Managers at manufacturing facilities are typically, and appropriately, focused on active production and associated support activities. When economics necessitate repurposing or closure of a facility, this focus must change, and it can be a challenge for many managers to adjust to this change. Management of environmental and safety issues related to repurposing, in particular, can be a challenge. Failure to consider, or plan for these issues can trigger a cascade of events that can complicate the process and cost both time and money. Careful assessment of environmental conditions and regulatory requirements, and development of a detailed management plan early in the process can help facility managers identify, avoid, or control potential problems, resulting in more efficient and cost-effective implementation.
This presentation will outline a three phase approach that will lead to a comprehensive and coherent strategy for environmental management during repurposing and redevelopment. The key decision points at each phase of the process, and criteria that should be considered for these decisions will be identified. Ideally, the process begins, almost immediately after the decision to repurpose a facility is made, with a feasibility study that includes identification of the planned endpoint, evaluation of an approach or approaches to reach this endpoint, and preparation of a budgetary cost estimate and schedule for each approach. It is important to inventory environmental liabilities and assets affected, as well as relevant permits and regulatory requirements, and risk management parameters to help set the scope of the future facility assessment. It is also critical to understand how repurposing, or site closure could affect existing permits, require new permits, or trigger previously irrelevant regulatory requirements. During this phase, it is also important to identify critical environmental data that are incomplete or unavailable, and identify assessments required to obtain these data. Critical safety issues, particularly hazardous chemicals or facility spaces that will require special attention or greater levels of safety documentation and oversight, should also be identified. Armed with the information obtained during this phase, a preliminary approach and schedule for planning and implementation can be developed that will identify key milestones and decision points for subsequent phases. It is important to complete this initial phase as early as possible, as many environmental assessments or permitting efforts can require a long lead time.