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WASHINGTON STATE

DEPA RT MEN T 0 F

E COL '0 G Y

Guidance for

Clean Closure of Dangerous Waste Facilities

Prepared by

Washington State Department of Ecology

HazardousWaste and Toxies Reduction Program

August, 1994

Publication #94-111

o Printed on RecycledPaper
(J

.For a copy of this report, please contact:

Department of Ecology

Publications

P.O. Box 47600

Olympia, WA 98504-7600

Please include your street address for UPS delivery.

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• .The Hazardous Waste and Toxies Reduction Program is responsible for the management

and reduction of hazardous waste and toxic substances in Washington State. We're here

to answer your questions. Contact your nearest regional office and ask for a Hazardous

Waste Specialist if you are uncertain about your responsibilities as a hazardous waste

generator. For information on reducing or recycling hazardous waste, ask for a Toxics

Reduction Specialist. .

State ofWashington

Department ofEcology Regional Office

. 24-Hour Oil & Hazardous Materials Spill Reporting Numbers

•

Need to Know

RagionoJ

• 011"_

Location

OR CALL:

DivisionofEmergency Management

24 Hour Number

1-800-258-5990 Revised5/94

• Reporting Party

• Company Name

• Contact Phone(s)

• Material

• ResourceDamages

(i:e. deadfish)

• Quantity

.: Concentnuion

• Location

• Cleanup Status

•

The Department ofEcology is an Equal Opportunity and Affirmative Action employer and shall not

discriminate on the basis ofrace, creed, color, national origin, sex-, marital status, sexual orientation, age,

religion or disability as defined by applicable state and/or federal regulations or statutes.

Ifyou have special accommodation needs, please contact Dave Dubreuil at (206) 407-6721 (Voice) or (206)

407-6006 (TDD).
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TABLE OF CONTENTS

1.0 INTRODUCfION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1

1.1 Authority 1

1.2 Disclaimer............................................ . . .. 1

1.3 Partial and Final Closure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1

1.4 Additional Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2

1.5 Additional Information 2

2.0 CLOSURE pLANs 3

2.1 Contents of the Closure Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3

2.2 Closure Plan Review and Approval 4

2.3 Public Participation ... . . . . . . . : .. . . . . . . . . . . . .. . ..'. . . . . . . . . . . .. 5

2.4 Amending Closure Plans : '. . . . . . . . . .. 6

2.5 Activities Conducted Prior to Closure Plan Approval 6

3.0 CLOSURE PERFORMANCE STANDARD 9

3.1 Clean Closure Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . 9

3.2 MTCA Method A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 10

3.2.1 Definition of Routine .'. . . . . . . . . . .. 10

3.2.2 Clean Closure Levels - MTCA Method A . . . . . . . . . . . . . . . .. 11

3.2.3 Misuse of the MTCA Method A Tables 11

. 3.3 MTCA Method B ., ; . . . . . . . . . . . . . . . . . .. 11

3.4 Adjusting Constituent Concentrations to Meet the Cleanup Standards .. 12

3.5 Natural Background . . . . . . . . . . . . . . . . . . . . . . . .. 12

3.6 Indicator Constituents '. . . . . . . . . . .. . . . . . . . . . . . . .. 12'

3.7 Pre-Existing Contamination 13

3.8 Post-Closure Care ' . . . . . . . . . . . . . . . . .. 13

4.0 REMOVAL '. . . . . . . . . . . . . . . .. 15

4.1 Waste Minimization ; 0........................... 15

. 4.2 Contaminated Environmental Media 16

. 4.2.1 Contained-In Policy for Media 16

4.3 Hazardous Debris . . . . . . . . . . . . .. 17

4.3.-1 Contained-In Policy for Hazardous Debris 18

4.4 The Empty Container Rule . .. 18
5.0 DECONTAMINATION 0 •• 0 0 •• 19 C

5.1 Unit Inspection Prior to Decontamination . 0 ••••• 0 •••••••••• 0 • • •• 19

5.2 Decontamination Standards 0 • 0 0 •••••••••••••••• 0 •• 0 0 • 0 20

5.3 Compliance with Decontamination Standards 0 •••••••••••• 0 20

5.4 Decontamination and Compliance with the LDR 21

5.5 Other Decon. Methods & Equivalent Technology Demonstrations 0.... 22

5.6 Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 22

5~7 Decontamination Residuals •... 0 •••••••••••••••••••••••••••o. 23

5.8 Decontamination of Concrete Containment Structures 0 • • •• 23

5.8.1 Contained-In Policy 0 •••••••••••••••••••••••o. 24

5.9 Decontamination of Metal Tanks and Tank Systems . 0 0 ••••••• 0 • • •• 24

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6.0 SAMPLING AND ANALYSIS FOR CLEAN CLOSURE .. 0 • • • • • • • • • • • • • •• 29

6.1 Sampling and Analysis Plan 0 0 • •• 29

6.2 Designing a Sampling Program 0 • 0 30

6.2.1 Area-Wide Sampling 0 •••••••••• 0 • 0 0 31

6.2.2 Focused Sampling 0-' ••• 0 31

6.2.3 Sampling for Hot Spots 0............................ 0 32

6.3 Sampling to Determine or Confirm Dean Closure 0 ~. 32

6.4 Statistical Guidelines 0 ••••••••• 0 ••••• 0 ••••••••••• 00 32

6.5 Soil Sampling During Closure o. 33

6.5.1 Soil Sainpling Under Structures 0 33

6.5.2 Soil Sampling at Various Depths 0 • • •• 33

6.6 Groundwater Monitoring During Closure' . . . . . . . . . . . . . . . . . . . . . . " 34

6.7 Selection' of Constituents to be Analyzed 34

6.8 Approved Analytical Methods 0 ••••••••• 0 ••••• 0 ••• " 35

6.9 Multiple Analytical Methods 0 •• 0 • • •• 36

6.10 Quality Assurance and Quality Control Requirements 36

6.10.1 Field Quality Assurance/Quality Control 0 • 0 ••••••• " 37

6.10.2 Laboratory Quality Assurance/Quality Control '. 37

6.11 Data Quality Objectives. " . 0 ••••••••••••••••••••• 0 '.'••• 0 0 •• 0 37

6.12 Practical Quantitation Limits 0 '" 38

7.0 CLOSURE TIME UNE 39

7.1 Closure Notification 0 •••• " 39

7.2 Time Allowed for Closure 0 ••• 0 0 40

7.3 Additional Time Allowed for Closure " 40

7.3.1 Extension of Closure 0 ••••••• 0 ••••••1 41

7.3.2 Delay of Closure .. 0 ••••••••• 0 0 ••••••••• 0 ••• 0 ••• 0 • 0 0 41

7.4 Closure Certification 0 •••• 0 ••••• 0 •••• 0 •••• 0 • 0 0 o. 42

7.5 Closure Verification 0 • 0 ••••••••••• 0 •• 0 ••••••• 0 • 0 0 0 43

8.0 REFERENCES .. 0 •••••••••• 0 •• 0 ••••••••••••••••••••••••• 0 ••• " 45

APPENDIX 1 ORDER FORM FOR OTHER ECOLOGY DOCUMENTS .... 0 • • 1-1

APPENDIX 2 LIST OF ECOLOGY ACCREDITED LABS 0 ••• 0 0 • 0 •• 0 2-1

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1.0 INTRODUCTION

The purpose of this document is to provide guidance for closure of dangerous waste .

management units at interim and final status treatment, storage, and disposal facilities

(TSDF). This document provides specific direction for demonstrating compliance with

the clean closure performance standard through removal and decontamination of

dangerous wastes (DW), DW constituents, and waste residue.

1.1 Authority

Owners and operators of dangerous waste treatment, storage, or disposal facilities must

comply with the Federal Resource Conservation and Recovery Act (RCRA) and its

implementing regulations in Chapter.af of the Code of Federal Regulations (CPR). The

U.S. Environmental Protection Agency (EPA) has delegated the responsibility to

administer major portions of the RCRA program, including closure requirements, to the

Washington State Department of Ecology (Ecology). Ecology has adopted associated

state regulatory language in Chapter 173-303 of the Washington Administrative Code

(WAC) entitled, "Dangerous Waste Regulations." Specific requirements for closure of

final status dangerous waste management units and facilities are found in WAC 173-303-

610 through WAC 173-303-680; requirements for closure of interim status units and

facilities are found in WAC 173-303-400.

1.2 Disclaimer

Conformance with this guidance does not release facility owner/operators from their

obligations to notify Ecology prior to beginning the closure process, to submit closure

plans for Ecology review and approval, or to in any other way comply with the

requirements of Chapter 173-303 WAC. This guidance does not constitute agency

rulemaking and cannot be relied on by any person to create a right or benefit

enforceable at law or equity. Ecology reserves the right to act at variance with this

guidance at any time.

The methods described in this document do not represent the only methods acceptable

to Ecology for demonstration of clean closure. Alternative methods to those presented

here may be used, subject to site specific consideration during the closure plan approval

process.

1.3 Partial and Final Closure

1.

Partial closure means the closure of a dangerous waste management unit in accordance

with the applicable requirements of WAC 173-303-400 and 173-303-610 through WAC

173-303-680 ata facility that has other active dangerous waste management units. For

example, partial closure may include the closure of a tank system, landfill cell, surface

impoundment, waste pile, or other dangerous waste management unit, while other

• dangerous waste management units at the same facility continue to operate. Final

Introduction 1
closure means the closure of all dangerous waste management units at a facility in C

accordance with the closure requirements so that dangerous waste management activities j

regulated under WAC 173-303-400 and/or WAC 173-303~610 through WAC 173-303-680

are no longer conducted at the facility.

1.4 Additional Requirements

This guidance does not address requirements which are applicable during the active life

of a dangerous waste management unit/facility including, but not limited to, requirements

for financial assurance, closure cost-estimates, groundwater monitoring, inspection and

recordkeeping. An order form for other Ecology guidance documents is provided at the

end of this document. "

1.5 Addltional Information

Ecology encourages facility owner/operators to work closely with the department when

developing closure plans and conducting closure activities. For more information on the

application of specific closure requirements to your dangerous waste management facility,

you may contact the appropriate regional"office of the Department of Ecology as listed in

the map at the beginning of this document and ask to speak with a hazardous waste

specialist. "

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2 Introduction
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2.0 CWSURE PLANS

The owner/operator of a dangerous waste management facility must have a written

closure plan. The written closure plan must address closure of each dangerous waste

management unit and final closure of the facility. At final status facilities, the closure

plan must be provided to Ecology with the RCRA Part B permit application for the

facility. Ecology will typically review the closure plan as part of the permit review

process. If a final permit is issued, the closure plan will be a condition of the final

permit.

At facilities operating under interim status, the closure plan must be maintained' at the

facility and provided to Ecology during site inspections and/or in response to written

requests. Ecology does not typically review and approve interim status closure plans until

the facility owner/operator notifies Ecology that they intend to begin closure activities.

2.1 Contents of the Closure Plan

Th~ closure plan must include, but is not limited to:

(1) The closure performance standard (see section 3):

A detailed description of how each dangerous waste management

unit at the facility will be closed in accordance with the closure

performance standard, including detailed descriptions of all activities

planned during the closure period; and

A description of how final closure of the facility will be conducted in

accordance with the closure performance standard. This description

must identify the maximum number and capacity of dangerous waste

management units which Will be in use (un-closed) during the active

life of the facility.

(2) Procedures for Removal of Wastes (see section 4):

.. An estimate of the maximum inventory of dangerous wastes on-site

during the active life of the facility;

A detailed description of the methods planned to remove wastes

and/or contaminated equipment, bases, liners, soils/subsoils during

partial closure(s) and final closure. The description should include,

but not be limited to, methods for removing, transporting, treating,

storing, or disposing of all dangerous wastes and waste residues

(including hazardous debris and contaminated environmental

media); and

Closure Plans 3
Identification of the type(s) of on- and off-site dangerous waste

management units to be used, if applicable.

(3) Decontamination Procedures (seesection 5):

A detailed description of the steps needed to remove or

decontaminate all dangerous waste residues and contaminated

containment system' components, equipment, structures, 'soils, and

subsoils during partial and final closure,including, but not limited to,

procedures for cleaning and decontaminating equipment and

removing contaminated soils/subsoils;

Methods for sampling and testing surrounding soils/subsoils, and

criteria for determining the extent of decontamination required to

satisfy the closure performance standard;

Procedures for inspecting all units prior to decontamination,

recording.releases and potential releases, and reporting such releases

and potential releases to Ecology;

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Detailed descriptions of implementation of planned decontamination

methods; and

Detailed description of methods which will be used to collect and C

manage decontamination residuals (e.g., rinse water).

(4) Procedures for Sampling and Analysis (see section 6):

A sampling and analysis plan prepared in accordance with section

6.1 of this guidance, including, sampling approach, methods, and

procedures and rationale for. each selection; and

Detailed descriptions of field and lab quality assurance/quality

control (QNQC) procedures.

(6) Discussion of the closure time line (see section 7):

A schedule for closure of each dangerous waste management unit

and for final closure of the facility. .

2.2 Closure.Plan Review and Approval

Ecology is responsible for ensuring that approved closure plans are consistent with the

closure performance standard and other applicable requirements of the dangerous waste

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4 Closure Plans
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regulations. Ecology is also responsible for ensuring meaningful opportunities for public

review of closure activities.

. For final status facilities, Ecology typically reviews and approves closure plans as part of

the dangerous waste permitting process. Public review of final status facility closure

plans typically occurs as part of the public review associated with issuance of dangerous

waste permits.

At facilities operating under interim status, Ecology typically reviews closure plans when

the facility owner/operator notifies Ecology that they expect to begin partial or final

closure activities. After receipt of a notification of intent to begin partial or final closure

and a written interim status closure plan, Ecology will review the plan and either

tentatively approve or disapprove the plan within ninety (90) days. If Ecology tentatively

approves the closure plan, the tentative approval will be included in the public notice

procedures discussed below. If Ecology disapproves the closure plan, the facility

owner/operator will be provided with detailed written comments summarizing the reasons

for the disapproval.

If Ecology disapproves the initial closure plan, the facility owner/operator has thirty (30)

days from receipt of Ecology's disapproval and comments to modify the closure plan and

submit a revised closure plan for Ecology review and approval. Ecology will then either

tentatively approve or modify the revised closure plan within sixty (60) days of receipt. If

Ecology tentatively approves the closure plan, the tentative approval will be included in

the public notice procedures discussed below. If Ecology modifies the plan, the modified

plan becomes the tentatively approved closure plan (also subject to the public

participation period discussed below) and Ecology will send a copy of the modified and

tentatively approved plan with a detailed statement of the reasons for the modifications

to the facility owner/operator.

The facility owner/operator and Ecology may agree to incorporate additional, informal

review and comment steps in the closure plan approval process. For example, many

facility owner/operators choose to coordinate informally with Ecology prior to submitting

. a closure plan for the initial 90 day review. 'Ecology has found that such informal

coordination can significantly increase the quality of initial closure plan submittals and

reduces the number of formal Ecology comments.

2.3 Public Participation

Ecology is responsible for providing meaningful opportunities for the public to review

and comment on closure activities. Ecology notifies the public of their opportunity to

review and comment on closure activities through a newspaper notice. At final status

permitted facilities, the public's opportunity for review of closure plans typically occurs

during the public review and comment associated with issuance of the final status permit

and/or as part of any major modifications to the final status permit. For facilities

operating under interim status, Ecology must provide a thirty (30) day public comment

Closure Plans 5
period to give interested persons an opportunity to review and comment on the tentative C~

.decision to approve any given closure plan. Significant changes to approved interim /

status closure plans are subject to additional public review.

. Final Ecology approval of closure plans must include consideration of all comments

. received during the public comment period.

2.4 Amending Closure Plans

Facility owner/operators can amend their closure plan at any time prior to the

notification of intent to begin partial or final closure. Facility owner/operators must

amend closure plans whenever:

(1) A change in facility design or operating planes) affects the closure plan;

(2) There is a change in the expected year of closure; and/or

(3) Unexpected events encountered during closure activities require a

modification of the closure plan.

Facility owner/operators who amend their un-approved closure plans do so at their

discretion. Facility owner/operators who wish to amend their Ecology-approved closure

plans must submit an amended plan to Ecology with a written request for Ecology review C

and approval. All amendments and changes to approved interim status closure plans are

subject to the review, approval, and public notice procedures discussed above.

Amendments and changes to final status closure plans are subject to applicable

requirements for permit modification.

. 2.5 Activities Conducted Prior to Closure Plan Approval

Closure plan approval (see section 2.2) and closure notification (see section 7.1) are

required; however, facility owner/operators may conduct activities, including removing

wastes and decontaminating or dismantling equipment and structures at any time prior to

closure. Provided Ecology determines that such activities were conducted in accordance

with the requirements for closure, they could be approved in the subsequently submitted

closure plan.

In order for Ecology to make such determinations, facility owner/operators must keep

detailed records documenting that all activities conducted prior to closure plan approval

are consistent with closure requirements. Information maintained to support consistency

with the closure requirements should, at a minimum, include the information required for

closure certification, as discussed in section 7.4 of this guidance.

Ecology cannot accept activities if they are inconsistent with the closure regulations or if

adequate information in not available to support a determination of consistency with ()

6 Closure Plans
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closure requirements. IfEcology determines activities were inconsistent with the closure

requirements and/or if adequate information is not available to determine consistency, . .

Ecology can require facility owner/operators to conduct additional activities, including,

but not limited to, removal and/or decontamination of wastes, waste residues, equipment

and/or structures, additional sampling and analysis, and/or investigatory activities designed

to determine the degree to which previously conducted activities comply with closure

requirements. See WAC 173-303-610(3)(c)(iv) and 40 CFR § 265.1l2(e) as referenced

by WAC 173-303-400.

Ecology emphasizes that facility owner/operators can incur considerable liabilities when

they choose to conduct removal and/or decontamination prior to closure plan review and

approval. Facility owner/operators are encouraged to work closely with Ecology formally

and informally to develop closure strategies which are appropriate for their facilityspecific conditions.

Closure Plans 7
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3.0 CLOSURE PERFORMANCE STANDARD

The closure performance standard is found at WAC 173-303-610(2). According to the

closure performance standard, all dangerous waste management units and facilities must

be closed in a manner that: .

(1) Minimizes the need for further maintenance;

(2) Controls, minimizes, or eliminates to the extent necessary to protect human .

health and the environment, post-closure escape of dangerous waste,

dangerous constituents, leachate, contaminated run-off, and dangerous

waste decomposition products to the ground, surface water, ground water,

and atmosphere; and)

(3) Returns the land to the appearance and use of surrounding land areas to

the degree possible given the nature of the previous dangerous waste

activity.

In addition to compliance with the performance standard, clean closure requires the

removal or decontamination of all dangerous waste, waste residues and equipment, bases,

liners, soils/subsoils and other material containing or contaminated with dangerous waste

or waste residue. Ecology will consider removal and decontamination complete when .the

concentrations of dangerous waste, dangerous waste constituents, and dangerous waste

residues throughout the closing unit and throughout any areas affected by releases from

the closing unit do not exceed numeric cleanup levels determined using residential

exposure assumptions according to the Model Toxies Control Act (MTCA) Regulations,

Chapter 173-340 WAC and all structures, equipment, bases, liners, and other materials

containing or contaminated with dangerous wastes, constituents,·or residues have met

specific removal and decontamination standards approved by Ecology in accordance with

WAC 173-303-610(2)(b)(ii).

3.1 Clean Closure Levels

. According to WAC 173-303-610(2)(b)(i), numeric clean closure levels for soils, ground

water, surface water, and air must be determined using residential exposure assumptions

according to the Model Toxics Control Act (MTCA). The MTCA regulations provide

three options for establishing site-specific cleanup levels, MTCA methods A, B, and C.

Each method uses human health risk as the main factor in determining cleanup levels.

Data on environmental risk are considered, when available. Each MTCA method also

includes provisions for consideration of natural or area background, practical quantitation

limits, and concentrations of individual hazardous substances established under applicable

state and federal laws.

For cancer-causing substances, MTCA defines the acceptable risk level as a conservative

estimate of a person's chances of developing cancer during a lifetime of constant

Closure Performance Standard 9
exposure. ·If more than one contaminant is present on a site, the total health risk from. C

all cancer-causing substances must be considered when determining cleanup levels.

For non-carcinogenic substances, the MTCA cleanup level for each substance at a site

must be below that which could cause illness in humans. If more than one substance at a

site affects the body in the same way, the effect of all those substances combined must be

considered when determining cleanup levels.

Facility owner/operators who wish to demonstrate clean closure must develop numeric

cleanup levels for dangerous wastes and dangerous waste constituents using residential

exposure assumptions under MTCA method A or B. In order for Ecology to approve

the clean closure certification, these cleanup levels must be met throughout the closing

unit and any areas affected by releases from the closing unit. The MTCA method A and

B cleanup standards for determining site- and media-specific cleanup levels are found in

WAC 173-340-700 through -760. The following sections of Chapter 173-340 WAC are

referenced in the MTCA cleanup standards but do not apply to clean closure: 130, 350, .

