KEMRON

Our Recent Projects

Steel Manufacturing Plant Closure

KEMRON has provided environmental support for the closure of a former coke plant since for decades. Initially contracted to conduct a Spill Prevention Control and Countermeasure (SPCC) evaluation and prepare a revised SPCC plan, KEMRON’s role expanded significantly following the facility’s shutdown in to manage solid and hazardous waste issues during the plant’s closure and decontamination.

Upon closure, KEMRON conducted a thorough evaluation of applicable solid and hazardous waste requirements under RCRA. This included a detailed risk assessment and regulatory summary to guide decision-making during the closure process. The regulatory summary reviewed solid and hazardous waste applicability, process materials, and planned material disposition. KEMRON also summarized other regulatory requirements, such as air, water, and state-specific performance criteria, ensuring compliance throughout the closure and demolition process.

The project required detailed process evaluations to define specific units and points of generation for listed hazardous waste versus other generated materials characterized using RCRA criteria. Based on these evaluations, unit-specific closure requirements were developed and integrated into the plant decontamination and demolition specifications. The management processes emphasized reuse, recycling, and waste minimization, ensuring that most process residuals were managed to eliminate hazardous waste disposal requirements and allow beneficial reuse.

During the complete facility decontamination and demolition, KEMRON conducted third-party reviews of all activities to ensure conformance to regulatory requirements and proper material management. Continuous re-evaluations identified further reuse and recycling opportunities, minimizing costs and controlling liability. KEMRON verified conformance to closure plans, documenting all decontamination and demolition activities through check sheets and photographs.

Following the initial facility sweep and regulatory review, the site underwent an inspection by the EPA Region 4 RCRA Enforcement and Compliance Unit. KEMRON represented the client during the inspection, managing documentation and follow-up responses. EPA issued RCRA 3007 information requests, for which KEMRON provided technical, regulatory, and site activity history summaries.

A RCRA 3013(a) Administrative Order required the development and implementation of a Sampling and Analysis Plan (SAP) and Quality Assurance Project Plan (QAPP) to assess identified areas. KEMRON prepared these plans, represented the client in negotiations with EPA, and provided technical oversight during the SAP implementation. They also prepared the SAP implementation report, including recommendations for Phase 2 sampling and analysis.

KEMRON employed extensive waste minimization strategies, conducting a plant sweep to recover usable and recyclable materials, including oils, greases, paints, and refractory sand. Materials were sorted and taken off-site for use at other locations. Tar residuals were recovered by mixing with coal and used in coke manufacturing, eliminating the need for hazardous waste disposal. A portable screening plant separated recyclable metals from other debris, resulting in significant cost savings by reducing off-site disposal requirements. Clean bricks and inert materials were reused on-site, further reducing costs and eliminating safety hazards.

The comprehensive facility decontamination and demolition project emphasized regulatory compliance and innovative waste management solutions. By thoroughly evaluating historical processes, KEMRON ensured all decontamination activities met regulatory standards, maximizing the recycling of cleaned equipment. The project was financially beneficial, yielding a net positive cash flow for the client due to metal recovery, with additional cost savings realized through residual recycling and material sorting operations. KEMRON’s approach ensured successful closure and compliance with all regulatory requirements, showcasing their expertise in managing complex regulatory and environmental project.

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