As existing electricity generation infrastructure matures, generation system owners are looking to the future for newer and greener technologies to meet consumption demands. An important part of this future perspective may include the demolition and removal of older generation plants and facilities to free up land resources for new development. Prior to the physical work of demolition, though, there are a number of key considerations that need to be addressed to enable the closeout of one chapter and facilitate the emergence of another.
While the sequence will vary from state to state, there will be some details in common, including when permit fees, registrations, and reporting can be discontinued. Ultimately, the sequence should be based on local and regional regulations, company policies, and corporate financial strategies. While some actions should occur before others, the below discussion should not be considered a step-by-step guide for a specific order of events.
Close-out activities should be initiated as soon as generation operations have ceased. Simply put, when no revenue stream is being generated, the maintenance of the host of permits and licenses and property costs become an unnecessary cost expenditure that should be discontinued. In this case, potential-carrying costs that will need to be identified and evaluated include insurance, site maintenance, and security costs. Full demolition of the generation facility will probably have significant tax implications that owners and shareholders will want to have resolved as well.
Â
Regulatory Mandates
From the perspective of regulatory mandates, a good starting point is listing all the held environmental permits and licenses. It can be safely assumed that all fossil-fueled plants maintained a requisite host of permits, licenses, and regulatory requirements that will need to be properly closed out prior to filing for a demolition permit and initiation of physical work. All of these have a variety of lead times that may precede the actual demolition permit or may be coincident with it. The timely closeout of certain permits and the execution of several on-site activities may be required before a demolition permit can be issued by a governing body, such as a Town, County, or State. In some cases, Federal agencies may also be involved, such as when a plant has underground injection control structures (UICs). Depending on the size and location of the generation facility, this may be simple or complex.
Air permits should be closed out immediately. For larger utilities that receive regional corporate emission allotments for various emission compounds, emission savings from one closed facility may be used to offset operations at another. The realization of additional offset revenue may be valuable during future financial considerations.
The owners of generating facilities may hold permits for and maintain one or more fueling capabilities. Tanks and process storage vessels should be sampled to determine their contents and facilitate appropriate disposal. Fuel and chemical piping and delivery systems should be emptied to preclude spills or releases during demolition. Once this is accomplished, closure of the fuel (and chemical) storage license is a common early step.
It is important to keep in mind the regulatory pre-notification periods required for various permit or license closure which may vary from 10, 30, 60, or up to 180 days, depending on the regulatory agency. These notification periods can affect demolition scheduling and result in adverse cost implications if not planned in advance.
Â
Inspection, Sampling, and Future Use Plans
Permit closures may require a Site Assessment Closure Work Plan that describes how the site will be inspected, investigated, and sampled. Generation units often require soil sampling near locations where fuel piping, lube oil tanks, oily water collection tanks, or pumping equipment were or are currently situated. Large fuel tanks will usually require sampling from beneath them, with piping runs inspected and sampled as needed. Monitoring wells will also need to be decommissioned properly, usually after a final round of sampling. If the facility has a Facility Response Plan (FRP), demolition may be considered a change in the facility’s status and a notice to the Regional Administrator is probably warranted.
If future options for a site have already been developed or envisioned, stormwater drainage requirements will need to be considered and examined for efficacy for future use. Likewise, National Pollution Discharge Elimination System (NPDES) discharge outfalls/points should also be evaluated with regard to demolition plans, as well as future uses of the site. Demolition permits will most likely involve Stormwater Pollution Prevention Plans (SWPPPs), which often inter-relate with NPDES discharges since most generation sites are located on or near a receiving body of water. Discharge limitations can be extremely strict and may command significant resources to achieve compliance.
Having detailed drawings of site drainage accompanied by ground contours is key to drainage control during demolition as well as site re-grading during the post-demolition period. Final surface conditions affect stormwater infiltration so final grading and the ground covering is an important consideration. For post-demolition stormwater management, it may be convenient to plan on using on-site recycled concrete aggregate as a surface cover. Keep in mind, though, the definition of and the use of porous vs nonporous materials. Many readers may be surprised that some regulatory agencies consider gravel to be an impervious surface that must be treated exactly like concrete or asphalt.