360, 410, and 440. In addition, MTCA method C and WAC 173-340-745 are not

appropriate for clean closure.

3.2 MTCA Method A

Use of MTCA method A is limited to routine closures at sites with relatively few

dangerous waste constituents or closures where numerical standards are available in the C

MTCA regulations or other applicable state and federal laws for all indicator dangerous .

waste constituents in all media of concern.

3.2.1 Definitfon of Routine

A routine closure is any closure that Ecology determines meets the MTCA definition of a

routine cleanup..Under MTCA, a cleanup may be considered routine if:

(1) It involves an obvious and limited choice among cleanup methods;

(2) It uses a cleanup method that is reliable and has proven capable of

accomplishing the cleanup standard;

(3) Cleanup standards for each hazardous substance addressed by the cleanup

are obvious and undisputed, and allow an adequate margin of safety for

protection of human health and the environment;

(4) Ecology has experience with similar actions; and

(5) The action does not require an environmental impact statement.

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10 Closure Performance Standard
• Routine cleanups may include one or more of the following activities: Cleanup of aboveground structures; cleanup of below-ground structures; cleanup of contaminated soils

where the cleanup will restore the site to cleanup levels; or cleanup of solid wastes,

including containers. For additional information on the MTCA definition of routine, see

WAC 173-340-130(7)(b).

Ecology believes that very few closures meet the criteria for "routine." Ecology may

consider closure of a container storage area with little or no contamination of the

containment system routine. Closures involving groundwater remediation and/or

decontamination of structures Will not normally be considered routine.

3.2.2 Clean Closure Levels - MTCA Method A

. Clean closure levels established using MTCA method A must, at a minimum, meet all of

the following:

(1) Concentrations of individual dangerous waste constituents listed in the

method A tables in WAC 173-340-720 or WAC 173-340-740;

(2) Concentrations of individual dangerous waste constituents established under

applicable state and federal laws;.and

• (3) For individual dangerous waste constituents which do not meet the

conditions in paragraphs one or two, concentrations that do not exceed

natural background concentrations or the practical quantitation limit (POL)

for the dangerous waste constituent in question.

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Guidance on use of POLs in determining MTCA method A cleanup levels is available

from Ecology.

3.2.3 Misuse of the MTCA Method A Tables

Care should be taken not to misuse the MTCA method A tables. The MTCA method A

tables were developed for specific purposes, they are intended to provide conservative

cleanup levels for sites undergoing routine cleanup actions and/or sites with relatively few

hazardous substances. The method A tables should not automatically be used to define

clean closure levels.

3.3 MTCA Method B

MTCA method B may be used to establish clean closure levels at any dangerous waste

management unit or facility. Clean closure levels established using method B must, at a

minimum, meet all of the following:

Closure Performance Standard 11
(1)

(2)

(3)

Concentrations of individual dangerous waste constituents established under

applicable state and federal law;

Concentrations which are estimated to result in no adverse effects ori the

protection and propagation of aquatic and terrestrial life; and

For dangerous waste constituents for which sufficiently protective health- .

based criteriaor standards have not been established under applicable state

and federal laws, concentrations which protect human health and the

environment as specified in WAC 173-340-705, excluding the references to

WAC 173-340-745. .

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When establishing clean closure levels using MTCA method B, the excess cancer risk

from individual carcinogens cannot exceed one-in-one-million (1~); if more than one

type of carcinogenic dangerous waste constituent is present or there is more than one

.exposure pathway, the total excess cancer risk from the unit may not exceed one in onehundred-thousand (1O"S). For non-carcinogens, MTCA method B clean closure levels

cannot exceed the concentration at which a constituent could cause acute or chronic toxic

. effects on human health and the hazard index of dangerous waste constituents with

similar toxic effects cannot exceed one (1).

3.4 Adjus~g Constituent Concentrations to Meet the Cleanup Standards

In order to meet the MTCA cleanup standards, clean closure levels for individual

dangerous waste constituents may need to be adjusted downward to take into account

exposure from multiple pathways and to multiple dangerous constituents. Any such

adjustments should be made in accordance with the procedures in WAC 173-340-708(4).

3.5 Natural Background

Natural background concentrations of dangerous waste constituents may be considered

when establishing clean closure levels. MTCA defines natural background as, "the

concentration of hazardous substance consistently present in the environment which has

not been influenced by localized human activities." (See WAC 173-340-200) I

3.6 Indicator Constituents

Certification of clean closure must consider all dangerous waste, dangerous waste

constituents, and dangerous waste residues (including decomposition products) generated

Of managed at the facility and within individual units at the facility; however, the closure

process can often be expedited through use of indicator constituents. Indicator

constituents are constituents proposed by the facility owner/operator and approved by

Ecology as representative of the wastes managed at the closing unit and their

degradation products. For information on selecting indicator constituents please refer to

section 6.7 of this guidance.

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12 Closure Performance Standard
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3.7 Pre-Existing Contamination

In some cases, hazardous substances may have been present at the location of a

dangerous waste management unit before the unit was constructed or before the

dangerous waste management occurred.' In other cases, hazardous substances may have

migrated to the unit from another, unrelated, source. In these cases, clean closure of

individual units may occur provided:

(1) All dangerous wastes, constituents, and waste residues which originated

from the unit or waste management activities associated with the unit are

removed to appropriate clean closure levels; and

(2) The facility owner/operator demonstrates to Ecology'ssatisfaction that the

remaining contamination did not emanate from the closing unit and was

not in any way caused by waste management 'activities at the closing unit.

A facility owner/operator's obligations for closure at any given unit are fulfilled when

Ecology accepts a unit-specific clean closure certification. If pre-existing contamination

remains at the clean-closed unit in concentrations above appropriate MTCA cleanup

levels, the unit is subject to additional remediation under RCRA corrective action,

MTCA, or CERCLA, as appropriate. Ecology encourages facility owner/operators to

work closely with the Department during closure activities to ensure that all

contamination 'at closing units is appropriately addressed and to minimize the need for

additional remedial activities after closure.

3.8 Post-Closure Care

Post-closure care is required when dangerous wastes or waste residues'are left in place at

a closed dangerous waste management unit. Ecology considers dangerous waste or waste

residues left in place when dangerous waste constituents, residues, or decomposition

products at the closed unit remain at concentrations above numeric cleanup levels

determined using residential exposure assumptions under MTCA method A or B. 'A

post-closure permit is typically required to ensure appropriate post-closure care.

This guidance does not address post-closure care or permitting. Facility owner/operators

who believe that clean closure is not feasible are encouraged to work closely with

Ecology to determine appropriate post-closure care requirements.

Closure Performance Standard 13
•

•

4.0 REMOVAL

In the case of most non-land based units (e.g., tanks and containers) and many land

based units (e.g., surface impoundments and waste piles), the first step of the closure

process will be to remove all waste from the closing unit. When removal of all waste is

required, Ecology will expect facility owner/operators to use all practical and appropriate

methods to remove the waste. In the case of removing waste from a tank, such methods

could include, but are not limited to, pumping, pouring, scraping, and shoveling. After

waste is removed from the closing unit, the unit and all equipment, bases, liners,

soils/subsoils, and all other materials containing or contaminated with dangerous wastes

or waste residue must also be removed or must undergo decontamination.

Decontamination procedures are discussed in detail in section 5 of this guidance.

All wastes, waste residues, debris, and contaminated media generated during closure

activities must be managed in accordance with all applicable requirements including

applicable requirements in Chapter 173-303 WAC and applicable Federal hazardous

waste requirements. Wastes removed from regulated units will continue to carry the

dangerous waste codes which were associated with the wastes managed in the units and

remain subject to all applicable dangerous waste regulatory requirements.

As discussed in section 2.1 of this guidance, a facility owner/operator who intends to

clean close a dangerous waste management unit must fully describe each step in

removing waste and waste residues in the closure plan. Each step in the removal process

should be fully descnbed, including, but not limited to, estimates of the volumes and

types of waste, hazardous debris, waste residue and contaminated equipment, structures,

and media which will be removed during closure, staging and containerization of waste or

reagents, equipment to be used, removal pattern and depth increments, and management

of loading areas. The closure plan should also describe provisions which will be taken to

minimize and/or prevent emissions of dangerous waste and dangerous constituents during

closure activities. For example, if waste management activities during closure will include

. loading and transport of contaminated materials in trucks, the closure plan should

describe the steps which will be taken to minimize air emissions from windblown dust.

4.1 Waste Minimization

The management of waste generated during the closure process must include

consideration of ECology's waste .management hierarchy. Ecology's waste management

hierarchy emphasizes recycling and treatment over land disposal and includes the

following waste management priorities, in order of diminishing preference:

(2) Waste recycling;

(1) Waste reduction;

• (3)

Removal

Physical, chemical,"and biological treatment;

15
(4) Incineration;

(5) Solidification/stabilization treatment; and

(6) Landfill.

Utilization of an approach higher on the waste management hierarchy could be used as a

basis for requesting additional time for closure (see section 7.3 of this guidance) if such

additional time were necessary to implement the higher priority approach.

4.2 Contaminated Environmental Media

Contaminated environmental media which contain dangerous waste must be managed as

dangerous waste unless or until they no longer contain the waste and do not exhibit a

dangerous waste characteristic or criteria, or are delisted, Not all contaminated

environmental media generated during closure will necessarily require management as

dangerous waste. Facility owner/operators should carefully consider the conditions at

their closing units, and work with Ecology to determine the regulatory status of

contaminated environmental media. As noted in section 4.1, Ecology encourages facility

owner/operators to consider recycling and/or reuse of contaminated environmental media

generated during closures.

4.2.1 Contained-in Policy for Media

Facility owner/operators may demonstrate that contaminated environmental media

generated during closure activities do not or no longer contain dangerous waste and

therefore do not require further regulatory control or decontamination (this

demonstration is referred to as a "contained-in demonstration"), Ecology reviews

demonstrations that contaminated media no longer contain dangerous waste on a caseby-case basis, in consideration of the facility and waste specific circumstances. Facility

owner/operators must continue to manage contaminated media as dangerous waste until

they receive a written determination by Ecology that the media in question does not or

.no longer contains dangerous waste (this decision is referred to as a "contained-in

determination"). Ecology typically bases contained-in determinations on a comparison of

the concentrations of hazardous substances of concern in the media to MICA residential

cleanup standards. Ecology may determine that the media in question no longer contains

dangerous waste when the concentrations of dangerous constituents in the media fall

below cleanup levels determined using residential exposure assumptions according to the

MTCA regulations and the media does not exhibit a dangerous waste characteristic or

criteria.

Facility owner/operators may submit a request for, and information supporting, a

contained-in determination in the closure plan. Provided the supporting documentation

is adequate, Ecology can include contained-in determinations in closure plan approvals.

Ecology can also consider contained-in demonstrations during or after implementation of

c

()

16 Removal
e "closure activities. Facility owner/operators who believe the contained-in policy may be

applied to their closures are encouraged to work closely with Ecology to develop

adequate information to support a contained-in determination.

4.3 Hazardous Debris

EPA has promulgated rules governing the application of the hazardous waste Land

Disposal Restrictions (LDR) to hazardous debris. These rules are in effect in

Washington State and are presently being implemented by the EPA Region 10 in

conjunction with Ecology. Debris is defined as solid material (in the physical sense)

which exceeds 60 mm (2.5 inches) particle size and intended for disposal. Hazardous

"debris is defined as debris which is contaminated with listed hazardous waste or which

itself exlubits a hazardous characteristic. Not all debris generated during the closure

process will meet the definition of hazardous debris. Facility owner/operators should

plan on working closely with Ecology to determine the regulatory status of debris and

other materials generated during the closure process and are encouraged to consider

recycling or reuse of such materials. .

Facility owner/operators have three options for managing hazardous debris:

e

(1) Most listed and/or characteristic hazardous debris can be treated using an

appropriate" technology listed in 40 CFR 268.45 Table 1. If the debris is

treated using an approved extraction or destruction technology, it need not

be managed as a dangerous waste after treatment, providing it meets the.

technology specific performance and/or operating standard(s) and does not

exlubit a dangerous waste characteristic or criteria. 40 CFR 268.45 Table 1

is reprinted on pages 26 and 27 -of this guidance.

e"

(2) Hazardous debris may be treated to meet the constituent-specific LDR

treatment standard for the waste or waste-specific constituents

contaminating the debris; however, such debris, even after treatment, may

still be considered a dangerous waste under Chapter 173-303 WAC and

may require management at a facility permitted to manage dangerous

waste.

(3) Facility owner/operators may ask Ecology to apply the "contained-in" policy

for hazardous debris. Using the contained-in policy; Ecology can

determine, on a ease-by-case basis, that the hazardous debris does not or

no longer contains dangerous waste and does not require management as a

dangerous waste. For more information on the contained-in policy for

hazardous debris, please see below.

For more information" on LDR treatment requirements for hazardous debris, refer to 57·

FR 37194 (August 18, 1992) or contact a hazardous waste specialist at your Ecology

Regional Office or at EPA Region 10.

Removal 17
4.3.1 Contained-in Policy for Hazardous Debris

The contained-in policy for hazardous debris' is similar to the contained-in policy .for

contaminated environmerital media discussed in section 4.2.1, above. Ecology will

typically base contained-in determinations for debris on the history of the unit undergoing

closure, the concentrations of dangerous constituents present, potential routes of

exposure to such dangerous constituents, and other applicable information. There are no

standards which are routinely used to define contained-in concentrations for hazardous

debris: In the absence of clear standards, Ecology believes that soil cleanup levels

determined under MICA using residential exposure assumptions represent very

conservative assessment of the potential risks posed by debris. If the concentrations of

dangerous constituents in debris are below MTCA residential cleanup levels Ecology will

likely determine that the debris no longer contains dangerous waste. Facility

owner/operators who choose this option are encouraged to work closely with Ecology to

develop appropriate supporting information. Ecology emphasizes that MTCA residential

soil cleanup standards should not automatically be used to define contained-in

concentrations for hazardous debris. Ecology may make contained-in determinations for

hazardous debris based only on facility- and debris-specific considerations and in the

absence of a comparison of concentrations of hazardous constituents in the debris to

MTCA cleanup levels.

4.4 The Empty Container Rule

The empty container rule is found at WAC 173-303-160. Under the empty container 0

rule, a container is considered "empty" when all wastes have been removed that can be

removed using practices commonly employed to remove materials from that type of

container and there is either less than one inch of waste remaining in the container or

less than 1 percent of the container's capacity of waste remains in the container,

whichever is lessI.

Tanks are not considered "containers" for purposes of the empty container rule.

Achievement of the performance standard and specific requirements of the empty

container rule does not remove the obligation to decontaminate closing container storage

areas, container systems, and ancillary equipment.

Iff the total capacity of the container is greater than 110 gallons the amount of waste remaining in the

container may not exceed 0.3 percent of the container's total capacity. o

18 Removal
I .

•

•

5.0 DECONTAMINATION

In the past, Ecology and the regulated community have struggled to make numerous site

specific decisions regarding the methods and degrees of decontamination which are

necessary in a clean closure scenario. The purpose of the following decontamination

guidance is to provide minimum decontamination standards for use during closure.

Although decontamination approvals will still involve site'specific considerations, Ecology .

believes that cleariy defining minimum standards will significantly improve and expedite

the closure plan approval process.

As discussed in sectionZ.I of this guidance, a facility owner/operator who intends to

clean close' a dangerous waste management unit must fully descnbe each step in

removing waste and waste residues and removing or decontaminating equipment,

structures, and contaminated environmental media from the unit in the closure plan.

These descriptions must include estimates of the volumes and types of waste, hazardous

debris, waste residue, and contaminated equipment, structures, and media which will be

removed or decontaminated during closure. Descriptions of staging and containerization

of waste or reagents, equipment used, removal pattern and depth increments, loading

areas and any other steps critical to removal and/or decontamination must also be

included, The closure plan should clearly explain how debris and contaminated media

will be decontaminated, stored, loaded, and managed, both at the unit and after it leaves

the facility (as applicable). For example, if the chosen decontamination method is high

pressure steam, the closure plan should detail the' temperature, pressure, and duration of

the high pressure steam decontamination and discuss any use of surfactants or detergents.

The closure plan should descnbe provisions which will be taken to minimize and/or

prevent emissions of dangerous waste and dangerous constituents during closure

activities. For example, if decontamination activities will include water washing, the

closure plan should fully descnbe the steps which will be taken to prevent release of

wash waters to the environment.

5.1 Unit Inspection Prior to Decontamination

Prior to beginning decontamination, but after wastes have been removed, facility

owner/operators must visually inspect the closing unit to identify all cracks and other

openings through which waste, debris, or decontamination media (such as wash water)

could be released to the environment. If cracks or other openings are found at the

closing unit, the facility owner/operator may be required to seal or repair.the .cracks or

other openings to prevent releases prior to or during decontamination of the unit.

Facility owner/operators must maintain a record of the location and dimension of all

cracks or other openings identified during closure because these areas are considered to

have a higher potential for allowing releases of dangerous waste from the closing unit

and may require more focused sampling and analysis.during closure. The records may be

kept in the facility operating record or in the field notebook discussed in section 6.10.1 of

• this guidance. Facility owner/operators must investigate and evaluate all cracks and other

Decontamination . 19
openings identified during closure to determine if releases of dangerous waste or

. dangerous waste constituents have occurred at or from the closing unit.

Facility owner/operators should include procedures for inspecting all units prior to

decontamination, recording releases and potential releases, and reporting such releases

and potential releases to Ecology in the closure. plan.

5.2 Decontamination Standards

In a continuing effort to build consistency into the dangerous waste regulatory program,

Ecology has chosen to reference the "Alternative Treatment Standards for Hazardous

Debris," as promulgated by EPA in the August 18, 1992 Federal Register (57 FR 37194)

as the minimum decontamination standards for closure. The Alternative Treatment

Standards.for Hazardous Debris are summarized in 40 CPR § 268.45 Table 1, which is

reprinted at the end of this section on pages 26 and 27.

Ecology recognizes that not all materials requiring decontamination during closure will

meet the regulatory definition of hazardous debris', For example, materials requiring

decontaniination during closure may include structures, such as concrete containment

systems, which are not intended for disposal.· Although these structures will not meet the

regulatory definition of hazardous debris, they still require adequate and appropriate

decontamination during closure. Ecology believes the Alternative Treatment Standards

for Hazardous Debris represent the best demonstrated available technology (BDAT) for

materials typically subject to decontamination during the closure process and, as such, are

appropriate minimum standards for closure decontamination regardless of the regulatory

status of the materials in question. EPA contemplated application of the Alternative

Treatment Standards for Hazardous Debris to the closure process when they wrote in the

preamble to the August 18, 1992 rule:

"The Agency (EPA) believes that the treatment methods in today's rule would

always satisfy the decontamination standard in the closure provisions. After all,

the purpose of these treatment methods is to decontaminate. EPA also interprets

the land disposal and closure rules to require that all hazardous debris be treated

to meet the debris treatment standards, even if the debris is generated during

closure." (57 FR 37243)

. 5.3 Compliance with Decontamination Standards

Ecology believes that materials requiring decontamination during the closure process may

include, but will not be limited to, glass, metal, plastic, rubber, brick, cloth, concrete,

pavement, rock, and wood. Ecology will consider such materials decontaminated" if they

have been treated using an appropriate extraction or destruction technology (as specified

ZSee Section 4.3 of this guidance for a discussion of the regulatory definition of

"hazardous debris." .

o.

()

20 Decontamination
.-.

•

•

below and in 40 CPR §.268.45 Table 1), meet the technology specific performance,

design, and/or operating standards and, if intendedfor disposal, the material does not

exhibit a dangerous waste characteristic or criteria. Ecology believes this is consistent

with EPA's determination that, after treatment with most extraction and destruction

treatment technologies, hazardous debris will no longer be subject to regulation as a

hazardous waste (e.g., appropriately treated debris can be recycled, reused, or land

disposed in a solid waste landfill without further control under the federal hazardous

waste regulations). .

Materials decontaminated using an immobilization technology could be subject to longterm monitoring requirements under a post-closure scenario. Requiring long-term

monitoring for materials treated using an immobilization technology is consistent with

EPA's determination that treatment using an immobilization technology will be adequate

to comply with LDR treatment requirements, but the treated debris will remain subject

to regulation as hazardous waste (e.g., can be land disposed only at a facility permitted to

manage hazardous waste).

Facility owner/operators who choose to decontaminate material using biodegradation,

chemical destruction (which includes chemical oxidation and chemical reduction), or

decontaminate dioxin wastes using thermal destruction, must prepare a demonstration of

equivalent technology. The demonstration of equivalent technology should be included in

the closure plan and should document that the proposed technology treats the material

undergoing decontamination such that residual concentrations of hazardous contaminants

will not pose a hazard to human health and the environment. IT the material undergoing

decontamination is considered hazardous debris and the purpose of the proposed

decontamination method is, in part, to satisfy lDR treatment requiremerits, the

demonstration must be prepared in accordance with the requirements of 40 CFR

§ 268.42(b).

