The removal of waste and waste residues is always required as part of a clean finish. Has it been described in detail how waste and waste residues are removed from the locking system?
In addition to the residues that normally arise from waste recycling or waste oil processing (e.g. tank or distillation plant bottoms), has the removal of waste and waste residues that may remain in the pipes and the recycling or waste oil processing plant been addressed?
Have the procedures and equipment used to remove as much waste and waste residues as possible from the installation been described in detail?
Has been addressed how the waste and waste residues removed from the facility will be handled, including plans for filling waste into containers, labeling and managing the containers and ensuring proper disposal?
Have the types of off-site hazardous waste disposal units that may be used been identified?
The maximum waste inventory is the largest waste that could ever be present in the facility, based on the capacity of the facility, based on how much waste could be managed, not how much waste is believed to be present. Has it been assumed that at the time of decommissioning the maximum waste inventory defined in the decommissioning plan must be managed and that the decommissioning activities must manage the maximum waste inventory?
Components, Parts and Accessories of the Unit
After all waste has been removed, it is possible to remove the unit, its components, parts and associated equipment and piping. If it was decided to remove all or part of the unit, was a detailed description given of how the removal should be carried out?
Have the procedures and equipment used to remove the unit or its components and parts been described?
In general, plant parts, plant components and other parts that have been in contact with hazardous waste must be treated as hazardous waste unless they are decontaminated. Has it been discussed how the unit components and parts should be handled
Has consideration been given to the waste management requirements that are believed to apply to the waste removed from the equipment and any parts, components or other materials of the unit that are to be removed, and how these requirements should be met?
Have the types of off-site units for the disposal of hazardous waste that may be used been identified?
Inspection of the Units before Closure
Inspection of the units before decontamination, but after removal of waste and waste residues is always required as part of a clean closure. Has there been a description of how the unit and the environment will be inspected after waste removal and before decontamination activities are started?
Cracks and other openings may indicate the potential for releases from the containment structure. Has it been described how to look for cracks or other openings in the unit containment structure?
Has been described how to keep records of indications of possible spills or releases to or from the containment structure?
Has been described how this information will be used in determining the need for soil and other sampling?
Have all types of materials being decontaminated been identified (e.g. metal tanks and concrete containment systems)?
Has a separate subsection been created for each material to describe the decontamination procedures?
Has a detailed description been provided of how the inside and outside of each material is to be decontaminated, including the procedures, methods and equipment to be used during decontamination?
Has been described how the decontaminated materials will be evaluated to determine if they meet the decontamination standard for a clean closure? (The decontamination standard previously specified in the closure plan must be used).
Are there plans to apply for approval of a site-specific decontamination standard?
Has the proposed standard been described in detail and explained why it is suitable for
Have any adjustments been described that are considered to be necessary during decontamination? (For example, what to do if decontamination is not successful at the first attempt).
Has there been a description of how equipment used during decontamination is to be decontaminated?
Has a description been given of how to handle all decontamination residues (e.g. rinse or wastewater and concrete dust)?
Have the waste management requirements been identified which will subsequently apply to decontamination residues and have plans been described to meet these requirements?
Has a description been provided of how an independent, qualified, registered, professional engineer will proceed in monitoring decontamination activities?
Identify and Manage Contaminated Environments
Have any environmental media (soil, groundwater, surface water, sediments) been identified that are contaminated?
Has a detailed description been provided of why it is believed that this contamination exists?
Has a detailed description been given of the sampling and analysis carried out to fully understand the nature and extent of the contamination?
If it is planned to take soil samples at depth, has it been stated that the underground geology must be described in accordance with official regulations? Environmental experts will use this description to better assess sampling and results.
Confirmation of a Clean Closure
Has every material (such as decontaminated concrete containment systems, metal tanks and soil) been described that is necessary to confirm a clean closure?
Has the applicable clean-closure standard (Section 2.0 of the closure plan) been reformulated and the procedures used to confirm that the clean-closure standards are achieved described?
Has it been described how to verify that the alternative hazardous waste treatment standards (or a site-specific waste decontamination standard) are achieved in all decontaminated areas?
Was there a description of how sampling and analysis or other methods are used to verify that contaminated soil is removed to achieve regulatory clean-up levels for full site use?
Has a description been provided of the records and other materials that are kept to enable the competent environmental authority to confirm that clean closure standards have been achieved?
Please note that this checklist template is a hypothetical example and provides only standard information. The template does not aim to replace, among other things, workplace, health and safety advice, medical advice, diagnosis or treatment, or any other applicable law. You should seek your professional advice to determine whether the use of such a checklist is appropriate in your workplace or jurisdiction.
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