Cleanup under RCRA - Corrective Action and Closure

Oversees RCRA hazardous waste facility closures and RCRA corrective actions. Cleanup under RCRA generally falls under one of two programs: closure or corrective action.

Hazardous waste facilities will eventually stop generating and/or receiving waste for treatment, storage or disposal. At that time, the owner/operator must either remove all waste that has accumulated in hazardous waste management units at the facility, or leave the waste in place while maintaining the units in such a way that ensures they will not pose an unacceptable future threat to human health and the environment. This is referred to as RCRA closure.

Past and present activities at hazardous waste facilities have sometimes resulted in releases of hazardous waste and hazardous constituents into soil, ground water, surface water, sediments and air. Hazardous waste regulations mandate that facilities investigate and clean up, or remediate, these releases. This program is known as RCRA corrective action.

  • Public Notices
  • Hazardous Waste Final Actions Issued
  • Ohio Revised Code (ORC) Chapters Ohio Administrative Code Chapter 3734 and Ohio Administrative Code (OAC) Chapters 3745-50 through 57, 65 through 69, 205, 256, 266, 270, 273 and 279 contain the rules for hazardous waste management in Ohio. These rules were developed with input from stakeholders and can be viewed on the RCRA Rules web page. To view these RCRA rules, see the Effective Rules tab.
  • Ohio EPA Publications Catalog - Enables users to search for forms, guidance documents, publications, newsletters, checklists etc. on a variety of Ohio EPA issues and topics. This link is filtered to provide publications specific to CRO related documents.
  • Ohio EPA Answer Place - Enables users to search frequently asked questions, or submit their own question/comment on a variety of Ohio EPA issues and topics. These links are filtered to provide responses specific to closure and corrective action questions:

How do I know if I’m subject to a RCRA Closure or RCRA Corrective Action?

RCRA Closure

Hazardous waste rules require owner/operators of facilities that store, treat or dispose of hazardous waste to be subject to, among other things, closure and post-closure requirements.

Closure is the period directly after a hazardous waste treatment, storage or disposal facility (TSDF) stops its normal operations. During this period, a TSDF stops accepting hazardous waste; completes treatment, storage, and disposal of any wastes left on site; and disposes or decontaminates equipment, structures, and soils. Some owners and operators will completely remove all waste that was treated, stored, or disposed in their unit. This operation is known as clean closure. In order to demonstrate clean closure, an owner and operator must show that levels of hazardous contaminants at the facility do not exceed EPA-recommended exposure levels.

If you store, treat, or dispose of hazardous waste, you are likely subject to the hazardous waste closure requirements. Closures are unit-based activities whereas Corrective Action is site-wide. In closure, it is important to define the physical boundaries of the hazardous waste management unit subject to closure based upon the hazardous waste, hazardous waste constituents, or breakdown products associated with hazardous waste managed at the unit.

In instances where hazardous constituents are found to be present at or near the closure unit but are not attributable to the unit activities, Ohio EPA has several alternatives. The hazardous constituents found within the unit boundary can be addressed as a part of the closure process; as such the unit will not be investigated during Corrective Action. Alternatively, the unit can be closed addressing only the hazardous waste managed at or attributable to the unit (without addressing the other hazardous constituents); the closed unit will then be subject to Corrective Action investigation.

Hazardous constituents outside the closure unit boundary may be addressed through Corrective Action or other programs available through the state. In cases where the closure unit has released hazardous waste or constituents into the surrounding soil or ground water and the closure units are located near Waste Management Units (WMUs) or Areas of Concern (AOCs) that also had releases to the environment, the clean-up of similar releases may be subject to two different set of standards and procedures. Therefore Ohio EPA may address the closure unit under Corrective Action by exempting the closure unit from certain closure requirements conditioned on the incorporation of the unit into the Corrective Action program through a permit or order.

RCRA Corrective Action

Facilities generally are brought into the RCRA corrective action process through orders when there is an identified release of hazardous waste or hazardous constituents from waste management units (WMU), or when Ohio EPA is considering a facility’s RCRA permit application. Additionally, a facility owner or operator may volunteer to perform corrective action by entering an agreement with Ohio EPA in order to expedite the process.

The RCRA Corrective Action program investigates and remediates waste management units (WMUs) on a site-wide basis, as necessary, which are typically permit or order driven. Unlike the closure process, which provides two options (closure by removal and closure with waste in place) the Corrective Action process provides considerable flexibility to Ohio EPA to choose a remedy that reflects the conditions and the complexities of each facility. For example, depending on the site-specific circumstances, remedies may attain media cleanup standards through various combinations of removal, treatment, and engineering and institutional controls.

Where a collection of adjacent WMUs and a hazardous waste management unit undergoing closure are releasing hazardous constituents to the environment, two separate remedial processes would apply to the cleanup of the respective releases. Many times, the regulatory distinction between the WMU and the closure unit cannot be maintained because unit boundaries overlap, contaminant plumes are commingled, or it is difficult to identify the exact source of the contamination. The post-closure rule developed by U.S. EPA, and effective in Ohio as of December 7, 2004, addresses this situation by allowing the hazardous waste management unit to be addressed under Corrective Action. This rule allows the regulating agency to choose whether to apply current 40 CFR Parts 264 and 265 (or OAC Chapters 3745-54 to 3745-205 and 3745-65 to 3745-256) to hazardous waste management units closed as a part of a broader Corrective Action or to address them through the Corrective Action cleanup requirements. However this rule was not intended as a way to bring WMUs under the unit-specific closure standards. For more information on RCRA Corrective Action, please go to the link for RCRA Closure Guidance on DERR’s Cleanup under RCRA web site.

Hagen, Erik Risk Assessment Manager (614) 644-3173
Allen, Michael Risk Assessment Supervisor (614) 644-2322
Martin, Jeff Ground Water Supervisor (614) 644-2294
Beal, Sarah Risk Assessment (614) 644-2972
Busalacchi, Dawn Risk Assessment (614) 644-3537
Christman, Tim ARARs, Engineering (614) 644-2297
Fogle, Corrin Risk Assessment (614) 902-4231
Kawatra, Kamal ARARs, Engineering (614) 644-2915
Langton, Melissa Risk Assessment (614) 644-2287
Rasik, Carrie Risk Assessment (614) 644-2324
Switzer, Doug Geologist 4 (614) 644-3127
Vogel, Don Environmental Specialist (614) 644-4826