5.4 Decontamination and Compliance with the LDR

Facility owner/operators who chose to decontaminate debris using an appropriate

extraction or destruction treatment technology from 40 CFR § 268.45 Table 1 will have

the advantage of concurrently complying with lDR treatment standards, per any

applicable restrictions in the federal regulations. Facility owner/operators who choose to

decontaminate materials using a treatment technology other than the appropriate

extraction or destruction technology from 40 CFR § 268.45 Table 1 could, subject to

Ecology review and approval, fulfill closure requirements but may have. continuing

obligations under the federal LDR program.

Remember, while requirements for removal and/or decontamination during closure apply

to all dangerous waste, dangerous waste constituents and dangerous waste residues

(including decomposition products) and all equipment, bases, liners, soils/subsoils, or

other material containing or contaminated with dangerous waste, constituents. o~ residues,

only materials intended for disposal are subject to LDR requirements. Facility

Decontamination 21
owner/operators are encouraged to work closely with Ecology to identify, early in the C

closure process,materials intended for discard or disposal so LDR compliance can be j

considered when developing site-specific closure decontamination strategies.

5.5 Other Decontamination Methods & Equivalent Technology Demonstrations

Instead of relying on the Alternative Treatment Standards for Hazardous Debris, facility

owner/operators may wish to propose other decontamination methods or, some facility

owner/operators may decide to use the Alternative Treatment Standards for Hazardous

Debris but propose other design, operating, or performance standards. At a minimum;

requests for approval of other decontamination methods and/or other design, operating

and performance standards should include:

(1) Information demonstrating that the proposed decontamination method or

standard is in compliance with the closure performance standard at WAC

173-303-610(2), including information demonstrating that the proposed

decontamination method or standard will control, minimize, or eliminate

post-closure escape of dangerous waste, dangerous constituents, leachate,

contaminated run-off, and dangerous waste decomposition products to the

ground, surface water, ground water, and atmosphere.

(3) Information demonstrating that the proposed decontamination method or

standard is protective of human health and the environment,

(2) Information demonstrating that the proposed decontamination method or

standard is in compliance with federal, state, and local requirements; and o

Based on such information and any other available or requested information, Ecology

may approve the use of the proposed decontamination method or standard. All

approvals will be in writing and may contain such provisions and conditions as Ecology

deems appropriate. If adequate information is provided in the closure plan, Ecology can.

grant such approval during the closure plan review process.

If the material undergoing decontamination is considered hazardous debris and the

purpose of the proposed decontamination method is; in part, to satisfy LDR tre~tment

requirements, the documentation must include a demonstration of equivalent technology

prepared in accordance with the requirements of 40 CFR § 268.42(b).

5.6 Sampling

Ecology may require sampling of material subject to decontamination to determine the

nature and extent of contamination present in the material and/or to confirm the

adequacy of any decontamination method. For example, chip sampling of concrete

containment systems and/or rinsate sampling for tank decontamination may be required.

22 Decontamination
•

•

•

Ecology recognizes that sampling of many materials typically subject to decontamination

during closure may be problematic. Ecology emphasizes that the advantage of using an

appropriate extraction or destruction technology from 40 CFR § 268.45 Table 1 for

closure decontamination is treated material may exit the dangerous waste regulatory

system and sampling will not typically be required.

If facility owner/operators anticipate sampling will be necessary during closure

decontamination, they should propose sampling methods in the sampling and analysis

portion of the closure plan. For more information on sampling and analysis

considerations, please see section 6 of this guidance.

5.7 Decontamination Residuals

Residuals from decontamination (e.g., rinse-water) may be subject to regulation as

dangerous waste and may be required to carry the dangerous waste codes associated with

the waste managed in the unites) undergoing closure. Facility owner/operators should

work closely with Ecology to determine the regulatory status of decontamination residuals

generated during closure. As discussed in section 2.1 of this guidance, procedures for

collection and management of decontamination residuals should be included in the

closure plan.

5.8 Decontamination of Concrete Containment Structures

Ecology believes that decontamination of concrete containment structures will be the

most common type of closure decontamination. Alternative Treatment Technologies for

Hazardous Debris appropriate to concrete include: abrasive blasting using water to

propel abrasive media, scarification, grinding and planing, vibratory finishing, and high

pressure steam and water sprays (considered physical extraction technologies); and water

washing and spraying and liquid or vapor phase solvent extractions (considered chemical

extraction technologies). Performance, design, and/or operating standards for physical

and chemical extraction technologies are specified in 40 CFR 268.45 Table 1 (reprinted

on pages 26 and 27 of this guidance).

The performance standards for physical extraction technologies are based on removal of

the' contaminated layer of debris. The physical extraction performance standard for

concrete is removal of 0.6 cm of the debris surface layer and treatment to a "clean debris

.surface." EPA has determined that the treatment performance standard for physical

extraction technologies cannot be met by treating concrete with high pressure steam

and/or water spray; however, facility owner/operators who believe that high pressure

3nclean debris surface" means the surface, when viewed without magnification, is free of all visible

contaminated soil and dangerous waste except that residual staining from soil and waste consisting of light

shadows, slight streaks, or minor discolorations, and soil and waste in cracks, crevices, and pits may be

present provided that such staining and waste and soil in cracks, crevices,and pits shall be limited to 5% of

each square inch of surface area. See 40 CFR § 268.45 Table 1, Footnote 3. .

Decontamination 23 .
steam and/or water spray treatment will achieve an adequate level of concrete

decontamination at their facility can propose an more appropriate performance standard

as discussed in section 5.5 of this guidance,

The performance standards for chemical extraction are based on dissolution of

contaminants in the cleaning solution. The chemical extraction performance standard for

concrete requires treatment to a "clean debris surface," limits the thickness of the

concrete to 1.2 em, and requires that the dangerous constituents being addressed are

soluble to at least 5% by weight in the water solution, emulsion, or solvent as applicable.

Facility owner/operators who believe that an adequate level of concrete decontamination

can be achieved through water washing and spraying of concrete which is greater than 1.2

em thick can propose an alternative performance standard or decontamination method as

discussed in section 5.5 of this guidance.

5.8.1 Contained-in Policy

Depending on the condition and degree on contamination present in the concrete, facility

owner/operators may wish to use the contained-in policy to demonstrate to Ecology that

their concrete containment system does not require decontamiriation because it does not

contain dangerous waste. Facility owner/operators can also propose contained-in

demonstrations for concrete which has been treated or decontaminated (using any

treatment or decontamination method except dilution) so that it no longer contairis .

dangerous waste.

Ecology will make contained-in determinations for concrete containment systems on a

case-by-casebasis after considering the history of the unit, the dangerous constituents

present and/or potentially present, potential routes of exposure, and other pertinent

information. There are no standards which are routinely used to define contained-in

concentrations for concrete; however, Ecology believes that soil cleanup levels

determined under MTCA using residential exposure assumptions represent very

conservative assessments of the potential exposure risks posed by concrete. If the

concentrations of dangerous constituents of concern in concrete are below MTCA

residential cleanup levels Ecology will likely determine that the concrete no longer

contains dangerous waste.

IT adequate information is provided, Ecology can make contained-in determinations as

part of the closure plan approval process. For more information, ·please see the

discussion of the contained-in policy in section 4.3~1 of this guidance.

5.9 Decontamination of Metal Tanks and Tank Systems

. Ecology believes decontamination of metal tanks, tank systems, and ancillary equipment

(e.g., pumps, piping) will be a common part of the closure process. Alternative

Treatment Technologies for Hazardous Debris appropriate for metal include: abrasive

blasting, scarification, grinding and planing, spalling, vibratory finishing; and high pressure

o

..

24 . Decontamination
•

•

•

steam and water sprays (physical extraction) and water washing and spraying, liquid and

vapor solvent extraction (chemical extraction).

The performance standard for physical and chemical extraction technologies is treatment

toa "clean debris surface." "Clean debris surface" is defined in footnote -3, on page 23 of

this guidance.

Remember, the first step in the closure process is to remove all waste from the closing

unit and visually inspect the unit for any cracks or other openings (see section 4 of this

guidance). Waste removal and visual inspection must be completed before tank

decontamination may begin. If you plan on going inside the tank to accomplish waste

removal, visual inspection, or decontamination, you may be subject to regulations for

worker safety and/or confined space entry under the Washington Industrial Safety and

Health Administration and/or the federal Occupational Safety and Health

Administration. To find our more about WISHNOSHA regulations, you may contact

the Washington Department of Labor and Industries at (206) 753-6502.

Decontamination 25
TABLE 1.-ALTERNATIVE TREATMENT STANDARDS FOR HAzARDOUS DesRIS 1

ContamInant I8ltlidlon,·

Sameas above -; Same as above.

.0BbtIs t:tJntsnNtIItI with • .-astr

Qltain an Tec:tliQllg(" approval

under f 268.42(1»).8 •

seme as abo¥e. --; Same as 8bcw&

Sridr. 00t1t, PIlpsr. p...".", Rod;.

WDOCt Contaminant must be IOIutlIe to at least

5,., by weigtllin water tolulion or 5,., by weight in

emulsion; if debris ill c:onIaminated will a

listed waste,- en "EquiYaIent Tec:tli~

aI under f 268.42(1») must be 0btIinecL8

AI DebM: Treatment to a dean debris surface;·

Stick. Ccn:rete, Pt1per. P'a..e"aent Rod;.

WoOct Debris inU5t be no more tNIn 1.2 em (~

1nd1) In one dimenIion (i.... Ilic:tneIs Iimit..

except I\a1 tis 1tlidulesS Iinit may be W8ived

under an "EquiYaIenITech"dotlr under

f 268.42(b);8 debris utaces must be In contad

wiltl water solution tot at least 15 lllilUea

Sameasabove---.---------l Bride, Q)t1t, Conc:nJte. hptJr. r~\

WDOCt Same as above. acept the1 contai\

must be soluble to at IeasI 5,., by weight .,_J

SOlYeftl.

For relining furnaces. treated debris must be ...

rated from treatment residuals using IimpIe

cal or mec:hal1ic:aI 8 and. prior to blt&

natment. suc:ta f9SiliIIls must meet the .....

IP8CifiC treatmenC IIanciBrdt tor orgerie

pounds In Itle waste conIamIna1ing !he debriL

AI Dt1bris: Obtain an "EqutvaJenI Tec:tli1Olo0'" • ptCMI under t 268.42(1));8 IreaI8d debris must be

separated from Ir8a1ment rusiduaIs using IimpIe

physical or mechIItlicaI means.- and. prior to Iur·

1her treatment. sudI reslcMl must meet Itle ...

specific: treatment standards for organic

pOWlds In Itle waste contaninatiI:lg !he debttL

8Iidc, Q)t1t, ,..., Rod;.

WOClCt Debris must be no more than 10 em (4

Inches) WI one 6mellSion (L'" IllduI8SS 1miQ,-

acept ht tis 1tidulesa Imit may be waNed

under Ole "EquiYaIent Tec:h'tl:ltotzr IPP'CMI

AI lJsbtis: ObtaIn an "E4MJenI Tec:twIOlog)"'. AI DfIbris: Metal

. prowaI under t 268.42(b);8 haled de!lrIs must be

tepII'at8d from -.tment resa.Ia using ..,.

or mee:hanicaI rrl88N,8 and. prior 10 Iur·

ther tr8a1menl, sudI residue muSt meet the was.

IP8CiIic lreatlMnl 8land8rda tar organic

PClUI'lds WI the weste cantaninating Ole detlria.

Bride. Q,6\ Ccn::r'f1te, PIJpttT. Pa~ Rod;.

WOClCt Detlris must be no more Olen 1.2 em (~

inch) In one dimension (Le~ lNc:knesa Imit).'

Same.as 8bcMt, 8XC8I't that brldl. c:Iolh. concrete, Same-as 8bowe.

paper, pavement. rock end wood IUrfeces must be

In conl8d with the orvaniC vapor tor at least 60

minutes.

Same "asabcMt--------__--l Same as IbcM.

Met6/. PlilstiC. 1MJbfIr. Trutment to a ete8n AIDtJIJris: None.

debris surface.·

Bni::*. 00Il\ ConcntM. PItt-. Pa~ Rod;.

WDOCt RemOval of at least 0.8 em01 the ..-:.

treatment 10 a debris 1Urfac:e.·

Sameas Same as abo¥e.

b. ThBnnaJ DesaptiorL Heating WI an enclosed

chamber under either 0Iicizing or noilOXidizii lQ

atmospheres at IUffident l8mpera1l.n and ....

denc:e time to vaporize hazardous

tram contaminBted surfaces and sdac:e pores

and to f8Cl1OlI8 Itle conIaminents from !he heatIng etlentMwWla gaseous exheust gas.7

8. DesIruction TedvlOlogies:

1. Bif:/IogCaIDsslnK:Iion (~b7): Rernow- .. 01 hazardous conIarninanIt from detldI ....

faces and IUf1ace pores In en aqueous IOIuIIan

and biOdegIatioo'l Of or;aric 01 norwnNIIic inor·

ganc. Cl... ft)igallic::a ltlaI CClnIain

ptlOsphoiUS, nitrogen, 0I1U1tur) In wiIa operaI8d

W1dllr eitha- .-otlic or anaerobic COldtioi..

A. &1rK1ioft T~

1. fItIrsIc* &IrIIc:tion

a. Bl8SIittfF Removal of contarhnat8d

debns IUI1ace Iayera using water and/or ..

....... to prcpeI • solid mecia (e.g.. steel

shot. aluminum oxide om. plastic beD).

b. Mtd Process

UIIiZing Rilling pIst.on heads. saws. or rotating

pning wtleeIa IUdI thai contaminated d6tlriI

turface IIlyers ani removed.

Co Drillingor e:tlil::Plnlil hoIet at

IocatiOM and deplft In the contaminaIed debris

..-:. and applying a tool whictI aetlI • forca

.on ...... of·1hoa8 holes IUd'! Chat the ... face .,., It NmCMId.. The surface __ ,.

mowed remeIns I'IaDIdous debriS NlIect to the

debrillreatrnenlllanderds.

d. F~ Pn:ic:ess utilizing IC:fWblng

IMCI&. Ilushing IIuid. osc:iIating enervr IUdl

tNt tIazaniouI contaminants or c:ontamnated

dllbtls utace.... ant AlmCMld..

a. High PrfI$SlIW Slam Mtd Wa" AppIcation Of water or steam sprays 01 tuIfic:ient

temperaVe, pr8SS&n, l'8sideIlC8 1I'ne, egiIation.

IUifadantI. and de1ergenIa 10 f8IIIO¥e hlWwdClUS contaminants Crom debriI IUffaces or to

remcMt ccntaminated debris -.face Iayera..

2. Cherhc:al ExtnIclion

a. .Watsr WashiJg Mtd App6:don 01

water IPf'8YS or water baths 0I1Uftic:ienll8mper·

.lure, pr8ssure, residence time. N1actants. acids, bases. and detergents to fIIIIlOWe

I'lazardous contaminants from debriI Nt8ces

and IUftace pores or 10 l'8rnOY8 CClfltIln*laIed

debrillUrface

b. Liquid Phase SoIwJnt &tr1It:tion: RenlCMII of

hazardous c:antaminants from debris aurteces

and eurtace pores by applying a

liquid orIiqlC solution whictI ClIUS8S ltle

ClUS contaminants 10 enterItle liquid phase and

be ftushed away from the detlfiS aJong will Itle

IquIc1 or IOlutiOn tmIe usWIg appropriate

agitation. temperature. and resldenc:e time.·

c: v~ PtIII58 SoNenI bIraction: ~tion of

en organic vapor using tuffic:ienl ~liOn, r"

dence time, and temperaUe to cause hazard. ous c:ontaIIWlanIs on contaminated debris ...

faces and IUrface pores to enter ltle yepor

ptIIlS8 end be bhed -.y wilh ltle organic

vapor••

3. ThermalExtraclion

a. High TtJI1f1InbrB IIetII/s R«JtNtJty: Application

of IUffic:ient heat. l'8sideIlCe lime., IIuJling

agenIS, antJIorC8Itlon in • Imelling. melting. or

retnng Iumece to i8p8flI1e metals tromdebriL
Technology~l

•

•

None.

None.

Stick. ConcretB, sass. A/Bt./. 1'8vemtJnI. Reck.

IJ<1t8J: Metals other ItIan men::ury. except that

there are nometaJ rest!iCtiOllS fer vi1rtftc:ation.

DeI:JM COfI!lImiMlSd with • dioJdn.IisISd Ir2J5I8. I

Obtain an"EQUivatent Tec:hlOloW' approyal.under

f 268.42(b).I except that this recoui'9menl does not

apply to 'Iitritication. "

AI D«JriII: 0tJtaIn en ""'EquIvalen( Tect.lOIogy" • AIDebtfs: Metal contamlnMtl.

proveI under I 268.42(b):1 IreaI8d d8tlrlI muIt be

aePera18d from natment r8IidueIa UIIng IimpIe

phySical or mectlanic:aI rneana.I end, prior to fur·

ther lr8lItment. such residue must rneel .......

spedfic: treatment standarda lor organic

pounds In the waste contan*lating ltie debriL

8rit:J4 0014" hptJT, Rod.

W<loct Debris must be no more Itl8ft 12 em (~

Inch) In one dimension (I.... "Ilicknesa 1imiO.I

8llC8PC that IIlia IifIIit be waMId

under ... "'Eeplt8lenl Tec:h1Olog)'"

Same asabcMI.------------I same as above.

Treated debris must be I8P8t8t8d from treatment

residuals using $Imple pt1ylIIcaI or mec:haNcaI

means.1 and. prior to fw1her treatment. such reeldue must meet the waste-spec:ific: treatment standards lor organic compound$ In the waste c0ntaminating the dobns.

Eneapsulating material must CCllitpletely encapsulate

dobria and be resistant to degradation by the

debria and its contaminants and materia into

"WtliCh It may come into contae:t after piacernent

(leachate. other waste. microbes).

Leaet\ability of the hazardous contamInanta must be

reduced.

Sealing must avoid ~1l'Of 1M debris Nface 10

potential Ieac:hng media and eee£an( muIt be

resiStent to degradatien by the debriI end ill

contaminanta and materialS i'ltD "whiCh • 1M)'

corne into contact after pIac:ement(1eec:NIt8. OCher

waste, mictobos).

2. a.mIc:8I Destndon

.. 0ttJmicM 0'Gmlc:aI or IlectoIyllc ...

dation utilizing ... toIIowing 0IIida1i0n reegena (or waste reagentS) or comtlinallon of ,..

gents-(1) hypocNorite bleach); (2)

rlne; (3) chlorine daxide: (4) ozone orLN

violet IighQ asaist8d ozone; (5) peroxidea; (6)

persulfates; (7) pen:Norates; (8)

ates; 8IldIor (9) other 0IIidIzing reagents of

equivalenl destrudicln effiQellCJ.· Qlemc:aI =-

dation specifically includes .....t II referred10 ..

alkaline etlIorination.

b. a.rrw:.J RstNctiotr l'88Ction utI2VIg

... IoIIowing nldudng reagentI (or nste·reagents) or combination of reagents: (1) lUlU

dioxide; (2) IOCUn. potassUn. or aIk.aI I8ItS of IUIfites. bisulfites, and ~_8f'd p0lyethylene gIyccII (e.g... HaPEG end" KPEG); (3)

sodium (4) f8ITOUI aaIts; and/or (5)

other reducing reagents of eIficien- "ct·' . 3. 1'htJI't1WIDBstrucIiotr Treatment In Cllncinetatar

operating In ac:c:orcsanc:e wilh &bpert 0 of Patts

264 or 26S of this chaptsr; a boiler or induSttiaI

tumace operating i'I ecCol'ltallc:e willi H

of PlItt 266 of this chaptar. or o:her tnermaI ....tment cnt operated In ac:consance wittt Subpart X. Part 264 of "this cN;lC8r. or Sctlpert p.

Pan 265 of this cNpt8r. but 8lidudIng for pur.

poses of these"detlris treatment 5talidaRiS Ther·

mal Desorption ll'lits.

C.Immobilization TechIOIogies:

1. ~tioa A;lplication of llUI'tace

coating materials IUCtI .. orgat*:s

(e.g.. resinS and plastic::s) or of a jadt8t 01

inert mganic materials to Slbstantialt ftlduC:e

uface £lqlOSln to potential IIllMfia.

2. ~tioa Stabilizalion of IIIe debtiS

with the following reagents (or waS!8 reagents)

such 1hat the Ieactlabiity 01 1Mhazardous c0ntaminants is reduced: (1) PolUand CllI"IClI'It or (2)

limelponolans (e.g.. fly ash end cement kiln

dust). Reagents (e.g.. Wn salts. IiIicates. end

days) may be eddecl to erNnce the MtlCln

lime and/or compessive strengttl. or 10 reduCe

... IeachatliIity of ltie ba:atdauI c:onstitu8ntS.'

