra DC is an independent global investor and asset manager. In order to support the growing demand for
high-capacity data storage and processing facilities within Australia’s technology infrastructure landscape,
Zerra DC have commissioned a proposed data centre development (Project Dune).
Project Dune involves the construction of a new 336 Megawatt (MW) Information Technology (IT) hyperscale
data centre campus, which features data halls with backup battery and generator power supply and on-site
Battery Energy Storage Systems (BESS) that will be seamlessly integrated into the facility’s infrastructure.
The full site (Lot 5 and 6) will be developed in stages, with the initial Stage 1 development focused on Lot 6
and the northern extremity of Lot 5 (boundaries will be realigned as the design progresses and is reflected as
such in drawings).
This Preliminary Hazard Analysis and Fire Risk Assessment report has been prepared to accompany the
planning permit application for Project Dune in accordance with the Hume Planning Scheme [1], Victorian
Planning Provisions [2], and the Victoria Planning and Environment Act, 1987 [3].
1.2 Purpose
Under the Hume Planning Scheme [1], a data centre is classified as a ‘Utility Installation’ and a BESS with a
power rating of 5 MW is classified as a “minor utility installation’.
The data centre and BESS is to be located within an area classified as Industrial 1 Zone (IN1Z) [4]. Pursuant
to Clause 33.01 (subclauses 33.01-1 and 33.01-4) of the Hume Planning Scheme, a planning permit is
required for utility installations and building construction on the site. Clause 33.01-2 of the Hume Planning
Scheme requires that permit applications must provide information regarding the “type and quantity of goods
to be stored, processed, or produced”, and that decisions on an application must also consider the “effect
that the use may have on nearby existing or proposed residential areas or other uses which are sensitive to
industrial off-site effects”.
Additionally, the permit application must determine “Whether a notification under the Victoria Occupational
Health and Safety Regulations 2017 is required, a licence under the Victoria Dangerous Goods Act 1985 is
required, or a fire protection quantity under the Victoria Dangerous Goods (Storage and Handling)
Regulations 2022 is exceeded.”
These requirements have been addressed in this Preliminary Hazard and Fire Risk Assessment report.
The report is used to support pre-planning documentation to meet the requirements for BESS developments
from the local emergency services, Fire Rescue Victoria (FRV).
1.3 Key Assumptions
The following assumptions have been made to conduct this PHA and FRA. Any fire and risk analysis should
be revised as new information comes to light and the design progresses.
 Specific battery chemistry and model are not known at this time, meaning the relevant UL 9540A testing
data is not currently able to be used. As such, conservative off-gas inputs have been used for both toxic
and flammable off-gas modelling, based on the “Review of gas emissions from lithium-ion battery thermal
runaway failure – Considering toxic and flammable compounds” meta-analysis [5].
 It is assumed that there will be 48 lithium-ion batteries on site in Lot 6 (and the northern extremity of Lot
5), with one battery power train unit (PTU) having a capacity of 2,000 kW @ 5 mins. It is assumed that
there are 12 battery racks per lithium-ion battery PTU, meaning each battery rack has a capacity of 13.89
kWh.
 Each battery rack within a BESS unit has the same power capacity as the battery racks within the PTUs.
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 Fire Risk Modelling has been based on outdoor modelling based on Lot 6 (and the northern extremity of
Lot 5) initial design details and drawings. Outdoor modelling is considered more conservative than indoor
data rack modelling, should the design be developed to move the batteries indoors.
 Assessment of the BESS is based on an aggregate 5MWh capacity.
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2 Facility Overview
2.1 Project Description
This proponent (Zerra DC) seeks approval for the use and development of a 336 MW IT hyperscale data
centre campus, which features data halls with backup battery power supply and diesel generators and future
on-site BESS (Project Dune).
An overall site plan is shown in Figure 2-1, which presents Lot 5 and 6. The project is master-planned across
multiple stages as shown in Figure 2-2. Stages 2-6 are located on Lot 5 and are allocated as a future
development.
The Lot 6 (and the northern extremity of Lot 5) and the BESS (Stage 1) development concept design
includes:
 A two-storey building with equipment on the roof
 The ground floor of the building comprises:
 2 x outdoor gantries located on the eastern and western sides of the floor, each containing:
 24 diesel generators
 24 transformers
 24 double-skinned diesel generator belly tanks (20 kL capacity)
 24 double-skinned diesel generator day tanks (1 kL capacity)
 2 × 1060 m2 Zone A data halls
 2 × 877 m2 Zone B data halls
 Lobby
 Office spaces
 Store rooms
 Level 1 of the building comprises:
 2 x outdoor gantries located on the eastern and western sides of the level, each comprising:
 24 x containerised Power Train Units (PTUs) containing batteries
 2 × 1059 m2 Zone A data halls
 2 × 878 m2 Zone B data halls
 Customer stores
 Office spaces
 The roof level of the building will contain external chiller platforms
 Fire tanks and pump room
 External 5 MW BESS
An overall site plan is shown in Figure 2-1, the master plan across multiple stages is shown in Figure 2-2 and
a general arrangement layout of each level of the site is shown in Figure 2-3, Figure 2-4, and Figure 2-5.
Jemena will operate a 66kV substation on-site adjacent to the Stage 1 development.
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Figure 2-1 Overall site plan
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Figure 2-2 Stages of the project
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Figure 2-3 General arrangement layout - Ground floor
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Figure 2-4 General arrangement layout - Level 1
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Figure 2-5 General arrangement layout - Roof
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2.2 Site Location and Surrounding Land Uses
The Project Dune site is to be located at 340 Barry Road in Campbellfield, Victoria (Lot 2 PS900725). The
site is approximately 17 km north of Melbourne Central Business District (CBD) and is within the City of
Hume local government area. As such, the site is governed by the Hume Planning Scheme.
The project site is located within an industrial area (Industrial 1 Zone), which extends further north and east
of the site. A State Transport Infrastructure Zone runs along the length of the western border of the site, with
Industrial 1 Zoning further west. Immediately to the south of the site is a General Residential Zone and a
small Commercial 1 Zone. The adjacent structures on surrounding properties are typically characterised by
low rise portal frame warehouses, transport infrastructure, residential housing, and commercial buildings.
The surrounding land use classifications are shown in Figure 2-6.
It should be noted that the lot boundaries in Figure 2-6 represent the existing parent lot boundary and will be
updated once subdivision is finalised.
Figure 2-6 Map of surrounding land uses (existing parent lot boundaries; to be updated after subdivision).
Distances from Stage 1 and future stages to sensitive and industrial receptors surrounding the site are listed
in Table 1 and Table 2 below.
Table 1 Approximate distances of BESS, Lot 6, and future stage development to sensitive receivers
Sensitive Receptors Distance to BESS Zone Distance to Lot 6 Distance to Future Stage
Development
Residential Areas 645 m south 690 m south 170 m south
Medical Centre and 645 m south 690 m south 130 m south
Pathology
Day Care 475 m northeast 395 m east 400 m northeast
All sensitive receivers are more than 70m from Project Dune and 200m from the BESS.
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Table 2 Approximate distances of BESS, Lot 6, and future stage development to industrial receivers
Industrial Receptors Distance to BESS Zone Distance to Lot 6 Distance to Future Stage
Development
Closest industrial neighbour 40 m east 40 m east 15 m north
(habitable building)
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3 Legislative and Policy Context
The Victorian Planning Policy Framework (PPF) aims to set clear planning objectives for Victoria that
balance environmental, social, and economic factors in land use and development. It highlights the
importance of community facilities that are well-designed, respect the local character, and support the local
industrial economy and employment. Additionally, the PPF encourages new developments to contribute to
the diversity and complexity of the built environment by considering the local context and addressing public
safety and amenity.
According to the Hume Planning Scheme [1], a data centre is classified as a ‘Utility Installation’. Also, the
Project Dune site is located within an Industrial 1 Zone (IN1Z). As such, the following clauses of the Hume
Planning Scheme relevant to IN1Z are applicable to Project Dune:
 Pursuant to Clause 33.01-1 Section 2, a permit is required to use the land for a Utility Installation.
 Pursuant to Clause 33.01-2, an application to use land for an industry or warehouse must be
accompanied by the following information, as appropriate:
‒ The purpose of the use and the types of processes to be utilised.
‒ The type and quantity of goods to be stored, processed, or produced.
‒ How land not required for immediate use is to be maintained.
‒ Whether a Development Licence, Operating Licence, Permit, or Registration is required from the
Environment Protection Authority.
‒ Whether a notification under the Occupational Health and Safety Regulations, 2017 (“the OHS
Regulations”) [6] is required, a licence under the Dangerous Goods Act, 1985 (“the DG Act”) is
required, or a fire protection quantity under the Dangerous Goods (Storage and Handling)
Regulations, 2022 [7] is exceeded.
‒ The likely effects, if any, on the neighbourhood.
 Pursuant to Clause 33.01-4, a permit is required to construct a building or construct or carry out works.
Additionally, Stage 1 includes a proposed <5 MW Battery Energy Storage System (BESS) and a 66 kV
substation to be delivered by Jemena. These pieces of infrastructure are classified under ‘Minor Utility
Installation’ and accordingly are exempt from requiring planning approval under Clause 62.01 and 62.02-1 of
the Hume Planning Scheme [8].
Figure 3-1 below outlines the required documentation to meet Fire Rescue Victoria (FRV) requirements for a
datacentre and commercial and industrial BESS installation based on the energy storage capacity of the
BESS, taken from the FRV Guideline No. 55 (GL-55) “Battery Energy Storage Systems” Version 1 (Aug
2025) [9].
The PTUs located on Lot 6 (and the northern extremity of Lot 5) are associated with the data centre the GL-
55 guideline recommends a Fire Risk Assessment (FRA) as part of the pre-planning permit.
The relevant requirements extracted from Appendix A of GL-55 [9] are highlighted in Figure 3-1 below.
This PHA and FRA report is therefore intended to support the planning permit application for the proposed
data centre by:
 Screening hazards based on the type and quantity of DGs present at the site
 Conducting a risk assessment of hazards and fire risks associated with the site
 Providing recommendations to manage and mitigate risks.
