Remediation Plan After Decommissioning of Orange

DECATECH operates a strict environmental policy. Therefore, it is firstly assumed that any shutdown of the site will be a well-planned and well-resourced event. This implies that the shutdown date will be known well in advance and that both production schedules and raw materials purchasing will be planned with the shutdown already factored in. It is not intended to remove all structures or systems from the site. In general, specialist equipment will be distributed to sister plants or sold off in the event of closure.
Resources in terms of both financial inputs and manpower to implement the decommissioning plan (DMP) through to completion, with no requirement for external financing or manpower other than for expert advice will be available. There would be utilization of existing staff resources to form a team to manage and execute the plan, supplemented where appropriate by outside resources. This Decommissioning Management Team would be responsible for managing and executing the complete plan. Outside contractors required for cleaning, waste disposal, incineration or recycling activities would be fully approved and licensed. A qualified third party will be given access to the plan in the event that DECATECH are not in a position to carry out the plan due to a sudden unforeseen closure. It is estimated that the duration of decommissioning and decontamination would be 3 to 6 months. Environmental monitoring would continue while the plan is in operation. The objective of the plan is to ensure that, upon completion of the plan, the facility would be in a suitable state for future industrial use and its condition would not pose a risk to public health and safety or the environment.

Closure Considerations

 

  1. General: DECATECH has a prescribed Decommissioning Guide to be adhered to in the event of planned or unplanned closure or divestiture of the site.
  2. Clean or Non-Clean Closure Declaration: Upon cessation of operations and subsequent decommissioning at the facility, it is anticipated that there will be no remaining environmental liabilities, i.e. clean closure is expected.
  3. Plant or Equipment Decontamination Requirements: All plant and equipment will be decontaminated to ensure the removal of any hazardous materials. Equipment will be verified either analytically or through a visual inspection, as appropriate.
  4. Plant Disposal or Recovery Plant: They may be removed for use at other locations, left in place as part of the asset to be disposed of, or scrapped, based on risk assessment and cost benefit analysis. Utility plant will be left with the asset, as mothballed equipment or ready-to–operate, depending on the best economic option.
  5. Waste Disposal or Recovery: All wastes, both non-hazardous and hazardous, will be sent for appropriate recycling, recovery, treatment or disposal, as per the conditions of the Industrial Emissions License.
  6. Soil Removal: The facility is not obliged under its license to conduct regular soil monitoring, as the processes conducted on site have little potential for the contamination of soil. Under Vistakon’s current Industrial Emissions Licence, annual monitoring of groundwater takes place and this will indicate if any contamination of soil has occurred or if testing is required

Production Areas


The DMP for all production areas will consist of the following actions:

  • Cessation of all production other than completion of work in progress in the event of a planned closure.
  • All products will be sent for suitable re-use, recovery, treatment or disposal. Any hazardous waste arising from the plant and utilities areas will be removed from site by an authorized haulier and disposed of to a suitably licensed facility
  • Cleaning and decontamination of all equipment which has had contact with hazardous materials. Existing site cleaning procedures would be sufficient for these operations. Additional specific procedures would be developed, if required. The state of cleanliness would be verified either analytically or through a visual inspection, as appropriate.
  • Cleaning and decontamination of any ducting or enclosure that would have hazardous material contact.
  • Shutting off unnecessary services to the building. Heating and ventilation capability would be maintained.
  • Maintenance of key instrumentation and computer systems required for on-going monitoring of the status of the equipment; the remaining instrumentation to be disconnected and rendered safe.
  • Cleaning and decontamination of all floor drains and sumps.
  • All remaining specialized equipment will be sent for suitable re-use or sold to an interested party. Obsolete equipment will be recycled where possible or otherwise disposed of by a licensed contractor

Utilities/Chemical Stores


The DMP for the utilities areas would consist of shutting down the following systems on a phased basis, depending on plant status and requirements:

  • Removal of any associated chemicals, oils or any other materials used in the utilities/staging area for redistribution, return to vendor or disposal, if required, according to best practice.
  • The firewater pump house/water room including the water supply system would be maintained due to the needs for fire protection and sanitary services
  • Waste Water Treatment Facility
  • All trade wastewater that need to be treated prior to discharge under the current licence will be treated as normal. The DMP includes:
  • Cleaning and decontamination of the tanks
  • Removal of any associated chemicals, oils or any other materials used in the utilities/staging area for redistribution, return to vendor or disposal, if required, according to best practice.
  • Dismantling of equipment and general cleaning and maintenance.
  • Maintenance and Engineering
  • All engineering documentation including drawings, process and instrumentation diagrams, validation documentation, vendor manuals and data, project files, maintenance records, inspection records and all other appropriate documentation will be securely archived.
  • All remaining equipment will be disconnected to leave in a secure state. Equipment will be sent for suitable re-use or sold to an interested party. Obsolete equipment will be recycled where possible, otherwise disposed of by a licensed contractor.