3. Saling: Application of an appcoprlate mat8riaJ

whiCh adheres lightly to the dabItI Nfac8 to

avoid aposure of ltie surtae:e to pol8IItiaIleac:hing rnoc:ia. When necesaary II) IIffedMIty leal

ltie ..... seaJing encaas ptetrealmllnl of 1M

debris surface10 remove Ioreign matter and to

dean and roughen the suiac:e.

... ft:Iude epoxy. 1iEcone. end ""thane ccm- pounds, but paint maynot be used ...NaIanL
..

• ,

6.0 SAMPLING AND ANALYSIS FOR CLEAN CLOSURE

All closures will include a sampling and analysis component. At a minimum, sampling

and analysis will be necessary to characterize the areal and vertical extent of .

contamination at and/or released from the closing unit and to confirm the effectiveness of

closure activities. .

6.1 Sampling and Analysis Plan

All closure plans must include a sampling and analysis plan. Sampling and analysis plans

should specify procedures which ensure that sample collection, handling, and analysis will

result in data of sufficient quality to plan and evaluate closure activities at the facility.

Sampling and analysis plans should be designed to define the nature, degree and extent

of contamination at and from the closing unit to the fullest extent possible. The level of

detail in the sampling and analysis plan should be commensurate with the complexity of

conditions at the closing unit. Sampling and analysis plans must include information

necessary to insure proper planning and implementation of sampling activities. All

sampling and analysis plans should include the following information and rationale for

each selection:

•

(1)

(2)

(3)

(4)

A statement of the purpose and' objectives of the data collection;

Organization and responsibilities for the sampling and analysis activities;

Project schedule;

General information on selection of types of samples needed (i.e., grab or

composite), and amount of samples to be analyzed;

•

(5) General information on selection of sampling locations and method used to

determine where the sampling will occur;

(6) Specific sampling approach and methods, including:

Sampling locations and a unique ill number for each location;

Protocols for sample labeling and chain of custody;

Procedures for installation of sampling devices;

Procedures for sample collection and handling;

Procedures for personnel and equipment decontamination;

Sampling and Analysis for Clean Closure 29
Procedures for the management of waste materials generated by (.-/

sampling activities; . ./

Description and number of quality assurance and quality control

samples, including blanks and duplicates;

Provisions for splitting samples, when appropriate; and

Confirmational sampling to demonstrate clean closure.

(6) Sampling and analysis procedures to confirm decontamination of tanks and

concrete containment systems and other media or equipment (if required).

(7) Procedures for analysis of samples and reporting of results, including:

Selection of a laboratory;

Identification and justification of parameters to be sampled and

analyzed;

Physical and chemical properties of the wastes to be sampled;

Analytical techniques and procedures;

Detection or quantitation limits;

Quality assurance and quality control procedures; and

Data reporting procedures and, where appropriate, data validation

procedures.

6.2 Designing a Sampling Program

Sampling programs should be designed to determine the probable maximum horizontal

and vertical extent of contamination at and from the closing unit. At the end.of the

closure process, additional sampling is typically required to confirm clean closure levels

have been achieved.

When designing a sampling program, facility owner/operators should consider area-wide

sampling, focused sampling, and sampling for hot spots. Knowledge of past management

practices at the facility should help. determine which type of sampling is the most

appropriate. In many cases, a, combination of sampling techniques will be required, for

example, area-wide sampling of a closing unit could be combined with focused sampling

at the location of a known release. Each type of sampling is discussed briefly in this

guidance. Facility owner/operators are encouraged to rely on Ecology's Sampling and

o

30 Sampling and Analysis for Clean Closure
•

•

•

Data Analysis Issues for Ecology Staff to Consider in Reviewing Independent Remediation

Reports (available September, 1994) for specific guidance on the preparation of sampling

programs. For additional information on sampling, facility owner/operators may consult

U.S. EPA (1986b), U. S. EPA (1984), and Schweitzer, et al, (1984).

6.2.1 Area-Wide Sampling

During area-wide sampling, an imaginary sampling grid, three-dimensional if necessary, is

imposed over the area to be sampled. The area to be sampled must encompass the

closing unit and the maximum extent of any releases from the closirig unit. Each node of

the grid is a sampling location with an assigned number. Area-wide sampling is

appropriate when the spatial distnbution of contamination at or from the closing unit is

uncertain.

Variations of area-wide sampling include random and systematic sampling. In these

variations, only certain nodes in the grid are sampled. For random sampling, a computer

can be used to choose each sample location randomly from the nodes on the grid. For

systematic sampling, a repetitive pattern of sampling is established such that, for example,

every fifth node on the grid is sampled.

6.2.2 Focused Sampling

.Focused sampling involves selective sampling of areas where contamination is expected

or releases have been documented. Focused sampling should be conducted, in addition

to grid sampling, where there is evidence of leaks or spills or potential for a dangerous

waste constituent to migrate. Focused sampling could involve linear sampling along a

drainage-way, boundary, or other linear dimension. Likely areas for focused sampling

include, but are not limited to: .

(1) Containers, tanks, waste piles, or any other units (such as ancillary pipes) in

contact with soil;

(2) Below any sumps or valves;.

(3) Load or unload areas;

(4)· Storage units with underlying pavements or concrete that appears to be

cracked or broken; and

(5) Areas receiving runoff or discharge from dangerous waste .management .

units, such as a ditch, a swale, or the discharge point down gradient from a

pipe.

Sampling and Analysis for Clean Closure 31
Evidence for additional areas of focused sampling could include:

, ,

(1) Visual or olfactory evidence of contamination including evidence based on

direct reading field instrumentation or field test kits;

(2) Knowledge, such as reports by employees, inspectors, or others, that

releases have or may have occurred;

(3) Length of time the unit has been in existence;

(4) Entries into the unit operating record; and

(5) Soil gas surveys or soil borings.

For small units where there is documentation of the extent of contamination, Ecology

may approve use of focused sampling exclusive of grid sampling.

6.2.3 Sampling for Hot Spots

Hot spots (or small patches of higher-level contamination) may be encountered during,

area-wide or focused sampling. If hot spots are encountered or suspected, sampling

programs can be designed to delineate their size and location. The intensity of sampling

for hot spots will depend ·on the anticipated size and/or number of hot spots. Detailed C'

information on designing sampling plans for detection and characterization of hot spots

can be found in Gilbert (1987).

6.3 Sampling to Determine or Confinn Clean Closure

The area-wide approach outlined above is generally appropriate for sampling to

determine or confirm that clean closure levels are achieved. The sampling grid used to

determine or confirm clean closure should overlay contaminated areas discovered during'

the initial sampling at the unit. .

If a sample collected duringclosure confirmation exceeds the cleanup standard, then the

area represented by the sample (subunit) will be considered to exceed cleanup standards

and additional actions will be required. These additional actions could include removal

of media followed by additional confirmational sampling, and/or additional sampling, or

statistical analysis at the subunit or across the entire closing unit.

6.4 Statistical Guidelines

Ecology will typically make decisions regarding clean closure by direct comparison of

sampling data to the site specific clean closurelevels. If contamination at or from the

closing unit is widespread, Ecology may require that the Statistical Guidance for Ecology

Site. Mangers (1992) be used to confirm that clean closure levels have been achieved. ()

32 Sampling and Analysis for Clean Closure
•

When a background comparison is used to determine cleanup levels, then the Statistical

Guidance for Ecology Site Managers (1992) or an equivalent method must be used to

confirm that clean closure levels have been achieved.

For more information on statistical analysis, facility owner/operators can consult U. S.

EPA (1986b) and Schweitzer, et al. (1984).

6.5 Soil Sampling During Closure

The following soil sampling considerations are specific to the closure process. Facility

owner/operators are encouraged to rely on Ecology's Sampling and Data Analysis Issues

for Ecology Staff to Consider in Reviewing Independent Remediation Reports (available

September, 1994) and U.S. EPA (1989b) for more detailed guidance on soil sampling.

6.5.1 Soil Sampling Under Structures

Soil sampling locations at a closing unit will typically belocated over structures as well as

exposed soil. When sampling points (including sampling points determined by the grid

system for area-wide sampling) overlay structures, Ecology may require the underlying

soil be' sampled. Soil sampling under structures should generally be conducted after

cleaning and decontamination of the structure but before the structure is removed.

Sampling of soils under structures will be done through holes bored in the overlying

structure, if possible. For example, samples of soil overlain by concrete should be

collected through holes bored in the concrete. Sampling under structures must be

conducted in a manner which minimizes disturbance to the underlying soil.

After any structure is removed, Ecology may inspect the underlying soil. Areas under

documented spills and areas susceptible to releases will receive close scrutiny. Additional

sampling and testing may be required if there are indications of discolored soil, the

presence of wet areas, volatile emissions detected on field detection equipment; odor, or

other signs of potential contamination.

6.5.2 Soil Sampling at Various Depths

Ecology may require soil sampling at various depths to determine the extent of

contamination. The intervals for sampling soil at various depths may be dependent on

several factors, including:

i.

(1) Soil type and permeability;

(2) Suspected magnitude of surface contamination;

(3) Physical state of the waste and its mobility;

• (4) Groundwater level;

Sampling and Analysis for Clean Closure 33
(5)

(6)

Length of time waste was present at the site; and

Relative toxicity of the waste.

If surface samples demonstrate contamination, then sampling must be conducted at

depth intervals to determine the extent of contamination.

6.6 Groundwater Monitoring During Closure

In the event of confirmed or potential soil contamination, groundwater monitoring may

also be required to demonstrate or confirm clean closure. Groundwater monitoring may

be required for any dangerous waste management unit, including those not subject to a

regulatory requirement for groundwater monitoring under WAC 173-303-645 (e.g., a

container storage unit). If the closing unit is already subject to ground water monitoring

requirements, the well location, frequency of sampling, or constituents for groundwater

sampling may be modified during and/or after closure activities, as necessary, to.verify

that clean closure levels have been achieved. The duration and frequency of

groundwater monitoring necessary to verify clean closure Will be determined by Ecology

on a case-by-case. basis taking into account hydrogeologic conditions, waste

. characteristics, and other relevant factors.

When groundwater is contaminated, post-closure care will generally be required.

For additional information on sampling and evaluating groundwater, facility 0

owner/operators are encouraged to refer to Ecology's Sampling and Data Analysis Issues

for Ecology Staff to Consider in Reviewing Independent Remediation Reports (available

~eptember, 1994) and U.S. EPA (1988).

6.7 Selection of Constituents to be Analyzed

The data developed to support clean closure certifications and other closure decisions

must be of sufficient quality to withstand any scientific and/or legal challenges. An

overview of analytical considerations is provided in this section. For additional

information, Facility owner/operators may consult Ecology's Guidelines and Specifications

for Preparing Quality Assurance Plans issued in 1991, document number 91-16.

Selection of the proper analytical constituents must reflect current and historic operations

at the facility and closing unit. Certification of clean closure must consider all dangerous

waste constituents generated or managed at the facility and within individual units at the

facility; however, the closure process can often be expedited through use of indicator

constituents. Indicator constituents are constituents proposed by the facility

owner/operator and approved by Ecology as representative of the wastes managed at the

closing unit and their degradation products. To recommend indicator constituents; the

facility owner/operator must first conduct relatively broad-based sampling and analysis to

gather information on conditions at the closing unit; therefore, the closing unit should ()

34 Sampling and Analysis for Clean Closure
•

first be sampled for the full suite 'of dangerous waste constituents generated or managed

at the facility. For some units, this may include all the constituents listed in Appendix IX

of 40 CFR 264 and/or WAC 173-303-9905.

Facility owner/operators should base their recommendations of indicator constituents on

knowledge of the facility and closing unit and the results of the broad-based sampling

discussed above. In most cases, indicator constituents will be those constituents which

are most likely to have been released at or from the unit. For example, soil underlying

an F006 surface impoundment might be analyzed for 1,1,1,-trichloroethane, a solvent

likely to be used at a plating facility in addition to constituents common to the listed

F006 waste; or; soil at a unit used to manage chlorinated solvents might also be analyzed

for vinyl chloride, a common breakdown product of chlorinated solvents.

When reviewing and approving indicator constituents, Ecology will consider the following:

(1) The toxicological characteristic of the constituents that influence its ability

to adversely affect human health or the environment relative to the

concentration of the constituent at the closing unit;

(2). The chemical and physical characteristics of the constituent which govern

its tendency to persist in the environment;

• (3) The chemical and physical characteristics of the constituent which govern

its tendency to move into and through environmental media;

••

(4) The natural background concentrations of the constituent;

(5) The thoroughness of testing for the constituent at the closin.g unit;

(6) The frequency that the constituent has been detected at the closing unit;

and

(7) Degradation by-products of the constituent.

6.8 Approved Analytical Methods

Samples should be analyzed consistent with methods appropriate for the facility, the

media being analyzed, the dangerous constituents being analyzed for, and the anticipated

use of the data. Ecology may require or approve modification to the standard analytical

methods identified below to provide lower quantitation limits, improved accuracy, and/or

.greater precision. All analytical procedures should be conducted in accordance with an

Ecology approved sampling and analysis plan, as discussed in Section 6 of this guidance.

The methods used for. sample collection; sample preservation, transportation, allowable

time before analysis, sample preparation, analysis, method detection limits, practical

Sampling and Analysis for Clean Closure 35
quantitation limits, quality control, quality assurance; and other technical requirements ( "j

and specifications must comply with the requirements of the following standard methods ./

as applicable:

Test Methods for Evaluating Solid Waste, Physical Chemical Methods, Third Edition,

US EPA, SW-846 and any revisions or amendments thereto;

Methods for Chemical Analysis of Water and Wastes, u.s. EPA, EPA-600/4-79-020

and any revisions or amendments thereto;

Standard Methods for the Examination of Water and Wastewater, ASTM American

Public Health Association, American Water Works Association and Water

Pollution Control Federation and any revisions or amendments thereto.

SW-846 methods should be used to determine contaminant concentrations in soil and

solid waste. Any of the referenced methods may be used to determine contaminant

concentrations in groundwater. Analyses for which methods have not been specified in

this section should be performed using standard methods or procedures such as those

specified by the ASTM when available.

6.9 Multiple Analytical Methods

When more than one of the approved methods specified in subsection 6.8 ofthis C

guidance has a practical quantitation limit less than the cleanup standard, any of the

methods may be selected. When selecting a particular method, facility owner/operators

should consider confidence in the data, analytical costs, quality assurance, and analytical

efficiencies.

Ecology may require an analysis be conducted by more than one method if there is a

reasonable concern about the quality of the data generated by a particular method.

-6.10 Quality Assurance and Quality Control Requirements

During closure activities, samples must be collected and analyzed with sufficient quality

assurance and quality control (QNQC) procedures to ensure representative and reliable

results. The validity of both sampling techniques and laboratory analytical procedures

must be assured so that the data from sampling activities can be used to accurately assess

the presence or absence of contamination at the closing unit. For more information on

QNQC requirements, please refer to Ecology's Guidelines and Specifications for Preparing

. Quality Assurance Plans issued in 1991, document number 91-16. Additional information

on field documentation and chain-of-custody can be found in U.S. EPA (1986a).

I

+I

I

36 Sampling and Analysis for Clean Closure
•

•

•

6.10.1 Field Quality Assurance/Quality Control

A field notebook must be maintained by the person conducting closure. The person

conducting closure should use the field notebook to record times, dates, and locations of

all samples, including QNQC blanks, as well as daily events, observations, field

measurements, and any other applicable information obtained during the field activities.

All entries should be made in ink, signed, and dated. Photographs should be taken of

each sampling location and of all unusual circumstances encountered during closure

activities.

Field QNQC may'.also include. collection of specific types of samples designed to monitor

sampling technique and/or field conditions. Field blanks, equipment blanks, and/or

transportation blanks can be used to check for contamination from field conditions,

equipment, and/or transportation respectively. Field duplicates can be collected to check

the precision of the sample collection and/or the procedures conducted at the laboratory.

Field notebooks and photographs should be kept for a minimum of five years to help

reconstruct sampling procedures and to aid, if necessary, in legal testimony.

6.10.2 Laboratory Quality Assurance/Quality Control

All samples taken to document compliance with closure requirements should be

submitted to a laboratory accredited under Chapter 173-50 WAC. A listing of accredited

laboratories is included as Appendix 1. Updated lists may be obtained by contacting

Ecology's Manchester Environmental Laboratory at (206) 871-8800.

Quality assurance/quality control requirements associated with approved analytical

methods include analysis of check standards, duplicate samples, spike samples, and

method blanks. Check standards are used to estimate the precision ofthe analytical

method. Duplicate analyses of samples are used to check the precision of instrument .

and the sample preparation. Spikes are used to test for bias due to matrix interference.

Method blanks are used to check for laboratory contamination. Such QNQC should be

routinely run because they provide information for interpreting the accuracy, precision, ..

and detection capabilities of the analytical procedures used. As discussed in section 2.1

of this guidance, specific QNQC methods and activities must be detailed in the closure

plan.

Facility owner/operators conducting clean closure must obtain the QNQC results run

with each batch of analyses from the laboratory and must save the QNQC results with

other closure documentation ·for a minimum of five years.

6.11 Data Quality Objectives

Facility owner/operators should consider data quality objectives before conducting any

sampling activity. Data quality objectives are statements of the precision, bias,

.~;'

Sampling and Analysis for Clean Closure 37
representativeness, completeness, and comparability of the data necessary for the data to COo'/

serve the objectives of the project. Guidance on. data quality objectives can be found in /

Ecology's Guidelines and Specifications for Preparing Qualitj Assurance Project Plans, 1991,

document number 91-16.

6.U Practical Quantitation Limits

Laboratories must achieve the lowest practical quantitation limits (PQL) consistent with

the selected analytical method; however, Ecology recognizes that there may be situations

where a dangerous waste constituent is not detected or is detected at a concentration'

below the POL of the chosen analytical method. In situations where the clean closure

level is less than the POL, Ecology may require one or more of the following:

(1) Use of surrogate measures of contamination;

(2) Use or development of specialized sample collection or analysis techniques

to improve the method detection limit or PQL; and/or

(3) Additional sampling to assure that the concentrations of dangerous

constituents does not exceed detectable levels.

If, after alternatives have been exhausted, the PQL is still higher than the clean closure

.level for the constituent, Ecology may, based on site-specific considerations and

depending on the POL, consider the PQL to be the clean closure level. If Ecology uses a

PQL as a clean closure level, the clean closed unit may be referred to the Toxics

Cleanup Program for the periodic review discussed in WAC 173-340-707(2).

o

(

38 Sampling and Analysis for Clean Closure
•

•

•

7.0 CLOSURE TIME LINE

The dangerous waste regulations prescribe specific regulatory time frames for the closure

process. These regulatory time frames were promulgated at the federal level to ensure

that closures begin and are completed in a timely manner. Ecology recognizes that many

facilities may be unable to meet the specific time frames articulated in the closure

regulations; however, we believe that using time lines and time limits to drive the closure

process is vital to timely completion of closure activities. Facility owner/operators who

have reason to believe, when developing their closure plans, that the closure time frames

articulated in the regulations are inappropriate for their unit and/or facility are

encouraged to propose alternative time frames for Ecology review and approval in

accordance with the provisions discussed below.

7.1 Closure Notification

Facility owner/operators are required to notify Ecology prior to beginning closure

activities. Closure notification is required so Ecology can ensure that the facility has an

approved closure plan and that closure proceeds in accordance with applicable

regulations. For facility owner/operators without approved closure plans, the closure

notification triggers Ecology review and approval of the closure plan in accordance with

the procedures discussed in section 2.2 of this guidance.

Facility owner/operators with approved closure plans (this will include most final status

facilities, since the closure plan would have been reviewed and approved as part of final

permit issuance) must notify Ecology at least sixty (60) days prior to the date on which

they plan to begin closure activities at a surface impoundment, waste pile, land

treatment, or landfill unit and at least forty-five (45) days prior to the date on which they

plan to begin closure activities at a facility with.only treatment or storage tanks, container

storage, incinerator and/or boiler and industrial furnace units. .

Facility owner/operators whose closure plans have not yet been reviewed and approved

by Ecology (this will include most facilities operating under interim status) must notify

Ecology and.submit a copy of their closure plan at least onehundred and eighty (180)

days prior to the date by which they expect to begin closure at a surface impoundment,

waste pile, land treatment, or landfill unit and forty five (45) days prior to "that date they

expect to begin closure at a facility with only treatment or storage tanks, container

storage, incinerator and/or boiler and industrial furnace units.

