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New Facility, Ownership change & Facility Closures


New Facility, Ownership change & Facility Closures

Opening or closing a facility that handles hazardous materials in California requires navigating complex EH&S regulations and permitting. For closures, requirements like hazardous waste tank cleanouts, permit terminations, and submitting closure plans to agencies are mandatory. When opening a new facility, permits and compliance need coordination starting 6+ months in advance to avoid delays.

CDMS has deep expertise guiding companies through these transitional stages successfully. For closures, we develop and execute plans meeting Department of Toxic Substance Control (DTSC), Water Board, and local agency mandates. For new facilities, CDMS identifies and secures all necessary permits on schedule so you open compliant and on time. We also conduct baseline compliance assessments when ownership changes to identify risks and liabilities.

Trust CDMS to manage the EH&S requirements for your new, closing, or transferred facilities. Our team knows these processes inside and out.

Regulatory bodies
  • Department of Toxic Substances Control (DTSC)
  • Regional Water Quality Control Boards (RWQCB)
  • Local CUPAs (Certified Unified Program Agencies)
  • Local Air Districts
  • California Occupational Safety & Health Association (Cal/OSHA)
  • Local Fire Departments
Who needs it

Facility Closures

Closing a facility that has used hazardous materials can require many regulatory actions. If a facility was required to have a Hazardous Material Business Plan, some regulatory closure action is usually required to ensure agencies that the closure is done properly. For facilities that have waste treatment systems, stormwater permits, etc., the requirements can be more extensive.

Permit Closures

Many permits from various environmental and safety agencies require the closure of the permits held by a closing facility.

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.

Regulation reference
  • Hazardous Waste Control Law
  • Title 22, Div 4.5
  • Title 27, Div 1, Subdiv 4
  • California Health & Safety Code 25100-25258
  • Conditional Use Permits
  • Fire Codes
  • OSHA Standards
What our service provides:

Closure Plans

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 (PE) registered with the State of California, as may be required by regulation.



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.


Permit Closures

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.


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 are significant closure activities that must be addressed.

There are many additional activities related to the closure of facilities that CDMS can assist with.


New Facility Requirements

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.

Request a Free EHS Compliance Assessment

Contact us

What EH&S permits are needed when opening a new facility?
Waste generator, air quality, hazardous materials handling, stormwater, wastewater, and local land use permits are common.

When should I start the permitting process for a new facility?
Begin engaging regulatory agencies 6+ months prior to planned opening to account for review times.

What agencies require notification when closing a facility?
Department of Toxic Substances Control (DTSC), Regional Water Quality Control Boards (RWQCB), Local CUPAs (Certified Unified Program Agencies), California Occupational Safety & Health Association (Cal/OSHA), Local Air Districts, Local Fire Departments at minimum.

What are requirements for closing hazardous waste tanks?
Tanks must be emptied, cleaned, and certified closed by a qualified inspector.

Do I need to sample for contamination when closing a facility?
Environmental sampling is often required to verify no release or to determine any needed remediation.

How long are records from facility closures retained?
Minimum 3 years, but longer retention periods may apply.

Can permits be transferred to a new owner without modification?
Some permits can be directly transferred, while others may require renewal.

What EH&S documents should I review when acquiring a facility?
Permits, compliance records, inspection reports, release records, monitoring data, etc.

Are facility closure plans approved by regulators?
Yes, Department of Toxic Substances Control (DTSC) and local agencies review and approve closure plans in most cases.

Can hazardous waste be stored onsite during facility closure?
Yes, but storage time limits apply. Tanks/containers must be closed prior to full facility closure.

Are air permits still valid after a facility changes ownership?
Air permit updates are typically needed within 30 days of ownership transfer.

What are the consequences for closing a facility improperly?
Regulatory enforcement, fines, delays reopening a contaminated site.

How long does full permitting for a new facility usually take?
From 6 months to over 1 year depending on complexity and agency review times.

When are local land use permits needed?
Land use approval is required when opening facilities in many jurisdictions.

Should I consult with the local fire department when opening/closing?
Yes, the fire department often has hazardous materials oversight roles.

What types of sampling are required during closure?
Soil, groundwater, surface water, waste characterization, and wipe sampling are common.

Can I self-certify cleanup of hazardous materials during closure?
No, an independent state-licensed professional must verify satisfactory cleanup. Please Contact Us to get support or request New Facility, Ownership change & Facility Closures. Our skilled team of EH&S specialists is ready to assist you.

Do facility closures require public notices?
Yes, public notices in newspapers or mailings are sometimes legally required.

What EH&S records should I maintain from ownership changes?
Documentation of updated permits, correspondence with agencies, prior ownership records.

How can consultants help with my new facility or closure?
By managing EH&S documentation, sampling, permitting, regulations compliance from start to finish. Contact Us to get support or request a facility assessment. Let CDMS manage the EH&S requirements for your new, closing, or transferred facilities. Our team has deep expertise guiding companies through these transitional stages successfully.