Offices, Administration, Reception


The DMP for the offices, administration areas, and reception would involve the removal of administration equipment for reuse or sale to interested party, where possible, otherwise for disposal by a licensed contractor.

Laboratory Areas


The DMP for laboratory areas would consist of the following actions:

  • Completion of all necessary analytical work on production in progress and all final products before removal from site.
  • Return to vendor or sell on all unopened and in-date laboratory chemicals
  • Removal of all opened chemical containers and out-of-date chemicals for recycling or for disposal by a licensed contractor.
  • Cleaning and decontamination of laboratory instruments
  • Cleaning and decontamination of all glassware, storage areas, waste systems and any other equipment or systems.
  • Shutting down of all computer systems other than those deemed necessary for ongoing monitoring of the area.
  • All remaining specialised equipment will be sent for suitable re-use or sold to an interested party. Obsolete equipment will be recycled where possible, otherwise disposed of by a licensed contractor.

Canteen and Kitchen


Canteen equipment would be removed for reuse or sale to an interested party, where possible, otherwise it would be disposed of by a licensed contractor.
Warehouse
The DMP for the stores warehouse would consist of the following actions:

  • Cancellation of all orders for incoming materials to the site
  • Negotiation with other plants with a view to distribution of unused materials
  • Negotiation with relevant suppliers to return unused materials to supplier
  • Dispatch of opened containers and non-returnable or out-of-date goods for appropriate treatment or disposal
  • Cleaning and decontamination of the storage areas.

Other Areas


The following other actions would be required to ensure the implementation of the DMP on a site-wide basis

  • Cessation of any construction project work on site so that the site is left in a safe and orderly condition. Contractors will be required to decommission any construction compounds and remove all construction equipment, construction materials and waste, storage units and temporary offices from the site at the completion of construction projects.
  • Disbandment of contract personnel, facilities and equipment.
  • Termination of all non-essential maintenance and other contracts.
  • Removal from site any temporary offices or storage areas.
  • Continuation of on-going monitoring programmes to ensure the integrity of the groundwater and surface waters on site.
  • Rationalization of the site electricity supply. This would involve removing transformers from service, allowing remaining site operations to run from one transformer. Oils would be removed from redundant transformers.
  • Testing of soils and groundwater at the time of decommissioning would be performed and remediation carried out, if necessary. Groundwater wells on-site shall be capped and locked off.
  • Retention of all necessary fire alarms and fire protection systems.
  • Retention of standard security patrols, CCTV monitoring and defined site access procedures.
  • Removal of all items that may contain mercury (for example fluorescent lights) or any other controlled compounds for recycling or disposal if necessary.
  • Drainage area will be emptied and cleaned following the completion of cleaning and decommission of the areas they serve. The drains and sumps will be surveyed. The sumps will then be filled with inert material (if not longer needed) and sealed to prevent unauthorized access. The silt traps will be cleaned out and the contents disposed of as per the licence. 
  • The boilers onsite will be decommissioned in accordance with good engineering practice and the manufacturer’s recommendations. It will be prepared for ‘dry storage’ or removal

Remediation


This involves the investigation and cleanup of hazardous materials to meet federal or state requirements. It also includes defining site-specific needs for redevelopment. The site owner is responsible for ensuring that the cleanup meets all regulatory requirements and works closely with stakeholders, environmental consultants and state environmental agencies to develop and execute the remediation plan. The cost and extent of the cleanup will depend on the anticipated reuse of the site and the type and location of hazardous materials stored or disposed on the property. For example, if industrial use is planned, the cleanup requirements may be less stringent than what is required for residential use, because the likelihood of direct or prolong human exposure to contaminants will be lower.
Remediation starts with collecting soil and ground water samples to investigate and document any contamination. Next, a plan for cleanup is developed and, once approved by state regulators, implemented at most sites, the public is invited to comment on the cleanup plan that is proposed by the state environmental agency, who is responsible for reviewing and approving the plan. Occasionally, low levels of contamination may be left in places. In such cases, future site activities and uses may be restricted. Any restrictions on the future use of the property (due to contamination being left onsite) is documented in legal notices (e.g., land use restrictions and institutional controls that often are filed with or attached to property titles and deeds).

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