Decommissioning and Reconfiguration

During the initial planning phase of facility reconfiguration or decommissioning, facility-specific environmental and potential construction permit requirements need to be identified to ensure regulatory compliance. Ultimately, permitting work will largely focus on areas that are materially changing to enable the new permit landscape to match the new configuration, to the extent practicable. For instance, air permit conditions are likely to change significantly. Also, facility operating permits (e.g. Orders, Resource Conservation and Recovery Act [RCRA], National Pollutant Discharge Elimination System [NPDES], Land Use Permits) will contain specific language regarding notification requirements for major facility alterations or process reconfigurations that should guide planning and stakeholder communication processes (for example, documentation and timing of written notice of intent materials).

Trihydro routinely evaluates and manages industrial facility permit requirements and has regulatory experts on staff who can help ensure permitting needs are accurately accounted for during the decommissioning or reconfiguration planning process. Our experience includes a broad range of land, water, and air-related permits.

Effective regulatory management has become a key strategic need in multidisciplinary teams working on decommissioning or reconfiguration projects. Increasingly complex regulatory environments on the local, state, and national scale, coupled with complex corporate structures commonly associated with mergers and acquisitions, highlight the importance of skilled regulatory management during decommissioning or reconfiguration projects. More than just the concept of managing environmental permitting and compliance for various media and/or processes, successful regulatory management now includes the concepts of risk management, sustainability, concurrent remediation/redevelopment, and pollution prevention, among others. Trihydro recognizes that when environmental regulatory managers relegate themselves to compliance issues only, they position themselves as cost centers, rather than profit centers.

Our focus on regulatory management as a core service since 1984 enables us to assemble teams so the right expertise comes to bear at the right time on decommissioning and reconfiguration projects, ensuring team members are informed and discussing the right topics to facilitate insightful and durable outcomes in alignment with clients’ business models and goals. Trihydro has experience in large-scale decommissioning, such as preparing former refineries across the country for reuse, as well as brownfields projects in both large and small municipalities.

If market conditions result in a potential change to business operations, reusing/repurposing an existing facility may be a cost-effective alternative that provides a clear pathway for ceasing current operations and may reduce infrastructure construction, while also providing capital for the new operation construction. As part of the due diligence activities for the current business operations, it is critical to thoroughly identify current assets (materials, products, and manufacturing/distribution equipment) to identify intrinsic value and options for use in future operations or for recycling credits. For example, depending on the extent of metal and other materials in current operations, the recycled content of tanks, pipes, and other materials may cover the cost of cleaning and demolition and possibly provide additional credit for use in the overall project.

Trihydro has extensive experience evaluating current conditions, facility operations, asset inventory, and permitting of industrial facilities and serves as a strategic partner to identify potential cost savings and allow for thorough planning of potential issues in aboveground demolition.

Trihydro's project experience with subsurface demolition involves the development of property strategies, planning, regulatory compliance and permitting, identifying and mitigating the risks from common contaminants on the Resource Conservation and Recovery Act (RCRA) hazardous wastes lists, and managing nonhazardous wastes and demolition.

Additional information on our comprehensive remediation services is available here.

Post-closure care activities typically consist of groundwater monitoring and reporting, maintaining the integrity of the waste containment or leachate collection systems, maintaining the integrity of cover or surfacing, and conducting settlement surveys and facility inspections.

Trihydro has extensive experience in closure and post-closure care of impoundments including waste stabilization, permitting, installation of final cover systems, and post-closure care/monitoring and reporting. Trihydro's impoundment closure experience has been gained by working on facilities across the country, in varying regulatory environments, and with numerous different client requirements and facility waste profiles including hazardous and non-hazardous wastes.

Trihydro has assisted clients with identifying end-use goals and designing redevelopment plans for contaminated properties. Examples of contaminated properties may include former gas stations, dry cleaners, or refineries. Once the end-use goals are established for a property, Trihydro guides clients through the regulatory process to determine the level of cleanup required for the intended use. Oftentimes, a level of contamination may remain on a property that does not allow for unrestricted reuse. In these instances, Trihydro assists with implementing institutional controls, engineering controls, and/or zoning restrictions as part of the cleanup and redevelopment process. Trihydro also works with local governments and the community by leading public meetings and informational sessions to facilitate conversations regarding the restrictions and controls with the public and local leaders.

Trihydro's engineering team is well versed in requirements for pipelines and our work includes ongoing support to meet the increasingly stringent oversight of active and abandoned lines. Our team maintains strong working relationships with state and federal regulatory agencies to better support our clients’ pipeline compliance. The Trihydro engineering team also maintains familiarity with the current and changing regulatory requirements of the Pipeline and Hazardous Materials Safety Administration (PHMSA).

Trihydro has the technical expertise and ingenuity to customize waste management solutions to the client's needs. Trihydro understands there should not be a one-size-fits-all approach to waste management and considers potential waste management requirements throughout the project's life to minimize wastes, determine practical solutions, and optimize long-term cost savings.