10    EPA-APPROVED, FULL-SCALE DECONTAMINATION OF A
COMMERCIAL HAZARDOUS WASTE STORAGE AND
TREATMENT FACILITY
Richard C. Krueger, Project Manager
RMT, Incorporated
Dublin, Ohio 43017
INTRODUCTION
This facility was operated as a hazardous waste storage and treatment facility in Ohio. The facility
occupies approximately 4'/2 acres in an area of primarily industrial land use. The site was originally a
low-lying area, and apparently accepted industrial fill from nearby foundries and other industries
during the late 1800s and early 1900s.
Beginning in 1916, the site was operated for industrial paint manufacturing. The paint manufacturing operations continued under various ownerships until 1973. The property was then vacant from
1973 until 1980 when hazardous waste management activities began. RCRA activities continued until
November 1990, when the facility owner/operator decided to cease operations and close the facility
under RCRA hazardous waste regulations.
The facility submitted a RCRA closure plan to the Ohio EPA in January 1991. After several
meetings and negotiations, the Ohio EPA approved the plan in April 1992, and the facility began the
scheduled closure activities. On-site closure decontamination, sampling, testing, and documentation
continued for approximately 14 months, and a final documentation report was transmitted to the
Ohio EPA in November 1993.
CLOSURE PLANNING DOCUMENTS
RMT developed a RCRA Closure Plan to address the applicable portions of 40 CFR Part 265 and
the Ohio Administrative Code, Chapter 3745-66. The plan identified how the facility owner/operator
intended to remove any remaining hazardous waste residue, decontaminate the structures and equipment, and restore the site to its pre-RCRA condition to achieve "clean closure." The Closure Plan
included the following:
1. Descriptions of the facility and the individual waste management units
2. Closure performance standards for determining clean closure of equipment, structures,
and site soils
3. Descriptions of the closure methods, including decontamination, residue management,
and confirmation sampling and analyses of decontamination rinsates
4. A soil sampling and analysis plan for determining background soil levels and documenting on-site soil quality
5. Health and safety issues related to closure activities
6. Estimated waste quantities, closure schedule, and closure costs
7. Descriptions of decontamination methods for the equipment used to handle materials
during the closure activities
8. A discussion of the documentation and certification of closure activities.
In addition, the facility owner/operator retained RMT to prepare construction specifications and
drawings for soliciting contractors' bids for the closure activities. The bidding documents include
contractual requirements, such as the owner's/operator's standard Environmental Services Agreement
and a description of the roles and responsibilities of the owner, engineer and contractor during the
project. The bidding documents also include the technical specifications for completing the work, and
discuss topics such as the removal of equipment and structures; the decontamination of tanks,
surfaces and equipment; the management of solid and liquid residues; project meetings; quality
control; temporary controls; and other aspects of the work.
49th Purdue Industrial Waste Conference Proceedings, 1994 Lewis Publishers, Chelsea, Michigan 48118. Printed in
U.S.A.
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