Dear Ms Raetsen:
RE: HORIZON’S EMERGENCY PROCEDURES FOR THE PROPOSED INDUSTRIAL WIND PROJECT IN THUNDER BAY OR LACK THERE OF
Following a review of Horizon’s Emergency Procedures for the Big Thunder Wind Park and comparing it to emergency management guidelines and protocols in Europe and in Australia, one can conclude that Horizon’s emergency procedures are inept, incomplete, non-comprehensive and dangerous to the surrounding forest and wildlife and to the approximately 1000 homes in the direct vicinity of the proposed site.
In the Design and Operations Report submitted in Horizon’s Draft REA, the fire protocol can be singled out as an example of the glaring inadequacies of this project’s plan. On page 13 of the Report, in section 5.2 (Emergency Notification) the following “plan” is outlined:
“In case of Fire, the Company First Responder will:
1. Call fire department (911);
2. Instruct all contractors and employees to go the the designated meeting place (Stage 1 or gate to site);
3. Notify the other Company First Responders;
4. Notify land owner (clerk of the City of Thunder Bay).”
1. Calling 911 will contact the Thunder Bay Fire Department, who is actually the back-up fire fighters for the area of the proposed wind farm and not the department whose jurisdiction it is to fight a fire at the proposed site of the wind farm on top of the mountain range. (I checked with Thunder Bay Fire Chief to confirm this fact.) The Municipality of Neebing Volunteer Fire Department is responsible for any fire since the site of the wind farm is in their municipality and they are NOT contacted by 911, but have separate phone numbers for each of their 6 fire stations. Horizon should have done their homework and perhaps checked a local telephone directory.
2. The plan also lacks any concrete protocols such as what the specific responsibilities of the First Responders are and what they would actually do or steps they would take in case of fire. In procedures and protocols that I reviewed for this subject, the responders have specific responsibilities and these responsibilities are listed. Further, each authority, whether it is the fire department or local or regional law enforcement agency also have specific tasks outlined by the wind company on what each entity will do in the event of fire. A responsible wind company would also have a written, public document revealing bushfire mitigation plans and fire prevention activities that are coordinated with local authorities, in this case, including the Ministry of Natural Resources.
Everything from who specifically to contact at the Ministry of Natural Resources to procuring an adequate water supply for fire fighting the secondary bushfire on top of the escarpment, should be part of the emergency plan.
I see no evidence of anything alluding to the existence of a comprehensive plan to fight a fire in Big Thunder Wind Park.
3. Once in operation, the risk of fire can be associated with malfunctioning turbine bearings, inadequate crank case lubrication, cable damage during rotation, electrical shorting or arcing occurring in transmission and distribution facilities (1) and lightning strikes. Wind farms can also be impacted by wildfire entering the site. Measures commensurate with the risk need to be considered.
ref: 1: Australian Wind Energy Association (2001). Wind Farm Safety in Australia.
According to a number of sources, an important measure to limit the risk of bushfire or forest fire from wind farms is simply, the location of the project. “It is preferred that wind farms be located on open grassed areas (such as paddocks grazed by cattle and sheep)(2).” It should be built “away from tall vegetation(3).”
ref: 2 and 3: Australian Wind Energy Association (2001). Wind Farm Safety in Australia.
Big Thunder Wind Park is being proposed on top of a thickly forested mountain escarpment with dense old growth trees that lies above a heavily populated area. Besides being built on a totally inappropriate site according to wind farm guidelines in other jurisdictions, Horizon’s draft REA does not address the risks of fire nor do they provide measures commensurate with this risk.
4. “Fires can occur in the nacelle, the tower, the electric power substation of the turbine or the power substation of the wind farm itself. However, because the switchgear, inverter, control cabinets, transformer and highly combustible lubricating oils, are located in the nacelle, the risk of fire increases significantly there. Due to the high density of technical equipment and combustible material in the nacelle, fire can spread rapidly(4).”
ref: 4: European Guideline – Wind turbines fire protection guideline (CFPA Europe)
The CFPA Guidelines explain further: “A fire in a wind turbine can lead to the situation, that burning elements, which fall down, can cause a secondary fire on the ground where the turbine is located. These circumstances can result in a forest fire, difficult in some cases to be extinguished. Very often long distances between the wind energy plant and the fire station and the strong prevailing wind in these places are both factors that can promote the quickly spreading of forest fires. In these cases the losses not only concern the direct costs for the burned forest, but more the unrecoverable damage to the environment.”
According to many sources, a fire in the nacelle, the most likely place that a fire would start, would be impossible to fight because of the height the nacelle is off the ground. In the proposed Big Thunder Wind Park, the nacelle would be 98.38 metres or 319 feet above grade and burning parts or burning lubricant would be dispersed into highly flammable vegetation surrounding the turbine. At that height, the fire would be unreachable by any turntable ladder and water jet and the hub height has made firefighting from the outside all but impossible(5).
ref: 5: Modern Power Systems, (2001)
The resulting forest fire on the top of the mountain escarpment where Horizon has planned to build their wind farm, even with a comprehensive fire suppression plan, which Horizon’s draft REA lacks, would be catastrophic.
5. Horizon’s draft REA also does not mention the toxic materials with which the wind turbine tower and blades are manufactured. The composites, fibreglass and carbon fibre composites give off highly toxic fumes when they are burned. Further, the composites liberate particles that can impair radio communication. I see no mention of these risks in Horizon’s draft REA and no reference to any plans to mitigate them.
AN ADDITIONAL POINT:
Because of the precarious siting of the project and the real risk of rapidly spreading forest fires being caused by a wind turbine in the Big Thunder Wind Park, every turbine should be equipped with an internal fire suppression system. The only reference to this issue is a brief mention that these systems would be reviewed at a time when Horizon was procuring the equipment. This instills absolutely no confidence that any concrete action would be taken.
Horizon makes no mention of these built in fire suppression systems that are being utilized in other jurisdictions. The prerequisites for the fire protection systems are being co-developed and established in co-operation of Allianz Centre for Technology (AZT). Additionally, the insurance industry is preparing a guide to fire protection in wind turbines. Perhaps Horizon could review those documents.
Each turbine should be equipped with a fire suppression system that detects the fire rapidly and utilizes an internal system of water mist and nitrogen gas. Gas is an ideal extinguishant for electrical systems because it displaces oxygen needed for combustion, thereby smothering the flames. Gas extinguishing systems are ideal for suppressing incipient fires – but only in combination with sophisticated sensors that “sniff out” the fire at an early stage. The principle of water mist is simple yet effective: nozzles are used to produce a fine water mist which immediately and radically reduces the fire temperature. At the same time, evaporation significantly increases the water volume, displacing oxygen.
Does Horizon have any concrete plans to utilize internal fire suppression systems in their turbines? With no specifics in the official REA, my confidence is minimal.
I would like to have these points entered into the critique, comments and questions of Horizon’s Draft REA.