Decommissioning Plan Report - Peterborough Utilities Inc.

Peterborough Landfill
Gas Generation Project
DECOMMISSIONING PLAN
REPORT
July 2011
Peterborough LFG Generation Facility
Decommissioning Plan Report
Table of Contents Page 1. Introduction .............................................................................................................. 1 2. The Proponent ............................................................................................................. 2 3. Project Location ........................................................................................................... 3 4. Decommissioning Plan Overview ................................................................................. 5 4.1 Decommissioning During Construction .................................................................. 5 4.2 Decommissioning After Ceasing Operation............................................................ 6
5. Equipment Dismantling and Removal .............................................................................. 7 5.1
5.2
Above‐Ground Structures ........................................................................................7
5.1.1 Generators .................................................................................................. 7 5.1.2 Gas Treatment Module and LFG Piping ...................................................... 7 5.1.3 Flare ............................................................................................................ 7 5.1.4 Transformer ................................................................................................ 8 5.1.5 Equipment Foundations and Pipe Supports ............................................... 8 5.1.6 Transmission Line and Associated Components......................................... 8 5.1.7 Access Roads ............................................................................................... 8 5.1.8 Other ........................................................................................................... 9 Below‐Ground Structures ........................................................................................9
5.2.1 Power Cables............................................................................................... 9 5.2.2 LFG and Condensate Pipe ........................................................................... 9 6. Site Restoration ........................................................................................................... 9 7. Managing Excess Materials and Waste........................................................................10 8. Emergency Response and Communications Plans .......................................................11 9. Decommissioning Notification ....................................................................................11 10. Other Approvals..........................................................................................................12 11. Conditions Of Approval ...............................................................................................12 12. Summary and Conclusions ..........................................................................................13 Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
List of Tables Table 1: Proponent and Consultant Contact Information ............................................................. 3 Table 2: Management of Wastes and Materials.......................................................................... 11 List of Figures Figure 1: Geographic Location of the LFG Project within Peterborough County .......................... 4 Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
Acronyms and Abbreviations Acronym CFM Dillon FIT FVB Genset LFG MOE MW O.Reg PCC PUI REA SPM Description Cubic feet per minute Dillon Consulting Limited Feed in Tarriff FVB Energy Inc. Reciprocating Engine and Generator Unit Landfill Gas Ontario Ministry of the Environment Megawatt Ontario Regulation Point of Common Coupling Peterborough Utilities Incorporated Renewable Energy Approval Suspended Particulate Matter Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
Table of Contents Page 1. Introduction .............................................................................................................. 1 2. The Proponent ............................................................................................................. 2 3. Project Location ........................................................................................................... 3 4. Decommissioning Plan Overview ................................................................................. 5 4.1 Decommissioning During Construction .................................................................. 5 4.2 Decommissioning After Ceasing Operation............................................................ 6
5. Equipment Dismantling and Removal .............................................................................. 7 5.1
5.2
Above‐Ground Structures ........................................................................................7
5.1.1 Generators .................................................................................................. 7 5.1.2 Gas Treatment Module and LFG Piping ...................................................... 7 5.1.3 Flare ............................................................................................................ 7 5.1.4 Transformer ................................................................................................ 8 5.1.5 Equipment Foundations and Pipe Supports ............................................... 8 5.1.6 Transmission Line and Associated Components......................................... 8 5.1.7 Access Roads ............................................................................................... 8 5.1.8 Other ........................................................................................................... 9 Below‐Ground Structures ........................................................................................9
5.2.1 Power Cables............................................................................................... 9 5.2.2 LFG and Condensate Pipe ........................................................................... 9 6. Site Restoration ........................................................................................................... 9 7. Managing Excess Materials and Waste........................................................................10 8. Emergency Response and Communications Plans .......................................................11 9. Decommissioning Notification ....................................................................................11 10. Other Approvals..........................................................................................................12 11. Conditions Of Approval ...............................................................................................12 12. Summary and Conclusions ..........................................................................................13 Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
1.
