Energy Transitions: Re-Powering Retired Coal Sites with Carbon-Free Nuclear Generation


June 14, 2022

Now, more than ever, energy industry participants are seeking creative pathways to minimize the cost and schedule for deployments of carbon-free electric generation facilities. Enter the latest trend: coal-to-nuclear transitions.

Electricity Supply and Demand: Carbon Matters

If you follow the energy industry, you probably know that nearly 1,000 coal plants have been retired over the last two decades—a trend that is expected to continue in the foreseeable future. The driving force behind these retirements is the push toward decarbonizing the electric grid, with sustained momentum from a combination of government action (e.g., clean energy targets), corporate pronouncements (think: environmental, social, and governance), and consumer preferences for carbon-free electricity. Meanwhile, projections for electricity demand are ever increasing, propelled by various factors such as the rising popularity of electric vehicles, which will move transportation-based energy demands “on grid.”

As a general matter, nuclear power plants are the only carbon-free source of baseload electricity. Not your father’s nuclear plants, the latest generation of nuclear power plant designs are smaller, modular, and less capital-intensive than the existing large light-water fleet, making them attractive investment options.

In contrast, solar and wind generation are intermittent sources—they only generate electricity when the sun shines or the wind blows. And recent studies have shown that the costs of pairing renewable generation with significant battery storage can make such projects financially unworkable.

To meet modern electric supply and demand trends, today’s project sponsors are directing significant investments to deployments of new nuclear facilities and other ventures that include a combination of nuclear and solar/wind facilities. But, for any capital-intensive project, cost and schedule are everything. So, developers are considering how they can minimize the scope and complexity of required regulatory and environmental reviews, reduce the litigation risk profile for projects, and mitigate the possibility that environmental matters become a critical path.

Possible Benefits of Repurposing Retired Coal Sites

In recent years, one approach for deployment of new carbon-free electric generating assets is gaining significant attention in the marketplace: repurposing retired coal sites.

As a general matter, bipartisan federal and state support for this approach continues to grow. For example, the State of Wyoming recently passed legislation to enable a de-powered coal site to be used for the deployment of a new advanced reactor.

Part of the political impetus for this support is the devastation to the local economy that otherwise might occur from the closure of a large coal-fired power plant. By reusing the coal plant site and retaining the coal plant workforce, closure impacts can be minimized, and the community can retain local tax contributions and symbiotic economic ties for decades to come.

For these same reasons, the local community may be more welcoming of a new nuclear project. In other words, the “Not in my back yard” project detractors of old may be replaced by a new generation of project supporters: “Please, in my back yard!”

A recent report prepared by an energy consulting firm explores the role of small modular reactors in reenergizing communities after a coal plant closes. The authors note that nuclear facilities may be a “drop-in replacement” due to the similar profile of the facilities and their ability to leverage an existing craft workforce.

In addition to community support, there are many other reasons why deploying new nuclear generation assets at de-powered coal sites may yield cost and schedule benefits.

  • First, it may be possible to demonstrate a net positive environmental benefit. This outcome could ease the way for National Environmental Policy Act (NEPA) reviews and other federal, state, and local approvals. At a minimum, replacing a carbon-emitting coal plant with a carbon-free nuclear energy source provides a beneficial environmental narrative.
  • Second, it may be possible to leverage existing environmental site characterizations and “need for power” analyses to streamline environmental and other regulatory reviews. To be sure, the availability of high-quality records may vary from site to site. But, any cost or schedule advantage that such records can provide is value added.
  • Third, existing high-voltage electrical transmission lines and switchyards can preclude the need for greenfield construction of a transmission and distribution system and avoid the additional costs and regulatory and environmental approvals associated therewith. This benefit, alone, makes de-powered coal sites an attractive siting option for developers.
  • Fourth, it may be possible to transfer existing environmental permits from the previous coal facility to the new nuclear facility, which could prove beneficial from a schedule standpoint. Outstanding state permits have caused significant delays in past energy infrastructure projects.


To be sure, coal sites also may present some unique environmental considerations. These are brownfield sites, after all, and there is a possibility of existing contamination—raising questions of liability, indemnity, and other possible complications that must be carefully considered if a property transfer is contemplated (as opposed to a current owner repurposing its own site).

But, as global demand for carbon-free baseload electricity increases, and the trend of coal plant retirements continues, the political, economic, and environmental benefits of coal-to-nuclear transitions may prove an attractive option for technology vendors, utilities, investors, developers, and other project sponsors.