Some generation facilities, particularly large, older, fossil-fuel plants may have multiple waste and regulated material storage areas. Some plants may even have permitted RCRA storage areas. A formal closure plan of an RCRA storage facility will be required. Prior to regulatory notification, cessation of operations, and removal of all wastes, including universal wastes, the Facility/Unit Closure Plan should be reviewed before it is executed. While storage areas may not be difficult to remove and dismantle, other aspects of closure may not be so easy. They can typically include some challenging sampling. Power washing of floors and subsequent “rinsate” sampling of the floor surface near and beneath structures and storage compounds may be required. Coring and sampling through strong and thick concrete floors with analysis of substrate may also be necessary.
Â
Physical Assets
An inventory of all property buildings, structures, sewer and drainage features, perimeter security and access points, tanks and chemical storage facilities, as well as a listing of onsite utility connections is important. Gathering all facility drawings, especially historic ones, will be critical for both demolition bidding as well as evaluating what assets may have future use value.
Identification of any and all on-hand salvageable materials and equipment should be conducted. Some materials and equipment may be useful elsewhere in the company or have substantial value if sold outright. If the company has an “Investment Recovery” department or equivalent, they will surely be interested and could be tasked with this effort. Besides copper, generation plant facilities may often contain special alloys and materials that have significant market value. Since the value of scrap steel varies widely on the open market, it may not be practical for the owner to consider this. One strategy could be to allow the demolition contractor to recycle all the steel but tie the profits to the consumer price index (CPI) whereby, if the market value exceeds a certain threshold, then the owner shares some of the revenue.
If the company has some or all its own water supply from an on-site water supply well, water well permit closure and well decommissioning should be considered, especially with an eye toward future use. A water well may represent an important future asset or a liability. The same examination should be afforded to surface water supplies and the potential impact of their removal or future use.
Â
Financial Considerations
Asset retirement accounts, if any exist, will need to be used to address issues that popup during the close-out process. A review of the site’s operational history and spill/release history may help when considering how to spend the reserved monies. A fossil fuel plant demolition may have legacy environmental issues that will need to be addressed in advance of or subsequent to plant demolition. Clean-up of known releases or contaminated areas has financial impacts in terms of both the direct incurred costs and through potential delays to demolition activities if the project is stopped or curtailed to accommodate clean-up efforts. Unfortunately, demolition of an existing facility may lead to the discovery of historical issues such as buried and long forgotten facilities and infrastructure. The generation plant owner’s insurance coverage should be reviewed for a potential source of clean-up revenue.
Â
Hazardous Substances and Materials
Owners will need to conduct a thorough hazardous and regulated materials survey to inventory all the fuels, wastes, process chemicals and storage areas, universal wastes, presence of metal-based paints, transformers, and, of course, asbestos that may be found throughout the facility. Fire-fighting foams, if present, should also be removed due to the presence of emerging contaminants, e.g., PFOAs. The value of removal of these materials before demolition or by the demolition contractor should be evaluated because abatement activities may exceed actual take-down costs.
Â
Remaining Utility Infrastructure
Utility cut-off will be required for the demolition permit. If a facility is fed with city water, the timing of the cut-off is critical to demolition. Water may be needed during abatement, for dust suppression, and, most importantly, for fire control since torch cutting and similar tasks may be employed. Often, especially in urban settings, maintenance of a fully functional standpipe during demolition activities is required. Site fire lines and hydrants will also need to be maintained during demolition and local fire districts are often reluctant to permit their removal, even after a plant is down.
Some electric infrastructure may need to be removed while some may be important for future site use. Plant main station, auxiliary, and other transformers will probably require removal and soil assessments. Dielectric oil sampling should be conducted.
Existing sanitary systems need to be addressed. While a current facility may be connected to a municipal system, especially in urban areas, notification and cut-off will be required. Where the existing facility may have its own sanitary system or an older sanitary system no longer in use, investigation of the discharge area is usually warranted. The further back in time that a system was in use, the greater the chance for the presence of a wide variety of contaminants.
Â
Conclusion
As discussed here, pre-demolition activities can be extensive, complex, and expensive and are particularly dependent on the regulatory environment. The better the composite picture of the facility and its historic legacy that can be developed, the more accurately the monetary implications of demolition can be captured. Furthermore, future site use following demolition activities should be considered in the planning stages if possible. Decisions on remaining utilities, surface cover, and final grading may be dependent on the planned future use of the property. It is acknowledged that, in many cases, older fossil fueled generating stations may be demolished primarily for reduced property tax implications. However, wherever possible, consider the local, regional, and national energy goals and prospective beneficial future uses of the property. At a minimum, if greener technologies remain the soup du jour, consider battery storage to support peak load demand and/or wind and solar options.