Introduction Peterborough Utilities Incorporated (PUI) intends to develop a waste‐to‐energy project located within the property boundary of the Peterborough County and City Waste Management Facility at 1310 Bensfort Road in the Township of Otonabee‐South Monaghan, Ontario. The Peterborough Landfill Gas (LFG) Generation Project would consist of two (2) LFG‐fuelled reciprocating engine generator sets (gensets) with a combined generating capacity of 2 MW (nameplate capacity) of electricity. The LFG will be collected from within the existing landfill and will be supplied to the engines via a collection and delivery pipe network. A 27 kV transmission line will connect the gensets to existing transmission lines along Bensfort Road. The proposed project is a “biogas facility” as per the interpretation provided in Part I of Ontario Regulation 359/09 (i.e. “a renewable energy generation facility at which biogas is used to generate electricity but does not include an anaerobic digestion facility”). There are no specific classes assigned to this type of facility under O. Reg. 359/09. An application by PUI was made to the Ontario Power Authority to obtain a contract for the sale of electricity from LFG through the Province’s Feed in Tariff (FIT) program (enabled by the Green Energy and Green Economy Act). This contract has been granted. In addition, the project will require approval under O. Reg. 359/09 – Renewable Energy Approval (REA) under Section V.0.1 of the Ontario Environmental Protection Act. This Decommissioning Plan Report is being submitted to the MOE as required under the Renewable Energy Approvals (REA) process as outlined in O. Reg. 359/09 and was made available for public review and comment prior to this final submission to the MOE. Other reports made available for public review prior to this submission included: •
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Project Description Report Construction Plan Report Design and Operations Report Noise Study Report Odour Study Report Emission Summary and Dispersion Modelling Report Natural Heritage Assessment (4 reports) Water Assessment Report (2 reports) Archaeological Assessment Cultural Heritage Screening Supporting Documents Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
In this REA submission, in addition to the above‐listed reports, the consultation report is also included. The Decommissioning Plan Report describes plans for the decommissioning of the renewable energy facility, activities related to the restoration of lands and waters negatively affected by the project and procedures for managing excess waste. 2.
The Proponent Peterborough Utilities Inc. will be the owner and operator of the proposed landfill gas generation project. PUI is part of the Peterborough Utilities Group of companies owned and operated by the City and County of Peterborough and has managed electrical generation and retail services since 2000. The company is pursuing projects with a focus on renewable and clean energy resources (including solar, hydropower and landfill gas) in recognition of the importance of growing electrical generation in tandem with respect for the environment and human health. FVB Energy Inc. (FVB) is providing engineering services for design, procurement, installation and commissioning of the landfill gas power generation facility. The scope of services includes the delivery of LFG from an existing LFG blower station, the treatment of the LFG, the generation of power using gensets and the delivery of power to the Point of Common Coupling (PCC) on the Hydro One 27 kV power grid. Dillon Consulting Limited (Dillon) is providing PUI with MOE application and permitting support, including assistance in preparing REA‐required reports and conducting consultation activities. Contact information for PUI, FVB and Dillon is as follows: Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
Table 1: Proponent and Consultant Contact Information Name Title Address Phone Fax Email John Wynsma 1867 Ashburnham Dr., Peterborough Utilities Inc.. 705‐748‐9301 705‐748‐3138 [email protected] Peterborough, Ontario (Applicant) ext 1248 K9J 6Z5 Kevin McKeown 1867 Ashburnham Dr., Peterborough Utilities Inc.. 705‐748‐9301 Peterborough, Ontario 705‐743‐5988 [email protected] (Project Manager) ext 1309 K9J 6Z5 Mark Tracey FVB Energy (Energy Consultant) 3901 Highway 7, Suite 300, Vaughan, Ontario L4L 8L5 905‐265‐1837 905‐265‐1756 [email protected]
ext. 310 Amir Iravani Dillon Consulting Ltd. (Environmental and REA Consultant) 235 Yorkland Blvd, Suite 800, Toronto, Ontario M2J 4Y8 416‐229‐4647 416‐229‐4692 [email protected] ext 2320 3.
Project Location The Peterborough LFG generation facility will be situated on approximately 0.051 ha (0.126 acres) of land located within the property boundary of a 25.7 ha (63.6 acres) landfill site located at 1310 Bensfort Road in the Township of Otonabee‐South Monaghan, Ontario. The landfill, operated by the City and County of Peterborough, is located approximately 8 km south‐
south‐east of downtown Peterborough. All project components will be contained within the landfill, with the exception of a small portion of a 27.6 kV transmission line that connects with the Hydro One grid in the municipal right‐of‐way on the west side of Bensfort Road. Figure 1 provides the geographical location of the proposed project within Peterborough County. The project location as defined in Ontario Regulation 359/09 is “a part of land and all or part of any building or structure in, on or over which a person is engaging in or proposes to engage in the project”. Facility components making up the project location have been identified in detail in the Design and Operations Report. The selection of the project’s location was based primarily on the available space, the proximity to existing landfill areas, proximity to the existing flare, access to the local electrical transmission system, interconnection economics, environmental constraints and socio‐
economic factors. Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
Figure 1: Geographic Location of the LFG Project within Peterborough County Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
4.
