1. | The project owner and/or their designee/subcontractor will engage a licensed battery recycling location to arrange for the disposal of the batteries by applicable state and federal regulations. |
2. | Permits, certifications, and training are required for decommissioning personnel all at the project owner's expense. |
3. | The project owner and/or their designee/subcontractor will ensure that all personnel on-site during the decommissioning process have received a site-specific safety briefing and know all electrical shock and arc flash risks, mainly when working within the battery containers. Hazmat training will be conducted for all personnel handling lithium-ion batteries during the process, subject to their job function per all federal, state, and local regulations. Only qualified electricians will be utilized to disconnect and remove battery modules from individual battery racks. As a handler (and storage) of universal waste, the project owner and/or their designee/subcontractor shall have an EPA identification number as required by 40 CFR 273.32 or applicable regulation. Additionally, lithium-ion batteries are classified by the US Department of Transportation (DOT) as Class 9 hazardous materials. All packaging, labeling, and transportation requirements in the Code of Federal Regulations, Title 49, Subchapter C, Parts 171 through 180, will be followed. |
| State of charge at decommissioning. |
| The battery facility will be fully discharged to the minimum charge required for removal and safe transportation as per battery manufacturer specifications. The facility battery management system (BMS) will validate such charge via remote telemetry. Following this validation, the DC disconnect switch for each battery container will be opened and locked out for the remainder of the decommissioning process to ensure no additional charging occurs. If the batteries are reused, the project will follow the manufacturer's instructions regarding the depth of discharge to prevent cell damage. |
| Individual battery removal process. |
1. | Battery modules are anticipated to be removed from their racks, repackaged on-site, and shipped to a regional recycling hub. No disassembly of battery modules will be required on-site, and the battery terminals will be taped off and protected to avoid a shortfall during packaging and shipping. The project owner or their subcontractor shall also ensure 49 CFR 173.185 addressing the transportation of lithium cells or batteries for disposal or recycling, or applicable regulations, are adhered to, including applicable packaging requirements and hazard communication. In the event of any breakage or damage to individual battery modules, such modules will be placed in separate, nonmetallic inner packaging that completely encloses the cell and will utilize inner packaging that is surrounded by cushioning material that is noncombustible, electrically nonconductive, and absorbent. Such internal packaging shall be placed in an outer packaging that meets applicable requirements of CFR part 178, subparts L, M, P, and Q, or applicable regulations, with proper marking denoting the package containing a damaged/defective lithium-ion battery. In all cases, the project owner, or their subcontractor, as appropriate, shall comply with all applicable, EPA, OSHA, security, safety, and health requirements during the removal and decommissioning. |
| BESS HVAC, fire suppression system, power conversion system, and transformer removal process. |
1. | BESS HVAC and fire suppression system equipment: The refrigerant/coolant from INAC units will be collected into separate containers on-site per the code and industry standard practice. The coolant can be reused after processing. The HVAC units and other recycling materials will be sent to the metal recyclers. Similarly, all fire suppression units will be cleared of the suppression fluids and sent to the suppliers for reuse following the industry standard practice. |
2. | Inverters, transformers, and ancillary equipment: All electrical equipment will be disconnected and disassembled. All parts will be removed from the site and reconditioned and reused, sold as scrap, recycled, or disposed of appropriately, consistent with applicable regulations and industry standards. |
3. | Gravel aggregate will be removed and shipped from the project site to be reused, sold, or disposed of appropriately, consistent with applicable regulations and industry standards. Clean aggregate can often be used as "daily cover" at landfills for no disposal cost. All internal service roads are constructed with geotextile fabric and eight inches of aggregate over compacted subgrade. All pile foundations will be pulled out completely. Underground cables and duct banks will be removed to a depth of four feet. Topsoil will be reapplied to the disturbed area. Soil and topsoil will be de-compacted, and the site will be restored to the pre-construction condition and re-vegetated. |
4. | Equipment foundation and pads: The project's foundations are assumed to be concrete pads. All unexcavated areas compacted by equipment used in decommissioning will be de-compacted to adequately restore the topsoil and subgrade material to a density like the surrounding soils. All materials will be removed from the site and disposed of appropriately, consistent with applicable regulations and industry standards. |
5. | Fence: All fence parts and foundations will be removed from the site, consistent with applicable regulations and industry standards. The surrounding areas will be restored to pre-developed conditions to the extent practical. |
6. | Access roads: Facility access roads, including entrances, will be used for decommissioning purposes, after which removal of roads will be discussed with the county engineer and the applicable landowner, using the following process: |
