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Plant shutdown
- 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)
- 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
- 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
- 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.
Editor's Notes
- Good afternoon and welcome to my presentation on the Trails an Tribulations of Shutting Dow a Chemical Plant.
- Well everything comes to an end at some time and there are times we just got to give it and move on – or take a nap. PMC purchased the facility in Feb 2013 and announced in July 2013 that they would consolidate the operations of Cincinnati and Carrolton, KY together in Carrolton, KY. In September, 2013 Cincinnati personnel were informed of their state and some were offered positions in Carrolton and some where not. I was not. BUT this being said, while everyone stated looking for work, there is a dedicated professional staff that has continued working to make sure all goes correctly without getting anyone hurt or spills/leaking of materials. This is a Google map shot of the plant. PMC owns the property including the ball fields out front. However the ball fields are rented for something like a dollar for 10 years but in reality is a buffer for the plant to the residential south of the plant. The plant was begun right after World War II and has been a manufacturing facility every since but as the title shows, it has gone through a number ownership changes. With each change, the products and process did remain somewhat constant and the real changes came from the management culture of each corporate purchase. We are a chemical plant with a variety of materials railcars of Chlorine and methyl Chloride Tanks of various organics Tin in both solid and liquid states We have the normal Large Quantity Hazardous Waste permits, We submit Sara Tier II and Form R reports, We have an air permit, discharge industrial waste to MSD under a permit. Further more the plant under went a RCRA 3013 inspection before me and had just finished up remediation of the site but had never gotten Federal EPA in Chicago to close out the account. So while we are not complicated, there are a number of issues that will need to be addressed. Also, we are shutting down because we want to not under orders from anyone.
- But moving large objects does get complicated and a lot of people will have to be involved otherwise things can go really wrong quickly.
- However even very large objects can be moved with the right equipment, personal and planning. This is Cape Hatteras lighthouse on the outer banks of North Carolina. For the full story and more photos go to http://www.nps.gov/caha/historyculture/movingthelighthouse.htm But it can be done so where to begin?
- So what do we mean by the term shutdown? Easiest answer, the date the last person walks out the gates and turns off the lights. Stop bringing materials on site To most this means end of production - but this is misleading in that stopping production does not mean you have shutdown
- There are a number of regulations and laws that apply to each site depending on what you do. Each of these agencies above have a different issue and determine shutdown a bit differently. Air Emissions Waste Water Discharges Hazardous and Solid Waste SARA reporting TSCA regulated materials (asbestos and lead) Lets start with the easiest – Air emissions.
- The end of production is simple enough Production stops, you are not making anything, nothing goes in and nothing comes out. Materials are removed from site – raw materials are off site and can not be used, leak or spill All cleaning of the permitted equipment and storage equipment is completed – opening a tank or container to wash it out can release more air toxics, VOCs or other regulated substances which need to be measured or estimated for reporting. Equipment is inactivated – Air gaped, disconnecting equipment with piping or removal of equipment from site.
- Once all the above occurs, then you
- This is a screen shot of PMC’s Emission Unit (EU) for a major process – all I have to do is edit this profile and at the bottom of the screen is a button that I click to say shut it down. There are a number of clicks you have to make for each of the sections. Each time, the software will warn you that once the equipment is removed, it can not be re-actived without a full permit application. So if all the sudden they want to put the system back on line for just one more day, you have to get a new permit. And once all the equipment is removed, all that is left is a final quarterly report and I will go ahead and do an annual report for submittal. This is the easy process. Now we go to the next step.
- This is just page one of three pages – could not find a link on MSD’s web page but they will be very happy to get you a copy if you request it. Nothing really surprising – required notification dates, need for contact person after transfer or closure and such and a closure plan.
- This is the big one since And if in doubt,
- http://codes.ohio.gov/oac/3745-66
- This is the big one since And if in doubt that it applies to you – the question to ask is, does anyone know about your operations? If yes then this applies.
- http://www.epa.ohio.gov/dmwm/Home/Cro.aspx
- http://epa.ohio.gov/portals/32/pdf/epa0327.pdf
- http://epa.ohio.gov/portals/32/pdf/epa0329.pdf
- http://epa.ohio.gov/portals/32/pdf/epa0330.pdf
- So What’s Next? For the facility we will continue working down the road in clearing out all the products and materials, removing and shipping all equipment and tanks other PMC facilities want, and cleaning the place up so that it will be safe for the salvage / demolition crews to come in and do their work. For me personally,
- Well its time for this super hero to take a short nap – I am looking around for a position but since I have some time before everything ends, I am taking my time
- But if you know of somewhere south within 100 miles of the Chattanooga, TN area feel free to let me know!! if you want a copy of this power point with the links to all the documents and information I hope to have this up on my linked in page – just look me up at Willard Vaughan.
- Thanks for you time and are there any further questions?