The date which a facility owner/operator expects to begin closure must be either:

(1) .Within thirty (30) days of the date on which any dangerous waste .

management unit receives the known final volume of dangerous waste or, if

there is a reasonable possibility that the dangerous waste management unit

will receive additional dangerous wastes, no later than one year after the

Closure Time Line 39
- date on which the unit received the most recent volume of dangerous

waste; or

(2) For landfills, land treatment units, or surface impoundments which have

been given approval to receive non-dangerous waste in accordance with

WAC 173-303-610(4)(d) and (e) or 40 CFR §265.113(d) and (e) as

referenced by WAC 173-303-400(3), thirty (30) days from the date on

which the unit received the known final volume of non-dangerous waste or,

if there is a reasonable possibility that the unit will receive additional nondangerous waste, no later than one year after the date on which the unit

received the most recent volume of non-dangerous waste. -

Ecology may require a facility owner/operator to initiate closure activities. If Ecology

requires an interim status facility owner/operator to begin closure activities, the

owner/operator must submit a closure plan to Ecology for review and approval no later

than fifteen (15) days after termination of interim status or issuance of a judicial decree

or final order to cease receiving dangerous wastes and close, see 40 CFR § 265.1l3(d)(3)

as referenced by WAC 173-303-400(3). At permitted facilities, Ecology will impose

requirements to initiate closure activities in accordance with the provisions for permit

modification or revocation or reissuance at WAC 173-303-830(3) or the provisions for

permit termination at WAC 173-303-806(12).

7.2 Time Allowed for Closure

Facility owner/operators are allowed ninety (90) days from the date a closing dangerous

waste management unit received the final volume of waste or ninety (90) days from the

date Ecology approves the facility/unit' closure plan (whichever is later) to remove all

dangerous wastes from the closing unit in accordance with the Ecology approved closure

plan. Facility owner/operators are allowed an additional ninety (90) days (for a total of

180 days) to complete closure activities in accordance with the approved closure plan.

The time allowed for closure is referred to as the "closure period."

7.3 Additional Time Allowed for Closure

Ecology may approve additional time for closure in two circumstances:

(1) Closure activities will, of necessity, require additional time to complete

(referred to as "extension of closure"); or

(2) The closing unit has capacity to receive additional dangerous waste or the

closing unit is a landfill, land treatment, or surface impoundment unit which

has capacity to receive additional non-dangerous waste and complies with

WAC 173-303-61O(4)(d) and (e) or 40 CPR § 265.113(d) and (e) as

referenced by_WAC 173-303-400 (referred to as "delay of closure").

c

40 Closure Time Line
•

•

•

Many facility owner/operators may foresee, when preparing closure plans, that closure

activities will, of necessity, take longer than 180 days to complete or that the closing unit

will receive additional dangerous or non-dangerous waste. If this is the case, facility

owner/operators may submit appropriate documentation and request additional time for

closure period in the closure plan. Provided the documentation is sufficient, Ecology may

approve additional time for closure when approving the closure plan.

At a minimum; all requests for extensions or delays to the closure period should be made

in accordance with the procedures discussed below and should be submitted at least

thirty (30) days before the deadline for which the extension or delay is requested.

7.3.1 Extension of Closure

In order for Ecology to approve an extension to the closure period, the facility

.owner/operator must demonstrate that closure activities will, of necessity, take additional

time to complete. Ecology will determine, on a case-by-case basis, circumstances which

constitute a "necessity" for extension; however, Ecology would likely consider extensions

associated with required analytical work, scheduling of equipment and personnel, or

inclement weather conditions (e.g., frozen ground could prevent sampling) as necessary.

In addition to demonstrating that the extension is necessary, the facility owner/operator

must show that he/she has taken and will continue to take all steps to prevent threats to

human health and the environment. At permitted facilities, the demonstration must also

'include documentation of compliance with all applicable permit conditions and the

facility owner/operator must comply with all applicable requirements for modification of

the permit. Final status facility owner/operators should refer to WAC 173-303-

61O(4)(a)(i) for an extension to the closure period for additional time ~~ remove waste

and/or WAC 173-303;.610(4)(b)(i) for extension of the closure period for additional time

to complete remaining closure activities. Owner/operators of facilities operating under

interim status, should refer to 40 CFR § 265.113(a)(I)(i) and (b)(I)(i) as referenced by

WAC i 73-303-400(3).

7.3.2 Delay of Closnre

In order for Ecology to approve a delay of closure, the facility owner/operator must

demonstrate that the closing unit has capacity to receive additional dangerous or nondangerous wastes', that there is reasonable likelihood operation of the unit will

recommence within one year, and closure of the unit would be incompatible with

continued operation of the facility. Ecology will review and approve requests for delays

of closure on a case-by-case basis. As an example, Ecology would likely approve a delay

of closure if a facility owner/operator could demonstrate that the unit subject to closure

was not in operation because the waste stream managed at the closing unit is generated

by a process shut down for extended maintenance, the extended maintenance will take

4 Delay of closure for units to receive additional non-hazardous waste is only available for landfills,

land treatment units, and surface impoundments.

Closure Time Line 41
less than one year, and the process, when restarted, will generate the same dangerous C

waste stream. The facility owner/operator must also demonstrate that he/she has taken /

and will continue to take all steps to prevent threats to human health and the

environment. At permitted facilities, the demonstration must include documentation of

compliance with all applicable permit conditions and the facility owner/operator must

comply with all applicable requirements for modification of the permit. Final status

facility owner/operators should refer to WAC 173-303-61O(4)(a)(ii) and WAC 173-303-

610(4)(b)(ii). Owner/operators of facilities operating under interim status should refer to

40 CFR § 265.113(a)(1)(ii) and (b)(l)(ii) as referenced by WAC 173-303-400(3).

For Ecology to approve a delay of closure for a landfill, land treatment unit, or surface

impoundment to receive additional non-dangerous waste, the final status facility

'owner/operator must also comply with WAC 173-303-61O(4)(d) and (e). The

owner/operators of a facility operating under interim status must also comply with 40 .

. CFR § 265.113(d) and (e) as referenced by WAC 173-303-400(3). Delays of closure to

allow a landfill, land treatment unit, or surface impoundment to receive additional non- .

hazardous waste are considered class two dangerous waste permit modifications and must

conform with the associated requirements for review and approval, including public

notice and a 60-day public comment period.

7.4 Closure Certification

Within sixty (60) days of completion of closure activities at each dangerous waste C

management unit and within sixty (60) days of completion of final facility closure, the .

facility owner/operator must submit a closure certification to Ecology. The closure

certification must be sent to Ecology by registered mail and must certify that the

dangerous waste management unit or facility was closed in accordance with the

requirements and specifications of the approved closure plan. The closure certification

must be signed by the facility owner/operator and signed and stamped by an

. "independent qualified registered professional engineer". Documentation supporting the

closure certification must be provided to Ecology on request. At a minimum, Ecology

will typically require the following documentation and information to support a clean

closure certification:

(1) All field notes related to closure activities;

SEcology defines·"independent qualified registered professional engineer" as, "a person who is licensed.

by the state of Washington, or a state which has reciprocity with the state of Washington as defined in

RCW 18.43.100, and who is not an employee of the owner or operator of the facility for which

construction or modification certification is required. A qualified professional engineer is an engineer with C.\.;

expertise in the specific area for which certification is given." See WAC 173-303-Q40. ./

42 Closure Time Line
• (2) A description of any minor deviations from the approved closure plan and

justification for these deviations";

•

•

(3) Documentation of the final disposition of all dangerous wastes and

dangerous waste residues, including contaminated media, debris, and all

treatment residuals;

(4) All laboratory and/or field data, including quality assurance/quality control

data, for all samples and measurements, including samples and

measurementstaken to determine background conditions and/or to

determine or confirm clean closure; and

(5) A summary report which itemizes the data reviewed by the independent,

qualified, registered, professional engineer and tabulates the analytical

results of samples taken to determine and/or confirm clean closure.

7.5 Closure Verification

Ecology will verify closure certifications by reviewing the information submitted to

support the certification, the facility closure plan, any documentation or information

generated by Ecology during oversight of closure activities (e.g., inspection reports), and

other pertinent information and documentation. If Ecology accepts the closure

certification, Ecology will inform the facility owner/operator of the acceptance in writing.

In some cases, Ecology may be unable to verify the certification of closure and, therefore,

unable to accept the closure certification. Typically, these cases will involve

units/facilities at which groundwater contamination was discovered during closure

activities or units/facilities whose owner/operators did not keep the records and other

documentation necessary for Ecology to verify a closure certification. In such cases,

Ecology may require additional groundwater or other sampling and monitoring to verify

the closure certification or may require the facility owner/operator to submit an

application for a post-closure permit. If sampling and/or monitoring is required, ECology

will extend the closure period to cover the time period of the required monitoring, and

the closure certification will not be accepted until the facility owner/operator has

completed the required activities.

6Most deviations from an approved closure plan are SUbject to prior Ecology review and approval in

accordance with the provisions for amending closure plans,.see section 3.3 of this guidance.

Closure Time Line 43
•

•

•

8.0 REFERENCES

American Public Health Association, American Water Works Association and Water .

Pollution Control Federation, Standard Methods for the Examination of Water

and Wastewater.

American Standard Testing Methods, 1916 Race Street, Philadelphia, PA 19103.

Gilbert, R.O., 1987, Statistical Methods for Environmental Pollution Monitoring, Van

Nostrand Reinhold Company, New York, NY, 320 pp.

Schweitzer, G.E., and I.A Santolucito, 1984, Environmental Sampling for Hazardous

Wastes, ACS Symposium Series No. 267, American Chemical Society, Washington,

D.C.

u.S. EPA, 1985, Guide for Decontaminating Buildings Structures and Equipment at

Superfund Sites, U.S. EPA, Cincinnati, 600/2-85/028, March 1985.

U.S. EPA, 1986(a), Test Methods for Evaluating Solid Waste, Vol. 1 (Lab Manual), EPA

OSWER SW-846, Third Edition and Subsequent Updates.

U.S. EPA 1986(b), Test Methods for Evaluating Solid Waste, Vol. 2, EPA OSWER SW846, Third Edition and Subsequent Updates.

u.S. EPA, 1988, Methods for Evaluating the Attainment of Cleanup StandardsVolume 2: Groundwater. Draft 2.0, U.S. Environmental Protection Agency.

u.S. EPA, 1989(a), Methods for Evaluating the Attainment of Cleanup StandardsVolume 1: Soils and Solid Media, EPA 230/02-89-042, U. S. Environmental

Protection Agency Office of Policy, Planning, arid Evaluation, Washington, D.C.

u.S. EPA 1989(b), Soil Sampling Quality Assurance, EPA 600/8-89/046, U.S.

Environmental Protection Agency, Environmental Monitoring System Laboratory,

Los Vegas, NV.

u.S. EPA, Guidelines Establishing Test Procedures for the Analysis of Pollutants Under

the Clean Water Act, 40 CFR 136, and Appendices A, B, and C.

u.S. EPA, Methods for Chemical Analysis of Water and Wastes, EPA-600/4-79-020.

Washington State Department of Ecology, 1991, Guidelines and Specifications for

Preparing Quality Assurance Plans, Environmental Investigation and Laboratory

Service Program, Washington State Department of Ecology, Document 91-16.

References 45
Washington State Department of Ecology, 1992, Statistical Guidance· for Ecology Site C· j

. Managers, Toxics Cleanup Program, Document 92-054. j

o

( 'tj

46 References
•

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Appendix 1

Order Form for Other Ecology Documents
•

•

•

Department of Ecology

Hazardous Waste and Toxics Reduction Program

PUBUCATIONS

The following publications are from the Hazardous Waste and Taxies Reduction Program. To

receive your free copy simply call (206) 407-7472.

An Evaluation of Atypical Hazardous Waste: Background Document to the Washington

State Hazardous Waste Plan, #92-60

Saatypical wastestreams are examined to determine how the state can best regulate these

wastes. Atypical wastes were selected as those which are both already addressed by other

federal and state programs, and are state hazardous waste.

Biological Testing Methods, #DOE 80-12

Describes the Static Acute Fish Toxicity Test and the Acute Oral Rat Toxicity Test.

These tests were developed to be used to determine whether a waste meets the state

definition of a dangerous waste. Contains testing procedure guidelines including how to

calculate results.

Carcinogens Regulated Under the Dangerous Waste Regulations .

This memo lists the carcinogens that have been identified as having sufficient or limited

evidence as a human and/or animal carcinogen by both the !ARC and the U.S. EPA.

Chemicals are listed by their CAS number.

Certification Guidelines

These guidelines establish the procedures to be followed for obtaining, maintaining, and

withdrawing a Certificate of Designation. This voluntary certificate establishes the

appropriate designation status for solid wastes.

... Chlorinated Solvents: A Guide to Evaluation Alternatives for Vapor Degreasers and Cold

Cleaning Operations, #93-BR-02

This guide provides a detailed cleaning alternatives chart, emissions control information

and other process, cleaning and pre-eleaning suggestions to reduce solvent use.

Choosing an Analytical Laboratory for Dangerous Waste Testing.

Information to help generators ask the right questions in choosing an analytical lab to test

samples to determine whether or not your waste designate as hazardous wastes.

Clean Closure Guidance, #F-HW1W-94-144

1
Cost Analysis for Pollution Prevention, #R-HWTR-93-129 C-~

A guidance document that can help compare the total costs of a.current process to the ./

total costs of a pollution prevention alternative by using the net present value.

Creosote-Treated Wood Excluded from Regulation as a Dangerous Waste

Discussion of Ecology's decision to exclude certain creosote treated wood wastes from

the Dangerous Waste Regulations. Outlines the special cases when the exclusion does

and does not apply.

The Dangerous Waste Pennit Process, #9O-BR-15

Pamphlet outlining the six steps to permitting a hazardous waste facility. Includes

information source list.

Dangerous Waste Regulations: ·Code Reviser #92-91

.1994 update of codes.

Dangerous Waste Regulations, Chapter 173-303 WAC, #92-91

This revision includes the rule amendments adopted in January. An index and glossary

have been·added.

Discussion Paper on Used Oil

Guidance to clarify when 'regulations apply, what the requirements are for the regulation c.

and management of used oil, specifically requirements regarding burning used oil for

energy recovery, and answers to some common questions.

Discussion Paper on Used Oil Burned in Space Heaters, September 1990

This document explains the current state used oil regulations, and answers specific

questions on burning used oil in space heaters.

Discussion on the Toxicity Characteristic Rule, #90-64

Do the Right Thing Study: Background Document to the Washington'State Hazardous

.Waste Plan, #92-58 .

This report was designed to provide abasis for estimating future waste reduction

potential to be used in the Needs Assessment for Washington. Nine individual waste

streams were studied to identify current practices, determine the best management for

these wastes, to ascertain the potential of achieving this management, and to understand

all the barriers to achievement.

Dry Cleaners- Fact Sheet #5

Pollution prevention information for the industry.

2 C~)
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Effective Date of the 9O-Day Storage (Accumulation) Requirement, TIM #82-5 .

Clarification of the storage time requirements for generators of hazardous waste,

specifically addressing "unknown" wastes.

Emergency Planning and Community Right to Know, #93-BR-ol

Employee WaSte Reduction Poster

Empty Pesticide Container Disposal, #92-BR-8·

Guidance for Growers and Commercial Applicators

Floor Drains and Waste Don't Mix, #94-117

This short publication gives information on why floor drains should be'sealed, and

outlines steps to follow that will keep existing drains from polluting the environment.

Focus: "Counting" Exemption for Recycled Used Antifreeze

This three 'page guidance document lists the best management practices.required for

participation in the pilot project. A sample form is included for logging your antifreeze

recycling.

Focus: Haurdous Waste Reduction Act, #91-111

An overview'of the goals and programs put in place by the Hazardous Waste Reduction

Act covering Hazardous Waste Pollution Prevention Plans, the Hazardous Waste·

Education Fee, business 'and industry technical assistance, and local government grants

are covered.

Focus: Hazardous WastelMaterials Transportation, #F-SHW-93-123,

This short document tells which vehicles are regulated as transporters of hazardous

materials, the responsible agencies and contact numbers for questions.

Focus: Noise Rule Amendments, #F-HWTR-94-141'

Soliciting public comment on proposed noise rule amendments designed to incorporate

three rules into one for simplification.

Focus: Proposed Amendment to the Wood Ash Exclusion.#FHWTR-94-138

FOCUS sheet details the regulatory exclusion for wood ash waste which designates solely

because of corrosivity (high pH.)Focus: Used Oil Dumping Ban, #F-93-123

Explanation of the ban on landfill disposal of used oil. Recycling of used oil is

encouraged, disposal is discouraged because it causes environmental damage.

Focus: Used Shop Towels, #92-116

This focus sheet provides guidance on ways to handle shop towels that become

contaminated with hazardous solvents.

3
Focus: Pollution Prevention Planning Requirements, #92-117 C--j

An outline for Hazardous Waste Pollution Prevention Plans that includes information on /'

who must prepare a plan, what information to submit, when plans are due, and.how to

get questions answered.

Focus: Treatment-Specif"IC Guidance: Solidif"lCation, #F-HWTR-93-132

Focus: Treatment-Specif"IC Guidance: Filtration, #F-HWTR-93-131

Focus: TreatDlent-Specific Guidance: Separation, #F-1IWTa-93-135

Focus: Treatment-SpecirlC Guidance: Carbon Adsorption, #F-HWTR-93-133

Focus: Treatment-Specif"IC Guidance: Evaporation, #F-HWI'R-93-134

Focus: Treatment-Specif"IC Guidance: Elementary Neutralization, #F-HWrR-93-130

Focus: Washington State Dangerous Waste Regulatory Reform PrOject, #F-HWrR-94-143

This FOCUS Sheet describes the background, goals and implementation strategy of a

current project that will identify possible changes to the Dangerous Waste Regulations.

Guidance for Reporting Progress in Pollution Prevention, #93-38

This guide contains six worksheets to help facilities prepare required annual progress C

reports as part of the pollution prevention planning arid implementation process. .

, Guide for Assessing and Certifying Tank Systems Storing and Treating Dangerous Waste, .

#94-114

Hazardous Materials Transportation Guide for Carriers

This guide is designed to simplify rules governing transport of hazardous materials.

Includes a step-by-step check list for transporters and shippers.

Hazardous Waste Annual Report Summary, #92-89

Hazardous Waste Do's and Don'ts

These guides offer industry specific guidelines with direct answers about how'to manage.

the wastes generated by these industries: Dry Cleaning #9i -12c, Electroplating #91-12g,

and Pesticide Application #91-12d..

Hazardous WaSte Pesticides

Determining if Your Pesticide Waste is a "Hazardous Waste" and Pesticide Waste

Reduction Guidance

4
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Hazardous Waste Regulatory Alert: Update on Used Oil Filters, 10/91

Iriterim guidance which recommends that used oil filters should be punctured and

drained, or crushed, and segregated from other wastes. Described conditions under which

they may be recycled or disposed.

Leasing Equipment for Pollution Prevention, #93-BR-04

This information sheet provides guidelines for leasing pollution prevention equipment,

and includes a list of leasing companies.

Legislative Briefsheet: Reducing HW andHazardous Substancesin Washington, #B-HWTR94-140

Management and Disposal of Asbestos Wastes Under the State's Dangerous Waste

Regulatiom

Describes the conditions under which asbestos wastes may be exempt from regulation as

hazardous waste. Includes an information source list.

Needs Assessment for Washington: Background Document to the Washington State

Hazardous Waste Plan, #92-59

This report examines past and future hazardous waste management. Trends are used to

project waste generation. Future demand for hazardous waste storage is projected with

an analysis ofimpacts of moderate risk wastes, regulatory changes, clean-up wastes and

out-of state wastes. Commercial capacity needs are examined under three possible

scenarios, each with its own implications.

Now Your Company can Save Two Things at Once, #93-BR-09

Pamphlet explains how waste reduction protects the planet and your bottom line. Includes

where to go and who to.call for help.

On-Site DajJ)ation: A Guide for Choosing and Operating an On-Site Distillation Unit

#94-31

This guide is designed to. help businesses in reclaiming solvent wastes. It includes:

questions to ask vendors, a cost-benefit analysis guide and information on regulatory

compliance. .

Pollution Prevention Planning Guidance Manual, #91-2

This manual is designed to guide planners through the calculations and reporting

requirements to prepare pollution prevention plans. It includes an overview of the state

law, planning requirements and due dates and the plan review cycle. Nineteen worksheets

are provided which include all the information required in the plans, the extensive

appendix can be used as a reference.

5
Pollution Prevention in the Fn1it Packing and Storage Industry, #94-56 . C·~.

This technical assistance document identifies usable ideas related to cost incentives, ---'

pollution prevention, and waste management available to the Fruit Packing and Storage

Industry, SIC code 0723.

Pollution Prevention in the Fn1it and Vegetable Food Processing Industry, #94:-52

This technical assistance document identifies usable ideas related to cost incentives,

pollution prevention, and waste management available to the Fruit and Vegetable Food

Processing Industry, SIC code 0727.

Property PurclIase and Hazardous Waste

Recommendations for the State Hazardous Waste Plan: Background Document to the

. Washington State Hazardous Waste Plan, #92-61 .