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Figure 3-1 Required documentation and consultation to comply with FRV GL-55 requirements [9]
Thus, this Preliminary Hazard and Fire Risk Assessment report aims to support the application for a planning
permit for the proposed Project Dune by screening hazards based on the type and quantity of dangerous
goods (DGs) at the site, conducting a risk assessment of hazards and fire risks on site, and providing
recommendations from the Preliminary Hazard and Fire Risk Assessment.
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4 Methodology
This section outlines the methodology used for the study. The analysis is confined to hazards within the
development application area. For this study, areas outside this boundary have been defined as off-site.
4.1 Preliminary Hazard Analysis
4.1.1 Task 1: Regulation Screening Assessment
The regulation screening assessment considers all legislative and planning criteria to determine if the facility
triggers any specific criteria related to the storage and handling of identified DGs. This involves identifying
and estimating the type and quantity of DGs, including any storage, transport, or handling activities.
In particular, the assessment is in accordance with the Victoria DG Regulations [7] and FRV Guidelines to
determine if Project Dune is potentially hazardous through the trigger of any Placarding Quantity, Manifest
Quantity or Fire Protection Quantity or land use threshold distance requirements within the Victorian
Planning Provisions.
Task 1 has been divided into Task 1A which assesses Lot 6 and the northern extremity of Lot 5, and Task
1B which assesses the future BESS zone.
4.1.2 Task 2: Preliminary Hazard Analysis
Following the regulation screening assessment, a PHA was conducted for the DGs stored and handled at
the facility in Lot 6 (and the northern extremity of Lot 5) and the external BESS zone.
The assessment focuses on hazard scenarios, especially fire that may result in impacts beyond the Lot 6
(and the northern extremity of Lot 5) facility boundary, defined as “offsite”. In this context, “impact” is defined
as the potential to cause fatalities. The analysis focusses on identifying and evaluating these scenarios to
ensure that any risks are appropriately managed and mitigated.
The methodology for the assessment follows the principles of ISO 31000 and involves the following steps:
 Hazard identification: Identifying hazards associated with Project Dune, particularly those related to
electrical and fire hazards, DGs and hazards that may pose an off-site risk.
 Consequence assessment: Assessing the consequences of each identified hazard and determining
where they may impact adjacent sites or sensitive receptors, screening out those hazards with no
significant impacts and carrying forward only those hazards identified as having a possible impact on
adjacent sites or sensitive receptors.
 Likelihood assessment: Assessing the likelihood of those hazards carried forward from the
consequence assessment using a likelihood assessment matrix.
 Risk assessment: Assessing the risk by evaluating the consequence and likelihood analysis for those
hazards identified to have a significant impact and documenting the risks in a comprehensive Risk
Register.
 Risk control: Identifying and documenting controls for the identified risks based on the hierarchy of
controls, and industry good practice.
For this assessment, a qualitative approach was assumed to be appropriate and sufficient to evaluate the
potential impacts on neighbouring land uses at a concept level of design.
Additionally, risk assessment is a continuous and iterative process. The risk assessment should be regularly
reviewed and updated throughout each stage of the project to address any emerging risks and ensure
ongoing safety.
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4.2 Fire Risk Analysis
The Fire Risk Assessment (FRA) investigates the potential consequences of battery fires and diesel fires,
including those that could extend offsite, based on findings from the Preliminary Hazard Analysis (PHA).
Details of the methodology are as follows:
 Battery Fires:
 Heat radiation –The Multi-Point Source Radiation Model developed by the FM Global Research
Division has been used for this analysis. Further details on this model can be found in Section 8.1.1
and Appendix B. More detailed modelling will be conducted within the Fire Safety Study as further
information becomes available.
 Off-Gassing – DNV PHAST’s Unified Dispersion Model has been utilised. Inputs would ideally be
taken from UL9540A testing data of the specific battery model being used in the project. Given that
these details are not available at this time, estimates were made based on previous project experience
and a meta-analysis of lithium-ion battery thermal runaway off-gassing from literature [5]. This method
was utilised to determine:
 Flammable Gas Release Impacts – The predominant off-gas components that contribute to
flammability were taken from the meta-analysis report. A 25% and 100% concentration of the lower
flammability limit was used as the consequence criteria for this modelling, also taken from the
meta-analysis literature.
 Toxic Gas Release Impacts – Toxic gas release amounts were taken from the meta-analysis
report. The Immediately Dangerous to Life and Health concentrations of relevant components were
used as the consequence criteria for this modelling.
 Diesel Fires: The location of the diesel tanks was assessed to determine if their surroundings are
sufficiently fire-rated to contain a diesel pool fire.
A Fire Safety Study (FSS) for the external BESS zone is also required in accordance with FRV requirements
in GL-55 [9] and will be conducted during the detailed design phase of the project as more information
becomes available.
4.3 Recommendations
Based on the findings from the PHA and FRA, recommendations have been made, if necessary, for
incorporating further effective emergency and fire management planning into the facility's design and
emergency response plan. These recommendations are informed by relevant Australian standards.
The assessment also details any quantitative risk assessments required as part of further detailed design
development prior to construction.
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5 Task 1A: Regulation Screening Assessment for
Datacentres (Lot 6 and the northern extremity
of Lot 5)
5.1 Storage Details of Dangerous Goods on Site
5.1.1 Lithium-ion Batteries
A total of approximately 44,790 kg of lithium-ion batteries has been assumed to be in use at the facility within
Lot 6 (and the northern extremity of Lot 5) based on previous project experience at this early stage of the
design.
It is noted that the Dangerous Goods (Storage and Handling) Regulations 2022 do not apply to DGs that are
batteries while they are in use as per regulation 6(c). No spare batteries will be stored on site.
Lithium-ion batteries do, however pose hazards from thermal runaway.
5.1.2 Diesel Fuel and Generators
The proposed Project Dune design contains 48 diesel generators in its Stage 1 design. Each generator set
will have a day tank with a 1 kL capacity and also an in-built double skinned belly tank with a 20 kL capacity.
The total volume of diesel storage on site for Stage 1 is therefore 1,008 kL. The total amount of diesel stored
on site (all Stages) is 7,060 kL.
5.1.3 Generator Lube Oil
It is anticipated that 300 L of lube oil will be provided for each generator at the site, resulting in a total
quantity of 13,200 L of lube oil for the site.
However, lube oil is classified as a C2 combustible liquid. As per Regulation 6(g) of the DG Regulations [7],
“dangerous goods that are combustible liquids other than C1 combustible liquids” are exempt from the
regulations. Therefore, lube oils have been excluded from this study.
5.1.4 Chilled Water Treatment Chemicals
Dangerous goods such as Class 8 corrosive substances may be used in the chilled water plant on the roof of
the building.
5.1.5 Sulphur Hexafluoride
The electrical switchgear proposed for Project Dune is insulated. Therefore, no sulphur hexafluoride (SF ) is
6
expected to be present on site. Note that the electrical switchgear is a preliminary selection at this early
stage of the project.
5.1.6 Transformers
The transformers proposed for Project Dune are dry-type transformers. Therefore, there are no oils
associated with them. Note that this transformer type is a preliminary selection at this early stage of the
project.
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5.2 Summary of Dangerous Goods Locations
Stage 1 includes generator belly tanks and generator day tanks that are located on the eastern and western
outdoor gantries of the ground floor of the building, shown in Figure 5-1.
Indicative locations of diesel stored on the entire site (All Stages) are presented in Figure 5-2. The diesel is
not in close proximity to residential houses, being >170 m away from the closest residential areas.
The Stage 1 PTUs that contain lithium-ion batteries are located on the eastern and western outdoor gantries
on Level 1, with 24 PTUs on each side shown in Figure 5-3.
Figure 5-1 Generator belly tanks and day tanks locations on the ground floor layout Stage 1
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Figure 5-2 Diesel, Fire Asset, and Site Exit Locations for All Stages
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Figure 5-3 PTU locations on the Level 1 layout
5.3 Dangerous Goods Storage and Handling Requirements
An assessment of the proposed development was conducted to determine if the development needs to
adhere to specific requirements under Victorian legislation. The following regulations and codes were
reviewed against the proposed hazardous materials/dangerous goods and quantities:
 Occupational Health and Safety Act, 2004 [10] (“the OHS Act”) and Occupational Health and Safety
Regulations, 2017 [6] (“the OHS Regulations”).
 Dangerous Goods (Storage and Handling) Regulations, 2022 [7] (“the DG Regulations”).
5.3.1 The OHS Act and OHS Requirements
Section 4(2) of the OHS Act states that “persons who control or manage matters that give rise or may give
rise to risks to health or safety are responsible for eliminating or reducing those risks so far as is reasonably
practicable” [10]. The OHS Regulations provide more detailed, practical requirements for managing specific
hazards and risks to assist duty holders in meeting their obligations under the OHS Act. This Preliminary
Hazard and Fire Risk Assessment report is an important step in the identification and management of health
and safety risks.
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One aspect of the OHS Regulations relates to the identification and requirements of Major Hazard Facilities
(MHFs) (i.e. facilities at which the quantity of Schedule 14 hazardous substances present or likely to be
present at the site exceeds the threshold amounts set out in the OHS Regulations).
A summary of the expected hazardous materials to be stored and handled on site for the project are listed in
Table 3. These have been compared to the MHF threshold quantities provided in Schedule 14 of the OHS
Regulations.
5.3.2 The Dangerous Goods Regulations
The DG Regulations set out the requirements for the use, handling, and storage of DGs at a workplace,
although it is noted that the DG Regulations do not apply to DGs that are batteries while they are in use (as
per regulation 6(c)). This includes the use of lithium-ion batteries used for power backup of the equipment in
the facility’s data halls.
A summary of the expected dangerous goods to be stored and handled on site for the project are listed in
Table 3. DGs that are within the scope of the DG Regulations have been compared to the threshold
quantities provided in Schedule 2 of the DG Regulations for placarding, manifest, and fire protection
quantities. Where these threshold quantities are exceeded, relevant requirements are assessed in this
report.
