Onboarding Best Practice Guidelines

9.1. Construction and operation under EPC warranty - Environment

Waste disposal and handling authorisation

A. Environment

Renewable energies are popular because of their low environmental impact, and it is important that solar plants are operated and maintained to minimise any adverse effects. Environmental problems can normally be avoided through proper plant design and maintenance – for example, bunds and regular inspection of HV transformers will reduce the chances of significant oil leaks – but where issues do occur the O&M service provider must detect them and respond promptly. Beyond the environmental damage there may be financial or legal penalties for the Owner of the plant.

Legal obligations to be fulfilled by the O&M service provider (or the Technical Asset Manager) may include long-term environmental requirements to be implemented either onsite or off-site. Typical requirements can be, amongst others, water tank installation, tree clearing, drainage system installation, amphibian follow-up, edge plantation, and reptile rock shelter installation. Such requirements should be implemented and managed by the O&M service provider to comply with the relevant regulations. As a best practice, the O&M service provider’s environmental preservation activities can go beyond legal obligations.

Other aspects that need to be considered as best practice, are recycling of broken panels and electric waste so that glass, aluminium and semiconductor materials can be recovered and reused, and hazardous materials disposed of in a safe manner, complying with legal requirements. In areas with water scarcity, water use for module cleaning should be minimised.

In many situations, solar plants offer an opportunity, where managed sympathetically, to provide opportunities for agriculture and a valuable natural habitat for plants and animals alongside the primary purpose of generation of electricity. A well thought out environmental management plan can help promote the development of natural habitats, as well as reduce the overall maintenance costs of managing the plant’s grounds. It can also ensure the satisfaction of any legal requirements to protect or maintain the habitat of the site. In any case, environmental requirements from building permits should be complied with. Maintenance services should comply with things such as the proper application of herbicides, pesticides, and poisons used to control rodents. The use of solvents and heat-transfer fluids should also be controlled. Cleaning agents (soap) should be environmentally friendly (no chlorine bleach) and applied sparingly to avoid over-spray and run-off.

For more information, see: www.lancaster.ac.uk/SPIES and www.energyenvironment.co.uk. 

The SolarPower Europe Solar Sustainability Best Practice Benchmark discusses how to make sure that biodiversity is increased on a solar PV power plant:

• Local best practices should be considered

• Decision frameworks and decision support tools should be used

• Local experts should be consulted

By doing this and after discussion of various management methods, a management plan should be decided, which defines certain objectives concerning biodiversity and describes the activities by which to achieve them. Some typical measures are:

• Categorically forbidding the use of herbicides

• Reducing the frequency of vegetation cutting to the necessary minimum (not all areas need the same frequency)

• Cut vegetation in different phases to make sure that there are always untouched parts

• Limit the number of sheep per hectare to avoid over-grazing (if sheep are part of the management plan)

• Planting hedges with local species at the borders of the plant

• Creating piles of stones as microbiotopes for reptiles

• Arranging heaps of dead wood

• Keeping specific surfaces vegetation-free

• Removing cut grass in specific areas

These activities should be accompanied by regular surveys by local experts, to control evolution of biodiversity. They shall propose changes to the management plan if this is necessary for achieving the objectives.

End-of-Life (EoL) management optimisation - solar PV O&M for circularity

Based to the latest available (2019) figures reported on the growth of solar PV installations, we can estimate that about 1-1.2 million solar PV modules are installed every day around the world. With this in mind and with an estimated average annual failure rate of 0.2% in the field, we may anticipate today ~8 million solar PV modules to fail every year, corresponding to a weight of 144 kt of potential annual solar PV waste from solar PV failures only. Adding also other solar PV waste sources and streams, such as the decommissioning of solar PV modules due to end of service lifetime, repowering, insurance claims, etc., the cumulative solar PV waste is expected to reach up to 8 Mt by 2030.

Reported field experiences show that, most solar PV modules with diagnosed/classified failures that are decommissioned, follow a linear EoL management approach: they enter the waste stream and are either disposed as waste (the majority of the time) or recycled. Currently less than 10% of decommissioned modules are recycled. However, experts from the IEA PVPS Task 13 and the CIRCUSOL project estimate that 45%-65% of them, can be diverted from the disposal/recycling path, towards repair and second life solar PV (re-use) or, as aforementioned, revamping.

To ensure the technical-economical bankability of solar PV re-use and second life solar PV, within the O&M framework and the overall solar PV value chain, it is important to:

• Identify the addressable “target volume”, i.e., the failed solar PV modules (or strings), the repair of which is technically feasible, and the occurrence or distribution of such failures

• Determine the post-repair efficiency and/or post-revamping reliability of these modules

• Integrate optimal sorting-repair-reuse and logistics procedures in the current solar PV O&M value chain, embracing the circular economy business model

On this basis, we identify certain future R&D pathways and challenges to be addressed, to support the development, growth, and bankability of second life solar PV and circular solar PV O&M business:

• Industrialisation and qualification of new solar PV module designs-for-circularity: including “repair-friendly” solar PV components, modular designs, and deployment of repair technology solutions in upscaled re-manufacturing lines

• Identification and tracking solutions (e.g., RFID) at solar PV components/modules/system level, to facilitate reverse logistics, sorting/inventory of solar PV and warehouse operations

• (Automated) detection, diagnostics, and classification (incl. recommendation) of repair or re-use operations in solar PV asset management tools for solar PV plants

• Standardisation/technical specifications for on-site quality control and sorting, as well as off-site design qualification and type approval protocols, towards solar PV reuse-repurposing-recycling

• Synergies of solar PV Asset Owners and O&M service providers, with innovators in supply chain / reverse logistics technologies, also leveraging AI/machine learning aided logistics, sorting, warehouse operations, inventory management for circular solar PV economy.

B. Interface with local energy authorities & regulatory compliance

The Technical Asset Manager is responsible for ensuring that the operation of the solar PV power plant complies with the relevant regulations. Several levels of regulatory and contractual compliance have to be considered: 

• Many countries have a governing law for the operation of energy generating assets and transmission and/or distribution network organisations will likely have specific requirements to be met. This is something the O&M service provider should be aware of in any case, even if the O&M service provider and the Technical Asset Manager are separate entities 
• Requirements of Power Purchase Agreements (PPA) and Interconnection Agreements. 
• Power generation license agreements 
• Terms and conditions of corporate PPAs and stricter contractual obligations by the Owner  
• Specific regulation for the site such as building permits, environmental permits, and regulations, which can involve certain requirements and the need to cooperate with the local (or regional or national) authorities. Examples include restrictions to the vegetation management and the disposal of green waste imposed by the environmental administration body or building permits restricting working time on site or storage of utilities 

• It is the O&M service provider’s responsibility to ensure grid code compliance.
• Other issues requiring formal compliance include reporting of safety plans and incidents, historic/cultural resource protection, noise ordinances that may limit work at night, and any other regulations imposed by an authority having jurisdiction. 

As a minimum requirement the O&M agreement should list all the relevant permits, regulations and contracts that are the responsibility of Technical Asset Manager and specify that the Asset Owner makes relevant documents available to the Technical Asset Manager. 

As a best practice, all regulations, permits and stipulations should be managed within a regulatory and contractual compliance system that is consistent with the size and complexity of the solar PV power plant. This system should set out: the requirements to be met; the parameters for meeting them; and the frequency of data gathering and assessment against the requirements. This allows the Technical Asset Manager to track compliance requirements and report back to the Asset Owner or the administration bodies, demonstrating a systematic approach to ensuring compliance.