The Power of a ‘Green’ Decommissioning, Remediation, and Redevelopment Plan
Credit to Author: POWER| Date: Thu, 01 Aug 2019 00:00:00 +0000
COMMENTARY
Economic pressures coupled with new and proposed regulations to reduce air emissions and regulate cooling water use and the management and disposal of coal combustion residuals (CCRs) continue to drive the closure and decommissioning of coal-fired power plants.
Decommissioning a power plant and repurposing the site for future use is often a lengthy and complex process. Many coal-fired facilities have operated for decades at the same location, and as a result remediation may involve removing asbestos, polychlorinated biphenyls (PCBs), and other constituents from buildings; excavating and disposing of, or covering and capping, CCR surface impoundments; testing and removing concrete pads and soil around old transformers and hydraulic equipment; testing soil for mercury or other air pollution contaminants and removing it if necessary; and monitoring and remediating impacted groundwater.
Amy Antoniolli
Alex Garel-Frantzen
Integrating green remediation and sustainable practices can assuage local community concerns, reduce greenhouse gas emissions, decrease costs and energy footprints, speed up site cleanups, and play a part in meeting state and local renewable energy standards.
Companies can implement sustainable practices and systems at any stage of decommissioning, remediation, and redevelopment by increasing the efficiency of existing treatment systems or planning and constructing new remediation systems.
Optimize Existing Remediation Systems
Companies can often increase the efficiency of existing remediation systems and decrease the overall environmental footprint of a decommissioning, remediation, and redevelopment plan. Consider greening the operation and maintenance of your treatment systems in the following ways:
■ Audit existing remediation systems. Energy audits can reveal whether energy-intensive equipment, such as pumps or blowers, are set at operating rates or temperatures that are higher than required to treat contamination, or larger than needed. An audit also could lead to identifying and removing redundancies in the treatment or operations and maintenance process.
■ Calculate your environmental footprint. The Environmental Protection Agency’s model collects data on energy consumption associated with various aspects of remediation.
■ Evaluate energy use. Track energy consumption through utility-provided meters to learn more about usage and identify opportunities where use of energy-efficient measures makes sense.
■ Optimize equipment. Maintain, inspect, and repair systems in a timely manner to ensure an optimized system.
■ Assess operating conditions. Evaluate whether it’s feasible to take advantage of real-time pricing and operate treatment systems at heavier loads during non-peak hours to lower energy costs and optimize efficiency.
■ Find ways to make your day-to-day operations more sustainable. It may be practical to use cleaner fuels to power vehicles or heavy equipment. Increasing efficiency of the cleanup can also minimize “investigation-derived waste,” such as contaminated personal protection equipment, because system operation would require fewer days of field work.
Green Practices
Build renewable energy and green practices into your decommissioning, remediation, and redevelopment plan. Green remediation at the forethought of a cleanup affords the greatest flexibility and likelihood that sustainable practices can be incorporated throughout the cleanup. Consider the following ways to fold sustainable practices and renewable energy systems into your remediation:
■ Conduct a renewable energy assessment. You’ll be able to gather information about how renewable resources can be used to meet the energy needs of a remediation. You’ll also be able to analyze energy demand, estimated output of possible renewable energy systems, estimated costs of those systems, and possible tax incentives available to you to decrease costs.
■ Consider alternatives. Evaluate whether you can meet remediation objectives by using treatment technologies with lower energy demands from the grid or by installing renewable energy systems to power long-term site controls and to offset or replace electricity requirements.
■ Minimize impacts on the land, water, and ecosystem with green infrastructure. For any vegetative landfill cover or soil excavation and revegetation, using native plants can lower water consumption needs and reduce erosion and flooding. Using pollinator habitats can also decrease the need for maintenance.
■ Reduce environmental effects. Find ways to reclaim any groundwater treated on-site for beneficial use, like watering those native plants.
■ Recycle. Decrease waste generation by using low-waste treatment technologies and reusing or recycling materials where possible. Remediation may require you to remove a building. In lieu of demolition, you may find a deconstruction company in your area that can take apart buildings and divert up to 90% of materials from landfills to reuse. You may also save money by selling or receiving a tax deduction from donating the used building materials.
Site location may also drive sustainable practices you wish to incorporate. In areas of non-attainment for national air emission standards, lowering your air emissions may be prioritized. In arid climates, decreasing water consumption might be key. Each site is unique, and a remediation plan should reflect the site-specific factors that come into play. ■
—Amy Antoniolli and Alex Garel-Frantzen are environmental attorneys with Schiff Hardin LLP.
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