1、STP-TS-060COAL-FIRED PLANT DECOMMISSIONING INVESTIGATION REPORTPrepared by: George W Galanes, PE Diamond Technical Services, Inc. Date of Issuance: March 22, 2013 This report was prepared as an account of work sponsored by ASME Pressure Technology, Safety, and Standardization preliminary planning, e
2、nvironmental and safety regulatory issues (permitting, Clean Air Act, National Pollution Discharge Elimination System (NPDES), waste management, asbestos, chemical and materials removal and disposal, underground storage tanks, FAA concerns related to stack or chimney lighting, superfund site concern
3、s, National Environmental Policy Act, National Historic Preservation Act, OSHA and notification of deed to property. My review of this document is that it is an extremely valuable resource and roadmap for those entities facing coal-fired plant decommissioning. STP-TS-060 Coal-Fired Plant Decommissio
4、ning Investigation Report 2 Document #2 “Power Plant Closure Guidebook”3 This guidebook was also developed by EPRI. A review of the Abstract/Objective and Results revealed information that would aid either a utility or IPP in plant decommissioning. The objective of this report was to anticipate wher
5、e problems will occur during the decommissioning process and to avoid adverse impact on decommissioning costs and schedule. Document #3 “Guidelines for Coal Plant Decommissioning” 4 This EPRI slide deck was authored by Mr. Jeff Clock, Sr. Project Manager with EPRI and consists of 12 slides that prov
6、ided high level guidelines for plant decommissioning. The three main guidelines for discussion were; Preliminary Planning Environmental and Safety Issues Decommissioning tasks For each of the bullet items mentioned, there was additional information provided. For example, under the heading preliminar
7、y planning, supplemental information in the form of guidelines were presented; alternative strategies for post-operational maintenance maintain the site at present condition with minimal clean-up perform minimal dismantling dismantle to the degree required to meet specific needs of a planned re-use
8、of the site full decommissioning For each of the above preliminary planning strategies, the main consideration was financial availability. The decommissioning tasks guideline had more high level color surrounding what steps are needed for consideration. For example, the following steps were listed;
9、detailed project planning administrative actions plant shutdown site preparation for dismantlement dismantlement of buildings and equipment site remediation and restoration The last portion of the slide deck dealt with actual examples of coal-fired plant decommissioning including estimated costs. Th
10、e examples included; Watts Bar fossil plant located in rural Tennessee with an estimated plant decommissioning cost of $17 to $25M USD. The plant was reported to have been retired in 2000. The second coal-fired plant that was mentioned in this slide deck was Plant Arkwright located in Macon, Georgia
11、. This plant was constructed in the 1940s, and consisted of four units. This plant was retired in 2002, with an estimated cost of $19M USD. Coal-Fired Plant Decommissioning Investigation Report STP-TS-060 3 The third coal-fired plant mentioned in this slide deck was the Port Washington Power Plant l
12、ocated in Port Washington, Wisconsin. This plant contained six coal-fired units built in the 1930s and 1940s era. The units were decommissioned in stages from 2004 to 2006. Total cost for decommissioning all six units during the stated time period was near $34M USD. The site was going to be partiall
13、y used for construction of gas-fired units. The general internet search using key words or phrases related to coal-fired plant decommissioning also revealed various articles that dealt with why plants are being considered for decommissioning. The articles focused on market forces and environmental p
14、ressures as being the causes for fossil plant decommissioning. The following articles were reviewed and a brief summary is provided; the articles were not relevant to development of standards and guidelines. Article 1: “Power Plant Decommissioning: A Noble Past, Many Possible Futures”5 A review of t
15、his article revealed what aging coal-fired plants are facing in terms of the threat from more restrictive emissions requirements, economic considerations and lower cost energy sources. This article looks at what pressures are looming to force owners to either decommission or re-power or modernizatio
16、n rather than what is required to decommission. Article #2: “Decommissioning Obsolete Power Plants - Why Do It Now?” 6 The article is also geared toward why versus how to decommission coal-fired plants. There is information provided that pertains to cost of demolition and why it should be done if de
17、commissioning is selected. TRC does provide a sales pitch for providing project management services to oversee decommissioning and demolition. Article #3: “Expanding Decommissioning Focus: A Comparison of Coal and Nuclear Costs” 7 The article is geared toward why versus how to decommission coal-fire
