This is a guest post by Matt Schroeder, Senior Environmental Engineer, Dragun Corporation (Environmental Advisors).
Several years ago, we saw many manufacturing plants closing their doors – permanently. We had the unfortunate experience of helping some of our clients close down and decommission manufacturing plants.
In recent years, the fortunes of many manufacturers have changed rather dramatically. In fact, business is so good for some of our manufacturing clients that they are outgrowing their buildings. In response to business growth, many manufacturers are closing down or modernizing older, outdated facilities.
And so, for different reasons, we find that site closure activities are in the forefront again. An issue complicating any closure or decommissioning is changing environmental regulations. In some cases, the regulations have changed rather drastically over the life of the plants. For example, vapor intrusion (VI) wasn’t even a consideration until relatively recently. And, if your plant is going to be repurposed, you will need to consider environmental issues such as VI as you develop your plans.
With this said, here is an updated version of an article I wrote in 2010 on 15 Essential Environmental Considerations for Site Closure Activity.
- What is the planned use of the property after closure? Will the property be sold, donated, or redeveloped? Are the structures going to be reused, mothballed, or demolished? Starting with the end in mind will help you strategize appropriately.
- Develop a list of all environmental permits and plans (air, water, wastewater, hazardous waste). These permits will have to be closed out with local, state, and/or federal agencies.
- Conduct a hazardous materials survey and removal. Industrial facilities often have hazardous materials, as well as hazardous waste-disposal obligations. The handling and disposal of these materials and wastes are regulated by state and federal environmental regulations. These materials can include asbestos, lead, mercury, PCBs, refrigerants, etc… Some of the potential sources include building materials, paint, switches, lights, ballasts, batteries, transformers, and cooling systems. A thorough inventory makes for a more efficient removal and fewer surprises during the demolition process.
- Inventory current and historic aboveground storage tanks (ASTs) and underground storage tanks (USTs). This may require some investigation of historical documents and blue prints. It can also be beneficial to interview senior employees with regard to chemical and waste storage activity.
- Are there any current or historical Resource Conservation and Recovery Act (RCRA) permitted storage areas? These require special attention and have very specific closure requirements, and “mixing” debris from a RCRA permitting area with other general debris can be a very costly error.
- Are there press pits and process tanks associated with the current machinery? Their structural integrity should be evaluated and the contents removed for recycling or disposal.
- Is there a wastewater treatment plant associated with the facility? If so, there may be treatment chemicals to consider (possibly returned to the manufacturer) and permits to consider. The integrity of the treatment tanks and chemical storage containers should also be evaluated.
- Transformers are often owned by a utility. If owned by the facility, these should be inspected and possibly drained. Fluids should be tested for PCBs unless a record of prior testing and certification is available.
- Is there air discharge abatement equipment on the property? If there are contaminated media or bag houses, make sure they are properly disposed.
- Other wastes or raw products stored in various locations can be problematic if they are not considered during the initial inventory. Look for satellite storage areas and cabinets used to store solvents, paints, and other chemicals.
- How will you handle abandoning storm and sanitary sewers? Are there local ordinances to be considered? How will you protect the local sewer system from illicit discharges, both during the decommissioning and after you have vacated the property?
- What level of security will be appropriate for the property? Will you need fencing, lighting, locks, and protection on windows? Security measures could be intended to protect against vandalism, theft, or exposure of third parties to any hazardous conditions remaining on the property.
- Whether you are going to prepare the building for sale or you raze the facility, you need to consider how you will handle the subsequent spoils. If you are preparing for future sale, how will you handle wash water and sludge? If demolishing, how will you handle the debris? It is important to know how you are going to answer these questions long before you begin.
- Is environmental remediation required under existing regulations? If not, does investigation and/or remediation make the property more marketable? What are the cost benefits of physically remediating the impacted areas verses restricting future uses at the property?
- Finally, when do you want to notify regulators? Is there a notification requirement in an existing agreement with an agency? Notifying regulators up front may slow the process – in some cases it may be better to bring regulators into the picture once you are underway.
These are just some of the many considerations for facility closures. Bringing together the right team will make the process considerably smoother, more cost effective, and, hopefully, allow you to move the property more quickly to reuse or sell it.
The original article can be found on Dragun Corporation's website here.