Understanding Closure Restoration and Aftercare Management Plans (CRAMPs) for Environmental Liabilities

Closure Restoration and Aftercare Management Plans (CRAMPs) are vital in determining and addressing environmental liabilities associated with the closure and decommissioning of facilities. These plans provide a comprehensive framework for costed mitigation and monitoring measures post closure, ensuring responsible environmental management. In this blog post, we will explore the key components of CRAMPs and shed light on the expertise of ORS and BMJ in completing CRAMPs for clients across various industries and sectors.

Components of a CRAMP: When preparing CRAMP reports, ORS and BMJ consider several essential factors to ensure thorough and accurate assessments.

The following components are integral to a comprehensive CRAMP:

Identification and Characterization of Known Environmental Liabilities:

Thorough identification and characterization of existing environmental liabilities are crucial to understanding the potential risks associated with facility closure. This step involves assessing contamination, waste management issues, and other environmental concerns.

Site Evaluation and Conceptual Site Model:

A site evaluation helps understand the specific environmental factors and risks associated with the facility’s location. It includes the preparation of a conceptual site model, which provides a visual representation of the site and its potential environmental impacts.

Inventory of Raw Materials, Products, and Wastes:

A detailed inventory of raw materials, products, and wastes at the facility allows for a comprehensive understanding of the potential environmental liabilities that may arise during closure. This inventory helps estimate the scope of work required for mitigation and restoration.

Closure and Restoration/Aftercare Tasks and Programme:

The closure phase encompasses short-term measures required to effectively shut down the facility, including decommissioning and residual management. Restoration and aftercare measures refer to long-term activities that address environmental liabilities that persist after closure, such as rehabilitation, remediation, ongoing emissions control, and monitoring.

Criteria for Successful Closure:

Establishing clear criteria for successful closure ensures that all necessary measures have been taken to address environmental liabilities and achieve compliance with regulatory requirements. These criteria act as benchmarks for determining when a facility can be considered satisfactorily closed.

Estimation of Financial Provision Required:

Financial provision refers to establishing a financial instrument, such as insurance, bonds, guarantees, or funds, to cover the costs associated with closure, restoration/aftercare, or any potential incidents. Accurate estimation of the financial provision required ensures adequate resources are available to address environmental liabilities effectively.

The Role of ORS and BMJ:

ORS, in partnership with BMJ, has extensive experience completing CRAMPs for clients in various industries and sectors. By leveraging their expertise, they help clients navigate the complexities of environmental liability and financial provision requirements. ORS and BMJ’s collaboration ensures that all aspects of a CRAMP are thoroughly addressed, from identifying and characterizing environmental liabilities to estimating financial provisions required for closure and restoration.

The EPA’s Risk-Based Approach:

The Environmental Protection Agency (EPA) applies a risk-based approach to environmental liability and financial provision requirements. This means that only licensed facilities that pose a high risk to the environment are obligated to assess and cost environmental liabilities and financial provisions. The EPA has published guidance on CRAMPs, Environmental Liability Risk Assessments (ELRAs), and Financial Provision to provide clear directives for facilities falling under this category.

Licensed Facilities Requiring Cost Agreements:

The EPA requires certain licensed facilities to agree on costs and provisions for environmental liabilities. These facilities include landfills, category A extractive waste facilities, upper and lower-tier Seveso facilities, hazardous and non-hazardous waste transfer stations, incineration and co-incineration waste facilities, high-risk contaminated land, and those falling under exceptional circumstances. Facilities that do not fall into these categories are no longer required to agree on costs and financial provisions for environmental liabilities.

Closure Restoration and Aftercare Management Plans (CRAMPs) are essential for addressing environmental liabilities associated with the closure and decommissioning of facilities. ORS and BMJ’s expertise in completing CRAMPs for clients across various industries and sectors ensure accurate assessment, costed mitigation measures, and compliance with regulatory requirements. By adhering to the EPA’s risk-based approach, facilities can effectively manage environmental liabilities and secure a sustainable future.

Note: The information provided in this blog post is based on the current understanding of CRAMPs and related regulations. It is always recommended to consult with experts and refer to the most recent guidelines for precise and up-to-date information.