| a. | After final cleanup, roads, and entrances may be left intact through mutual agreement of the applicable landowner, the project owner, and the county engineer unless otherwise restricted by federal, state, or local regulations. |
| b. | If any roads and entrances are to be removed, aggregate will be removed and shipped from the project site to be reused, sold, or disposed of appropriately, consistent with applicable regulations and industry standards. Any ditch crossing connecting access roads to public roads will be removed unless the relevant landowner requests it remains. The subgrade will be de-compacted using a chisel plow or appropriate subsoiling equipment. All large rocks will be removed. The access roads and the adjacent regions compacted by the equipment will be de-compacted. |
7. | Substation: All steel framing, conductors, switchgear, transformer, security fence, and other facility components will be disassembled and recycled or reused off-site. Foundations and underground components will be removed up to a depth of four feet or any applicable regulation. The rock base will be removed, and the material will be hauled from the site to be recycled or disposed of at an off-site facility. Permanent stormwater treatment facilities like retention basins will be removed and graded to blend with the surrounding topography to promote pre-construction drainage patterns. Topsoil will be reapplied to the disturbed area. Soil and topsoil will be de-compacted, and the site will be restored to the pre-construction condition and re-vegetated. |
| Restoration/reclamation of site. |
1. | The project owner will restore and reclaim the site to the pre-development state, ready for farming conditions consistent with applicable laws, rules, regulations, and lease agreements. The goal of restoration will be to restore natural hydrology and plant communities (nonagricultural related) to the greatest extent practicable while minimizing new disturbance. During the operating phase of the project, the areas not hard-surfaced will be vegetated with native grasses and forbs and pollinator-friendly vegetation. This vegetation will rebuild soil health during the operating phase of the project. The vegetation is expected to withstand the decommissioning of the site, and only a minor effort will be required to restore the site to a pre-developed state. The decommissioning effort will implement best management practices ("BJ.1Ps") to minimize erosion and to contain sediment on the project site to the extent practicable. The BMPs are anticipated to include: |
| a. | Minimizing new disturbance and removing native vegetation to the greatest extent practicable during decommissioning. |
| b. | Removing equipment and access roads up to full depth, backfill with native subgrade material, and cover with suitable topsoil to allow adequate root penetration for plants and so that subsurface structures do not substantially disrupt groundwater movements. |
| c. | Stabilizing soils and returning them to agricultural use, such as decompacting the soil, according to landowner direction. |
| d. | Installing erosion and sediment control measures, such as silt fences, bio-rolls, and ditch checks in all disturbance areas where the potential for erosion and sediment transport exists, consistent with stormwater management objectives and requirements during and after decommissioning activities. |
| e. | Remediating any petroleum product leaks and chemical releases before completion of decommissioning. |
| f. | Decommissioning and restoration activities at each site will be completed within 12 months. Specifically, following a continuous one-year period in which no electricity is generated, or if substantial action on the project is discontinued for one year ("pre-decommissioning period"), the project owner will have one year to complete decommissioning of the project. The project owner will notify the Henderson City-County Planning Commission at least 30 days before the conclusion of the pre-decommissioning period. |
| Post-restoration monitoring and environmental studies. |
1. | Decommissioning of the project site will comply with all federal, state, and local regulations. Decommissioning may include post-restoration monitoring as required by the NPDES/SDS CSW permit, SWPPP, and other applicable requirements. In addition, the project owner's field representative assigned to decommissioning monitoring will contact the applicable landowners, including on-site check-ins and site walk-downs for any flown debris to the neighboring properties until the NPDES/SDS CSW permit is closed. |
| Estimated net decommissioning costs and financial assurance. |
1. | The reclamation bond estimate uses current pricing for removing components and is based on three years of degradation and depreciation of the modules. Due to construction techniques and technology changes, subsequent revisions to the decommissioning plan and cost estimate will be required. The mechanism for calculating the adjusted costs over the project's life will be based on updating the cost estimates for the decommissioning and restoration of the project site. The analysis used to revise the forecast will be like the one used to prepare this estimate. An engineering evaluation of the current construction techniques and equipment used for decommissioning will be performed, and the cost estimate will be revised to reflect any changes in productivity resulting from new techniques, equipment, and inflation. The required financial assurance will be updated every three years. |
2. | The recycling costs will be updated biannually to reflect the industry standard values. |
3. | The decommissioning plan will be updated every three years and will be audited. |
4. | The decommissioning estimate has been prepared under the responsible supervision of a third-party certified professional. |