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Table 3 Lot 6 (and the northern extremity of Lot 5) hazardous/dangerous goods and their threshold quantities
Material UN Number DG Category Packing Project storage quantities Dangerous Goods Threshold MHF Threshold
Class Group Schedule 14 quantities
Threshold exceeded?
Placarding Manifest Fire
Protection
Lithium-ion 3536 (Lithium 9 Miscellaneous II Batteries in use[1]: 1,000 kg 10,000 20,000 kg N/A[2] N/A[1]
batteries batteries DGs and 576 battery racks within PTUs kg
(data centre) installed in articles
= 44,790 kg total
cargo transport
unit)
Diesel 1202 N/A – diesel is a C1 N/A Stage 1: 10,000 L 100,000 L 100,000 L N/A Placarding,
combustible liquid. C1 48 x 20,000 L generator belly tanks Manifest, and
combustible liquids are = 960,000 L Fire Protection
covered by the DG thresholds
48 x 1,000 L generator day tanks =
Regulations. exceeded
48,000 L
= 1,008,000 L total
Total stored on site (All Stages)
= 7,060,000 L
Various Various 8 Corrosive II Typically less than 500L. Assumed 250 L 2,500 L 10,000 L MHF Placarding
potential (depending on substances that storage quantities of any water Schedule 14 threshold
chilled water specific treatment chemicals will be less thresholds will quantities
treatment chemicals than Manifest and Fire Protection not be exceeded
chemicals used) Threshold quantities listed in the exceeded.
DG Regulations.
Notes:
1. Lithium-ion batteries are not subject to the requirements of the DG Regulations as per Regulation 6(c) and hence do not have a prescribed storage threshold under Schedule 2 of the
DG Regulations. However, batteries in storage (not in use) are subject to the requirements of the DG Regulations and subsequent thresholds.
2. Not listed in Schedule 14 of the OHS Regulations
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A licence under the Dangerous Goods Act, 1985 (“the DG Act”) is required [11]. A summary of the additional
requirements under the DG Regulations [7] are listed below.
5.3.3 Diesel Fuel
Placarding Requirements
In accordance with Regulation 46 of the DG Regulations, “HAZCHEM” outer warning placards are to be
displayed at every entrance for road vehicles.
These placards are to have the word “HAZCHEM” in red (Signal Red (R13) – AS 2700:2011) letters not less
than 100 mm high on a white or silver background, in the style shown in Figure 5-4.
Figure 5-4 Form and dimensions of outer warning placard
Specifically for the diesel generator belly tanks, the placard for C1 combustible liquids (in bulk) must display
the words “COMBUSTIBLE LIQUID” in the style shown in Figure 5-5, in black letters that are not less than
100 mm high and on a white or silver background.
Figure 5-5 Placard for C1 combustible liquids
Manifest Requirements
In accordance with Regulation 44 of the DG Regulations, the occupier of premises must ensure that a
manifest is kept on premises in a location or place where it is readily accessible to the emergency services
authority, in this case, Fire Rescue Victoria (FRV).
As per regulation 53(5), the location of the manifest must be clearly described in the emergency plan for the
facility.
Regulation 64 of the DG Regulations states that “An occupier of premises where notifiable goods are present
must ensure that the Authority is provided with a notification of the presence of those goods that complies
with subregulation (2)”. Under subregulation (2)(c)(viii) the operator of the facility has a duty to notify the
Authority (WorkSafe Victoria) of DGs exceeding manifest quantities, including details specifically regarding
any C1 combustible liquids.
Fire Protection Requirements
In accordance with Regulation 52 of the DG Regulations, where DGs are stored and handled in quantities
that exceed the fire protection threshold quantities, the occupier must:
 Request the written advice of FRV, in relation to the design of the fire protection system for the premises;
and
 in establishing the fire protection system for the premises, have regard to that written advice.
To support this written advice, FRV’s Guideline No. 55 (GL-55) “Battery Energy Storage Systems” [9]
recommends a Fire Safety Study (FSS) in line with FRV’s Fire Safety Study Guideline (GL-54) [12] as part of
detailed design development.
It is noted that this Regulation will be triggered with each Stage of the development meaning an FSS will be
required for each stage of the development to support the request for written advice.
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5.3.4 Chilled Water Treatment Chemicals (Class 8 DGs)
The chilled water treatment chemicals to be utilised within the chiller systems are not determined at this
stage of the design. Typically small quantities of sodium hypochlorite are used.
The following placarding requirements may apply, provided Class 8 DGs are utilised for water treatment
(common practice for data centres) and applicable storage and handling manifest quantities are not
exceeded.
Placarding requirements
In accordance with Regulation 46 of the DG Regulations, “HAZCHEM” outer warning placards are to be
displayed at every entrance for road vehicles. The placard must have the form and dimensions shown in
Figure 5-4.
In addition to outer warning placards at the entrance for road vehicles, there are other placarding
requirements. Additional placarding must be
 Displayed at the following locations:
 at the entrance to any building where the DGs are stored
 at the entrance to each room in which the DGs are stored; and
 adjacent to any external storage area where the DGs are stored.
 Clearly legible and separate from any other sign or writing that contradicts, qualifies or distracts attention
from the placard
In accordance with Regulation 47, where DGs are stored and handled, any storage of packaged DGs that
exceeds the quantity specified Schedule 2 must be placarded.
 The placard must be kept clean, in good order and unobstructed
 The placard must be located so that it is clearly legible by persons approaching the placard and separate
from any other sign or writing that contradicts, qualifies or distracts attention from the placard.
 The placard must be located:
 at the entrance to any building in which the DGs are stored; and
 within a building, at the entrance to each room or other closed or walled section of the building in
which the DGs are stored; and adjacent to any external storage area where the DGs are stored.
 adjacent to any external storage area where the DGs are stored.
 For packaged DGs the placard must:
 have the form shown in Figure 5-6; and
 be of sufficient size to accommodate the labels to be displayed on it.
 In relation to Figure 5-6, the Class label must have sides at least 100 mm long.
Figure 5-6 Placard for Class 8 DGs
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6 Task 1B: Regulation Screening Assessment for
BESS zone
6.1 Storage Details of Dangerous Goods in BESS Zone
A total of approximately 74,250 kg of lithium-ion batteries has been assumed for the BESS to be in use at
the facility in the external BESS Zone.
It is noted that the Dangerous Goods (Storage and Handling) Regulations 2022 [7] do not apply to DGs that
are batteries while they are in use as per regulation 6(c). No spare batteries will be stored on site.
Lithium-ion batteries do however pose hazards from thermal runaway.
6.2 Summary of Dangerous Goods Locations
The BESS is located adjacent to Lot 6 on the southern side, shown Figure 6-1 below.
Figure 6-1 BESS zone location on overall site layout
6.3 Dangerous Goods Storage and Handling Requirements
An assessment of the proposed development was conducted to determine if the development needs to
adhere to specific requirements under Victorian legislation. The following regulations and codes were
reviewed against the proposed hazardous materials and quantities:
 Occupational Health and Safety Act, 2004 [10] (“the OHS Act”) and Occupational Health and Safety
Regulations, 2017 [6] (“the OHS Regulations”).
 Dangerous Goods (Storage and Handling) Regulations, 2022 [7] (“the DG Regulations”).
6.3.1 The OHS Act and OHS Requirements
Section 4(2) of the OHS Act states that “persons who control or manage matters that give rise or may give
rise to risks to health or safety are responsible for eliminating or reducing those risks so far as is reasonably
practicable” [10]. The OHS Regulations provide more detailed, practical requirements for managing specific
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hazards and risks to assist duty holders to meet their obligations under the OHS Act. This Preliminary
Hazard and Fire Risk Assessment report is an important step in the identification and management of health
and safety risks.
One aspect of the OHS Regulations relates to the identification and requirements of Major Hazard Facilities
(MHFs) (i.e. facilities at which the quantity of Schedule 14 hazardous substances present or likely to be
present at the site exceeds the threshold amounts set out in the OHS Regulations).
A summary of the expected hazardous materials to be stored and handled on site for the project is listed in
Table 3. These have been compared to the MHF threshold quantities provided in Schedule 14 of the OHS
Regulations.
6.3.2 The Dangerous Goods Regulations
The DG Regulations set out the requirements for the use, handling, and storage of DGs at a workplace.
Although it is noted that the DG Regulations do not apply to DGs that are batteries while they are in use (as
per regulation 6(c)).
A summary of the expected hazardous materials to be stored and handled on-site for the project is listed in
Table 4. DGs that are within the scope of the DG Regulations have been compared to the threshold
quantities provided in Schedule 2 of the DG Regulations for placarding, manifest, and fire protection
quantities.
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Table 4 BESS zone hazardous goods and their threshold quantities
Material UN Number DG Category Packing Project Dangerous Goods Threshold MHF Threshold
Class Group storage Schedule 14 quantities
quantities Threshold exceeded?
Placarding Manifest Fire Protection
Lithium-ion 3536 (Lithium 9 Miscellaneous II Batteries in 1,000 kg 10,000 kg 20,000 kg N/A[2] N/A[1]
batteries batteries installed DGs and articles use[1]:
(BESS) in cargo transport 5 x battery
unit) enclosures
= 74,250 kg
Notes:
1. Lithium-ion batteries in use are not subject to the requirements of the DG Regulations as per Regulation 6(c) and hence do not have a prescribed storage threshold under Schedule 2
of the DG Regulations.
2. Not listed in Schedule 14 of the OHS Regulations.
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7 Task 2: Preliminary Hazard Analysis
Following the regulatory screening assessment in Section 5, it was determined that a PHA and FRA should
be conducted for batteries and diesel as manifest and fire protection quantities have been exceeded, and
lithium-ion batteries and diesel pose a fire risk.
7.1 Lithium-ion Battery Hazards
The primary hazard consideration for lithium-ion batteries is adequate cooling and management of
temperature excursions. The optimal storage conditions are typically between 20°C and 40°C in dry
conditions (45- 85% humidity) [13]. However, at a minimum lithium-ion batteries should be kept below 80°C
[13] to prevent thermal runaway, which causes propagation of increasing temperatures, pressures, and fire
towards neighbouring cells. The temperature of the lithium-ion batteries should also not drop below -20°C
[13] to prevent lithium plating around the anode during charging, which can cause internal shorts.
