Discussion of Regulatory issues in closing a chemical manufacturing facility. Presented the Alliance for Chemical Safety July 9, 2014 by Willard Vaughan, PE CIH

1. “Trials and Tribulations
of Shutting Down a
Chemical Plant.”
Willard Vaughan, PE, CIH
Environmental Specialist

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

4. Cape Hatteras

5. What Does Shut Down Mean?
• Last one out turn off the lights and lock the
door?
• EPA calls it:
Cessation of Regulated Operations

6. When Does Shutdown Occur?
• The simple answer is, when you stop doing
the regulated activity.
• What activities are regulated by:

7. Why?

8. 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

9. 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.

11. 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

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

14. Waste Water
• MSD has its own 7 step procedure for Process
Closure / Transfer

16. Waste Water Equipment

17. Run Off?
• SPCC

21. RCRA
• There is a whole section in the regulations
dealing with Cessation of Regulated Activities.
Ohio Administrative Code 3745 – 66

23. 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

24. 3745-66 -11
Closure 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.

25. 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

26. There is even a website!

27. CRO Links

28. Haz Waste Storage Area

29. 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

33. 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.

34. Other things to think of
• Freon
• Asbestos/Lead
• Florescent Bulbs – Universal Waste
• Oils and Glycols
• Mercury Switches
• Lab Waste

35. Issues
• What are you going to do with documents like
RCRA records?
• Who is going to do annual reports?

36. What to do with all the Stuff

37. Cleaning out Tanks

38. What to do with Leftovers

39. Clearing out transfer lines

40. 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.

43. www.linkedin.com/in/willardvaughan/