Cessation of Regulated Operations Implementation and Reporting
The Cessation of Regulated Operations (CRO) program, under the Ohio Revised Code (ORC) Chapter 3742, is intended to prevent threats to human health and the environment that are created when business owners/operators irresponsibly abandon businesses where chemicals were produced, used, stored, or handled. This program typically applies to owners/operators of facilities who are required to file a chemical inventory report.
In the spring of 2019, a long-time client of Cox-Colvin & Associates (Cox-Colvin) reached out for assistance in the implementation and reporting requirements under CRO. Cox-Colvin prepared a CRO workplan and provided oversight to ensure that waste removal and surface decontaminations were completed properly. Following the industrial cleaning process, Cox-Colvin performed and documented integrity evaluations of sumps, pits, and containment structures. Upon completion of these activities, a final report was submitted to the client that documented the closure activities, the volume of waste generated and removed, the analytical results associated with waste characterization, the closure performance standards that were achieved, and the shipping manifests associated with the wastes disposed. Cox-Colvin submitted required documentation to Ohio EPA in accordance with CRO regulations.