Although the choice of anode-cathode chemistry can result in different thermal stability and volatility, all
lithium-ion batteries are flammable when exposed to fire. Lithium-ion fires are a unique class of fire that may
result in the emission of large volumes of toxic or combustible gases, which must be managed accordingly.
Thermal runaway or lithium-ion battery fires could cause significant damage to the facility, whilst the smoke
could cause off-site health consequences to the surrounding population.
7.2 Combustible Liquid Hazards
The primary hazard for combustible liquids such as diesel is a loss of containment. A release of combustible
liquid can result in harm to human health, as a result of the following incidents:
 Fire
 Explosion
 Chemical reaction to incompatible substances.
A fire involving combustible liquids in the facility could cause significant damage, whilst the smoke could
cause off-site health consequences to the surrounding population. With no or inadequate safeguards in
place, there is also the potential for a fire to escalate to impact off-site areas.
7.3 Combustion Emissions
Diesel generators will produce emissions that include nitrogen oxides, carbon monoxide and possibly other
volatile components, particles and sulphur oxides, all of which can have serious impacts on human health.
Operational emissions are not considered hazardous in the context of this analysis and are regulated by the
Environment Protection Authority Victoria.
7.4 Chilled Water Treatment Chemicals
Should Class 8 DG water treatment chemicals be selected for the chilled water system, chlorine compounds
e.g. sodium hypochlorite, can cause chemical burns that may affect skin, eyes and the respiratory tract. A
reaction with incompatible materials (such as aluminium, zinc or any acid) may cause a release of hydrogen
or chlorine that could lead to an injury or fatality.
7.5 Natural Hazards
The natural hazards relevant to this site of development have been detailed in Table 5.
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Table 5 Natural hazards
Hazard Description
Extreme High ambient temperatures may result in thermal expansion of diesel, which can increase the
temperatures pressure inside the tank and result in leaks. Both the diesel generator day tanks and diesel
generator belly tanks are located in the outdoor gantries of the ground floor.
The temperature data at Essendon Airport weather station (Site No. 086038) over the course of 56
years were as follows: annual maxima and minima were 47.3°C and -3.3°C, respectively with
temperature data recorded at 9 am [14].
Bushfires The site location is not located within a bushfire prone area per VicPlan [4].
Seismic Seismic activity may result in:
activity  Damage to infrastructure and equipment.
 Potential injury and death are dependent on the magnitude of a seismic event.
According to the National Seismic Hazard Assessment 2018, the peak ground acceleration for a
10% exceedance in 50 years is 0.02 – 0.03 g [15].
Flooding Flooding may result in damage to infrastructure and equipment.
The 1% Annual Exceedance Probability (AEP) Flood Extent in VicPlan does minorly overlap the
proposed site. Water is projected to intrude the Western property line by a maximum of ~11m.
Further detail regarding the project’s stormwater management strategy through on-site drainage
infrastructure is captured in the Stormwater Management Plan [16].
Excessive High wind speeds may result in damage to infrastructure and equipment.
wind Based on wind rose data from the Bureau of Meteorology weather station at Essendon Airport (Site
No. 0866038,), it was found that the wind at 9 am predominantly comes from the northern direction
[17], whereas the wind at 3 pm predominantly comes from the south [18]. At 9 am, the wind blows
from the north for almost 30% of the time. The northerly wind also has the highest frequency above
40 km/h. At 3 pm, the wind blows from the south for more than 30% of the time, however the
northerly wind still has the highest frequency above 40 km/h.
Lightning Direct lightning strikes may result in:
 Damage to infrastructure and equipment
 Potential battery fire hazard resulting in burns or smoke / chemical inhalation.
The average annual ground lightning flash density in Campbellfield, Victoria is ~0.5-1 km2/yr [19].
7.6 Risk Analysis
In this study, risk is defined as the likelihood of a specified undesired event occurring within a specified
period or in specified circumstances. It may be either a frequency (the number of specified events occurring
in a unit of time) or a probability (the probability of a specified event following a prior event), depending on
the circumstances.
7.6.1 Risk Analysis Methodology
The matrices set out in Table 6, Table 7, and Table 8 were used to complete a qualitative risk assessment of
the identified hazards. Consistent with AS 5139 risk assessment methodology, the risk rating for a given
hazard is a product of the likelihood and the consequence of its occurrence.
As such, the potential consequence for each identified hazard carried forward due to posing a significant off-
site risk was first assessed (Table 6) followed by an assessment of their estimated likelihood of occurrence
(Table 7). Finally, the overall inherent risk rating was calculated using likelihood and consequence as inputs
(Table 8) with and without mitigations and controls in place.
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Table 6 Hazard consequence assessment matrix
Consequence People Property Environment Community
Permanent /
Virtual irreversible
Outrage by a sizeable
A – complete loss widespread
Single or multiple fatality. community or many
Catastrophic of plant or ecological damage
communities. Riots.
system. not able to be
remediated.
Disabling injury or illness
Extensive
(i.e. amputation and/or Extensive ecological Community / NGO legal
damage to
B – Major permanent loss of bodily damage, lengthy actions. Pickets,
plant or
function), or any kind of remediation process. demonstrations.
system.
permanent health impact.
Persistent formal
Any lost time injury (i.e. an Significant
Substantial ecological community complaints.
illness or injury resulting in damage to
C – Moderate damage but able to Formal complaints to
one or more consecutive plant or
be remediated. politicians or comparable
days or shifts off work). system.
representatives.
Damages
Localised ecological Formal complaints from
A medical treatment case / impacting on
D – Minor damage, easily local community
or restricted work case. budget and
remediated. complaints locally.
program.
No informal community
First aid case, or an injury or Minor damage Negligible ecological
complaints and/or
E – Incidental illness not requiring to plant or damage, may not
negative comments /
treatment. system. require remediation.
views.
Table 7 Hazard likelihood assessment matrix
Likelihood Descriptor Likelihood Industry incidences
The threat is expected to be
5 – Almost Certain 90% < likelihood ≤ 100% Common incident.
realised.
The threat is likely to be
4 – Likely 5% < likelihood ≤ 90% Several incidents nationally.
realised.
One or a few incidents
3 – Possible The threat may be realised. 1% < likelihood ≤ 5%
nationally.
No known national incidents.
The threat is not expected to One or a few incidents in
2 – Unlikely 0.1% < likelihood ≤ 1%
be realised. comparable international
operating regimes.
The threat may be realised in No known incidents in
1 – Rare reasonably foreseeable but 0% < likelihood ≤ 0.1% comparable international
exceptional circumstances. operating regimes.
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Table 8 Risk rating matrix
Consequence
1 – Incidental 2 – Minor 3 – Moderate 4 – Major 5 – Catastrophic
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ytilibaborP
A - Almost Certain Medium High Critical Critical Critical
B – Likely Medium Medium High Critical Critical
C – Possible Low Medium Medium High Critical
D – Unlikely Low Low Medium Medium High
E – Rare Low Low Low Medium Medium
The risk rating presented in Table 8 above is a conservative iteration of the risk rating matrix presented in
AS/NZS 5139:2019 – Electrical Installations – Safety of battery systems for use with power conversion
equipment.
7.6.2 Risk Controls
After hazard identification and risk analysis, controls are proposed for each individual risk, with the aim of
reducing the risk rating, either by reducing the likelihood or the consequence. Controls can be mitigative or
preventative and should follow the hierarchy of controls (used by WorkSafe Victoria). In descending order of
importance, these are:
 Elimination: Physically remove the hazard
 Substitution: Replace the hazard
 Engineering controls: Isolate people from the hazard
 Administrative controls: Change the way people work
 Personal protective equipment: Protect the worker from the hazard.
High level controls that should be considered for each identified hazard are listed in the risk register in
Appendix A.
7.6.3 Risk Register
The identified hazards, events, applicable infrastructure, and the relationships with causes, consequences,
and controls are summarised in the risk register in Appendix A.
Importantly, the consequences of these events are not anticipated to lead to significant impacts.
The risk assessment has shown that, whilst there is potential for major consequences, implementation of risk
controls will make these consequences unlikely. The current and recommended technical and management
safeguards set out in Section 9 are intended to reduce the residual risk.
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8 Fire Risk Analysis
Consequence modelling of battery fires and off-gas dispersion has been completed for the batteries. The
modelling is considered representative for the PTUs and BESS units as they are assumed to have the same
power capacity per battery rack as stated in the Key Assumptions in Section 1.3.
8.1 Battery Fires
8.1.1 Multi-Point Source Radiation Model
It is noted that a battery fire event is transient in nature, involving the rapid emission of flammable and toxic
gases. The release of flammable gases may lead to flash fires, jet-like flame emissions, or overpressure
events. The release of toxic gases and unignited flammable gases is covered in Section 8.2. This section is
related to the heat radiation impacts of a battery rack fire located within the PTUs in gantries and BESS units
external to the data halls.
In order to estimate the worst-case radiative characteristics of a lithium-ion battery fire (i.e. heat flux
experienced in the vicinity of a battery rack fire), a multi-point source radiation model has been used. The
model used is the one developed by the FM Global Research Division [20], which was validated against
battery fire test results and applied to predict the radiative heat flux at arbitrary distances from the fire. The
multi-point source radiation model is expected to be superseded by more detailed modelling in the Fire
Safety Study to be completed during the detailed design.
A visual representation of the multi-point source radiation model is shown in Figure 8-1. The flame is
modelled as a vertical line consisting of multiple evenly spaced radiation point sources along the length of
the flame (𝐿 ). One such radiation point source (𝑧 ) is shown in the Figure 8-1 below. The emissive power of
(cid:3033) (cid:3043)
the fire is assumed to have a linear distribution with a peak location at height 𝑧 . The cumulative heat flux
(cid:3040)
experienced at an observer point (e.g. the point 𝑥 ,𝑦 ,𝑧 shown below) is calculated by summing the heat
(cid:2868) (cid:2868) (cid:2868)
flux from each point source that makes up the flame model.
