The RMP – What does the EPA want?
The preparation of the Residuals Management Plan, a.k.a. the Closure Restoration and Aftercare Management Plan, is a requirement in the majority of IPPC and Waste Licences issued by the EPA. In summary the RMP should detail the costs associated with the closure of the activity and the returning of the site to an environmentally inert state. The EPA refers to the issues to be addressed as ‘known liabilities’. The following issues need to be planned for and costed;
- removal of waste stored on-site
- removal of raw materials stored on-site
- removal of product stored on-site
- cleaning of vessels and tanks
- removal of asbestos and other hazardous materials
- soil and/or groundwater contamination remediation
It is not necessary to return the site to greenfield status but all scenarios that may have a significant negative impact on the environment need to be dealt with.
For facilities where soil and groundwater contamination has been a know issue for a number of years, the decision to close will often trigger remediation. This is usually the largest single cost associated with a closure. If soil and/or groundwater cleanup is required then the closure is termed ‘non-clean’. Normally the IPPC/Waste licence will remain in force until the contamination is dealt with. In some cases this may take a number of years.
EPA guidance requires that a financial instrument is put in place to cover the costs identified in the RMP. This instrument could be a bond or other mechanism that allows the EPA easy access to the funds required to deal with residuals. However in practice the EPA has accepted parent company guarantees in relation to cleanup costs, especially where those guarantees are provided by large multinationals.
It is usually not possible to take out insurance to cover the costs associated with the RMP as many of the costs relate to day-to-day type activities such as the removal of wastes and the cleaning of equipment. However any soil and groundwater contamination cleanup costs may be covered depending on when the contamination occurred and the nature of the insurance cover in place for the facility.
For further information or to discuss your requirements please contact Gerard Kelly at 058-51155.