18、d plants. Article #4: “AEP informs organizations of planned coal-fired power plant retirements”8 This article provided a brief discussion on how AEP plans to retire coal-fired power plants and notifications required to address regional reliability issues. This article primarily dealt with the conseq
19、uences of decommissioning on grid stability. Article #5: “Retirement of the Mohave Generating Station” 9 This was an interesting high level presentation on the involvement of four owners and what options were available and ultimately steps which led to full decommissioning of this power station. Som
20、e of the relevant topics that were mentioned in the nine page presentation include: history and drivers behind retirement financial depreciation and life consideration accounting considerations and dismantlement plans Article #6: “Power Industry Faces Challenges of Decommissioning, an Industrial Inf
21、ormation News Alert” 1 An attempt was made to solicit current industry peers and to reach out to the American Coal Council, whose charter is to promote the increasing use of coal in the U.S. A visit of the STP-TS-060 Coal-Fired Plant Decommissioning Investigation Report 4 American Coal Council web s
22、ite and follow-up discussion revealed little in the way of coal plant decommissioning information. The American Coal Council web site did contain a wealth of information on facts and presentations related to how coal is coping with current market conditions and the promotion of clean coal technology
23、 in the U.S. Other documents that were reviewed for relevant data or information pertaining to coal-fired plant decommissioning information or status were; Article #7 - “U.S. Coal Review” 10 A review of this source revealed no pertinent information related to coal-fired plant decommissioning. It dea
24、lt with promotion of coal and possible plants facing either decommissioning or modernization. This document is not relevant to development of standards and guidelines. Article #8- “Argus Coal Daily- U.S Coal Market Prices, News and Analysis”11 A review of this source revealed no pertinent informatio
25、n related to coal-fired plant decommissioning. This document is not relevant to development of standards and guidelines. Article #9- “Coal and Energy Price Report” 12 There was little to no public information related to processes or steps for coal-fired plant decommissioning. There is a wealth of in
26、formation on coal market pricing and analysis related to utilities and IPPs, and the effect of gas supply on coal volatility pricing, which is ultimately leading to more plants being considered for decommissioning in the near future. This document is not relevant to development of standards and guid
27、elines. A review of companies on the Internet that can perform turnkey decommissioning revealed several hits. One of the companies was AECOM. A review of their brochure revealed a high level approach to the decommissioning process. Under plant decommissioning versus re-powering or modernization, the
28、 brochure does list the following activities with a brief description assessment of the plant, review of hazardous materials, equipment/building salvage evaluation and regulatory document submittals. Other companies like TRC and smaller vendors all advertise similar capabilities for offering project
29、 management services to support power plant decommissioning. Various approaches are provided and the drawback is that the owner/user is placing complete trust in the capabilities of the various companies or contractors. Thus far, the only credible and beneficial source of information directly relate
30、d to this topic has been information under EPRI. Unfortunately, EPRI publications are not fully accessible in the public domain accept for what has been released to the public over the years, and is outdated. Clearly, there are significant gaps in technical information related to coal-fired plant de
31、commissioning steps or guidance in the US, except for those regulated utilities or IPPs that are members of EPRI. Based on the information reviewed, EPRI has taken the lead in working with utility and IPP members to provide a road map for coal-fired plant decommissioning. Coal-Fired Plant Decommissi
32、oning Investigation Report STP-TS-060 5 2 COAL-FIRED PLANT DECOMMISSIONING REGULATION REVIEW Once the decision has been made to decommission a coal-fired power plant, a project team is assigned and a checklist is developed to ensure necessary steps are taken to safely secure the asset prior to retir
33、ement or demolition. The question is what regulations are applicable to the closure of a given plant? The following narrative provides a high-level overview of steps necessary to identify and notify, local, state and federal regulatory bodies. This narrative was based on actual decommissioning exper