Decommissioning Plan Overview The Decommissioning Plan provides an overview of all activities during the decommissioning phase of the Project, as well as all activities related to the restoration of lands and water and managing excess materials and waste. Properly maintained gensets have a life expectancy between 20 to 30 years. This report, however, assumes that the decommissioning process will be initiated upon completion of the project’s useful life (i.e. landfill gas production levels) or the end of the power purchase agreement with the Ontario Power Authority (or legal successor) or another green energy power purchaser. Decommissioning of the landfill gas facility involves the removal of the above‐ground and below‐
ground project components. The premises will be restored to their original condition with the exception of reasonable wear and tear and casualty. Within three (3) months of initiating the decommissioning PUI will have removed all the relevant components from the project area. The decommissioning of the facility will follow the Ontario Health and Safety Act along with any applicable municipal, provincial and federal regulations and standards. As with the construction of the facility, a construction safety representative will be on site for the duration of the decommissioning work. Potential negative environmental effects for decommissioning activities are similar to those during construction. Measures to mitigate negative effects, as described in the Construction Plan Report, will be followed for decommissioning activities. 4.1
Decommissioning During Construction While not expected and considered to be extremely unlikely, in the event that construction activities and associated work cease prior to facility completion and commissioning (with no expectation of construction re‐start) the project would be decommissioned in a manner as described in this report. The site would be returned to the state that existed prior to project construction. Roadways modified for site access would be restored to their original condition. Mitigation measures as described in the Construction Plan Report will also be implemented where appropriate (e.g. to stabilize exposed soils). Dillon Consulting Limited: Project 10-3636
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4.2
Decommissioning After Ceasing Operation The project will cease once the landfill gas quantities reach a production level that is too low to sustain continuous operation of the generating equipment or when the end of the electricity purchase contract. The landfill is expected to maintain adequate levels of LFG production for more than 20 years. When operation ceases, the equipment would be removed from the foundations, and the equipment, interconnecting piping and wiring, foundations and the transmission line from to Bensfort Road would be removed. Decommissioning activities will occur in the following sequence: • Removal of electrical connection of the grid to eliminate exposure to high voltage electricity. The hydro poles and power line that connects the power generation facility to the Hydro One grid may be removed at this time or in parallel with the removal of other components. • Removal of liquids to remove the risks of spill. The oil stored in the gas treatment modules and the genset modules will be removed. • Dismantling of the power generation facility beginning with modular components located on the concrete foundations. This includes the electrical components such as the transformer, high voltage switchgear and metering cabinets. • Removal of above ground piping or electrical conduit/wiring that interconnects the equipment modules. • Removal of the equipment modules. This includes the gas treatment module, the two generation modules, LFG flare and any additional equipment modules added over the life of the project. • Removal of underground piping and electrical conduit/wiring in order to create space for removal of larger underground structures such as the equipment foundations. • The equipment foundations are removed. • Site fencing and fence poles are removed. • Site granular base is removed and replaced with engineered fill and topsoil. • Final site restoration and site inspection. Dillon Consulting Limited: Project 10-3636
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5.
