Title Page

  • Facility Name

  • Conducted on

  • Prepared by

  • Location

Closure Activities

Removal of Wastes and Waste Residues

  • Removal of wastes and waste residues is always required as a part of clean closure. Did you describe in detail how you will remove wastes and waste residues from the closing unit?

  • In addition to the residues normally managed from waste recycling or used oil processing (such as tank or distillation unit bottoms), did you address removal of wastes and waste residues that may remain in piping and the recycling or used oil processing equipment?

  • Did you describe in detail the procedures and equipment you will use to remove as much waste and waste residue as possible from the closing unit?

  • Did you address how you will manage waste and waste residue removed from the closing unit, including plans to put wastes in containers, label and manage containers, and provide for proper disposal?

  • Did you identify the types of off-site dangerous waste management units that will be used, if applicable?

  • The maximum inventory of waste is the most waste that could ever be present at your facility based on facility capacity, based on how much waste could be managed, not how much waste you think will actually be present. Did you assume that you will have to manage the maximum inventory of waste identified in the closure plan at the time of closure and have to manage the maximum inventory of waste as part of closure activities?

Unit Components, Parts, and Ancillary Equipment

  • After you remove all waste, you have the option of also removing the unit, its components, parts, and associated equipment and piping. If you choose to remove all or part of the unit, did you give a detailed description of how you will accomplish the removal?

  • Did you describe the procedures and equipment you will use to remove the unit or unit components and parts?

  • In general, unit parts, unit components and parts that have come into contact with dangerous waste must be managed as dangerous waste unless they are decontaminated. Did you address how you will manage the unit components and parts?

  • Did you address the waste management requirements that you believe will apply to waste removed from the closing unit and any unit parts, components, or other materials you plan to remove, and how you plan to comply with these requirements?

  • Did you identify the types of off-site dangerous waste management units that will be used, if applicable?

Inspection of Units before Decontamination

  • Inspection of units before decontamination but after wastes and waste residues are removed is always required as part of clean closure. Did you describe how you will inspect the unit and the area surrounding after waste removal and before beginning decontamination activities?

  • Cracks and other openings may indicate the potential for releases from the containment structure. Did you describe how you will look for cracks or other openings in the unit containment structure?

  • Did you describe how you will keep a record of any indication of the potential for spills or releases at or from the containment structure? Did you describe how this information will be used when determining soil and other sampling needs, if any?

Decontamination

  • Did you identify all the types of materials you will decontaminate (such as metal tanks, and concrete containment systems)? Did you create a separate subsection to describe decontamination procedures for each material?

  • Did you describe, in detail, how you will decontaminate the inside and outside of each material, including the procedures, methods, and equipment you will use during decontamination?

  • Did you describe how you will evaluate decontaminated materials to determine if they meet the decontamination standard for clean closure? (Remember, you identified the decontamination standard you plan to use earlier in the closure plan.)

  • If you plan to request approval for a site-specific decontamination standard, did you describe in detail the standard you propose and explain why you believe it is appropriate?

  • Did you describe any adjustments that you believe might be necessary during decontamination? (For example, what you plan to do if decontamination is not successful on the first attempt.)

  • Did you describe how you will decontaminate any equipment that you use during decontamination?

  • Did you describe how you will manage all decontamination residuals (such as rinse or waste water and concrete dust)? Did you identify the waste management requirements you believe will apply to decontamination residuals and describe your plans to comply with these requirements?

  • Did you describe how the independent qualified registered professional engineer will play in overseeing decontamination activities?

Identifying and Managing Contaminated Environmental Media

  • Did you identify any environmental media (soil, ground water, surface water, sediments) that you know is contaminated?

  • Did you describe in detail why you believe this contamination is present? Did you describe in detail the sampling and analysis you will carry out to fully understand the nature and extent of contamination?

  • If you plan to collect soil samples at depth, did you indicate that the subsurface geology will be described in accordance with the Unified Soil Classification System (USCS)? Ecology will use this description to better evaluate your sampling strategy and results, and can consider the potential for any soil contamination to contaminate ground water.

Confirming Clean Closure

  • Did you describe each material (such as decontaminated concrete containment systems, metal tanks, and soil) that you anticipate addressing during confirmation of clean closure? Did you restate the clean closure standard that will applies (Section 2.0 of your closure plan), and describe the procedures you will follow to confirm that clean closure standards are achieved?

  • Did you describe how you will verify that the Alternative Treatment Standards for Hazardous Debris (or a site-specific debris decontamination standard) are achieved throughout areas you decontaminated?

  • Did you describe how you will use sampling and analysis or other methods to verify that any contaminated soil is removed to achieve MTCA unrestricted site use cleanup levels?

  • Did you describe the records and other materials that you will retain so that Ecology can verify your confirmation that clean closure standards were achieved?

Completion

  • Comments/Recommendations

  • Name and Signature

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