Planning a plant closure properly — the complete guide

A plant closure in an industrial context is subject to a dense web of federal and Land legislation. Operators are obliged to notify the competent immission control authority of the dismantling, or to obtain its approval — depending on the type of plant and the underlying permit. For plants subject to the Federal Immission Control Act (BImSchG), a formal notification of decommissioning under § 15 BImSchG is required at least one month before operations cease.

• Notification of decommissioning under § 15 BImSchG to the competent authority
• Review of the aftercare obligations under § 5 (3) BImSchG
• Obligation to dismantle under the operating permit and building regulations law
• Contaminated land obligations under the Federal Soil Protection Act (BBodSchG)
• Employment law obligations: social compensation plan, notification of collective redundancies to the Federal Employment Agency

The schedule for a plant closure does not begin with the first demolition excavator, but with the strategic decision to close the site. For medium-sized industrial sites, 12 to 24 months typically elapse between the decision and a development-ready site — and considerably longer for contaminated sites. A realistic schedule takes account of permitting procedures, hazardous-substance investigations, tendering and the operational dismantling phase.

• Months 1–3: strategic decision, site survey, commissioning the hazardous-substance survey report
• Months 3–6: permitting procedure, disposal concept, tendering of the dismantling works
• Months 6–9: hazardous-substance remediation, soft strip-out, disassembly of technical equipment
• Months 9–15: demolition of the building structure, disposal, soil remediation
• Months 15–18: final sampling, documentation, handover of the development-ready site

A plant closure affects numerous stakeholders, all of whom have to be involved. Structured stakeholder management prevents blockages and creates the conditions for a smooth process. Involving all parties at an early stage — from the workforce and the authorities through to neighbouring municipalities — is decisive for the success of the project.

• Senior management: strategic decision, budget approval, communication strategy
• Works council and workforce: social compensation plan, transfer company, information obligations
• Permitting authorities: immission control, building inspectorate, environmental authority
• Waste management contractors and remediation firms: hazardous-substance register, disposal routes, record-keeping
• Neighbouring municipalities and local residents: information on noise, dust and traffic
• Insurers: dismantling insurance, environmental liability, contaminated land cover

Operational dismantling is divided into clearly defined phases that build on one another. Each phase has its own requirements in terms of personnel, equipment, permits and documentation. The sequence is prescribed both technically and legally: hazardous-substance remediation before demolition, soft strip-out before building demolition, soil investigation before handover.

• Phase 1 — site survey: building register, hazardous-substance survey report (asbestos, MMMF (man-made mineral fibres), PAH, PCB, heavy metals), assessment of the building fabric
• Phase 2 — hazardous-substance remediation: professional removal of all hazardous substances in accordance with TRGS 519, TRGS 521 and the GefStoffV
• Phase 3 — soft strip-out and disassembly: removal of technical equipment, operating equipment and installations
• Phase 4 — selective demolition: controlled demolition of the building structure, separation of the material streams
• Phase 5 — disposal and recovery: material classification, maximising the recovery rate, record-keeping
• Phase 6 — soil remediation and handover: decontamination, final sampling, development-ready site

The cost of a plant closure is made up of numerous individual items and varies considerably depending on the size of the site, the degree of contamination and regional disposal prices. A robust cost estimate requires a qualified site survey — lump-sum quotations produced without knowledge of the site are generally unreliable.

• Hazardous-substance investigation and survey reports: depends on the number of buildings and their year of construction
• Hazardous-substance remediation: the largest single item at contaminated sites
• Demolition and disposal: depends on building volume and material composition
• Soil remediation: highly site-dependent, and considerable where groundwater damage has occurred
• Planning, site management and documentation: typically 8–12 % of the total cost
• Provisions: allow for the unforeseen (contamination, structural problems)

Complete documentation is not optional in industrial dismantling; it is mandatory. It protects the client legally, provides evidence of proper disposal and forms the basis for a subsequent declaration of exemption from contaminated land liability. Without complete documentation there is a risk of liability extending well beyond the end of the project.

• Hazardous-substance register and remediation reports with clearance measurement records
• Disposal records: consignment notes, acceptance notes, weighbridge tickets
• Photographic documentation of all dismantling phases (georeferenced and dated)
• Final report with mass balances and recovery rates
• Soil investigation reports and groundwater monitoring results
• Handover record with site documentation and clearance for use