Equipment Dismantling and Removal The landfill gas facility makes use of the existing Peterborough County/City Landfill infrastructure, including the South and North Fill Area cells, existing flare station, conduit between the weigh station and main facility components, gravel roads south of the facility, and underground LFG piping. This infrastructure will not be subject to decommissioning activities. The following describes the decommissioning process for above and below ground components of the landfill gas facility. All waste and excess materials will be managed as per Section 7. 5.1
Above‐Ground Structures 5.1.1 Generators The two 1 MW generator sets will be removed. The first step is to drain oil from storage tanks and reservoirs. The water‐glycol fluid used on the gas treatment system would be removed. The oil and glycol will be disposed of at an approved disposal site. LFG piping would be purged to remove flammable gases. The next step would be to remove all components that are not transported with the genset module. This would include the stack, exterior components of the refrigeration system and exterior piping and electrical cabling. 5.1.2 Gas Treatment Module and LFG Piping Any liquids associated with the refrigeration system will be drained from the equipment and piping. The LFG piping would be purged to remove any combustible gases. The exterior piping, electrical cabling and equipment will be removed from the gas treatment module. The gas treatment module would be removed from the foundation and loaded on a truck with a crane. 5.1.3 Flare The 500 cfm LFG flare will be removed by disconnecting LFG gas source and electrical power supplies and removing interconnecting piping and electrical cabling between blower and LFG flare. This includes any piping and wiring between electrical and instrumentation panels and equipment. Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
5.1.4 Transformer Oil will be removed from the transformer and disposed of at an approved facility. The 27 kV/600 V 3 MVA transformer will be removed by disconnecting electrical cabling and any foundation bolting. The transformer would be removed from the foundation with a crane. 5.1.5 Equipment Foundations and Pipe Supports The decommissioning of the foundations would involve the excavation and temporary stockpiling of the top four to five feet of the soil around the foundation. Once cleared, the top three feet of the foundation will be removed using appropriate equipment. The removed concrete and rebar scrap will be hauled off site by truck and properly disposed of at a registered landfill or recycling facility. Afterwards, the stockpiled soil will be used to replace the excavated area on‐top and around the foundation. The disturbed area will be feathered out and graded. No off‐site soil is predicted to be needed. The soil will be seeded with native vegetation as required and or prepared for future uses. Pipe supports would be removed in a manner similar to the equipment foundations as described above. 5.1.6 Transmission Line and Associated Components Decommissioning of the transmission line components will involve the removal of the 27 kV high voltage line that connects the generation station to the Bensfort Road distribution line. All poles, and associated equipment (isolation switch, fuses and metering) will also be removed. 5.1.7 Access Roads The two access roads will be removed. Decommissioning of access roads will involve the removal of the aggregate materials by a backhoe/front‐end loader. This material will be transported from the site by truck to a nearby location where the aggregate can be processed for salvage. It is possible that the local townships may accept this material without processing for use on local roads, however, for the purposes of this report it is assumed that the materials will be removed and hauled to a reprocessing site within 25 km of the landfill gas facility. Decommissioning of access roads will also involve the removal and proper disposal of geotextile fabric. It is assumed that during excavation of the aggregate a large portion of the geotextile will be ‘picked up’ and sorted out of the aggregate at the aggregate reprocessing site. Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
Decommissioning Plan Report
Geotextile fabric that is remaining or large pieces that can be readily removed from the excavation aggregate will be disposed of off site at a registered landfill. 5.1.8 Other The dismantling of the site fencing will be one of the last activities prior to removal of fence pole foundations and the final remediation of the site. 5.2
Below‐Ground Structures 5.2.1 Power Cables The following cables will be removed: • Underground high‐voltage power cable between the 27 kV isolation switch and high voltage side of the 27 kV/600 V transformer; • 600 V cables that connect the low voltage side of the transformer to the electrical building; • 600 V and lower voltage power and control cabling between electrical building and equipment modules. These cables will be removed by disconnecting them at the equipment and then extracting them from the ducts or conduit using cable pulling equipment. The empty cable ducts and conduit can be removed using small excavation equipment. 5.2.2 LFG and Condensate Pipe Underground pipe would be purged of flammable gases and then removed by excavating to the depth of warning tape. The remainder of the pipe would be exposed by hand so that piping could be cut in section lengths that are appropriate for transportation. A crane would be used to remove pipe sections and load them onto a truck. The piping would be transported to an approved disposal or recycling facility. 6.
Site Restoration Prior to construction the project location consisted of barren earth with little vegetation since it was recently created as part of the North Fill Area development. Since the location is currently unused land located on the landfill, the landfill gas facility will not negatively affect the lands or waters in any significant way. However, once all components have been removed, the project Dillon Consulting Limited: Project 10-3636
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Peterborough LFG Generation Facility
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area will be restored to as close to a pre‐construction state as feasible for use by the landfill for its own purposes. Prior to abandonment of the site a land survey will be conducted to ensure that conditions satisfy those set out in O. Reg. 359/09 and any agreements with the municipality. The following steps outline how the lands and waters potentially affected by the landfill gas facility will be restored to a safe, clean and pre‐facility condition: • As discussed earlier in the report, the site will be restored to the original condition by excavating granular base and replacing with fill and top soil; • The site will be seeded to grow vegetation that in a manner that is consistent with the rest of the landfill; • The site can then be returned to the landfill operator as unused space. It is not expected that the lands surrounding the facility will require any special remediation since any hazardous materials used on the site will be contained with adequate spill protection. As with the construction process, any land that was disturbed or compacted during the decommissioning of components will be de‐compacted and graded, followed by the application of soil (if required) and seeding with native species (in consultation with the landfill operator). No direct impact to the aquatic environment is expected from site restoration activities as it is assumed that culverts will remain in place. While there is the potential for temporary disturbance to watercourses (erosion/sedimentation/fuel spills) from the removal of access roads and grading of lands, these effects would be minimized through the implementation of storm water protection measures (see measures proposed for construction activities in the Construction Plan Report). 7.