Figure 8-1 Visual representation of multi-point source radiation model
The key inputs to the model are:
 Flame height (𝐿 (cid:3033) )
 Heat release rate of the fire (𝑄(cid:4662) (cid:3030)(cid:3035)(cid:3032)(cid:3040) )
 Radiant fraction (𝜒 (cid:3045) )
 Distance between radiation point sources (𝑑𝑧)
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 Height of flame corresponding to peak fire emissive power (𝜃).
Refer to Appendix B for a description of how the multi-point source radiation model has been constructed.
The input values used in the model are provided in the next section.
8.1.2 Summary of Inputs for Battery Fire Modelling
The inputs for the battery fire modelling are listed in Table 9. These inputs have been used for the batteries
in use within the PTUs/BESS units located in gantries external to the data halls.
Table 9 Inputs for battery fire modelling
Parameter Value Comment
Height of battery rack 2.0 m Dimensions of representative Battery Rack unit that may be used at
the Facility within a PTU/BESS unit.
Flame height (𝐿 ) 2.82 m Height has been assumed based on typical dimensions of a
𝑓
PTU/BESS unit.
Heat release rate of the fire 0.3221 kW The maximum heat release rate in accordance with the multi-point
(𝑄(cid:4662) ) source radiation model by the FM Global Research Division, where
(cid:3030)(cid:3035)(cid:3032)(cid:3040)
the battery rack capacity is 13.89 kWh.
Radiant fraction (𝜒 ) 0.36 Based on the average radiant fraction recorded during the growth
(cid:3045)
phase of the fire in the FM Global large-scale battery fire testing.
Vertical distance between 0.1 m Small distance between point sources resulting in 29 point sources
radiation point sources (𝑑𝑧) along the flame height of 2.82 m.
Height of flame 40% of flame Assumed value based on development of multi-point source
corresponding to peak fire height (i.e. radiation model by the FM Global Research Division and modelled
emissive power (𝜃) 1.13 m) heat fluxes showing good agreement with measurements.
8.2 Battery Thermal Runaway Off-Gassing
8.2.1 Outdoor Dispersion Model
The Unified Dispersion Model (UDM) within the DNV PHAST consequence modelling software was used to
model the battery off-gassing scenarios, including both flammable and toxic impacts. The key inputs for the
model are:
 Off-gas release rate, release velocity and duration
 Height and orientation of release
 Weather parameters.
The release rates, velocities and duration are outlined in the following sections for flammable and toxic
components.
The height of the release was assumed to be 2.5 m to represent the height of the vents on the PTU/BESS
unit. The orientation of the release was assumed to be horizontal (assuming vents on the sides of the
PTU/BESS unit).
The dispersion of gas clouds and impacts of thermal radiation are governed by prevalent weather conditions
including wind speed and direction (horizontal mixing) as well as stability of the atmosphere (vertical mixing).
The latter is the extent that wind turbulence, responsible for the dispersion, is either suppressed or assisted.
On cold windless nights, cold air is trapped close to the surface of the earth, and any gas release would not
be easily dispersed. In comparison, on a hot summer’s day there is increased turbulence of the air due to
heating of the earth’s surface, this aids the dispersion of gases.
Pasquill-Gifford classes have been used as the method to classify atmospheric conditions, as follows:
 A – Turbulent
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 B – Moderately unstable
 C – Slightly unstable
 D – Neutral
 E – Slightly stable
 F – Moderately stable.
Two weather conditions were used for each modelling iteration:
 Representative daytime: 6 m/s wind speed in D stability atmospheric conditions (neutral – little sun and
high wind)
 Representative night-time: 2 m/s wind speed in F stability atmospheric conditions (stable – night with
moderate clouds and light/moderate wind).
8.2.2 Flammable Gas Modelling Inputs
Given the battery chemistry, original equipment manufacturer (OEM), and model are not confirmed for the
Facility at this time, UL 9540A testing was not able to be used as the basis for flammable off-gas modelling
inputs. Instead, the off-gas composition and volumes were taken from a meta-analysis of lithium-ion battery
thermal runaway off-gassing [5].
The predominant off-gas components are hydrocarbons, carbon monoxide (CO), carbon dioxide (CO ) and
2
hydrogen (H ). Smaller amounts of other non-flammable compounds, such as fluorine compounds, organic
2
compounds, and other gases were also recorded in the meta-analysis but were excluded from this report’s
flammable gas modelling.
Based on the meta-analysis, the estimated off-gas component volumes generated from a 13.89 kWh battery
rack undergoing thermal runaway are listed for both lithium iron phosphate (LFP) and nickel manganese
cobalt (NMC) battery chemistries in Table 10.
Table 10 Estimated off-gas component volumes generated from a 13.89 kWh battery rack undergoing thermal
runaway
Recorded off-gas component LFP NMC
Total hydrocarbons (propane 664 L 1,038 L
equivalent)
CO 716 L 2,163 L
CO2 1,534 L 3,113 L
H2 2,198 L 1,729 L
Total 5,112 L 8,042 L
Using these off-gas volumes, the overall off-gas mass flow rate was calculated assuming a total off-gassing
duration of 60 minutes. Whilst a thermal runaway event for an entire battery rack may last longer than this,
using a shorter duration results in higher, and therefore more conservative, off-gas release rates.
The off-gas mass flow rate for the LFP chemistry battery rack was calculated as 9.41 × 10-4 kg/s, whilst for
the NMC chemistry battery rack the off-gas mass flow rate was 1.92 × 10-3 kg/s.
8.2.3 Toxic Gas Modelling Inputs
Similar to the flammable gas modelling, the meta-analysis of lithium-ion battery thermal runaway off-gassing
[5] was used to estimate the toxic component off-gas rates. The predominant toxic components of battery
thermal runaway off-gas are carbon monoxide (CO) and hydrogen fluoride (HF). Smaller amounts of other
toxic compounds, such as hydrogen cyanide, hydrogen chloride, nitrogen dioxide, and sulphur dioxide may
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also be released but were excluded from this report’s toxic gas modelling as the impact zones for CO and
HF will dominate.
The CO off-gas volumes for LFP and NMC battery chemistries are listed in Table 10 were also used for the
toxic gas modelling.
For HF, the following data was used to derive HF generation rates:
 Based on the data for LFP batteries [5], the total mass of HF emitted from batteries undergoing thermal
runaway is dependent on the state of charge (SOC) of the battery and is a function of the battery
capacity. The highest average value recorded was ~150 g/kWh. This figure was used to calculate the HF
generation rate for the LFP battery chemistry.
 Similarly, for NMC batteries [5], the highest average value recorded was ~17 g/kWh. This figure was used
to calculate the HF generation rate for the NMC battery chemistry.
Table 11 shows the overall mass and mass flow rates of HF and CO generated for both battery types. As per
the flammable gas modelling inputs, the mass flow rates of HF have been based on an overall off-gassing
duration of 60 minutes.
Table 11 Generation rates used in toxic modelling
Battery type HF generated (g) HF generation rate CO generated (g) CO generation rate
average (kg/s) average (kg/s)
LFP 2,084 5.79 × 10-4 560 1.56 × 10-4
NMC 236 6.56 × 10-5 1,694 4.70 × 10-4
8.3 Diesel Pool Fires
Diesel pool fires from the generator belly tanks and day tanks were not modelled due to their location within
2-hour fire-rated enclosures in the outdoor gantry on the ground floor. The heat radiation effects of a diesel
fire in these enclosures would be contained within the enclosure.
8.4 Consequence Criteria
8.4.1 Heat Radiation Impacts
The heat radiation consequence criteria assessed for each representative fire scenario are listed in Table 12
below. These criteria are primarily based on those provided in HIPAP 2 [21] except for 3 kW/m2, which has
been derived from AS 1940 and is the threshold heat radiation exposure limit for fire services personnel to
operate firefighting equipment for up to 10 minutes.
For escalation of a battery fire from one battery rack to adjacent battery racks, the temperature at the
adjacent battery rack would have to increase to a point that induces thermal runaway. Understanding the
temperature profiles around a battery rack on fire as well as heat flux levels is therefore also important. The
temperature required to induce thermal runaway is typically provided in UL 9540A testing. However, as
UL 9540 is not available for battery racks to be used for this project, the temperature profile was not
estimated. This should be assessed as part of the fire safety study, in the detailed design phase of the
project.
Table 12 Heat radiation consequence criteria
Heat Radiation Effect
(kW/m2)
3  Threshold heat radiation exposure limit for fire services personnel to operate firefighting
equipment for up to 10 minutes.
4.7  Will cause pain in 15-20 seconds and injury after 30 seconds’ exposure (at least second-degree
burns will occur).
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Heat Radiation Effect
(kW/m2)
12.6  Significant chance of fatality for extended exposure. High chance of injury.
 Causes the temperature of wood to rise to a point where it can be ignited by a naked flame
after long exposure
 Thin steel with insulation on the side away from the fire may reach a thermal stress level high
enough to cause structural failure.
23  Likely fatality for extended exposure and chance of fatality for instantaneous exposure
 Spontaneous ignition of wood after long exposure
 Unprotected steel will reach thermal stress temperatures which can cause failure
 Pressure vessel needs to be relieved, or failure would occur.
8.4.2 Flammable Gas Release Impacts
Flammable gas impacts from thermal runaway were assessed by modelling the downwind distances to
100% and 25% of the lower flammable limit (LFL) of the mixture. The LFL values for the off-gas mixtures for
each battery type (refer to the mixture compositions in Table 10) are given in Table 13 below.
Table 13 Battery off-gas LFL values
Battery type 25% LFL (ppm) 100% LFL (ppm)
LFP 13,842 55,370
NMC 18,289 73,154
8.4.3 Toxic Gas Release Impacts
The toxic impacts from thermal runaway were assessed by modelling the downwind distance to the
Immediately Dangerous to Life and Health (IDLH) concentrations:
 CO: 1,200 ppm
 HF: 30 ppm
8.5 Results
8.5.1 Battery Fires
Using the multi-point source radiation model, distances to the heat radiation criteria were calculated for a
representative battery rack fire within a PTU/BESS unit. LFP and lithium nickel oxide (LNO) / lithium
manganese oxide (LMO) battery chemistries were considered, based on available data from the FM Global
Research Division [20]. The resulting distances at a receptor height of approximately 1.1 m are summarised
in Table 14.