This report is the culmination of 1989-91· effort by the State Solid Waste Advisory

Committee on Hazardous Waste Planning. Drawing on three other research reports

prepared by the same body. Recommendations include; maximizing the hazardous waste

management priorities, addressing the states' need for additional hazardous waste

management facilities, regulationsimprovements, information collection goals, and public

education strategies.

Recovering Heat Energy While Burning Dangerous Waste: The Regulatory Status of a

"Unit.", Pub. #94-85 0

Technical Iriformation Memorandum with updated guidance on the status of "units" that

recover heat energy from burning dangerous waste.

Reducing ,H~zardous Waste and Haozardous Substances in Washington: 1992 Annual

Progress Report, # 93-103

In 1992 307 state facilities which generate hazardous. waste submitted their required

pollution prevention plans. This report summarizes the results of annual progress reports

from these facilities. Ecology's technical assistance activities and an industry specific

staff list is included.

Reducing Hazardeus Waste: Waste Reduction Guide for the Electroplating Industry

This guide offers industry specific waste reduction techniques for specific wastes types,

. including: plating baths, sludge, spent solvents, paint wastes and wastewater .

Regulation of Dangerous Wastes Being Recycled, #91-46, Revised February, 1994

This guidance document is designed to help generators determine if a recycling activity

involving hazardous materials is regulated under Washington State Dangerous Waste

Regulations.

6 C)
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Regulatory Impediment Study: A Report on Impediments to Waste Reduction and

Recycling in State Dangerous Waste Rules, #93-16

This study addresses and offers solutions to the conflicting regulations contained in the

hazardous waste hierarchy and the dangerous waste rules. A plan for implementing six

key recommendations is included.

Regulation of ·Used Antifreeze·, TIM #90-1

An interpretation of the existing regulatory status of used antifreeze as a dangerous waste

with brief guidance for generators, transporters, recyclers and treatment, storage or

disposal facilities dealing with used antifreei:e.

Responsiveness Summary: Amendments to the Wood Ash Exclusion, #94-40

Responsiveness Summary: Amendments to the Dangerous Waste Regulations, #94-40

Siting Criteria Guidance .

Guidance on "Demonstration ofCompliance for the Siting ofLand-Based and Non Landbased Hazardous Waste Management Facilities" and "Demonstration of Net Increase in

Protection Under Washington's Hazardous Waste Siting Criteria."

Step by Step: Fact Sheets for Hazardous Waste Generators, #91-12

Packet of ten easy to use guidelines and a glossary to .help answer all your hazardous

waste management questions. Our most popular publication.

Success Stories .

These stories outline the waste reduction and recycling successes of state businesses.

Each story examines how one business developed and implemented successful strategies.

Auto Body Restoration and Painting

Chemical Manufacturing

Metal Recovery Aids Compliance

Recycling Cuts Discharge

Vapor Degreaser Alternative

Success Stories Volume I, n and m

Washington businesses share their experiences with pollution prevention planning.

Summary Report Automotive ·Shop Sweep" Campaign, #94-05

This reports summarizes findings from the 1992 "Shop Sweeps" short assistance visits

made to over 1,700 automotive repair shops in the state. The unique attributes of the

campaign are examined, including the approach and goals. Findings are analyzed and

include detailed comments from participants and recommendations.

7
Toner Cartridges

Treatment by GeDerators, TIM # 86-3

Guidance on 'how generators of hazardous waste may treat these wastes on-site, in

accumulation tanks or containers, without a dangerous waste treatment permit. Includes

background information, how to proceed, general standards and Ecology contact list.

Washington State Hazardous Waste Plan: 1994 Update

This document reviews Ecology"s ongoing and future activities and their impact on

, hazardous waste generators.

Washington State Toxic Release Inventory: Summary Report, 1991 and 1992, #94-91A

The second annual summary of toxic chemical report forms submitted by manufacturing

facilities in Washington State.

Washington State Toxic Release Inventory: Public Data Release, 1991 and 1992, #94-9IB

Companion document to the Washington Stille Toxic Release Inventory: Summary

Report. Summary of information submitted by manufacturing facilities in Washington.

·,

C~

Waste Reduction In Your BUsiness, #89-56

This manual is designed as a tool"to help businesses reduce that amount of waste they

produce. It includes worksheets and checklists and explains: the benefits of waste

reduction; how to start a program; how to conduct an audit; How to evaluate options and C"

who to call for assistance.

Waste Reduction for Vehicle Maintenance Shops, #92-107

This guide offers industry specific waste reduction techniques for specific wastes types,

including: solvent wastes, hot tank wastes, used antifreeze, used oil, oil filters, spent

batteries, shop rags, refrigerant, steam cleaning, wastewater.

Your Home, Your Health and Pesticides

Safe Handling and Disposal of Home-Use Pesticides

You're Invited: Pollution Prevention Networks, #92-BR-23

Invitation to join a list of area pollution prevention networks. Describes who members

are, what's on the agenda and why to participate.

1995 Dangerous Waste Annual,Report Forms InstmctionBook, #94-107A

1995 Dangerous Waste Annual Report Guidebook and Codes, #94-107B

8 ()
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Appendix 2

List of Ecology Accredited Labs
'. ENVIROHENTAL LABORATORIES ACCREDITED

•~y THE ~ASHINGTON DEPARTMENT OF ECOLOGY

As of August 4, 1994

••

This Is a list of the labs accredited by the Washington Department of Ecology as of the date above. An "X" In a column at the right Indicates the lab Is accredited for

specific parameters In a general category. Refer to the last page for the category codes. If you need specific Information on the parameters or methods for which a lab Is

accredited, contact the leb and ask for the Information or a copy·of the lab'a Scope of Accreditation. Call the Ecology QA Section at (206) 895-4649 for general Information.

LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 011 R M B S

--- ----- - C150 A and BLabs 1643 Federal Road Houston TX 77015 Lela Walker (713) 453-6060 X X X X

C078 AAA Superior Lab S 16924 Curtis Road Cheney lolA 99004 Cheryl Blake (509) 448-1740 X X X

C045 ACZ Laboratories, Inc 30400 Downhill Drive Steamboat Springs CO 80487 Bradley Craig (303) 879-6590 X X X X X

'..-ioez Anco Products Co -Cherry Point·· . P.O. -Box 8100,· ~'. .,'.-.. "'. .\ .. Blaine lolA 98230 Greoor.y Gehrman '.. .(206). 371-1182 X X ..' " .. ··x

C162 ATEC Associates 5150 E. 65th Street Indianapolis IN 46220 Caprice Sims Beardon (317) 849-4990 X X X X

M033 Aberdeen Wastewater Treatment Plant . 1205 W. State Street Aberdeen lolA 98520 Jim Barkman (206) 533-4100 X X

C093 Advanced Analytical Services E 1514 Sprague Avenue Spokane lolA 99202 Lane Crandall (800) 366-8596 X X

1002 Advanced Silicon. Materials, Inc. 3322 County Road "N" NE, po Box 1667 Moses Lake WA 98837 David Livingston (509) 766-9341 X

M142 Alblon'Wastewater Treatment Plant PO Box 38, 310 F Street Albion lolA 99102 Kenneth Smith (509) 332-5095 X

C015 Alchem Laboratories, Inc. 104 West 31st Street· Boise. 10 83714 Suzanne Howell (208) 336-1172 X X X

M083 Alderbrook Inn water Treatment Plant E 7101 HWy 106 Union lolA 98592 Gregory Rae (206) 437-2798 x

M052 Alderwood Wastewater Treatment Plant 6315 Picnic Point Road Ednonds lolA 98026 Roger Gorham (206) 787-1940 X X

C091 Alta Analytical Laboratory, Inc 5070 Robert J. Mathews Parkway, STE 2 El Dorado Hills CA 95630 Sharon Pierson (916)933-1640 X

1026 Aluminum Company of America PO Box 221, 6200 Malaga Highway Wenatchee lolA 98801 Harvey F. Hillegass (509) 663-9206 X X X

C029 AmTest, Inc. 14603 NE 87th St Redmond lolA 98052 Mark Fuglel (206) 885-1664 X X X X X X

C152 American Analytical services, Inc. 8220 - 7th Avenue South Seattle lolA 98108 Mark Perin (206) 762-7599 X X X

M037 Anacortes Wastewater Treatment Plant PO Box 547, 500 T Avenue Anacortes lolA 98221 Rebecca Fox (206) 299-0953' X X

C190 AnalySys, Incorporated 4221 Freldrlch Lane, STE 190 Austin TX 78744 Hopkins Haden (512) 444-5896 )( )( )(

C038 Analytical Resources, Inc. 333 Ninth Ave North Seattle WA 98109 Michelle Turner (206) 621-6490 X X X X X )( X

C154 Analytical Services Corp. 16406 US 224 East Findlay OH 45840 Anne Sidney (419) 425-6054 . X X X X

C086 Analytical Technologies (Fort Collin 225 Commerce Drive Fort Collins co 80524 Polly Brogan-Paley (800)443-1511 X )( X X X

C125 Analytical Technologies (Phoenix) 9830 S 51st St, STE B-113 Phoenix AZ 85044 Bob Hermerath (602) 496-4400 X X X X

C026 Analytical .Technologles (Renton) 560 Naches Ave SW, Suite 101 .Renton lolA 98056 Lorraine Davis (206) 228-8335 X X X X X

C010 Analytical Technologies (San Diego) 5550 Morehouse Dr San Diego CA 92121 Patricia Schroder (619) 458-9141 X X X X

C110 Anametrix 1961 Concourse Drive, STE E San Jose CA 95131 Larry Kent (408) 432-8192 X X X X

C126 Anatek Labs 1917 South Main Moscow 10 83843 Mike Pearson (208) 883-2839 X X X

C064 Aqua Test, Incorporated 28620 Maple Valley Road S.E. Maple Valley lolA 98038 Linda Mount (206) 432-9360 X X

COB9 Aquatic Environmental Sciences 644 Old Eaglemount Road Port Townsend lolA 98368 Ken Brooks (206) 732-4464 X

C019 Aquatic Research 3927 Aurora Ave N Seattle lolA 98109 Steve lazoff (206) 632-2715 X X

MOB6 Arlington Wastewater Treatment Plant 3d &Olympia Ave Arlington lolA 98223 Bruce Schlagel (206) 435-3811 X X

M131 Asotin Wastewater Treatment Plant PO Box 517 Asotin lolA 99402 Steven Weldon (509) 243-4187 X X

C143 Avocet Environmental Testing 1500 North State Street Bellingham lolA 98225 Joann Ernst (206) 734-9033 X X X X

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LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 011 R M B S

--- ----- - C102 B&P Laboratories 5635 Delridge Way SW Seattle WA 98106 Victor Broto (206) 937-3644 X X

1071 Baker Commodities PO Box 58368, 5795 South 130th Place Seattle WA 98138 Jerry Stevens (206) 243-7387 X X

C043 Battelle Marine Research Labs 1529 West Sequim Bay Road Sequim WA 98382 Eric Crecelius (206) 683-4151 X X X

C041 Battelle NWL Chem Measurements Lab P.O. Box 999, Bldg 329, MS P8-08 Richland WA 99352 Kristine Kuhl-Klinger (509) 372-0398 X X ·X

C117 Beak Aquatic Bioassay Services 12931 NE 126th Place Kirkland WA 98034 Charles Wisdom (206) 823-6919 X

C133 Beak Consultants Blotestlng Lab 14 Abacus Road BraJ11)ton ON L6T 5 Emilia Jonczyk (416) 794-2325 X

1054 Beatrice Cheese Inc. 1515 Puyallup St. Sumner WA 98390 James Lee II (206) 863-3857 X X

M022 Bellingham Wastewater Treatment Plan 200 McKenzie St Bellingham WA 98225 Julie Hirsch (206) 676-7689 X X

M132 Benton City Wastewater Treatment PIa PO Box 70, 708 9th Street Benton WA 99320 Blaine Church (509) 588-3322 X X

M133 Benton-Franklin Health Dist Labs 506 McKenzie Richland WA 99352 Dave Miller (509) 943·2614 X X

M172 Bingen Wastewater Treatment Plant PO Box 607, 112 NAsh Bingen WA 98605 Ken Miles (509) 493-1348 X X

"'--C-100··BioassaY··Tcllting Services, -- .,' ,·.. ·8455-,··S··19~hi'·Suite,121\ -~. ' -'..- -·'•. ~-,Tacoma.···" ",",' .,..1~1\,.98465-,Chr~s,Getchell . . "',:(206.)_565-5492, .",~., .....".. ". ','" -"'.' ....X,.·

C073 Bloconsultants, Inc. 2897 152nd Avenue NE Redmond WA 98052 John Majnarlch (206) 869-4224 X X

M106 Birch Bay Water and Sewer District 7096 Pt. Whitehorn Blaine WA 98230 Steve Hovde (206) 371-2400 X X

M076 Blaine Wastewater Treatment Plant 1200 Yew Avenue Blaine WA 98230 Jill Parker (206) 371-5549 X X

1035 Boeing Commercial Airplane (Renton) . Boeing N Fld, Box 3707, MS 63-01 Seattle WA 98124 Joyce Nelson (206) 965-1403 X X X

C187 Boeing Company (Huntsville) 499 Boalng Blvd, Mail Stop JW-66 Huntsville AL 35824 Harold Cole (205) 461-2916 X X X X

1041 Boeing Defense and Space Group (Kent PO Box 3999, MS 8J-55 Seattle WA 98124 Peter Welckmann (206) 544-1224 X X X )(

1010 B~elng Everett QA Lab Boeing N Fld, Box 3707, MS 04-02 Seattle WA 98124 Mike O'Bryant (206) 342-8050 X X X

1015 Boise Cascada Corp (Steilacoom) 4302 Chambers Creek Rd Steilacoom WA 98388 Molly Hemmen (206) 588-2115 X

1008 Boise Cascade Corp (Wallula) PO Box 500 .Wallula WA 99363 Dennis Ross (509) 546-3417 X

1018 Boise Cascade Paper Div (Vancouver) PO Box 690 Vancouver WA 98666 Fredrick A. Weber (206) 690-7000 X

1086 Boundary Powerhouse Wastewater Treat P.O. Box 507 Metaline Falls WA 99153 Jerry Evans (509) 446-3083 X

C166 Braun Intertec 6875 Washington Avenue South,' PO Box Minneapolis MN 55439 Louise Ogden (612) 942-4814 X X

M043 Bremerton Wastewater Treatment Plant 1600 Oyster Bay Rd Bremerton WA 98312 Jackie Horton (206) 479~4646 X X

M011 Bremerton/Kltsap Cty Health Dept Lab 109 Austin Drive Bremerton WA 98312 Jesusa Magdamit (206) 478-5285 X

M088 Brewster Wastewater Treatment Plant PO Box 340, 14 South Third Street Brewster WA 98812 Lynn Lawson (509) 689-3464 X X

M097 Bridgeport Westewater Treatment Plan PO Box 640 , Bridgeport WA 98813 Bruce PLimpton (509) 686-5653 X X

M095 Buckley Wastewater Treatment Plant PO Box D, 600 STP Ave Buckley WA 98327 Al Wolfe (206) 829-1734 X X

C021 ~urlington Environmental Corporate L 955 Powell Avenue, SW Renton WA·98055 Kathy Kreps (206) 227-6100 X X X X

C136 CANVIRO Analytical Laboratories Ltd Unit #12 - 50 Bathurst Drive Waterloo ON N2V 2 Dale Sutherland (519) 747-2575 X

C142 CCI Laboratories 3229 Pine Street Everett WA 98201 Chuck Rancatti (206) 258·4548 X X X

C036 'CH2H Hill (Corvallis) 2300 NW Walnut Blvd Corvallis OR 97339 Hike Stanaway (503) 752-4271 X II

AD03 CWU Chemistry Department Central Washington University Ellensburg WA 98926 CLInt Duncan (509) 963-2811 X

H162 ,Camas Wastewate~ Treatment Plant PO Box 1055, 616 NE 4th Ave Camas WA 98607 louis Nichols (206) 834·3263 X X

.1076 Camrln Environmental Laboratory 2801 SW Florida St Seattle WA 98126 Sal Regala (206) 933-1013 X X X

C049 ,Cascade Analytical, Inc. 3019 GS Center Road Wenatchee WA 98801 Laura Mrachek (509) 662-1888 X X X

M091 Cashmere Wastewater Treatment Plant 101 Woodring St Cashmere WA 98815 Charlie Cruickshank (509) 782-3513 X.. X

M137 Castle Rock Wastewater Treatment PIa PO Box 370, 118 Cummings Street SW Castle Rock WA 98611 David Vorse (206) 274-6986 X X

M115, Cathlamet Wastewater Treatment Plant 100 Main Street Cathlamet WA 98612 Tony Schmidt (206) 795·8032 X X

._ .. _-----------------------------------------_._-------_._----_._------_._._-----------------------------_.----.------------_._._------------------------_.--------------------

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LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 Oil R M B S

--- ----- - - - S009 Cedar Creek Corrections Center PO Box 37, 1 Bordeaux Road SW Littlerock WA 98556 Ed Burns (206) 664-0718 X X

M013 Central Kltsap Plant Lab 12350 St. Hwy. 303NE Poulsbo WA 98370 Craig Hanson (206) 779-7720 X X X

1031 Centralia Mining Company 1015 Big Hanaford Rd Centralia WA 98531 Edward Kapello (206) 736-2831 X X

M038 Centralia Wastewater Treatment Plant 1401 Mell en St Centralia WA 98531 Denise Lehmann (206) 736-2853 X X

C022 Century Testing Labs P.O. Box 1174, 1444 NW College Way Bend OR 97701 Mel Lindbeck (503) 382-6432 X X X X

C101 Chadwick &Associates, Inc. 5575 S Sycamore St, STE 101 Littleton CO 80120 Darrln Dentin (303) 794-5530 X

M047 Chehalis Wastewater Treatment Plant P.O. Box 871, 1191 Shoreline Or. Chehal Is WA 98532 William Pounds (206) 748-0238 X X

M066 Chelen Wastewater Treatment Plant PO Box 1669 Chelan WA 98816 Al Merchant (509) 682-2211 X X

M110 Chewelah Wastewater Treatment Plant PO Box 258 Chewelah WA 99109 Gordon Stevenson (509) 935-8311 X

1047 Circuit Technology, Inc. 12226 - 134th Court NE Rednond WA 98052 Todd Kirkendall (206) 881-3477 X X

S008 Clallam Bay Corrections Ctr P.O. Box 5000, Charley Creek Road Clallam Bay WA 98326 James Maneval (206) 963-3294 X X

.M056' ClalllJmBay/Sekiu-Water Treatment-Pl·· ,·PO .Box·' 21,3.·· """ ." .~ -"'.,. . _.. ... .~- Clallam.Bay·..• ·- HA 98326 JoeCiar.lo .......---. .-(206).963:.239:r..,..~x..,_ ...._......"......·x. -., ~."'"

