The county's disaster plan: four hazards, no batteries

I’ve said it before and I will say it again. I don’t think anyone is paying attention to the xAI data center issue that is the most immediately dangerous.

The xAI files

Every essay in this series is pinned to a question on the board at rachelandthecity.com/the-xai-files.

Elon Musk built fields of giant batteries on top of the Memphis aquifer, and the county that plans for disasters has no file on them.

I know because I asked for the records.

Here’s a recap for anyone who missed my other essays about this:

xAI has already built yards of Tesla Megapacks at both campuses – next to the data center in Boxtown, and at the second campus on Tulane Road in Whitehaven. A Megapack is a steel box about the size of a shipping container, packed with lithium batteries. You line hundreds of them up on concrete pads in the open air. That’s the yard.

The Tulane yard is the big one, and it’s been there for a while. The Boxtown yard is built and running, and the city permits on file are for two more phases there. So this isn’t a plan for something coming. It’s here, and it’s growing.

Data centers eat a huge amount of power and the grid can’t always keep up, so the batteries store power and push it out when it’s needed. Same reason they put in the gas turbines. The site is short on power, and they’re stacking every source they can.

Like I’ve said before, some of this reads as a positive. Batteries are the cleanest thing on that site. If they cut how hard the turbines run – that’s a good thing. I am not against them using the batteries.

And these are the safer kind of lithium battery. I’m not saying any of them are gonna blow up or anything.

However, these big batteries can catch fire. And if one does, you can’t just put it out.

Firefighters mostly have to let it burn and spray water on everything around it – for hours, sometimes days. Are Memphis firefighters even trained for these kinds of fires?

Also, the smoke carries poisonous gas, and the water used to put out the fire runs into the ground. Colossus I sits on top of the aquifer the whole region drinks from.

That’s why the fire code says a battery site this big needs a fire study before it goes in – a plan for how to stop a fire, alarms to catch it early, space between units so it can’t jump, and an emergency plan worked out with the fire department.

On July 29 I filed a records request with Shelby County for its hazard mitigation plan. That’s the FEMA-approved document where a county writes down what could go wrong here and what it’s doing about it.

I asked for any part of that plan, or the risk assessment behind it, that covers battery storage, data centers or big on-site generation. I asked for anything that lists the battery yard at 3231 Paul R. Lowry Road. I asked for the Tier II chemical reports – the forms a facility files with the county so the fire department knows what’s inside before it rolls up.

And I asked for nearly three years of agendas and minutes from the Local Emergency Planning Committee. That’s the room where industry, the fire department and emergency management are supposed to talk to each other.

On August 19 the county wrote back. Seven answers.

The plan they sent? It’s the 2021 plan. It covers five hazards – flooding, severe weather, extreme heat and cold, earthquake, and disease.

The words battery, lithium and energy storage aren’t in it. “Data center” shows up four times – three about a small facility in Germantown on a list of new businesses, and once in the name of a federal weather office.

Anything in the plan about battery storage or data centers? “There are no responsive records regarding Request #3.”

Any risk assessment that lists 3231 Paul R. Lowry? “There are no responsive records regarding Request #4.”

Tier II reports for these sites? “There are no responsive records regarding Request #6.”

Any update in the works? None right now. The county said to ask again after January 2027.

I’d asked one more thing. If the plan doesn’t look at battery storage at these sites, say so in writing. The answer was the same sentence. No responsive records.

Then the committee records. Twenty-three agendas and minutes, November 2023 through July 2026 – the whole stretch in which the biggest new industrial hazard in the county got built.

In those 23 files, xAI, Colossus, CTC, MZX, Megapack, Tesla and battery storage at any local site come up zero times. The committee talked about a chemical plant, a refinery, an ExxonMobil drill, ammonia training, rail cars, and firefighting foam.

The one lithium conversation in the whole set is a truck that overturned in Henderson County, a hundred miles away, with 76,000 pounds of batteries on it.

In July 2024 the committee held a long meeting with lunch. On the agenda: the county health department’s air regulator, on air regulations. Trinity Consultants, the firm that went on to do the air permit work for xAI’s sites.

In all 23 records, the batteries were never brought up.

The plan they gave me was written before any of this existed. Plans like this run on a FEMA cycle, and the county’s own minutes from July 2026 say emergency management is “gearing up to work on Hazard Mitigation Plan 2027.”