The results indicate that heat radiation impacts from a single battery rack fire are highly localised. The
PTU/BESS unit enclosure may provide some degree of physical shielding, reducing heat radiation to
adjacent areas. However, the fire resistance rating of the enclosures has not been confirmed at this stage of
design. Should the enclosures not be fire-rated, degradation of the enclosure over the duration of the fire
would result in external heat radiation impacts.
These findings are preliminary and should be reassessed in the Fire Safety Study with specific battery data
(i.e. from UL 9540A testing) as inputs.
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Table 14 Heat Radiation Distances for Representative PTU/BESS Battery Fire
Heat radiation (kW/m2) Distance (m) to heat radiation Distance (m) to heat radiation
criteria (LFP batteries) criteria (LNO/LMO batteries)
3 1.7 2.5
4.7 1.3 1.9
12.6 0.7 1.1
23 0.5 0.8
8.5.2 Battery Thermal Runaway Off-Gassing
The 100% and 25% LFL concentrations were not reached for any instance of the LFP or NMC battery
chemistries at a height of interest of 1.5 m aboveground, which was used to assess potential impacts to a
person. Side-view profiles of the flammable vapour clouds are provided in Appendix C.
It was found that neither the IDLH for HF (30 ppm) or CO (1,200 ppm) were reached for the LFP or NMC
battery chemistries at the height of interest of 1.5 m aboveground. Side-view profiles of the toxic vapour
clouds are provided in Appendix C.
Prompt detection of the off-gases from the battery thermal runaway is critical to minimise the chance of a
large-scale battery fire from developing. Detection measures included in the design are discussed in Section
9.1. The response to an incident should be covered through the development of the Emergency Response
Plan for the Facility to be completed prior to commissioning or operation of the facility, in consultation with
FRV (refer to Section 9.5.2).
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9 Recommendations
There are several Australian and international standards which govern the best practice design and
installation of the facility. The following recommended safeguards are expected to reduce the residual risk
such that no identified hazards pose a significant risk.
9.1 Lithium-ion Battery Safeguards
The following safeguards are recommended to mitigate the risk of lithium-ion battery thermal runaway and
fire so far as is reasonably practicable (SFAIRP), thereby meeting the requirements of Regulation 4 of the
OHS Act [10]:
 Conduct full-scale fire testing once the OEM for the BESS zone is determined to determine the safe
separation distances and layout required for this zone.
 The lithium-ion batteries adopted for this project must be UL certified in accordance with UL-9540A as
well as being sourced from a reputable supplier which adheres to Australian quality and testing
standards.
 Battery Management System (BMS) to provide functional safety of electronic safety-related systems.
 Adequate ventilation (e.g. mechanical exhaust) sized to limit the concentrations of flammable and toxic
off-gases that would be generated during thermal runaway.
 Provision of cooling systems to remove excess heat.
 Provision of thermal and smoke detection systems, including an off-gas detection system.
 A red visual alarm device (VAD) that conforms with AS ISO 7240.3-2021 to be affixed to the wall at or
near the entrance to an occupiable physical enclosure that contains lithium-ion batteries. The activation of
the VAD should be initiated by the installed detection system, BMS or any other automatic or manual
protection measure that may be in place.
 Provision of a fire suppression system suitable for battery fires (e.g. pre-action sprinkler system, gaseous
fire suppression system).
 Provision of suitable fire extinguishers (e.g. 6 kg Aqueous Vermiculite Dispersion or 9 L F-500 portable
fire extinguishers) that are accessible under all reasonable circumstances.
 Batteries and associated balance of plant certified and designed to Australian Standards.
 Fire and explosion risk assessment to be undertaken as part of the Fire Safety Study to ensure heat
radiation and overpressure do not impact adjacent infrastructure.
 Fire hydrant system designed in accordance with AS 2419.1 that provides coverage throughout the area.
 Trained operators / maintainers.
 Plant operating and maintenance procedures.
 Provisions for on-site containment of any contaminated firewater used as a result of a lithium-ion battery
fire.
 Demonstration that the following standards have been considered and utilised, where appropriate, in the
design and operation of the battery systems and/or spare battery stores, as per FRV Guideline No. 55 [9]:
 AS/NZS 4681: The storage and handling of Class 9 (miscellaneous) dangerous goods and articles.
 AS/IEC 62619: Secondary cells and batteries containing alkaline or other non-acid electrolyte – Safety
requirements for secondary lithium cells and batteries, for use in industrial applications.
 AS/NZS 5139: Electrical installations – Safety of battery systems for use with power conversion
equipment.
 IEC 62897: ED1 Stationary Energy Storage Systems with Lithium Batteries – Safety Requirements.
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 NFPA 855: Standard for the Installation of Stationary Energy Storage Systems.
 UL 9540: Energy Storage System Requirements.
 UL 9540A: Battery Energy Storage System (ESS) Test Method.
 FM Global Property Loss Prevention Data Sheet 5-32: Data Centres and Related Facilities.
 Specific ventilation requirements and smoke control measures that are contained within the following:
 NFPA 68 (Standard on Explosion Protection by Deflagration Venting).
 NFPA 69 (Standard on Explosion Prevention Systems).
 AS 1668.1:2015: The use of ventilation and air conditioning in buildings - Part 1: Fire and smoke
control in buildings.
 AS 1668.2:2012: The use of ventilation and air conditioning in buildings - Part 2: Mechanical
ventilation in buildings.
9.2 Combustible Liquid Safeguards
AS 1940:2017 “The storage and handling of flammable and combustible liquids” will be followed for safe
management of combustible liquids on site. Given diesel’s classification as a C1 combustible liquid and the
commonplace use of diesel in buildings, compliance with AS 1940 is considered sufficient to mitigate the
risks associated with the storage of diesel. The following key safeguards relevant to diesel storage have
been applied:
 Fire-rated design of enclosure that diesel belly tanks and day tanks will be located within.
 The generator day tanks and generator belly tanks will be double skinned.
In addition, the following is recommended:
 Regular testing and maintenance of diesel pumps and moving components.
9.3 Chilled Water Treatment Chemicals Safeguards
The chilled water treatment chemicals that will be used at the site may include Class 8 corrosive substances
(not yet determined at this stage of the design). The management of these chemicals is largely covered by
AS 3780:2023 The storage and handling of corrosive substances.
The key safeguards that may need to be included in the design of the facility with regards to water treatment
chemicals are:
 Bunding of water treatment chemical tanks / containers
 Segregation of incompatible materials
 Regular testing and maintenance of pumps and moving components
 Safety Management Plans
 Trained operators / maintainers
 Plant operating and maintenance procedures.
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9.4 Natural Hazards Safeguards
Natural hazards have the potential to cause a loss of control. These hazards will be mitigated by ensuring
the design satisfies the requirements of standards and the Hume City Council as outlined in Table 15 below.
Table 15 Natural hazards safeguards
Hazard Description
Extreme The datacentre including the batteries within the PTUs and the BESS should be designed to
temperatures operate beyond the temperature extremes recorded near the site location (refer to Table 5), with
allowance for higher maximum temperatures of approximately 1.5-2°C to account for the likely
effects of global warming.
Bushfires Project Dune is not located in a bushfire prone area.
Seismic activity For the purpose of seismic design, the site and proposed structure must be assessed in
accordance with AS 1170.4:2007 – Structural Design Actions Part 4: Earthquake actions in
Australia. The Annual Probability of Exceedance for ultimate seismic design is 1:1000.
Flooding The BESS and auxiliary infrastructure shall be located outside the extent of the flooding zone.
Excessive wind The data centre building must be designed to satisfy AS 1170.2:2021 – Structural Design Actions –
Wind Actions.
Lightning A lightning protection system must be installed for the facility.
9.5 Additional Supporting Documentation
Recommendations
9.5.1 Fire Safety Study
Prior to construction during the detailed design phase (of each Stage), a Fire Safety Study (FSS) should be
submitted to FRV to help inform the written advice of FRV in relation to the design of the fire protection
system for the premises as legislated.
As described in FRV’s Battery Energy Storage Systems Guideline (GL-55), the following details are required
as part of an FSS:
 A deterministic analysis considering credible fire scenarios and determining adequate control measures
to demonstrate that a fire will not propagate from the initiating module or unit, i.e. mitigation of escalation.
During the design phase, the deterministic analysis should be represented within a fire engineering
evaluation.
 Where controlled burnout is proposed for the site, separation distances between equipment are required
to be quantitatively validated to mitigate the potential for fire spread between equipment on-site. The
calculated total heat release rate and time to total burnout for a BESS unit fire event are also to be
provided in this analysis.
 Separation distances between equipment and other exposures (e.g. allotment boundary, buildings,
storage of hazardous materials, access for emergency services etc.) are to be substantiated.
 Demonstration through deterministic analysis that is informed by suitable qualitative or quantitative
methods that the ventilation system is adequate for managing the flammable, corrosive, and toxic
vapours and gases produced during a thermal runaway event.
9.5.2 Emergency Response Plan
An emergency response plan (ERP) for the site is required to be submitted to FRV at least 30 days prior to
commissioning.
In addition to standard content, the ERP should also address the following additional issues as listed in
FRV’s GL-55 Battery Energy Storage Systems Guideline No 55:
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 Procedures for alerting the owner/operator to abnormal operations, faults, or hazards in the BESS.
 Procedures for notifying fire services of an incident. FRV preference is for an automatic notification. That
is, upon detection of a fire in the BESS or on the site via an automatic detection system, notification to the
fire services should be immediate.
 Communication strategies with the remote operator representative during an incident.
 Arrangements for the attendance of an emergency liaison officer (ELO) on-site during any incident.
 Clear procedures for communicating critical battery status and operational information to emergency
services. This includes details on the activation of deflagration panels and other essential safety
measures.
 Personnel escape times to travel to an exit are calculated from the Fire Safety Study.
9.5.3 Emergency Information Book
Prior to operation and commissioning of the facility, an Emergency Information Book (EIB) shall be prepared
and situated at the site's Emergency Information Container (EIC). The EIB shall be stored at each of the site
entrance/exit locations shown in Figure 5-2.
