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Description / Abstract:
The proposed scope of work under this ASME ST-LLC investigation
was separated into three tasks as it pertains to coal-fired plant
decommissioning.
The task for Part 1 focused on what documentation exists within
the public domain related to coal plant decommissioning (once the
decision has been reached for either economic or political means to
retire a unit or plant). The results revealed sparse information in
the way of standards or guidelines to direct an owner/user or
Independent Power Producer (IPP) in steps necessary to conduct
plant decommissioning. The only source of credible information
found in the public domain was an Electric Power Research Institute
(EPRI) publication on coal-fired plant decommissioning
handbook.
For the task of Part 2, the author performed a high-level review
of what specific decommissioning steps are required by regulation
or mandate. The investigation revealed high-level decommissioning
steps are published within the EPRI Handbook noted above. Each
decommissioning step was discussed along with applicable regulatory
standards and gaps. The results of this high level gap analysis
revealed current standards exist for decommissioning activities
related to air permits, water discharge or NPDES permits, waterway
and storm water spill prevention, safety, security and hazardous
waste removal and disposal. The author's position was that current
regulatory standards apply across the board to plants in operation,
as well as those plants to be decommissioned. One of the gaps found
that a decommissioning team should be selected to provide an
interface with the mentioned regulatory agencies and ensure proper
communication and understandings of requirements are being
followed.
For the task of Part 3, the research effort focused on the
complete list of units which have been decommissioned and what
units or plants have been identified for either decommissioning or
upgrades in the future. The results of this effort revealed close
to 300 units/plants are affected within the U.S. The author
believes that given the current market forces and possible number
of scheduled shutdowns and eventual decommissioning of units or
plants, there is a need to have either a separate ASME standard or
guideline to provide direction for owner/users into how to
adequately plan and execute plant decommissioning.