HomeMy WebLinkAbout10a Jerry Smith Storage Decommissioning Plan_DRAFT Jerry Smith Storage
Decommissioning Plan
MAY 261 2026
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Contents
Summary.......................................................................................................................................................1
Introduction ..................................................................................................................................................2
Decommissioning Process.............................................................................................................................3
Environmental Safety and Impact.................................................................................................................4
Financing.......................................................................................................................................................5
Decommissioning Timeline...........................................................................................................................5
Appendix 1—Tesla Megapack 2XL Operations and Maintenance Manual ..................................................7
Summary
Purpose
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This Decommissioning Plan provides an overview for the safe and proper retiring of the Robinson Road
Storage Battery Energy Storage System (BESS)facility at the end of its operational life and ensuring all
activities are performed in compliance with regulatory standards.
Project Overview
The Robinson Road Storage project is located within parcel 339 Jerry Smith Road, Lansing, NY, 14882.
The project consists of an energy storage system with a system capacity of 5,000 kW/23,500.8 kWhs
which includes Six (6)Tesla Megapack 2XL BESS units, ancillary electrical equipment and fencing.The
total fenced in area of the BESS is 9,689 ft2 and is expected to be installed as shown in Figure 1.The
expected operational life of the BESS facility is 20 years,which is assumed under the guidance of the
Original Equipment Manufacturer(OEM).
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Figure 1 BESS layout
Requirements
Decommissioning will be conducted in accordance with the New York State regulations, ensuring all
system equipment/components are removed, recycled, and/or disposed of safely and properly.This
includes but is not limited to adhering to the following:
• Town of Lansing Building Code
• NFPA 855 2026 Edition
• 2025 FCNYS
• NYSDEC
• NYSEG DER Interconnection Guidelines
Introduction
Overview
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Decommissioning activities will ensure that the site is suitable for future use by removing all equipment
and its components' parts of the BESS.This will be performed to restore the site to its pre-construction
condition.This protocol includes the disconnection, dismantling, material recycling, and land
restoration.
Pre-planning Activities
The following activities will be done in pre-planning:
• Review and update the decommissioning plan and funding mechanism
• Establish a detailed decommissioning schedule with clear milestones
• Notify stakeholders, including local Authorities Having Jurisdiction (AHJs) and utility companies
(NYSEG) at least Six(6) months before decommissioning activities begin, with Lansing Fire
Department receiving written notice at least 30 days prior to the start of decommissioning
• Gather technical documents, equipment manuals, engineering drawings, material safety data
sheets (MSDS) and transportation guidelines
• Secure necessary permits and approvals
Decommissioning Process
Equipment Removal
Decommissioning will proceed in the reverse order of installation, with activities including the following:
1. Electrical disconnection
a. Disconnect the BESS from Grid and ancillary electrical equipment
b. Remove above and underground electrical lines/cables, poles, and conduits
2. Removal of Major Components
a. BESS units (including batteries and inverters), MV transformers, and other electrical
equipment will be removed and transported to certified and pre-approved facilities
b. Hazardous materials, including batteries and transformer oil, will be managed as per
EPA, DOT, and NYSDEC standards
c. NYSEG Interconnection Equipment:
i. Remote trip/SCADA disconnect will be disconnected and decommissioned
ii. Metering equipment will be removed and returned to NYSEG
3. Structural Removal
a. Dismantle and recycle fencing, concrete foundations, and equipment pads
4. Debris and Waste Management
a. Separate and transport waste to approved recycling and/or disposal facilities
Material Recycling and Disposal
The following materials will be recycled and disposed of:
• Batteries will be transported to OEM and their recycling partners for proper recycling and
disposal
o Due to the nature of energy storage facilities, a Tesla Megapack 2XL specific
decommissioning plan is provided within Appendix 1 (Tesla Megapack 2XL Operations
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and Maintenance Manual).This plan is developed by the OEM and is intended to guide
owner/operators of the energy storage system.
• Transformer oils will be sent to certified facility
• Metals and wiring will be salvaged for recycling
• Concrete foundations will be broken and transported for reuse
• Gravel and geotextiles will be reused where possible or sent to approved facilities
Site Restoration
Site restoration will include the following:
• Grade disturbed areas to restore drainage patterns to the original design
• Apply topsoil and reseed with a native seed mix to prevent the possibility of erosion
• Verify restoration quality through inspections and photographic documentation
Town of Lansing final sign-off and restoration inspection will be conducted to confirm all structures are
removed or restored.
Environmental Safety and Impact
Safety Protocols
A comprehensive environmental Health &Safety Plan (EH&S)will be developed and will govern all
decommissioning activities.This plan will comply with OSHA standards (29 CFR 1910.120) and
incorporate best practices for protecting workers and the community.The key components of this plan
includes but is not limited to the following:
• Job Hazard Analysis(JHA): Detailed risk assessment for each job/task, identifying potential
hazards and their mitigating measures
• Personal Protective Equipment (PPE):Appropriate PPE will be provided to workers, including arc
flash suits, gloves, etc., based on the nature of the work activity
• Fire Prevention and Control:
o All fire protection systems will remain operational during decommissioning
o Fire department will be made aware of the decommissioning activities in the event an
emergency arises
• Emergency Response Plan:
o Site-specific procedures for handling emergencies such as fires,thermal runaway,
chemical spills,or injuries will be available, and the fire department would have been
trained with respect to this plan.
o Coordination with local emergency response teams and Lansing Fire Department for
incident management.