M204 Clarkston Wastewater Treatment Plant Clarkston City Hall, 830 Fifth St Clarkston WA 99403 Dorian Larson (509) 758-1674 X X

M074 Cle Elum Wastewater Treatment Plant 301 Pennsylvania Ave Cle Elum WA 98922 Robert Morrell (509) 674-2262 X X

C070 Coffey Laboratories 12423 NE Whitaker Way Portland OR 97230 Victor Perry (503) 254-1794 X X X X X

H177 Colton Wastewater Treatment Plant PO Box 157 Col ton WA 99113 Bill Frye (509) 224-3874 X

1006 Columbia Aluminum Co 85 John Day Dam Rd Goldendale WA 98620 Stan Casswell (509) 773-7350 X X X X

C052 Columbia Analytical Svcs (Bothell) 18912 N. Creek Parkway, STE 118 Bothell WA 98011 Colin Elliott (206) 486-6983 X X

C001 Columbia Analytical Svcs (Kelso) P.O. Box 479, 1317 South 13th Ave. Kelso WA 98626 Lawrence Jacoby (206) 577-7222 X X X X X X

C135 Columbia Aquatic Sciences 6060 Corte del Cedro Carlsbad CA 92009 F.C. "Skip" Newton (619) 931·9225 X

C083 Columbla/Blo Medical Laboratories 7131 W. Grandrldge Blvd. Kennewick WA 99336 Marden Kohler (509) 736-1111 X X

H075 Colville Wastewater Treatment Plant 170 SOak Colville WA 99114 Ralph Lane (509) 684-2244 X X

S004 Consolidated Support Services PO Box 500, Lakeland Village #1 STP Medical Lake WA 99022 Steve Holden (509) 299-4678 X

C072 Core laboratories (Aurora) 10703 East Bethany Drive Aurora CO 80014 Linda Benkers (303) 751-1780 X X X X

M069 Coupeville Wastewater Treatment Plan PO Box 725 Coupeville WA 98239 Harold Dill (206) 678-6695 X X

M016 Cowlitz Water Pollution Control Plan 207 - 4th Ave N Kelso WA 98626 Don Hultgren (206) 577-3127 X .X

C194 Crescent Bar Resort 8894 Crescent Bar Rd NW Quincy WA 98848 Jim Hoersch (509) 787-1511 X

C138 Curtis and Thompkins Ltd. 2323 - 5th Street Berkeley CA 94710 Kathy O'Brien (510) 486-0900 X X X X

C128 D&M Labs P.O. Box 808024 Petaluma CA 94975 Mary Janney (707) 763-8245 X X X X

1045 Daishowa America Corp P.O. Box 271 Port Angeles WA 98362 Peter Williams (206) 452-0668 X

C127 DataChem Laboratories 960 West LeVoy Drive Salt Lake City UT 84123 Don Lewis (801) 266-7700 X X X X X

M160 Deer Park Wastewater Treatment Plant PO Box F, East 316 Crawford Deer Park WA 99006 Mark Lewis (509) 276-8802 X

S002 Department of Fisheries Water Quallt P.O. Box 43154 Olympia WA 98504 Jennifer Shefler SCAN 902-2503 X

H070 Douglas County Sewer District #1 PO Box 7129, 1050 Sunset Highway East Wenatchee WA 98802 Jim Robins (509) 884-1283 X X

C096 EA Engineering Science &Technology 19 Loveton Circle Sparks HD 21152 Cameron Soulis (410) 771-4920 X X X X

C170 ENSECO - Somerset 2200 Cottontail Lane Somerset .NJ 08873 George Gatlin 908-469-5800 X X X X

C090 ENSECO-Rocky Mountain Analytical 4955 Yarrow St. Arvada CO 80002 Carl Craig (303) 421-6611 X X X X

C164 ENSECO-Wadsworth/Alert Labs ·450 William Pitt Way PIttsburg PA 15238 Connie Schussler (412) 826-5477 X X

C066 ENSR C&E Houston Environmental Toxic 10161 Harwln, Suite 150 Houston TX 77036 Deanna Duke. (713) 272-7444 X

C053 ENSR Consulting and Engineering 1716 Heath Parkway Fort Collins CO 80524 David Pillard (303) 493-8878 X X

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LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 011 R M B S

--- ----- - ·C046 EVS Consultants, Inc 200 WMercer St., Ste 403 Seattle WA 98119 Margot Daykin (206) 217-9337 K K

A002 EWU. Limnology Laboratory 260 Hall of Sciences, MS 72 Cheney ( WA 99004 Ray Soltero (509) 359-2532 K K

C105 EcoTek 3342 Int'l pk Dr, SE Atlanta GA 30316 Leslie Papa. (404) 244-0827 K

C063 Ecology and Environment, Inc. 4285 Genesee St. Cheektowaga NY 14225 Ray Piccione (716) 631-0360 K X K X

M009 Edmonds Wastewater Treatment Plant 250 5th Ave N Ednonds .WA 98020 Tina Higman (206) 771-0220 K K

1055 Eka Nobel, Inc. 2701 Rd N - NE Moses Lake WA 98837 Gene Hanson (509) 765-6400 K K

1009 Elf Atochem North America 2901 Taylor Way Tacoma WA. 98421 Warren Fisk (206) 596-6841 K X X

M026 Ellensburg Wastewater Treatment Plan 420 NPearl St Ellensburg WA 98926 Irma Grogan (509) 962-7269 X X

M173 Endicott ~astewater Treatment Plant PO Box 418 Endicott WA 99125 Dan Larson (509) 657-3314 X

MO~5 Entiat Wastewater Treatment Plant P.O. Box 228, 1947 Lakeshore Drive. Entiat WA 98822 Roger Mickelson (509) 784-1224 X X

'M004 Enumclaw Wastewater Treatment Plant 2041 Railroad Street Enumclaw WA 98022 Bing Baslm (206) 825-1115 X X

.C·124 Envi ro~ntal"Se-lence·llnd·Engiheerin· . 890:r N·'lndustr~al,· Road· ..·.···• ··p.eor.! a",~.'..-=·· ",. >-It. 61615 Lettie Schmitt .... ,(,309)692-1,422e r , X..._..X....J( .... ,,)(. ... ,.,

C109 Environmental Testing and Certiflcat 320 Tesconl Circle Santa Rosa CA 95401 Barbara Bowman (707) 544-5570 X X X X

M085 Ephrata Wastewater Treatment Plant 121 Alder Street SW Ephrata WA 98823 Paul Wasko (509) 754-2992 X X

C098 Eureka Laboratories 6790 Florin Perkins Rd. Sacramento CA 95826 Steve Leung (916) 381-7953 X X X X X

M020 Everett Environmental Laboratory 3200 Cedar St. Everett WA 98201 Robert Waddle (206) 259-8819 X X X

M028 Federal Way Water &Sewer Dlst (Lako PO Box 4249, 3203 SW Dash Pt Rd Federal Way WA 98023 Melanie May (206) 874-8200 X X

M114 Ferndale Wastewater Treatment Plant PO Box 936, 5405. Ferndale Road Ferndale WA 98248 Jerry Leuenberger (206) 384-4607 X X

1083 Fleischmann's Yeast Co. (Sumner) PO Box 488, 1115 Zehnder Street Sumner WA 98390 Ed Walter (206) 863-6311 X

M007 Forks Wastewater Treatment Plant PO Box 1998 Forks WA 98331 Dan Wahlgren (206) 374-3124 K

C080 Friedman &Bruya 3012 16th Avenue West Seatt le WA 98119 Bradley T. Benson (206) 285-8282 X X X

C199 GT Environmental Laboratories - wlch 4211 May Street Wichita KS 67209.John Sattler (316) 945-2624 X X X X

C054 GT Environmental Labs (Concord) 4080 Pike Lane Concord CA 94520 Ilona Taunton (510) 685-7852 X X X X

1051 General Chemical Corporation . 655 North Texas Anacortes WA 98221 Bill Black (206) 293-2171 X

1013 Georgia-Pacific Corp (Bellingham) PO Box 1236, 300 W. Laurel Street Bellingham WA 98227 Jerry Price (206) 676-7263 X X

M175 Gig H~rbor Wastewater Treatment Plan PO Box 145, 4216 Harborvlew Dr. Gig Harbor WA 98335 Bill Irey (206) 851-8999 X x

C173 Golden State/CAS Labs 6925 Canoga Avenue. Canoga Park CA 91303 Gene Bennett (818) 587-5550 X X X X

M060 Goldendale ~astewater Treatment Plan PO Box 69 Goldendale WA 98620 James Brokaw (509) m-3788 X X

M196 Grand Coulee-Electric City WTp PO Box 180, USSR (Grand Coulee Dam) 11. Grand Coulee WA 99133 Darrel Fleischman (509) 633-2503 X X

M118 Grandview Wastewater Treatment Plant 207 West Second St. Grandview WA 98930 Dave Lorenz (509) 882-9215 X X

M094 Granger Wastewater Treatment Plant PO Box 1100, East "A" Street Granger . WA 98932 Catherine Warrington (509) 854-2770 X X

M120 Granite Falls Wastewater Treatment 11. PO Box 1440, 500 W. Wallace Granite Falls WA 98252 Bruce Hays (206) 691-7432 X X

1019 Grays Harbor Paper, L.p. 801 23rd Street Hoquiam WA 98550 Ron Lutzvlck (206) 538-5613 X X

M170 Harstene pt Wsstewater Treatment Pia PO Box 578 Shelton WA 98584 Tom Moore (206) 427-9670 X X

C134 Hart Crowser Chemistry Lab 1910 Fairview Ave E Seattle WA 98102 Jack Herndon (206) 324-9530 X X

C149 Heritage Labs 7901 West Morris Street Indianapolis IN 46231 Curtis Beck (317) 243-8304 X X X X

M021 Hoquiam Wastewater Treatment Plant 609 8th St Hoquiam WA 98550 Larry Erickson (206) 532-5700 X X

C094 Hughes Analytical Lab 21920 NE Glisan Gresham OR 97030 Renee Chauvin'; (503) 669-3745 X

1085 IBP, Inc. PO Box 4239, Dodd Road Pasco WA 99302 Mohammed Rezaee (509) 547-7545 X

C059 IML (Bozeman) 1160 Research Drive Bozeman MT 59715 Jack Felkey (800) 828-1413 X X X X

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LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 011 R M B S

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X.

X

X

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(714) 523-9200 'X

(314) 298-8566 X

(615) 690-3211

(509) 235-5762 X X

(509) 924-1911: X

(509) 928-5651 X X

(206)650-3385 X

(206) 384-7318 X X

(206) 834-3021 X

(206) 834-8318 X X X X

,-(,206) .,385.•.9·14.9, __X-- ,.•... __ ._ ....._~_•.. " ...>,. -s:

(509) 468-5487 X

(206) 591-0450 X

(509) 927-6070 X X

(206) 673-2550 X

(206) 673-4570 X

(509) 586-4181 X

(509) 738-2449 X

(206) 895-2440 X

(509) 968-3255 X

(206) 263-3335 X

(206) 334-5539 X

(509) 763-3580 X

(206) 767-5060 X X X X

(509) 248-4695 X

(404) 421-3324 X X X X

(509) 548-5994 X

(206) 748-9121 X

(509) 928-6123 X

(509) 677-3241 X

(702) 361-1626 X X X X X

(206) 425-1550 X

(509) 233-8132 X

(206) 437-2798 X

(206) 354-0633 X

(206) 775-1971 X

(916) 852-6600 X X X X

(206) 684-2412 X

(206) 684-2413 X X

CA 90701 Nasreen DeRubles

MO 63045 Jim Kleszczewskl

TN 37923 Mary Tyler

IlA 99004 Mohammed IkranJddln

IlA 99212 Rick fink

IlA 99216 Dano Cummings

~A 98225 Thomas Storch

WA 98248 Mark Lytle

WA 98607 Mike Elder

~A 98607 Dwight Eastey

WA,98339 Glenn.Gately.. , .,-'..."-

WA 99021 Pat Hampton

WA 98421 Bob Wheaton

WA 99215 Mike Piotrowski

WA 98625 Kate Dugas

WA 98625 Pete Poulson

WA 99336 Michael Smith

WA 99141 Johnle Pitman

WA 98366 Mark Morgan

~A 98934 Vern Aliemand

~A 98668 Bill Michaud

~A 98205 Rick 'Lewellen

WA 98826 Kent ~atson

~A 98108 Harry Romberg

WA 98902 Tamls Root

GA 30144 Dale Darley

WA 98826 Bill Russ

WA 98532 Ellen Dodds

~A 99019 Dan Grogg

WA 99341 Norman Waddell

NV 89119 Sevda Aleckson

WA 98632 Henry Rakoz

WA 99148 Jean Russel

WA 98365 Bob Thurston

WA 98264 larry Zima

~A 98046 Don Davis

CA 95670 Cheryl Matterson

~A 98116 Richard finger

WA 98055 Richard finger

-----,---------------------------------- -- - - - - - - C034 IT Analytical Services (Austin) 5307 Industrial Oaks Blvd, STE 160 Austin TX 78735· ALice Clark-Wusterhause (512) 892-6684

C114 IT Analytical Services (Cerritos) 17605 fabrlca Way Cerritos

C116 IT Analytical Svcs (Earth City) 13715 Rider Trail North . Earth City

C092 ITAS Special Analysis Laboratory 304 Directors Orlve Knoxville

C130 Igal Labs 111 College Ave. Cheney

1038 Inland Empire Paper Co N 3320 Argonne Rd Spokane

C065 Inland Environmental Laboratories Spokane Ind'l Pk, S-19, E16810 Euclid Spokane

A006 Institute for Watershed Studies M.S. 9069, ~uxley College, Western Wa Bellingham

1028 Intalco Aluminum Corporation .PO Box 937, 4050 Mountain View Road ferndale

1024 James River Corp Camas Mill N.E. 4th &Adams Streets Camas

1029 James River Corp Environmental Svcs 904 N~ Drake Street Camas

""1~063'Jefferson County Water Qual·!-t,y-!:-llb .:"" ,p,0.·90)('·1220· ... ,.',.-, '" '. ,POr.t.Hlldlock"

1034 Kaiser Aluminum and Chemical (Mead) E 2111 Hawthorne Rd Mead

1039 Kaiser Aluminum and Chemical (Tacoma 3400 Taylor Way Tacoma

1014 Kaiser Aluminum and Chemical (Trentw PO Box 15108, E 15000 Euclid Ave Spokane

1011 Kalama Chemical Company 1296 NW Third Kalama

M158 Kalama ~astewater Treatment Plant PO Box 1007, 206 Hendrickson Drive Kalama

M044 Kennewick Wastewater Treatment Plant PO Box 6108, 416 N. Kingwood Street Kennewick

1064 Kettle falls Generating Station Lab Hgwy 395N and Peachcrest, P.O. Box 60 Kettle falls

MOSS Kltsap County Sewer Dlst #5 1165 Beach Drive Port Orchard

M099 Kittitas ~astewater Treatment Plant PO Box 719 Kittitas

M143 La Center Wastewater Treatment Plant PO Box 8900 Vancouver

M157 Lake Stevens Sewer Dlst 9327 - 4th Street NE, 500 Sunnyside B Everett

M197 Lake Wenatchee WTP 21251 State Hwy 209, PO Box 1231 Lake Wenatchee

C030 Loucks Testing Labs (Seattle) 940 So Harney St Seattle

C132 laucks Testing Labs (Yakima) 1106 Ledwlch Yakima

C107 Law Environmental National Labs 112 Town Park Drive Kennesaw

M154 Leavenworth Wastewater Treatment Pln PO Box 287, 1400 Commerlcal Street Leavenworth

M078 Lewis County Health Dept. PO Box 706 Chehalis

H068 Liberty Lake Sewer Dlst #1 PO Box 184, N. 1925 Harvard Road Liberty Lake

M165 Lind Wastewater Treatment Plant PO Box f Lind

C084 lockheed Analytical Services 975 Kelly Johnson Drive las Vegas

1017 Longview fibre Company PO Box 639 Longview.

M089 Loon Lake Sewer District #4 PO Box 98 Loon Lake

M072 Ludlow Sewer (Pope Resources) 8481 Oak Bay Road Port Ludlow

M096 Lynden Wastewater Treatment Plant 323 front Street Lynden

M006 Lynnwood Wastewater Tmnt Plant 19100 44th Ave W(PO Box 5008) Lynnwood

C048 MBT Environmental Laboratories 3083 Gold Canol Drive Rancho Cordova

M046 METRO (Alkl) Wastewater Treatment Pl 3380 Beach Dr SW Seattle

M041 METRO (Renton) Wastewater Treatment 1200 Monster Rd, SW Renton

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--- ----- - - - M035 METRO (Uest Point) Uater Treatment P 821 2d Ave Seattle UA 98104 Teresa Schoonejans (206) 689-3811 X X

M008 METRO Environmental Labs 322 U Ewing ) Seattle UA 98119 George Perry (206) 684-2399 X X X X X X X

M058 Mabton Uastewater Treatment Plant PO Box 655 Mabton UA 98935 Uayne Beeman (509) 894-4096 X X

S001 Manchester Environmental Lab 7411 Beach Drive East Manchester UA 98353 Bill Kammln (206) 871-8801 X X X X X X X

M080 Marysville Uastewater Treatment Plan 514 Delta Avenue Marysville WA 98270 Dale Thayer (206) 659-7643 X X

M039 Mason County Uater Quality Lab P.O. Box 1666 Shelton UA 98584 Carol Spaulding (206) 427-9670 X X

C057 Materials Testing &Consulting P.O. Box 309, 1729 Britt Mount Vernon WA 98273 Lawrence Henderson (206) 757-1400 X X X X

M073 Messenger House Nursing Home 10861 Manitou Park Blvd NE Bainbridge Island WA 98110 Mike Boyce (206) 842-2654 X X

M019 Midway Sewer District PO Box 3487 Kent UA 98032 John Hura (206) 824-2760 X X

M054 Miller Creek Uastewater Treatment Pl 1015 SU 174th St "ormandy Park Seattle UA 98166 Tim Yokers (206) 244-2202 X X

1063 Milne Fruit Products Inc 804 Bennett Avenue Prosser UA '99350 Carman McKinney (509) 786-2611 X

1-1191 ~Iontesano ·\Jostewater"·Treotmcnt-Plant-·-.. ·112··MalnStreet II. ,....1-30h·Stilte.·Route·,.Montesano..·... . ·.··l-/A98563 Herb Vaughn........ ,,~...;.,._ ..(206). 249"3532.. X -" .. X....,.._.~..,'..

M151 Morton Wastewater Treatment Plant PO Box 1089, 250 E. Main Street Morton WA 98356 Mike Tiller (206) 496-5287 X X

M100 Moses Lake Uastewater Treatment Plan PO Box 1579, 1808 U. Lakeside Drive Moses Lake WA 98837 Richard Leishman (509) 766-9229 X

M164 Mossyrock Wastewater Treatment Plant PO Box 96 Mossyrock WA. 98564 Clay Anderson (206) 983-3300 X X

M003 Mount Vernon Wastewater Tmnt Plant 1401 Britt Rd Mount Vernon WA 98273 Bill Fullner (206) 336-6219 X X

M186 Moxee Wastewater Treatment Plant PO Box 249, 7412 Postma Road Moxee WA 98936 Laura Henley (509) 575-8853 X X

C097 NCA - Portland 9405 SU Nimbus Ave. Beaverton OR 97005 Dennis Wells (503) 481-9200 X X X X

C137 NET Pacific 17400 SU Upper Boones Ferry Rd, STE 2 Portland OR 97224 Tabatha Brochu (503) 624-5449 X X X X

M101 Naches Wastewater Treatment Plant PO Box 95 Naches WA 98937 Donald Gosnell, Jr. (509) 653-2881 X X

C012 National Chem Lab P.O. Box 635,' 103 12th SU Ephrata WA 98823 Jim Blanchard (509) 754-5725 X X X X

M159 Newport Uastewater Treatment Plant PO Box 546, S 200 Washington Ave Newport WA 99156 Ray King (509) 447-5611 X X

F002 Nisqually Natural Resources WQ Lab 12501 Yelm Highway SE OlYJ1llia UA 98513 Tom Connor (206) 438-8687 . X

M134 North Bend Wastewater Treatment Plan PO Box 896, 400 N. Bend Blvd. North Bend WA 98045 Douglas Repp (206) 888-0282 X X

M084 North Bonnevllle'Wastewater Treatmen PO Box 7 North Bonneville WA 98639 Ray Hays (509) 427-8200 X X

C008 North Creek Analytical (Bothell) 18939 120th Ave NE, Suite 101 Bothell WA 98011 Dennis Uells (206) 481-9200 X X X X X X X

C147 North Creek Analytical (Spokane) E 11115 Montgomery, STE B Spokane WA 99206 Scott Armand (509) 924-9200 X X X

C042 Northwestern Aquatic Sciences PO Box 1437 Newport OR 97365 Richard Caldwell (503) 265-7225 X

C169 Nytest Environmental, Inc. 60 Seaview Blvd Port Washington NY 11050 Nancy Egan (516) 625-5500 X X X X X

C088 OMI (Gresham) 20015 NE Sandy Blvd Portland OR 97230 Shawn Cassidy (503) 661-4997 X

C180 OMI (Hood River) 818 Riverside Drive Hood River OR 97031 John Robinson (503) 386-2432 X

C181 OMI (The Dalles) P.O. Box 1022, East First &Laughlin The Dalles OR 97058 Clifford Leeper (503) 298-1779 X

C099 ORTEK 1609 Wester Avenue Green Bay UI 54303 Becky Detage (414) 498-2222 X X X X

M059 Oak Harbor Wastewater Treatment Plan 3075-300th Ave W., 7059-70th Ave SW Oak Harbor WA 98277 Aaron Atwood (206) 679-5551 X X

1036 Occidental Chemical Corporation P.O. Box 2157, 605 Alexander Ave Tacoma WA 98401 George Karscig (206) 593-1383 X X X

M057 Ocean Shores Uastewater Treatment Pl PO Box 909,' 1440 Ocean _Shores Blvd Ocean Shores WA 98569 Myles Beach (206) 289-2388. X X

C025 Ogden Environmental &Energy svcs 5510 Morehouse Dr San Diego CA 92121 Barry Snyder (619) 458-9044 X

M064 Okanogan Uastewater Treatment Plant PO Box 752 Okanogan WA 98840 Joe Davidson (509) 422-0000 X X

M032 OlYJ1llla (LOTT) Wastewater T'ment Pla P.O. Box 1967, 500 N. Adams Olympia WA 98507'Asha Mhatre (206) 753-8181 X X X X

5010 OlYJ1llic Corrections Center HC 80, Box 2500 Forks UA 98331 Rodney Christy SCAN 737-6181 X X

._ ..................._--......._---.. - ................ _._ .... __.. -... _-_.. -.-._---~_ ..._._-------_._-.-.. _.. . . . . . . . . . . . _---_ ... _.. --_ ... _._------_ ......-._..----.. _---------_.-

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LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 011 R M B S

------------------------------------ -- - - - - - - - -

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X X

X

X X X X

X X X

X X X

X X X

X X X

X

X

X X X

X X X

X X X

X

X

X X X

X

X X X

(206) 355-6637 X

(509) 826·2383 X

(206) 883-3881 X

(503) 644-5300 X

.(206) 952-6717 X

(509) 476-3432 X

(415) 964-0844 X

(206) 754-5009 X

(504) 283-4223 X

.(415) 883-6100 X

(619)438-3100

-: .."...(206.) ·.881,..7538•._ X"", ..)(" ·x.._X.·.."---_ ..•. "-"'";.--'-·~ ..