34、ience and a literature review performed by the author. The following decommissioning checklist was based on information contained within the literature review conducted in Part 1. The two main checklist items (a) and (b) are the main topics of discussion in terms of applicable existing codes, standa
35、rds or regulatory requirements; (1) Preliminary Planning (2) Environmental and Safety Issues (Chemicals of concern: asbestos, lead, PCBs, mercury abatement) (a) Clean Air Act (b) National Pollution Discharge Elimination System (NPDES) (c) Solid Waste Management (d) Underground Storage Tanks (e) Fede
36、ral Aviation Authority (f) OSHA (g) Historic Preservation (h) CERCLA (superfund site status) (i) Property Records (j) Retire or Demolish (1) Preliminary Planning once a decision has been reached by an organization (owner/user or IPP) to retire an operating unit or site, the organization should assem
37、ble a project management team of various disciplines to properly manage this process. The team should consist of environmental engineers, process engineers (related to boiler, turbine and balance of plant equipment), corporate engineering, legal and accountants. The team should be instructed to deve
38、lop a checklist and decide on retirement options retirement with no demolition, partial demolition or full demolition to turn the site into a Greenfield site. A Greenfield site is where the property is returned to the state prior to when the plant or facility was originally built. Unfortunately, the
39、re is no regulatory guidance to ensure proper representation of a plant decommissioning team. The team concept is based on either past experience of other organizations having gone through decommissioning or by contractors who proclaim expertise in this area. The author believes there are no local,
40、state or federal requirements for how to assemble a cross-functional team to address plant decommissioning. STP-TS-060 Coal-Fired Plant Decommissioning Investigation Report 6 (2) Environmental and Safety Issues once the decommissioning decision has been made, the environmental engineers on the team
41、should conduct an exhaustive review of all local operating permits, local EPA permits and USEPA permits involved with air and water emission regulations. The following activities are associated with the mentioned Plant decommissioning check list and what steps are required to interface with local, s
42、tate and federal regulatory bodies and ensure current requirements, as applicable, are met. Contact must be initiated by the Plant decommissioning team with the appropriate local, state and federal agencies to provide notification of the decision to decommission. Second, the team should request what
43、 steps are required to either surrender or simply allow permits to expire. In some cases retirement of a coal-fired plant may occur well before decommissioning and for other cases retirement and decommissioning can be considered one in the same. After official notification has been made with the app
44、ropriate regulatory agency, certain environmental permits regarding water discharge limits may still remain in effect for a site, as though it were operational, until the site is either demolished or a final decision has been made regarding future use. In this case, a site individual responsible for
45、 reporting requirements to the appropriate agency may be required to ensure NPDES permits are enforced. Again, there is minimal guidance for how an owner/user should establish this activity. A review of various government web sites and the 2004 EPRI Handbook on Plant Decommissioning contain specific
46、 information on rules to be followed for hazardous material abatement. However, these rules apply across the board to projects associated with removal, and not necessarily unique to coal-fired plant decommissioning processes. For many older coal-fired plants that are nearing retirement, asbestos and
47、 lead abatement and disposal will be the major concerns related to the costs of decommissioning. The next activity for the Plant decommissioning team is to begin the process for managing removal of all process fluids (oil, gas, chemicals, diesel, lubricants and contaminated water, etc) from plant sy
48、stems. This is a very important activity because lack of removal of process fluids can result in either a safety hazard during demolition or leakage or spillage of process fluids during long term lay-up of the site before final demolition. Again, there is little in the way of regulatory guidance for
49、 this activity. Local, state and federal agencies have general enforcement rules to monitor plant sites regardless of being operational or are undergoing plant decommissioning to avoid inadvertent discharge of liquids (oil, chemically treated water) into waterways. This same approach applies to either above or underground storage tanks on the site property where process fluids could potentially leak out and result in a discharge to a surrounding waterway or environmental contamination of soil. The local, state or federa
