“Trials and Tribulations of Shutting Down a Chemical Plant.”

Willard Vaughan, PE, CIH Environmental Specialist

PMC Group (formerly Dow , formerly Rohm and Haas, Formerly Morton Chemical)

Cape Hatteras

What Does Shut Down Mean?

• Last one out turn off the lights and lock the door?

• EPA calls it:Cessation of Regulated Operations

When Does Shutdown Occur?

• The simple answer is, when you stop doing the regulated activity.

• What activities are regulated by:

Why?

PMC Air Permit

• When:– Production stops– Materials are removed from site– All cleaning of the permitted equipment and

storage equipment is completed,– Equipment is inactivated

PMC Air Permit

• Then – PMC will/can no longer discharge regulated VOCs.

– Go into eBiz and notify Ohio EPA that the is decommissioned and no longer in service.

SARA

• Once all materials are off site submit a revised Tier II report, AND

• Notify LEPA, Fire Department that materials are off site and processes have been shutdown

SARA Form R

• Don’t forget to gather your data while you can for next year’s Form R.

Waste Water

• MSD has its own 7 step procedure for Process Closure / Transfer

Waste Water Equipment

Run Off?

• SPCC

RCRA

• There is a whole section in the regulations dealing with Cessation of Regulated Activities.

Ohio Administrative Code 3745 – 66

3745-66-10 Closure and post-closure: applicability.

Except as rule 3745-65-01 of the Administrative Code provides otherwise:

(A) Rules 3745-66-11 to 3745-66-15 of the Administrative Code, which concern closure, apply to the owners and operators of all hazardous waste management facilities; and

(B) Rules 3745-66-16 to 3745-66-20 of the Administrative Code, which concern post-closure care, apply to the owners and operators of:

(1) All hazardous waste disposal facilities;

(2) Waste piles and surface impoundments for which the owner or operator intends to remove the wastes at closure to the extent that these rules are made applicable to such facilities in rule 3745-67-28 or 3745-67-58 of the Administrative Code;

(3) Tank systems that are required under rule 3745-66-97 of the Administrative Code to meet requirements for landfills; and

3745-66 -11Closure Performance Standard

The owner or operator must close his facility in a manner that:

(A) Minimizes the need for further maintenance; and

(B) Controls, minimizes, or eliminates, to the extent necessary to protect human health and the environment, post-closure escape of hazardous waste, hazardous constituents, leachate, contaminated run-off, or hazardous waste decomposition products to the ground water, or surface waters, or to the atmosphere; and

(C) Complies with the closure requirements of rules 3745-66-10 to 3745-66-21, including, but not limited to, the requirements of rules 3745-66-97, 3745-67-28, 3745-67-58, 3745-67-80, 3745-68-10, 3745-68-51, 3745-68-81, 3745-69-04, and 3745-205-1023745-256-102 of the Administrative Code.

3745-66 Closure performance standard

• 3745-66-97 deals with hazardous waste tanks• 3745-67-28 deals with surface impoundments• 3745-67-58 deals with waste piles• 3745-67-80 deals with land treatment• 3745-68-10 deals with landfills

There is even a website!

CRO Links

Haz Waste Storage Area

Permanent/Temporary CRO and Contact Person Form (30/45 Day Form)epa0327.pdf

Regulated Substance & Equipment Removal Form (90 Day-Final Form)epa0329.pdf

Holder of the First Mortgage/Fiduciary/Indentured Trustee/Receiver Form (15/60 Day Form)epa0330.pdf

Government Forms

Closure Plan

• 3745-66-12 Closure plan; amendment of plan.(A) Written plan. On April 15, 1981, the owner or operator of a hazardous waste management facility must have a written closure plan. Until final closure is completed and certified in accordance with rule 3745-66-15 of the Administrative Code, a copy of the most current closure plan must be furnished to the director upon request, including request by mail. In addition, for facilities without approved plans, it must also be provided during site inspections, on the day of inspection, to any officer, employee, or representative of Ohio EPA who is duly designated by the director.

Other things to think of

• Freon• Asbestos/Lead• Florescent Bulbs – Universal Waste• Oils and Glycols• Mercury Switches• Lab Waste

Issues

• What are you going to do with documents like RCRA records?

• Who is going to do annual reports?

What to do with all the Stuff

Cleaning out Tanks

What to do with Leftovers

Clearing out transfer lines

Problems

• Half way through the process, the other facility can’t make the product and you have to start back up.

• If your plant has been in operation for more than 20 years, you have things in the closet that you never knew was there.

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