As part of the Hazardous Material and Safety Regulatory Compliance Services that Chemical Data Management Systems (CDMS) has provided since 1988, we have been involved in many aspects of facility closures for numerous clients.
CDMS has an experienced staff that is familiar with local and State requirements for facility closure and includes resources that are properly trained and certified to conduct closure activities. Staff and resources can include:
- Registered Professional Engineer (P.E.)
- Registered Environmental Assessor (R.E.A.)
- 40 hour HAZWOPER trained resources
- Certified Industrial Hygienist (C.I.H.)
- Environmental Specialists
- Environmental Technicians
CDMS can provide assistance with specific closure activities, or can perform a full turnkey solution, where we address all aspects of closure, acting as the company interface with agencies and ensuring the closure is completed properly. The turnkey service makes it easy for a company to implement a closure with few or no employees remaining on site.
Following are some of the activities that CDMS can assist with as part of a facility closure:
CDMS can prepare facility and Tiered Permitting Treatment unit Closure plans to meet local and State requirements. This includes the initial Plan development, interfacing with agencies to discuss planned closure activities, preparing final closure reports, and providing certification of closure activities by a Professional Engineer (P.E.) registered with the State of California, as may be required by regulation.
CDMS can provide services required to decontaminate all or part of a facility to satisfy local and state requirements. This can include
- Washing down of equipment and/or facilities,
- Removal and disposal of hazardous and non-hazardous materials or debris.
- Assistance in determining the appropriate methods of decontamination or disposal. Considering regulatory requirements, economic issues, time factors, etc.
- Sampling areas to ensure that decontamination has occurred.
CDMS can conduct soil and groundwater sampling to determine if there is contamination at the site. This is often required by local agencies for sites where hazardous materials have been handled and there is a possibility of contamination.
CDMS can conduct Wipe Sampling at the facility. This is generally conducted during closure to determine the presence of contamination and/or to show that contamination has been cleaned up.
CDMS can manage part or all of the closure activities to ensure that appropriate time lines are met. Many of the closure activities rely on previous activities. Not being aware of how individual activities interrelate can cause costly delays in the closure. CDMS can assign an individual project manager that will assist in facilitating the activities related to the closure and manage other CDMS Specialists as well as outside resources.
Many permits from various environmental and safety agencies require the closure of the permits held by a closing facility. Not doing so can lead to administrative and financial hardships later.
CDMS can assist with the closing or notification required by these permits by identifying the necessary permits that need to be addressed and preparing the documentation required to terminate these permits.
Interfacing with Regulatory Agencies
CDMS can work with regulatory agencies to facilitate the closure of the facility. This can include:
- Negotiation of required activities
- Discussions of closure activities
- Identification of regulatory requirements for closure
- Meetings with the agency to discuss closure activities.
- Conducting facility visits and walk throughs with Agency representatives.
- Correspondence with agencies to document discussions.
Should a facility find that there is contamination that goes beyond surface contamination, CDMS can assist with remediation efforts including soil and groundwater contamination.
Turnkey Closure Assistance
CDMS can facilitate all aspects of the closure as a turnkey solution. Many facilities find that when a closure is needed, either staffing is greatly reduced or costly to retain for the closure period, or a facility move is creating a significant load on current employees. CDMS can come ensure that all aspects of closure are addressed, from initial contact with the local CUPA though decontamination, sampling, hauling of waste, to final closure reports.
CDMS has facilitated numerous facility closures, and understands all that is required and typical. We find that many facilities come to us after assuming closure issues would be minimal and after contacting the local agencies, realize there is are significant closure activities that must be addressed.
There are many additional activities related to the closure of facilities that CDMS can assist with. For more information, or to discuss your specific facility needs, please call CDMS’s Northern or Southern California office.
Contacting CDMS early can help companies to have a realistic time frame and budget for a facility closure. If you have a closure in your future, give us a call.
New Facility Requirements
Establishing a new facility can be a real challenge when hazardous material operations are involved. Whether a company is relocating, expanding, or starting a whole new operation, numerous agencies and their requirements, documents, permits, inspections, etc., must all be coordinated with building activities to achieve a timely completion of the project.
Some permit applications require as much as three months lead time before permits to operate will be granted. Starting the process late can seriously delay the project and cause considerable cost overruns. CDMS can coordinate and implement the hazardous material related aspects of a new facility to make sure that permits are obtained in a timely manner and the facility is in compliance when production begins.