Managing Excess Materials and Waste During the decommissioning of the landfill gas facility, a variety of materials and wastes will be generated. Where possible, materials will be reused or recycled. Waste materials will be landfilled at the Peterborough County and City Waste Management Facility or will be transported to a licensed landfill by a certified contractor. Table 2 describes the type of material or waste and how it will be managed. Dillon Consulting Limited: Project 10-3636
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Table 2: Management of Wastes and Materials Material/Waste Process piping Electrical equipment Process equipment - Gensets - LFG flare - LFG treatment equipment Asphalt and concrete foundations Site aggregate and fill. Buildings, structures 8.
Means of Managing Excess Materials and Waste Removed, cleaned and transported by certified and licensed contractor to landfill or recycling facility. Electrical wire, transformers, switchgear, and motors will be removed, cleaned and transported by certified and licensed contractor to landfill or recycling facility. The process equipment will be well maintained during the life of the project. At the end of the project, process equipment can reused if a market exists for the equipment and outdated equipment will be dismantled, cleaned and transported by certified and licensed contractor to landfill or recycling facility. Asphalt and concrete foundations will be broken down and transported by certified and licensed contractor to landfill or recycling facility. The site aggregate and fill used for construction will be tested for contamination prior to removal and disposed of at landfill or recycling facility. To the extent possible, fill we be reused to re‐establish site elevations. Topsoil will be added as necessary to return site to condition equivalent to the surroundings. All buildings, site fencing, transmission line poles, will be dismantled and transported to landfill or recycling facility. Emergency Response and Communications Plans The Emergency Response and Communications Plans are provided in the Design and Operations Report and cover the life of the project, including decommissioning. 9.
Decommissioning Notification Notification of decommissioning activities will follow the same process as for non‐emergency communication outlined in the Emergency Response and Communications Plan in the Design and Operations Report. Once the facility has been fully decommissioned all responders and stakeholders listed in these plans will be notified. This will allow those parties to make the appropriate changes to their own plans and organization. Dillon Consulting Limited: Project 10-3636
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10.
Other Approvals PUI is aware that after the decommissioning of the Project, a Record of Site Condition under the MOE Records of Site Condition Regulation (O. Reg. 153/04) may be required. Should additional approvals and permits be required from other agencies at the time of decommissioning, PUI will ensure that they are obtained. 11.
Conditions Of Approval PUI will ensure that the decommissioning stage of the proposed facility is carried out in accordance with REA requirements and the measures/practices as described in this report. In addition, PUI respects the need to fully inform and co‐operate with landowners and the local government authorities. PUI understands that the MOE Director of Approvals could request specific decommissioning activities as a condition of REA approval that could include: • Providing notification regarding the plans to continue or cease the operation of the proposed facility by the end of power purchase agreement; • Providing notification regarding the need for an application for amendment to the REA to keep the proposed facility in operation after the end of power purchase agreement; • Providing timelines for the start and completion of the decommissioning activities; • Keeping this report updated to ensure that when required a portion of the facility which is not operational due to technical failure can be properly decommissioned; • Continuing ground water and surface water monitoring after operation, for a period of time acceptable to the MOE REA Director; • Providing site restoration measures that would ensure that the nutrient content of the soil is restored, if necessary and if required for agricultural purposes; • Providing restoration of the site as close to a pre‐construction state as feasible; and, • Providing a decommissioning cost estimate as well as the methods for ensuring that the funds will be available for decommissioning and site restoration. Dillon Consulting Limited: Project 10-3636
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Summary and Conclusions This Decommissioning Plan Report has been completed to assist PUI and any subsidiary or successors in fulfilling regulatory requirements as mandated by the provincial government agencies for the decommissioning of the Peterborough LFG Generation facility. This report is consistent with the provision of Ontario Regulation 359/09 for a biogas facility. In the event of the abandonment of the proposed facility or in the even that the LFG operation ceases, PUI and any subsidiary or successors will adhere to all decommissioning requirements provided in this report and will ensure that the project site is properly restored to a safe, clean, pre‐facility condition. It is the overall conclusion of this Decommissioning Plan Report that the decommissioning of the LFG facility and ancillary equipment will be conducted in such a manner as to ensure that there will be no significant negative environmental or social effects. Dillon Consulting Limited: Project 10-3636
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