There are five key components to the EIB covering:
 Site Layout drawings including fire protection drawings
 Dangerous Goods location drawing and related manifest
 On and off-site emergency contact list
 Evacuation points warden identification
 Safety data sheets and additional resources.
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10 References
[1] Hume City Council, Hume Planning Scheme, 2025.
[2] Department of Transport and Planning, Guide to Victoria's Planning System, 2023.
[3] Chief Parliamentary Counsel, Planning and Environment Act 1987, 2025.
[4] State Government of Victoria, “VicPlan,” [Online]. Available: https://mapshare.vic.gov.au/vicplan/.
[5] P. Bugryniec, “Review of gas emissions from lithium-ion battery thermal runaway failure - Considering
toxic and flammable compounds,” Journal of Energy Storage, vol. 87, 2024.
[6] State Government of Victoria, Occupational Health and Safety Regulations, 2017.
[7] State Government of Victoria, Dangerous Goods (Storage and Handling) Regulations, 2022.
[8] Urbis, “300-340 Barry Road Campbellfield Palnning Permit Application,” Urbis, Melbourne, 2025.
[9] Fire Rescue Victoria, Battery Energy Storage Systems Guideline No. 55 Version 1.0, 2025.
[10] State Government of Victoria, Occupational Health and Safety Act 2004, 2025.
[11] Chief Parliamentary Council, Dangerous Goods Act, 1985, 2025.
[12] Fire Rescue Victoria, Fire Safety Study Guideline (GL-54) v1.0, 2024.
[13] Panasonic, “Safety Data Sheet for Transportation - Lithium-ion battery,” 2021.
[14] Bureau of Meteorology, “Climate Statistics For Australian Locations: Essendon Airports,” [Online].
Available: https://www.bom.gov.au/climate/averages/tables/cw_086038_All.shtml. [Accessed 2025].
[15] Geoscience Australia, Earthquakes@GA National Seismic Hazard Assessment, 2018.
[16] Aurecon, “Project Dune - Stormwater Management Plan,” 2025.
[17] Bureau of Meterology, “Rose of Wind direction versus Wind speed - 9am,” 2023. [Online]. Available:
https://www.bom.gov.au/clim_data/cdio/tables/pdf/windrose/IDCJCM0021.086038.9am.pdf.
[18] Bureau of Meteorology, “Rose of Wind direction versus Wind speed - 3pm,” 2023. [Online]. Available:
https://www.bom.gov.au/clim_data/cdio/tables/pdf/windrose/IDCJCM0021.086038.3pm.pdf.
[19] Bureau of Meteorology, “Average annual thunder-day and lightning flash density,” 2012. [Online].
Available: http://www.bom.gov.au/climate/maps/averages/thunder-lightning/?maptype=otdg.
[20] FM Global, Fire Hazard of Lithium-ion Battery Energy Storage Systems: 1. Module to Rack-scale Fire
Tests, 2020.
[21] NSW Department of Planning, “Hazardous Industry Planning Advisory Paper No. 2 (HIPAP 2): Fire
Safety Study Guidelines,” 2011.
[22] State Government of Victoria, “Dangerous Goods (Storage and Handling) Regulations,” 2022.
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Appendix A
Risk Register
No. Component Hazard Cause Consequence Does the Inherent Risk Proposed Controls – Technical / Proposed Controls – Safety Residual Risk Does the
Hazard Pose Design Management Hazard Pose a
a Potential Potential
Off-site Off-site
Significant Significant
Risk? Risk?
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1 Lithium-ion Arcing or Cable or equipment Electrocution resulting in No potential (in Rare Catastrophic Medium Design and compliance to AS 3000  Safety system maintenance, testing Rare Major Medium No potential (in
Battery short-circuit fault. This can be injury or fatality. terms of and inspections terms of electrical
caused by wear and electrical shock  Safety Management Plans shock hazard
tear, improper hazard affecting  Trained operators / maintainers affecting public)
installation, or public)
 Plant operating and maintenance
manufacturing defects. procedures
2 Lithium-ion Battery cell fire Fire hazard arising from Personnel injury due to Potential Unlikely Major Medium  The lithium-ion batteries adopted for  Safety system maintenance, testing Rare Major Medium Unlikely with
Battery hazard flammable materials burns or smoke / this project shall be UL certified in and inspections implementation of
(e.g. electrolytes) used chemical inhalation. accordance with UL-9540A  Safety Management Plans mitigation
in the battery being Damage / destruction of  Battery Management System  Trained operators / maintainers measures
exposed to high battery cell. provides functional safety of
 Plant operating and maintenance
electronic safety-related systems
temperatures. procedures
 Adequate ventilation (e.g. mechanical
exhaust) sized to limit the
concentrations of flammable and
toxic off-gases that would be
generated during thermal runaway
 Fire-rated construction (floor, walls,
ceiling, doors) of battery enclosures
 Provision of thermal and smoke
detection systems, including an off-
gas detection system
 Provision of a fire suppression
system suitable for battery fires
 Provision of suitable fire
extinguishers, accessible under all
reasonable circumstances
 Batteries and associated balance of
plant certified and designed to
Australian Standards
 Layout of battery racks to be
informed by outcomes of Fire Safety
Study to limit impacts of heat
radiation and overpressure
 Fire hydrant coverage throughout
area (with two hose lengths subject
to FRV consent)
3 Lithium-ion Battery cell Overheating or thermal Personnel injury due to Potential Unlikely Major Medium  The lithium-ion batteries adopted for  Safety system maintenance, testing Rare Major Medium Unlikely with
Battery thermal runaway due to burns or smoke / this project shall be UL certified in and inspections implementation of
runaway improper temperature chemical inhalation. accordance with UL-9540A  Safety Management Plans mitigation
hazard control or internal faults Damage / destruction of  Battery Management System  Trained operators / maintainers measures
causing increasing battery cell. provides functional safety of
 Plant operating and maintenance
temperatures and fire. Fire may propagate electronic safety-related systems procedures
towards neighbouring  Adequate ventilation (e.g. mechanical
cells. exhaust) sized to limit the
concentrations of flammable and
toxic off-gases that would be
generated during thermal runaway
 Fire-rated construction (floor, walls,
ceiling, doors) of battery enclosures
 Provision of thermal and smoke
detection systems, including an off-
gas detection system
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No. Component Hazard Cause Consequence Does the Inherent Risk Proposed Controls – Technical / Proposed Controls – Safety Residual Risk Does the
Hazard Pose Design Management Hazard Pose a
a Potential Potential
Off-site Off-site
Significant Significant
Risk? Risk?
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 Provision of a fire suppression
system suitable for battery fires
 Provision of suitable fire
extinguishers, accessible under all
reasonable circumstances
 Batteries and associated balance of
plant certified and designed to
Australian Standards.
 Layout of battery racks to be
informed by outcomes of Fire Safety
Study to limit impacts of heat
radiation and overpressure
 Fire hydrant coverage throughout
area (with two hose lengths subject
to FRV consent)
 Access controls for high-voltage
areas (arc flash risk)
4 Lithium-ion Chemical Chemical hazard caused Personnel injury from Limited potential Unlikely Major Medium  Equipment designed to be compliant  Emergency Response Plan to be Rare Major Medium Limited potential
Battery hazard by (unforeseen) contact burns or gas inhalation. (affect local with applicable Australian / developed to define actions in (affect local
between person and Environmental damage. personnel) International Standards. unlikely event of potential hazards. personnel)
toxic, acid or corrosive (biophysical  Spill containment design.  Trained operators / maintainer (biophysical
components leaking damage - local)  Plant operating and maintenance damage - local)
from the battery. procedures.
5 Lithium-ion Explosion Battery ventilation failure Personnel injuries or Potential Unlikely Catastrophic High  Batteries and associated balance of  HVAC systems correctly installed Rare Catastrophic Medium Unlikely with
Battery hazard (off gas extraction) fatalities. plant certified to relevant international and maintained implementation of
and/or overcharging of Damage / destruction of standards (e.g. UL-9540A)  Safety system maintenance, testing mitigation
battery causing rapid battery cell.  Layout of battery racks to be and inspections measures
expansion and informed by outcomes of Fire Safety  Safety Management Plans
Study to limit impacts overpressure
confinement of gases.  Trained operators / maintainers
 Battery Management System
 Plant operating and maintenance
provides functional safety of
procedures
electronic safety-related systems
 Each battery enclosure shall be
provided with thermal, smoke and off-
gas detection systems
6 Lithium-ion Vandalism Unauthorised access, Damage to battery cell Potential Unlikely Catastrophic High  Site to be surrounded by fencing,  Regular and appropriate operations Rare Catastrophic Medium Unlikely with
Battery damage few staff on-site. and/or other locked gates and other security and maintenance covering implementation of
infrastructure. measures as necessary (e.g. CCTV, inspections of the facilities mitigation
Electrolyte emission. continuous remote monitoring) measures
Electrocution resulting in
injury or fatality.
Potential to induce
battery thermal runaway
and fire.
7 All Contaminated Water used to fight Environmental damage Potential Unlikely Major Medium  Provision of contaminated firewater  Safety Management Plans Rare Major Medium Unlikely with
firefighting lithium-ion battery fire or from heavy metals and containment tanks implementation of
water diesel fire spills into solvents in soil.  An Emergency Response Plan with mitigation
defined actions in the event of an
surrounding land and Environmental and measures
enters the soil and health effects from emergency situation
groundwater
groundwater system
contamination.
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No. Component Hazard Cause Consequence Does the Inherent Risk Proposed Controls – Technical / Proposed Controls – Safety Residual Risk Does the
Hazard Pose Design Management Hazard Pose a
a Potential Potential
Off-site Off-site
Significant Significant
Risk? Risk?
