What Goes Into a Facility Closure Plan: A Section-by-Section Look
A California facility closure plan is not a short letter. The template our team has built and refined over decades of California closures runs through ten distinct sections.
A California facility closure plan is not a short letter. The template our team has built and refined over decades of California closures runs through ten distinct sections. Each one answers a question your local CUPA (Certified Unified Program Agency, which may be a county environmental health department, fire department, or another local agency depending on jurisdiction) will ask before it allows any regulated closure activity to start on site. This piece walks each section, what the agency expects to see in it, and where facilities most often fall short.
If you are still working out whether a closure plan is the right document for your situation, start with our California facility closure plan process guide and the closure plan vs. closure report comparison. For the broader context of opening, transferring, and closing a hazardous materials facility in California, see our facility changes guide.
Why the Structure Matters
California closure plans are reviewed against the framework in California Code of Regulations Title 22 (the state hazardous waste regulations) and the California Health and Safety Code. The exact format your CUPA prefers can vary, but the substance is the same wherever you are in the state: identify what is on site, describe how it will be removed and the space decontaminated, prove the work with sampling, and document it in a way another agency could pick up and follow.
The Ten Sections of a California Closure Plan
| # | Section | What it answers |
|---|---|---|
| 1 | Facility Description | What and where is the site? |
| 2 | Hazardous Materials Inventory | What is on site, where, and in what form? |
| 3 | Health and Safety Plan | How will closure crews stay safe? |
| 4 | Closure Procedure | How will materials, equipment, and surfaces be handled? |
| 5 | Sampling Plan | How will you prove the work was effective? |
| 6 | Proposed Closure Schedule | When does each phase happen? |
| 7 | Contractors | Who is doing the work, and are they qualified? |
| 8 | Agency Coordination | Which other agencies are in the loop? |
| 9 | Certifications | Who is signing off, and with what credentials? |
| 10 | Notification Letters | Who has been notified, and when? |
Facility Description
Location, current use, site history, square footage, and a labeled building layout. The agency uses this section to understand what kind of operation it is reviewing and what the next occupant is likely to be. Site history matters because prior operations point to areas with potential historical contamination that the sampling plan will need to cover.
Hazardous Materials Inventory
Every hazardous material currently on site, the area where it is used or stored, typical quantity, and physical form. This is not the HMBP inventory by itself. The closure version groups chemicals by physical location and process so the closure procedure and sampling plan can reference exact areas. Special items get called out here because they change scope: radiation sources, underground storage tanks, perchloric acid hoods, azides, mercury use, and any prior release locations. Missing one is the difference between a clean closure and a deficiency notice.
Health and Safety Plan
An organizational chart for the closure project, hazard analysis of each closure task, PPE selection, emergency response procedures, and air monitoring requirements during decontamination. Cal/OSHA and the CUPA will both expect this section. Where lead, mercury, or biological agents are in play, the HASP gets longer and more specific. A generic HASP is a flag to inspectors.
Closure Procedure
The core section. It describes, in order: how chemicals will be removed from the site, how containers and equipment will be decontaminated or disposed of, how building surfaces (floors, walls, sumps, secondary containment) will be cleaned, how decontamination wastewater and process wastewater will be managed, and how the work will be logged daily. The procedure has to match the sampling plan. Every surface or piece of equipment named here needs to appear in the sampling locations.
Sampling Plan
The verification half of the plan. Includes sample locations on a site map, sample types (wipe, chip, and core samples are common in California closure work), the accredited lab, chain-of-custody protocol, analytical methods, and the acceptance criteria agreed with the agency. Typical field screening includes oxidizer test strips, pH, and VOC monitoring. Specialty sampling (mercury vapor, perchlorate, heavy metals, radiation) follows from what was in the inventory.
Proposed Closure Schedule
A working timeline showing when each phase begins and ends, with milestones for plan submittal, agency approval, decontamination, sampling, lab turnaround, and the final inspection. California closures generally take at least three months from plan submittal to closure confirmation, with CUPA review the largest variable. The schedule has to leave the agency notification window intact (most CUPAs require a minimum of 30 days’ notice before regulated closure activities can start) and account for any pre-closure inspection the agency wants to run.
Contractors
The people and firms doing the work, their licenses and certifications, and their scope. Reviewers check that decontamination is performed by qualified personnel trained for the specific hazards and tasks involved (which may include HAZWOPER (Hazardous Waste Operations and Emergency Response) training under Cal/OSHA requirements, along with task-specific PPE, respiratory protection, and hazard communication training), not by general janitorial staff, and that the hazardous waste hauler is California-registered. Standard janitorial cleaning of hazardous-materials surfaces is one of the most common pitfalls flagged in California CUPA enforcement. The contractor section is where the agency confirms that gap is not present.
Coordination with Other Agencies
Closures rarely involve only the CUPA. Notification letters and parallel actions are typically needed for DTSC, the Department of Toxic Substances Control (for hazardous waste and any permitted treatment unit), the Regional Water Quality Control Board (for industrial wastewater and stormwater), the local Air District (for permitted equipment and exhausts), and Cal/OSHA (for closure-crew safety). This section lists which agencies are involved, the contact at each, and what document each one is getting.
Certifications
Who is signing the plan as accurate and complete. For most CUPA facility closures, the certification is signed by an authorized facility representative. For closures involving a permitted treatment unit (Conditionally Authorized, Permit-by-Rule, and similar DTSC-administered tiers), a California-registered Professional Engineer certifies the plan and, later, the closure report.
Notification Letters
The actual letters sent to landlords, building owners, agencies, and any other party with a stake in the closure. The letters become part of the project record. CUPAs and downstream landlord audits both check that the notifications went out on time and reached the right contacts.
How the Plan Changes by Facility Type
The structure stays the same. What changes is what fills each section. A biomedical research lab closure leans heavily on Section 3 (biological agents, BSL-level controls) and Section 5 (wipe sampling for chemical and biological contaminants). A chemical or manufacturing closure usually has a heavier Section 2 (high-volume solvents, acids, heavy metals) and adds Jerome-meter mercury vapor and perchlorate sampling in Section 5. An automotive shop closure focuses on used oil, parts-washer residues, and concrete-floor sampling. The agency expects the plan to look like the site.
How Inspectors Read the Plan
When we walk a closure with the CUPA in advance, the reviewer reads the sections in pairs. Section 2 (inventory) is checked against Section 4 (procedure) and Section 5 (sampling) to confirm every material is removed, every surface is cleaned, and every cleaned surface is verified. Section 4 is read against Section 7 (contractors) to confirm the work is being done by qualified people. Section 6 is checked against Section 10 to confirm the agencies have enough notice. A plan that holds together across those pairs is the one that gets approved on the first pass. For more on what inspectors look for during closure itself, see what CUPA looks for at facility closure.
Section 4: Closure Procedure
Section 5: Sampling Plan
Section 7: Contractors
Section 10: Notification Letters
We have written closure plans for California labs, manufacturers, and chemical handlers since 1988. We come to your facility, walk the site, build the inventory section against the floor (not the HMBP), and write the plan in the format your specific CUPA prefers. We then run the field work, sampling, and closure report under one team and one schedule.
Scoping the work before you commit? What drives the cost and scope of a facility closure →
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
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