And here’s something I didn’t know until I read the minutes. The committee has no budget. The county doesn’t fund it. Nobody does. In its own words from July 2026: “LEPC is not funded by any outside entities. We work off of donations.”

Who donates? The companies that file chemical reports with it. The minutes show the committee mailing a letter to every facility that filed a Tier II report, asking for money. The one gift named in three years of records is $600 from Valero, the refinery. Lunch at the big July 2024 meeting was provided by an environmental services company.

And that setup isn’t working. The balance was about $15,000 in early 2024. By September 2025 it was $8,076. By July 2026 it was $5,581, and the May minutes say no donations had come in and the committee needed funds.

So the room where Memphis is supposed to plan for its hazardous materials lives on donations from the companies that handle them, and it’s running out of money. And the county told me it holds no Tier II report from the company with the biggest new hazard in town – the report that would have put it on the mailing list.

So, nobody kept the batteries off an agenda.

What the records say is narrower, and to me it’s worse. As of August 2026 the county’s disaster planning file has nothing in it about the batteries at all.

The city’s building permit for the first phase of the Boxtown yard – record COM-NEW-26-000025 – lists the use as “water oriented” and the occupancy as “U Utility and Miscellaneous.” That’s the box the form gives for farm buildings and garages.

And the permit for the next two phases of that yard is no longer sitting in review. As of September 5, the city’s portal lists it as issued.

Pull up every record the city’s portal has at an address and you get building permits, signs, elevators, and the fire department’s records on buildings. As of September 5 that’s 154 records at 3231 Paul R. Lowry, 76 at 5420 Tulane, 11 at 5414 and one at 5408. Not one of them is a fire department building record. The school down the road at 5250 Tulane has one. The fire bureau did review the first phase of batteries – but only the foundation.

The day before the county’s records came back, on August 18, xAI posted a job in Memphis – only Memphis – for a Lead Engineer, Battery Storage. The duties include owning “the fire and life-safety case: UL 9540 and 9540A basis, thermal runaway propagation, deflagration venting, water supply, emergency response plan, and AHJ engagement.” I wrote about that listing last week.

Now, could it really be a coincidence that the day before my records request was fully answered – xAI posted a new job to oversee what my requests were asking about? Well, an agency’s emails about my request are themselves public records. I guess I will have to go back and ask for those too.

Anyway, put that job listing next to the county’s letter and you can see the shape of things. The public body that plans for disasters has no file. The company is hiring someone to hold the fire case itself.

I can see why people might not have put the mitigation plan for these Megapacks at the top of a safety list. These units go through a fire test before they’re sold. Testers force battery cells to overheat on purpose and watch how far it spreads. In Tesla’s own certification test, the overheating spread to just one extra cell out of thousands – with no fire in the cabinet. A yard-wide fire is not likely. But previous testing has not factored in one of these catching fire over the aquifer a whole region drinks from. What is the worst case scenario if even one of these Megapacks caught fire at Colossus I?

That’s the thing I wish we knew before these were allowed to be placed there. And there is still time to figure this out before phase 2 and phase 3 finish.

I am still waiting to hear back from the Memphis Fire Department – the “authority having jurisdiction” in that job posting – which holds the records that would say who inspected the yard and what the response plan is.

Two requests are in for those, one of mine and one my treasurer filed. His has been extended five times. Mine has been extended six times, and of its nine items, a single set of incident reports has come back. I’ll let you know what they say when they finally get back to me.

And the county told me to ask again after January 2027 for an update on the mitigation plan.

I will.

If you like facts-first info on all this, consider leaving a tip on Venmo or PayPal – this stuff takes a lot of time to put together. And check out everything I’ve written with citations and receipts at the xAI Files.

Sources

Correction, September 27th, 2026: This essay first said all four mentions of “data center” in the county’s hazard plan were about the Germantown facility – one is the name of a federal weather office. And it said the Megapack fire test spread fire to one extra cell – in Tesla’s test, the overheating spread to one extra cell, with no fire in the cabinet.

Update, September 27th, 2026: The Tier II line now says what the county told me – that it holds no such report.

Everything I have written about AI is in one place at rachelandthecity.com/the-ai-files.

The xAI files

Sources

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