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8 Diesel fuel Fuel spill Equipment failure, Damage to infrastructure Potential Unlikely Catastrophic High  Hydrocarbon leak detection systems Implementation of regular inspection Rare Catastrophic Medium Unlikely with
storage and operational error during Personnel injury from will monitor critical areas, including: and maintenance schedules implementation of
handling refuelling or structural chemical exposure. Trained personnel for fuel handling. mitigation
 Drip trays (including under
damage to storage Environmental  measures
pumpsets and bulk tank system
tanks. contamination
interconnecting pipework outside
tank rooms)
 Bunded tank chambers
 Interstitial spaces of double-
walled tanks
 Generator enclosures
 Double skin steel tanks unless within
a bunded enclosure or otherwise.
 Fire Extinguishers and Hose Reels
within bulk tank and generator rooms
 Design to AS1940
9 Diesel fuel Fire hazard of Generator or other Loss of property Potential Unlikely Catastrophic High  Hydrocarbon leak detection systems  Conducting regular fire drills and Rare Catastrophic Medium Unlikely with
storage and combustible equipment malfunction, Harm and injuries to will monitor critical areas, including: providing fire safety and emergency implementation of
handling liquid electrical malfunction, or personnel response training for personnel. mitigation
 Drip trays (including under
properties. spreading of external Operational disruption measures
pumpsets and bulk tank system
fires.
Environmental damage
interconnecting pipework outside
tank rooms)
 Bunded tank chambers
 Interstitial spaces of double-
walled tanks
 Generator enclosures
 Double skin steel tanks unless within
a bunded enclosure or otherwise.
 Fire Extinguishers and Hose Reels
within bulk tank and generator rooms
 Design to AS1940
10 Diesel fuel Inadequate Inadequately designed Accumulation of Little potential Rare Major Medium Tanks storing diesel will be designed, Rare Major Medium Unlikely with
storage and ventilation for ventilation system or hazardous emissions constructed and vented in accordance implementation of
handling exhaust system malfunction within the data centre, with AS 1940. The standard requires mitigation
posing health and safety
emissions provision of normal venting to measures
risks for personnel.
accommodate thermal expansion and
contraction of liquids due to temperature
variations, thereby preventing excessive
internal pressure build-up.
11 Environment Natural Seismic activity Damage to infrastructure Potential Rare Catastrophic Medium  Data Centre Building designed to Rare Catastrophic Medium Potential.
Hazard and equipment. AS 1170.4 – 2007 Structural Design However, these
Potential injury and Actions Part 4: Earthquake actions in hazards will be
death are dependent on Australia mitigated by
the magnitude of a ensuring the
seismic event. design satisfies
the requirements
of standards
12 Environment Natural High wind speeds Damage to infrastructure Potential Rare Moderate Low  Building designed to AS 1170.2:2021 Rare Moderate Low Potential.
Hazard and equipment. – Structural Design Actions – Wind However, these
Actions hazards will be
mitigated by
===== PAGE 50 =====
No. Component Hazard Cause Consequence Does the Inherent Risk Proposed Controls – Technical / Proposed Controls – Safety Residual Risk Does the
Hazard Pose Design Management Hazard Pose a
a Potential Potential
Off-site Off-site
Significant Significant
Risk? Risk?
Project number 529578 File Project Dune PHA and FRA Rev 0.docx 2026-04-10 Revision 0 48
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ensuring the
design satisfies
the requirements
of standards
13 Environment Natural Flooding Damage to infrastructure Potential Rare Moderate Low  Stormwater management strategy for Rare Moderate Low Potential.
Hazard and equipment. the site. Sitewide stormwater However, these
drainage system and discharge in hazards will be
line with council and authority mitigated by
requirements. ensuring the
design satisfies
the requirements
of standards
14 Environment Natural Extreme climate – High temperatures Potential Rare Major Medium  Tanks storing diesel will be designed, Rare Major Medium Potential.
Hazard exposure to high cause the thermal constructed and vented in However, these
ambient temperatures expansion of diesel, accordance with AS 1940. The hazards will be
which can increase the
standard requires provision of normal mitigated by
pressure inside the tank
venting to accommodate thermal ensuring the
and result in leaks (toxic
inhalation). expansion and contraction of liquids design satisfies
due to temperature variations, the requirements
thereby preventing excessive internal of standards
pressure build-up.
15 Environment Natural Lightning Damage to infrastructure Potential Unlikely Major Medium  Lightning protection system for Rare Major Medium Potential.
Hazard and equipment. building and site designed to However, these
Potential battery fire AS 1768:2021 hazards will be
hazard resulting in burns mitigated by
or smoke / chemical ensuring the
inhalation.
design satisfies
the requirements
of standards
===== PAGE 51 =====
Appendix B
Lithium-Ion Battery Fire Modelling Approach
A multi-point source radiation model has been used to represent the worst-case radiative characteristics of a
lithium-ion battery fire. The model used is the one developed by the FM Global Research Division [20], which
was validated against battery fire test results and applied to predict the radiative heat flux at arbitrary
distances from the fire.
A visual representation of the multi-point source radiation model is shown in Figure 10-1 below. The flame is
modelled as a vertical line consisting of multiple evenly spaced radiation point sources along the length of
the flame (𝐿 ). One such radiation point source (𝑧 ) is shown in Figure 10-1. The emissive power of the fire is
(cid:3033) (cid:3043)
assumed to have a linear distribution with a peak location at height 𝑧 . The cumulative heat flux experienced
(cid:3040)
at an observer point (e.g. the point 𝑥 ,𝑦 ,𝑧 shown below) is calculated by summing the heat flux from each
(cid:2868) (cid:2868) (cid:2868)
point source that makes up the flame model.
Figure 10-1 Visual representation of multi-point source radiation model
The heat flux from a radiation point source with a height of 𝑑𝑧 flame at a height 𝑧 to an observer is
(cid:3043)
calculated utilising Equation (1) below
Equation (1):
𝑄(cid:4662)(cid:4593) 𝑑𝑧
𝑞(cid:4662)" (cid:3404) (cid:3045),(cid:3053) cos(cid:4666)𝜉(cid:4667)
(cid:3043) 4𝜋𝑟(cid:2870)
where:
𝑄(cid:4593) = local emissive power per unit height (kW/m) of a radiation point source at a height z (m)
(cid:3045),(cid:3053)
𝑑𝑧 = distance between radiation point sources (m)
𝑟 = The distance between the radiation point source and the observer point (m)
𝜉 = the angle between the surface normal of the observer point and the line connecting the
radiation point source and the observer point (°)
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For the purpose of this assessment, the angle 𝜉 is assumed to be 0° (i.e. the observer is always facing each
radiation point source along the length of the flame). Therefore, cos(cid:4666)𝜉(cid:4667) = 1.
The fire emissive power is assumed to have a linear distribution with a peak location at height 𝑧 . The
(cid:3040)
maximum value of emissive power per unit height (kW/m) is calculated utilising Equation (2) below:
Equation (2):
𝑄(cid:4662)
ℎ (cid:3404) 2 (cid:3045)
(cid:3040) 𝐿
(cid:3033)
where:
𝑄(cid:4662) = the total radiative power of the fire (kW)
(cid:3045)
𝐿 = the flame height (m)
(cid:3033)
The total radiative power of the fire is calculated utilising Equation (3) below:
Equation (3):
𝑄(cid:4662) (cid:3404) 𝑄(cid:4662) 𝜒
(cid:3045) (cid:3030)(cid:3035)(cid:3032)(cid:3040) (cid:3045)
where:
𝑄(cid:4662) = the heat release rate of the fire (kW)
(cid:3030)(cid:3035)(cid:3032)(cid:3040)
𝜒 = the radiant fraction (dimensionless) (i.e. the ratio of radiative and chemical energy released)
(cid:3045)
The local emissive power per unit height (kW/m) of a radiation point source at a height z (m) is calculated
utilising Equations 4 and 5 below and depends on whether the radiation source is above or below the height
corresponding to the maximum value of emissive power per unit height (𝑧 ).
(cid:3040)
Equations (4) and (5):
𝑧 𝑧
𝑄(cid:4662)(cid:4593) (cid:3404) (cid:3043) ℎ (cid:3404) (cid:3043) ℎ , 𝑧 (cid:3409) 𝑧
(cid:3045),(cid:3053) 𝑧 (cid:3040) 𝐿 𝜃 (cid:3040) (cid:3043) (cid:3040)
(cid:3040) (cid:3033)
𝐿 (cid:3398) 𝑧 𝐿 (cid:3398) 𝑧
𝑄(cid:4662)(cid:4593) (cid:3404) (cid:3033) (cid:3043) ℎ (cid:3404) (cid:3033) (cid:3043) ℎ , 𝑧 (cid:3408) 𝑧
(cid:3045),(cid:3053) 𝐿 (cid:3398) 𝑧 (cid:3040) 𝐿 (cid:3398) 𝐿 𝜃 (cid:3040) (cid:3043) (cid:3040)
(cid:3033) (cid:3040) (cid:3033) (cid:3033)
where:
𝑧 = elevation of the radiation point source (m)
(cid:3043)
𝑧 = elevation along the flame length with peak fire emissive power (m)
(cid:3040)
𝜃 = Fraction between 0 and 1 representing the elevation along the flame length with peak fire
emissive power
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===== PAGE 53 =====
Finally, the total heat flux experienced at an observer point is the sum of the heat flux from each radiation
point source that makes up the multi-point source flame model calculated utilising Equation (6) below:
Equation (6):
(cid:3013)(cid:3281)
𝑄(cid:4662)(cid:4593) 𝑑𝑧
𝑞(cid:4662)" (cid:3404) (cid:3505) (cid:3045),(cid:3053)
(cid:3045) 4𝜋𝑟(cid:2870)
(cid:2868)
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===== PAGE 54 =====
Appendix C
Side View Profiles of Off-Gas Modelling
Side view concentration profiles showing the extents to 25% LFL and the IDLH concentrations for CO and
HF are shown below in Figure 10-2 to Figure 10-7.
Figure 10-2 LFP battery chemistry – 25% LFL side view profile
Figure 10-3 NMC battery chemistry – 25% LFL side view profile
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Figure 10-4 LFP battery chemistry – CO IDLH concentration side view profile
Figure 10-5 NMC battery chemistry – CO IDLH concentration side view profile
Figure 10-6 LFP battery chemistry – HF IDLH concentration side view profile
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Figure 10-7 NMC battery chemistry – HF IDLH concentration side view profile
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