TANK CLOSURE CHECKLIST

Hazardous Waste Program fact sheet
04/2014
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB2218

Use this checklist to ensure the information necessary for a complete Tank Closure Report is included in the report. Be aware that, as each site is different, the following may not address all issues at a particular site. The checklist includes most of the items that need to be addressed.

Missouri Risk-Based Corrective Action, or MRBCA, Forms and Notifications

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Submittal of Closure Notice (780-2121) 30-days prior to underground storage tank closure. This form is available online at www.dnr.mo.gov/forms/780-2121-f.pdf.

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Provide notification to the department’s Tanks section three days prior to beginning closure activities. Phone number for the section is 573-751-6822.

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Call the spill hotline at 573-634-2436 if contamination is confirmed (e.g., staining, odor).

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Submittal of a Closure Report Form (780-2120) as part of closure report. The Closure Report Form needs to contain signature of underground storage tank owner or operator. This form is available online at www.dnr.mo.gov/forms/780-2120-f.pdf.

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Submittal of closure report within 60 days of the completion of closure activities.

Narrative

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Timeline of site activities.

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Cleanup target levels clearly stated.

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Reusable product recovered and its fate?

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Number of tanks removed and their observed condition.

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Number of tanks left in place.

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Planned future use of site.

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Are new tanks to be installed on-site?

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Amount of backfill and native soil removed and its fate.

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Concrete pad in pit and its condition?

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Groundwater in pit? Removed? Recharge within 12 hours?

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Bedrock present?

 

Site Maps

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Drawn to scale.

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Current on-site buildings are identified.

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All adjacent property use is detailed.

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Location of tanks, excavation boundaries, product lines, dispenser islands.

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Depth of excavation.

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Underground utilities.

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Downgradient direction and degree of slope.

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North arrow.

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Locations of all obtained soil samples.

Color Photos

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Condition of the site before and after the closure is complete.

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The ends, sides and interior of each tank.

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The excavation floor and sidewalls.

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Tank pad if present.

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Bedrock if exposed

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Product line and dispenser trenches.

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Sealed underground tanks/lines that are closed in place.

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Description of photos.

Laboratory Data

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Sample results from appropriately obtained samples (Section 4.4.2 of the MRBCA guidance for petroleum storage tanks).

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Sample results for the appropriate contaminants of concern, or COCs, (Table 5-1).

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If total petroleum hydrocarbons - diesel or oil range organics are detected, 25 percent (or a minimum of two, whichever is greater) of samples with highest concentrations must be analyzed for polynuclear aromatic hydrocarbons. See the fact sheet MO Risk-Based Corrective Action for Petroleum Storage Tank Sites - Sampling for Polynuclear Aromatic Hydrocarbons (PUB2160) available online at www.dnr.mo.gov/pubs/pub2160.htm.

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Sufficient sample results from all soil returned to the pit to establish it was below clean up target levels for the site.

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Sufficient sample results for disposed soil.

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Background sample results for waste oil sites and pre-1980 gasoline tanks.

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Quality assurance or quality control documentation.

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A complete chain of custody with all signatures, as well as the dates and times the samples were obtained and subsequently relinquished to the laboratory and the temperature of the samples as they were received by the laboratory.

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Laboratory reporting limits must meet the required reporting limits as outlined in Table 5-3 of the Missouri Risk-Based Corrective Action for petroleum storage tanks guidance document.

Tanks and Tank Cleaning

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Photographic documentation and a signed statement by the party performing tank cleaning activities attesting to the proper cleaning of the tanks.

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A signed statement by the underground storage tank owner or the owner or operator of the receiving facility attesting to the fate of the underground storage tanks.

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Documentation about the fate of any usable product recovered from the underground storage tanks.

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Proper characterization of the sludge or rinsate generated during tank cleaning activities as well as the appropriate manifests signed by the generator, transporter and receiving facility of the waste.

Soil and Water Disposal

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Documentation of the proper disposal of contaminated soil (e.g. landfill disposal receipts, weight tickets).

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Documentation of the proper disposal of contaminated pit water, including:

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Signed statement of permission from the publicly owned treatment works prior to disposal.

  • Documentation of wastewater characterization required by the publicly owned treatment works.
  • Appropriate documentation that the wastewater was accepted by the publicly owned treatment works.

Other Possible Inclusions

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If bedrock is encountered in the excavation, a geologic assessment performed by a registered geologist or a qualified professional engineer is necessary.

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If the cleanup target levels are above the default target levels, the domestic use of groundwater pathway must be evaluated in strict accordance with Section 6-3 and Figure 6-2 of the MRBCA guidance for petroleum storage tanks.

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If the cleanup target levels are for non-residential use, documentation on the reasonably anticipated future use of the site must be submitted.

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Sample results below default target levels? If above, ecological receptor, then the checklist should be completed. These checklists are available as attachments to chapter five of the MRBCA guidance for petroleum storage tanks.

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Sample results within established Tier 1 cleanup levels.

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Sample results within appropriate groundwater use column Table 4-1.

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Tank(s) “Closed-In-Place”? If so, a Statement of Closure may be used to record the existence of the tank(s) on the property.

Closure Contact Information
Closure Main Phone Line: 573-751-6822

References and Forms
Missouri Risk-Based Corrective Action Guidance Document www.dnr.mo.gov/env/hwp/tanks/mrbca-pet/mrbca-pet-tanks.htm

Missouri Risk-Based Corrective Action Closure Forms www.dnr.mo.gov/env/hwp/tanks/ustclosure.htm

MO Risk-Based Corrective Action for Petroleum Storage Tank Sites - Sampling for Polynuclear Aromatic Hydrocarbons, Fact Sheet (Pub2160) (PAH analysis). www.dnr.mo.gov/pubs/pub2160.htm

Soil Type Determination Guidelines
The above is available on the department’s website at www.dnr.mo.gov/env/hwp/tanks/mrbca-pet/mrbca-pet-tanks.htm

For More Information

Missouri Department of Natural Resources
Hazardous Waste Program Tanks Section
P.O. Box 176
Jefferson City, MO 65102-0176
800-361-4827 or 573-751-6822
573-526-8922 fax
www.dnr.mo.gov/env/hwp/tanks/tanks.htm
www.dnr.mo.gov/env/hwp/index.html