• Emergency Response Access:
o Nexamp will ensure that Lansing Fire Department will have site access and keys(if
required) during the decommissioning phase
• Site Security:
o Fencing and restricted zones will ensure unauthorized personnel are kept out of active
work areas.
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o Security measures will also safeguard equipment and prevent theft and/or vandalism.
Hazardous Material Handling
The handling and disposal of hazardous materials, such as lithium-ion batteries and transformer oils, will
follow local and federal regulations, including those outlined in EPA standards. Key protocols include but
are not limited to the following:
• Identification of Hazardous Materials:A thorough inventory of all regulated materials, including
batteries, transformers, and associated electrical equipment.
• Containment and Transportation: Ensuring all hazardous materials are securely packaged,
labeled, and transported to certified facilities using licensed hazardous material
handlers/carriers.
• Spill Prevention and Control:
o A Spill Prevention, Control, and Countermeasure (SPCC) Plan will be implemented to
address potential leaks or spills during the dismantling process.
o Secondary containment systems will be utilized for any containers exceeding 55 gallons
o Each Tesla Megapack 2XL includes a plenum for electrolyte (hazardous material in the
lithium-ion battery) leakage that has the potential to contain 200+%of the hazardous
material present in a single Megapack 2XL unit
o Trained personnel will manage cleanup of any spills, and incidents will be reported to
the appropriate authorities
Lithium-ion batteries have a hazard classification of Class 9. As such,the shipping UN 38.3 classifications
for the batteries ensure that safe transportation and labeling compliance can be achieved.
Stormwater Management
Nexamp will implement any required stormwater management controls as required by local AHJs and
ensure compliance with the New York State Department of Environmental Conservation (NYSDEC) at the
time of decommissioning. Specific measures include:
• Minimizing soil disturbance and controlling sediment runoff during decommissioning activities.
• Stabilizing disturbed areas with appropriate erosion and sediment control methods, such as silt
fencing and sediment traps.
• Regular monitoring of stormwater discharge to ensure compliance with State Pollutant
Discharge Elimination System permit conditions.
If any potential contaminated areas are disturbed, appropriate mitigation will be undertaken in
coordination with the NYSDEC and regional water management authorities.
Financing
Robinson Road Storage, LLC will pay for the decommissioning of the system from the existing balance
sheet.
Decommissioning Timeline
The following table provides an overview of the Decommissioning Timeline:
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Table 1 Decommissioning Timeline
Decommissioning Activity Timeline(Months)
Stakeholder Notifications 0-6
Permitting and Approvals 2-6
Equipment Removal and Recycling 6-9
Site Restoration 9-15
Final Reporting 15
The decommissioning process for the facility will adhere to a structured and carefully planned timeline
to ensure the safe dismantling, compliance to regulations and OEM guidance, and thorough site
restoration.The Decommissioning activities outlined in Table 1 are outlined in greater detail below:
1. Stakeholder Notifications(Months 0-6)
In this activity, Nexamp will notify all stakeholders of the intent to decommission the BESS
facility. Notifications will be issued to Lansing Building Department, NYSEG, OEMs, and relevant
AHJs (local and federal). A stakeholder list will be updated to include all involved and
responsible parties, and preliminary discussions regarding permits and approvals will
commence.
2. Permitting and Approvals (Months 2-6)
In parallel with Stakeholder Notifications, Nexamp will secure all necessary permits and
approvals for decommissioning activities.This activity includes the submission of permit
applications for decommissioning, environmental reviews, and compliance certifications.
Nexamp will coordinate with regulatory agencies to ensure that all documentation is updated,
complete, and compliant with the latest standards and best practices. Preparations for safe
material handling and waste management will be finalized in this activity.
3. Equipment Removal and Recycling(Months 6-9)
The physical dismantling of the Facility will begin at month six and its activities include:
a. Disconnecting the BESS from the electrical grid an ancillary equipment
b. Removing above and underground components
c. Transporting recyclable materials
d. Handling and disposing of hazardous materials per EPA and NYSDEC guidelines
This phase ensures that all components are safely removed while maximizing recycling
opportunities to minimize the environmental impact of the Facility and its decommissioning.
4. Site Restoration (Months 9-15)
Once all equipment has been dismantled and removed from the site, Nexamp will restore the
site to a vegetated and vacant condition. Restoration activities include:
a. Grading the land to match the original drainage patterns
b. Applying topsoil and seeding to disturbed areas with native seed mix to stabilize soil and
prevent any erosion
c. Conducting inspections to verify restoration quality
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d. Review of restoration activities with local AHJs for approval
5. Final Reporting(Month 15)
Nexamp will prepare a comprehensive decommissioning report as part of the final reporting
activity.This document will detail the timeline and milestones, components removed and their
whereabouts, final site conditions (with photographs and inspection results), and compliance
validation to regulation and permits.The report will be submitted to any relevant AHJs to
confirm the successful completion of the decommissioning process of the Facility.
Appendix 1 — Tesla Megapack 2XL Operations and Maintenance Manual