Background/ History
The Washington University School of Medicine (WUSM) is located at 600 S. Euclid in St. Louis, and is part of the larger Washington University Medical Center complex. The complex was founded on February 22, 1853, and currently includes WUSM, Barnes Hospital, Jewish Hospital of St. Louis, Missouri, St. Louis Children’s Hospital, Barnard Skin ad Cancer Hospital, Central Institute for the Deaf, Clinical Sciences Research Building, the East Building, the Medical Library and Communication Center. WUSM is a research institution, containing approximately 1200 laboratories, and responsible for managing the hazardous waste operations for the other complex properties.
Various types of biological research are performed in the WUSM laboratories. A variety of hazardous wastes are produced as part of the facility operations, most of which are surplus chemicals from its biomedical research, education and clinical activities. WUSM operated a Surplus Chemical Facility, located at 4500 Parkview Place, to receive and store hazardous waste for less than 90 days, until shipped off-site for disposal. WUSM also operated several other smaller hazardous waste storage areas and a boiler/industrial furnace, used to dispose of hazardous waste. WUSM operated under the “interim status” portions of the federal Resource Conservation and Recovery Act (RCRA). Since closing its interim status hazardous waste management units, WUSM continues to manage hazardous wastes under the applicable hazardous waste generator regulations.
Cleanup Summary
WUSM clean-closed the boiler/industrial furnace in 1998, which included cleaning out the units primary combustion chamber, dismantling and removing the pumping and piping equipment used to transport the hazardous waste to the unit, and decontaminating the units storage/pumping room. The remaining interim status hazardous waste management units were also clean-closed. The department accepted WUSM’s closure certifications for the units in 1999. After closure, the boiler/industrial furnace continued to be used for burning infectious wastes that were deemed non-hazardous. Because they clean-closed all its interim status hazardous waste units, WUSM is not subject to the permitting requirements of the Missouri Hazardous Waste Management Law or federal Hazardous and Solid Waste Amendments for post-closure care.
As a former interim status facility, WUSM remains subject to corrective action because they completed closure of the interim status hazardous waste areas after the effective date of the federal Hazardous and Solid Waste Amendments (1984) to RCRA. The properties 1994 RCRA Facility Assessment (RFA) identified several areas that required further investigation. However, taking into consideration all the hazardous waste management units were clean-closed, investigation and remediation efforts at the facility related to the Hartog Oil site and a follow-up corrective action inspection by the Department, further investigation and remediation of the areas identified in the RFA do not appear to be necessary. As time and resources allow, the Department intends to administratively release WUSM from regulation as a former interim status hazardous waste treatment, storage, and disposal facilities subject to the corrective action requirements of the Missouri Hazardous Waste Management Law and regulations. This process will include an opportunity for public review and comment before the Department makes any final decisions.
