Environmental Regulations for Plant Decommissioning

LPG Ventures has experience with complete site dismantling projects.  However, this process can be quite complex having to adhere to many laws and regulations for proper decommissioning of a plant.  Regulations concerning environmental remediation, equipment dismantlement and demolition must be strictly followed to avoid costly violations and fines.

Environmental regulations are numerous and important to follow to protect our land, people and the future. Propane-air plants have a host of environmentally sensitive chemicals that pose risks to human health. These include ethylene glycol, lead-based paint, asbestos, and mercury. Environmental incidents are more likely to occur in the decommissioning process, especially where tanks must be excavated. Underground tanks of older vintage almost always have asbestos and/or lead paint in the tank coatings which can be scraped or come loose in the excavation process, contaminating soil and groundwater. Mercury switches must also be carefully dismantled and disposed of in accordance with stringent regulations.

Plant decommissioning must also be done in accordance with the National Emissions Standards for Hazardous Air Pollutants (NESHAP) and the National Ambient Air Quality Standards (NAAQS). NESHAP governs air pollutants not covered by NAAQS that the EPA has found may cause an increase in fatalities or in serious, irreversible or incapacitating illness. The standards for a particular source category require the maximum degree of emission reduction that EPA determines to be achievable, which is commonly known as the Maximum Achievable Control Technology (MACT).

Asbestos and ethylene glycol, commonly found in propane-air plants, are regulated by the EPA as hazardous air pollutants under the MACT standards. NAAQS apply to outdoor air throughout the country. Primary standards are designed to protect human health, with an adequate margin of safety and are targeted toward sensitive populations such as children, the elderly, and individuals suffering from respiratory disease. Secondary standards are designed to protect the public welfare from known or anticipated adverse effects of a particular pollutant and are targeted toward building facades, visibility, crops and domestic animals. Lead, sometimes found in tank coatings, is regulated under both NAAQS primary and secondary standards. Decommissioning a plant in some cases should also be done with an eye toward CERCLA22 compliance.

LPG Ventures performs storage tank excavation and removal, decommissioning of plants, tank transportation and other services with the expertise and experience to adhere to all environmental rules and regulations.

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