(206) 330-2353 X

(206) 822-8880

(509) 545-3463 X

(509) 923-2571 X

(206) 835-2131 X

(206) 675-2001 X

(206) 565-3013 X

(509) 843-3939 X

(509) 445-2162 X

(206) 457-0411 X

(206) 385-3170 X

(206) 385-3193 X

(509) 839-3187 X

(509) 332-0928 X

(913) 749-2381

(509) 786-1101. X

(206) 476-8092 X

(509) 334-4555 X

(206) 841-5511 X

(916) 244-5262 X

(615) 588-6401 X

(412) 731-8806 X

(509) 375-3131 X

(714) 898-6370 X

(916) 372-1393 X

(509) 787-4131 X

(503) 639-3400 X

(206) 457-2352 X

Hulkllteo YA 98275 Genna Drewry

Ornak WA 98841 Ron Stevens

Redmond WA 98052 Bob Wallace

Beaverton OR 97007 Suzanne LeMay'

Federal Way WA 98093 Michael Martin

Oroville WA 98844 Ted Williams

Mountain View CA 94043 James Harper

Olympia WA 98507 Rick Berndt

New Orleans LA 70126 Elaine Wild

Novato CA 94949 Nlrmela Watts

Carlsbad CA 92009 Bruce Colby

..c:-·Redmoncl;..· .__ .-,._., HA 98052..Cynthla Rezanla..·

Centralia YA 98531 Larry Webster

Kirkland WA 98033 Kevin V.

Pasco YA 99301 Harold Posthuma

Pateros WA 98846 Dale Perks

Washougal WA 98671 James Nail

Oak Harbor WA 98277 Dave Dlugosh

Tacoma WA 98467 Steve Thompson

Pomeroy WA 99347 Glen Davis

Usk WA 99180 Lori Blau

Port Angeles WA 98362 Kevin Curtis

Road Port Townsend WA 98368 Al Gould

Port Townsend WA 98368 Marel Harstad

Sunnyside WA 98944 Clarence L. Bolt

Pullman WA 99163 A. Azlm Khan

Lawrence KS 66049 Dawn Thomaa

Prosser WA 99350 Gregory Pletz

Bremerton WA 98314 Michael Heeton

Pullman WA 99163 Pat YIltzius

Puyallup WA 98372 Martha Spear

Redding CA 96003 Terry Davis

Knoxville TN 37921 Chris Rlgell

Export PA 15632 Nasreen De~ubels

Richland WA 99352 Douglas Swenson

Garden Grove CA 92641 Bob Sundberg

West Sacramento CA 95691 Gall Cho Celaschl

Quincy WA 98848 Peter Smith

Portland OR 97223 Seen Gormely

Port Angeles WA 98362 Molly Hemmen

PO Box 91

PO Box 72, 635 S Fir St

14924 NE 31st Circle

14855 SW Old Scholls Ferry Road

P.O. Box 24943

PO Box M

625-B Clyde Avenue

PO Box 947

6801 Press Drive - East Bldg

11 Digital Drive

6349 Paseo del Lago

.-153·14· NE ·95th···

913 Big Hanaford Rd

5808 Lake Washington Blvd NE

PO Box 293, 1015 S. Grey

PO Box 8

PO Box 145, #2 17th St

PO Box 954, 1178 W. Scenic Heights

10311 Chambers Creek Rd Yest

PO Box 370

P.O. Box 130, 422757 Hwy 20

PO Box 1150, 321 E Fifth

PO Box 3170, 100 Paper Mill Hill

5210 Kuhn Street

PO Box 329

HE 2345 Hopkins Court

4820 West 15th Street

601 Seventh St

Code 134.3, Building 371

PO Box 249, NW '1025 Guy Street

2028 River Road

5090 Caterpillar Road

·5815 Middlebrook Pike

5103 Old WID Penn·Hlghway

2800 Geo Washington Way

7440 Lincoln Way

2544 Industrial Blvd

P.O. Box 33B

7477 SW Tech Center Drive

700 North Ennis

M061 Olympus Terrace W'water Treatment Pl

M071 Ornak Wastewater Treatment Plant

Cl15 On-Site Environmental (Redmond)

C129 Oregon Analytical

C005 Orion Labs

Ml02 Oroville Wastewater Treatment Plant

C191 PACE/Mid-Pacific

1058 Pabst Brewing Co

C188 Pace, Incorporated (New Orleans)

C079 Pace, Incorporated (Novato)

C159 Pacific Analytical, Inc.

.•. C14 FPac rf ic Northern' Ana lyt-tcel-·..·•

1025 Pacific Power &Light

C033 parametrlx, Inc.

M049 Pasco Wastewater Treatment Plant

M081 Pateros Wastewater Treatment Plant

1003 Pendleton Woolen Mills

H148 Penn Cove Park Sewer Dlst

H014 Pierce Cty/Chambers Crk Water Tmot P

M093 Pomeroy Wastewater Treatment Plant

1020 Ponderay Newsprint Company

M023 Port Angeles Wastewater Treatment PI

1004 Port Townsend·Paper Co

MOB7 Port Townsend Wastewater Treatment P

M130 Port of Sunnyside

C068 Preclalon Analytlcs, Inc

C071 Professional Service Industries, Inc

M042 Prosser Wastewater Treatment Plant

F001 Puget Sound Naval Shipyard Envlronme

M010 Pullman Yastewater Tmot Plant

M025 Puyallup Wastewater Treatment Plant

C037 Quality Analytical Laboratories, Inc

C120 Quanterra Inc. (Knoxville)

C119 Quanterra Incorporated (Export)

COSO Quanterra Incorporated (Richland)

C085 Quanterra, Incorporated'(Garden Grov

COB7 Quanterra, Incorporated (Sacramento)

M040 Quincy Wastewater Laboratory

COll RZA AGRA, ·Inc. Environmental Lab

1032 Rayonier Port Angeles Mill

Page 7
LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 011 R M B S

--- ----- - 1044 Rayonler Research Center. (Shelton) PO Box 501~ 409 E. Harvard Shelton WA 98584 Stan Olsen (206) 426-4461 X X

M199 Reardan Wastewater Treatment Plant PO Box 228 Reardan WA 99029 Bruce Johnson (509) 796-3921 X

1021 Reynolds Metals Co PO Box 999, 4029 Industrial Way Longview WA 98632 Harold Hays (206) 636-8251 X X

M015 Richland Wastewater Treatment Plant PO Box 190, 555 Lacy Blvd. Richland WA 99352 Willaim Harlan (509) 943-7483 X X

M176 ~Idgefleld Wastewater Treatment Plan PO Box 608, West Cook Street Ridgefield WA 98642 Ben Hasson (206) 887-8251 X

M156 Roslyn Wastewater Treatment Plant PO Box 451, 201 S. 1st Street Roslyn WA 98941 Joe Peck (509) 649-3105 X X

C017 Roy F. Weston, Inc. 212 Frank West Circle Stockton CA 95206 Rosa Beas (209) 983-1340 X X X

C189 Rust Remedial Svcs/Western Processln 20015 - 72nd Avenue S. Kent WA 98032 Jerry McCaslin (206) 395-0573 X X X X

C140 S-Cubed 8808 Balboa Avenue San Diego CA 92123 Jane Goodin (619) 637-7417 X X X X X

C103 SCS Analytical labs 2860 Walnut Avenue. Long Beach CA 90806 Loree Kenyon (310) 595-9324 X X. X X

C074 SVL Analytical, Incorporated PO Box 929, 1 Government Gulch Kel~ogg ID 83837 Brandan Borglas (208) 784-1258 X X X X

.'r'1150 :Sa'lnt John Wastewater treatment- Nan-·-: PO'·Dox··298·..:-. ..:......... , .. Salnt·John. ·,·14/\ 991711·/ayne Bly ..,. (509). 648~.3905 .... X.. ~.·:' ..... ..... _.,__ ,

M053 Salmon' Creek .Wastewater Tmnt Plant 12550 Shorewood Dr SW Seattle WA 98146 Tim Yokers (206) 244-2202 X X

1052 Sandvik Special Metals Environmental PO Box 6027 Kennewick WA 99336 Vicki Marquis (509) 586-4131 X

C146 Savannah Labs, Tallahassee Dlv 2846 Industrial Plaza Dr Tallahassee FL 32301 Pam Staerker (904) 878-3994 X X X X

C165 Scientific Control Labs, Inc. 3158 S. Kolin Avenue Chicago IL 60623 William Eberhardt (312) 254-2406 X X X

1023 Scott Paper Company PO Box 925, 2600 Federal Way Everett WA 98206 Ginger Knox (206) 259-7333 X X

1065 Seattle City Light - Diablo 1015 Third Avenue - EHS Seattle WA 98104 Janice Gedlund (206)386-4583 X X

1066 Seattle City Light - Newhalem 1015 Third Avenue - EHS Seattle WA 98104· Janice Gedlund (206) 386-4583 X X

M123 Sedro Wooley Wastewater Treatment PI 720 Murdock Street Sedro Wooley WA 98284 Debbie Allen (206) 856-1100 X X

M018 Selah Wastewater Treatment Plant 115 WNaches Ave Selah WA 98942 Joe Ford (509) 697-4201 X X

M001 Sequim Wastewater Treatment Plant 152 West Cedar Street Sequim WA 98382 Wayne Balholm (206) 683-3883 X X

1012 Shell 011 Co (Anacortes) PO Box 700 Anacortes WA 98221 E.J. Ledet (206) 293-9143 X X

M034 Shelton Wastewater Treatment Plant PO Box 1277, 1700 E Fairmount Shelton WA 98584 Clarence Symes (206) 426-6521 X 'X

1046 Siemens Nuclear Power Corp P.O. Box 130, MS 29 Richland WA 99352 Helen Law (509) 375-8212 X X

1040 Simpson Tacoma Kraft Company PO Box 2133, 801 Portland Ave N Tacoma WA 98421 Ron Stuart (206) 596-0304 X

M067 SkagIt County Health Dept 700 S. 2nd Street Mount Vernon WA 98273 Pat Anderson (206) 336-9380 X

M079 Snoqualmie Pass Sewer Dlst PO Box 131, 68902 SE Snoqualmie Pass Snoqualmie Pass WA 98068 Dave Johnston (206) 434-6600 X X

M104 Snoqualmie Wa$tewater Treatment Plan PO Box 987, 150 Railroad Avenue Snoqualmie WA 98065 Dean Collins (206) 888.-4153 X X

M145 Soap lake Wastewater Treatment Plant PO.66x 1270, Road 20 and St. Andrews Soap lake WA 98851 .11m Whitmore (509) 246-1823 X X

C157 Solltest Farm Consultants 2925 Wapato Dr Moses lake WA 98837 Brent Thyssen (509) 765-1622 X X

1043 Sonoco Products Co. PO Box 489, 1802 Steele Ave. Sunner WA 98390 Forrest Ballard (206) 863-6366. X

C027 Sound Analytical Services 4813 Pacific Highway E Tacoma WA 98424 Andrew J. Riddell (206) 922-2310 X X X X X

1033 Sound Refining, Incorporated P.O. Box 1372, 2628 Marine View Dr. Tacoma WA 98422 Ray Burke (206) 272-9348 X

C156 Southern Petroleum labs, Inc. 8880 Interchange Houston TX 77054 Cynthia Schreiner (713) 660-0901 X X X X

M012 Southwest Washington Health District 2000 Fort Vancouver Way Vancouver WA 98663 Carl Addy (206) 695-9215 X X

1078 Specialty Minerals, Inc. (Camas) PO Box 1046, North Construction Gate Camas WA 98607 Barry Emge (206) 834-4651 X

1075 Specialty Minerals, Inc. (Longview) 3515 Industrial Way Longview WA 98632 Sal lee (206) 577-0912 X

1057 Specialty Minerals, Inc. (Wallula) POBox 107 Wallula WA 99363 Lori Golze (509) 545-9777 X

C077 Spectra Labs, Inc. 2221 Ross Way Tacoma 'WA 98421 Mike Minner (206) 272-4850 X X X

----_.-_._------_._------_._----------_._-_._._._......_._. __ ._--_.-.-----_._._... _-----_._._------------------_._-.......... _- .... _------------._ .......... -......... - ....--...

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LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 011 R M B S

X

x

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

x

x

X

X

X

X

X X

X

X

X

X X

X

X X X

X

X

X X

X

X X X

X X

X

X X

X

x X X

X

X X X

X

X X

X

X X

X

X X

X

X

(509) 625·4640 X X

(206) 692-9782 X

(206) 973-2804 X

(206) 863-7153 X

(206) 683-3880 X

(509) 837·5206 X

(415) 647·1513 X X X

(415) 647·1513 X X X

(206) 763-2992 X X

(206) 459-4670 X.

(818) 357·3247 X X X

.~. :.(3.13)..662-3104 ..X ..; X-...,,,. ,,,~,,,,,,"~_,,,, .__ .~ ....''''

(510) 235-2633

(617) .890·7200

(206) 591,5588

(206) 591·5588

(206) 591-6415

(206) 884·2044

(206) 293-0805

(206) 864-4565

(206) 384~8403

(206) 577·3030

(509) 535-5501

(509) 697·7251

(509) 662-1372

(919) 544·5729

(206) 659,4130

(509) 997·4081

(206) 780-5109

(206) 383-1651

(918) 446-1162

(509) 586-5403

(206) 543-4691

(206) 696-8622

(206) 696-0959

(708) 208-3202

(509) 377-8462

(509) 335-2453

(509) 527-4509

(206) 835,5011

-----------~- -------- -- - - - -- N 4401 A. l. ~hite Parkway Spokana ~A 99205 Mike Coster

10220 270th Street NW, 26729 - 98th A Stanwood WA 98292 Kevin Hushagen

PO Box 98 leavenworth ~A'98826 George Valentine

1104 Maple St Sumner WA 98390 Greg Kongslie

137 Fairway Dr Sequim WA 98382 Bill Thomsen

818 E. Edison Ave Sunnyside. WA 98944 Joe Ortega'

P.O. Box 1545 Martinez CA 94553 John Hurphy

1555 Burke, Unit I San Francisco CA 94124 John Murphy

309 S. Cloverdale Street, Suite A-11 Seattle WA 98108 Elizabeth Fenton

7110 38th Drive lacey WA 98503 Mike Korosec

160 Taylor Street Monrovia CA 91016 David Kohlenberger

525 Avis Drive" STE-·7·. ' .. ···.. 'I\nn..!u'bor ...--, .... - Hk48108HarkRuwe

P.O. Box 4040 Richmond CA 94804 lawrence Johnson

300 Second Ave, P.O. Box 521 Waltham MA 02254 Susan Woodyatt

4002 Waterview St Tacoma 'WA 98421 Martin Collamore

2201 Portland Ave Tacoma WA 98421 Martin Collamore

3629 South D St, MS ASD006 Tacoma WA 98408 Joanne Meyers

PO Box 65, 8230 178th Avenue Court lakebay WA 98349 Jessica Haskell

PO Box 622, 600 South Texas Road Anacortes WA·98221 Fred lenna

PO Box 236, 130 2d St N Toledo WA 98591 Charles Brown

PO Box· 8, 3901 Unick Rd Ferndale WA 98248 Mary Kelleher

207 - 4th Avenue N. Kelso WA 98624 Gordon Templeton

P.O. Box 14642, N 1403 Green St #4 Spokane WA 99202 John Trechter

PO Box 248, 220 E 2d Ave Selah WA 98942 Herle Frost

PO Box 1300, 1111 Van Sickel East ~enatchee WA 98801 Glen Sagdal

801 Capitola Drive Durham NC 27713 Wanda Dean

10610 ~aterworks Road Marysville ~A 98270 Chiara De Neve

P.O. Box 278 Twisp WA 98856 Gary McConnell

7865 NE Day Road West Bainbridge Island WA 98110 Steve Twiss

PO Box 2255, 3001 Marshall Ave Tacoma WA 98401 Shauna-May TecleMarlam

4322 S 49th West Ave Tulsa OK 74107 Beth Walker

P.O. Box 5797 Kennewick WA 99336 Keith Topham

Rm 218, Bloedel Hall (MS AR-l0) Seattle WA 98195 Koross Hosieni

PO Box 9805, 5701 NW lower River Road Vancouver. WA 98666 Allison Diller

1800 Kotobuki Way Vancouver WA 98660 Richard Vaughn

2100 Cleanwater Drive Geneva IL 60134 Donna Bierschenk

PO Box 968 (Mall Drop 280) Richland WA 99352 Terry Northstrom

101 Sloan, Washington State Universlt Pullman WA 99164 Mark ~orthington

Rte 5, Box 79, 571 Hatch St Walla ~alla ~A 99362 lora lyons

1701 C Street, 3900 SR 14 Washougal WA'98671 Dale Hammrlch

M030 Spokane ~astewater Treatment Plant

M187 Stanwood ~astewater Treatment Plant

M181 Stevens Pass Sewer Dist

M031 Sumner ~astewater Treatment Plant

M152 Sunland ~ater District STP

M029 Sunnyside ~astewater Treatment Plant

C144 Superior Precision Analytical (Marti

C145 Superior Precision Analytical (San F

C182 Superior Precision Analytical Hobile

C076 TEG, Inc.

C121 TMA/ARLI

·C139 ,ntA/ERG··; .' ...... .>, ":'''-'''~''' . i

Cl04 TMA/Norcal

Cl08 fHA/Skinner &Sherman Labs

M048 Tacoma North End - ~TP #3

M036 Tacoma Public Works Utility Services

M050 Tacoma/Pierce County Health Dept

M117 Taylor Bay Wastewater Treatment Plan

1001 Texaco, Inc

M077 Toledo Wastewater Treatment Plant

1005 Tosco NW Div Ferndale Refinery

Ml07 Toutle Sewer Treatment Plant

C039 Treclen Laboratories

1056 Tree Top - Selah

1049 Tree Top - ~enatchee

C067 Triangle labs of RTP, Inc

M017 Tulalip Tribes ~aterQuality laborat

M062 Twisp ~astewater Treatment Plant

C122 Twiss laboratories, Inc.

1016 U.S. Oil and Refining Company

C08l USPCI Analytical Services

1037 Unocal Chemicals (Kennewick)

A004 UofW College of Forest Resources

1022 Vanalco, Inc.

M024 Vancouver Westside Wastewater Tmnt P

C023 WMX Environmental Monitoring Labs

C047 WPPSS Environmental Sciences

A007 WSU Environmental Engineering lab

M002 ~alla ~alla ~ater Quality Control La

M171 Washougal Wastewater Treatment Plant

Page 9
LAN LAB NAME ADDRESS CITY ST ZIP CONTACT TELEPHONE CI CII 01 011 R M B S

--- ----- C007 Water Management Laboratories, Inc 1515 80th St E Tacoma WA 98404 Chris Mueller' (206) 531-3121 X X X

M045 Wenatchee Wastewater Treatment Plant PO Box 519, 201 N'Worthen St Wenatchee WA 98801 Jayne Rlckenberg (509) 664-5980 X X

C003 Weston Analytlcs 208 Welsh Pool Rd, Pickering Ind'l Pk Lionville PA 19341 Keith Ryan (610) 701 -6100 X X X X

C013 Weston-Gulf Coest Labs, Inc. 2417 Bond Street University Park IL 60466 Donna McCarthy (708) 534-5200 X X X X

C020 Weyerhaeuser Analytlcel and Testing WTC 2F25 Tacoma WA 98477 Karl Doxsee (206) 924-6148 X X X X X X

1042 Weyerhaeuser Co (Cosmopolis) PO Box 1000, 1701 First Street Cosmopolis WA 98537 Dennis Davies (206) 538-8433 X X

1030 Weyerhaeuser Co (Longview) PO Box 188, 3401 Industrial Way Longview UA 98632 Terry Hopkins (206) 425-2150 X X

M124 Uilbur Wastewater Treatment Plant PO Box 214 Uilbur UA 99185 Bob Kreb (509) 647-5821 X X

M180 Ulnthrop Uastewater Treatment Pl~nt PO Box 459 Winthrop UA 98862 Richard Karro (509) 996-2119 X

MOOS Yakima Wastewater Treatment Plant 2220 East Viola St Yakima UA 98901 Scott Stockton (509) 575-6077 . X X X

Labs accredited as of August 4, 1994 - 362

CATEGORIES

CI - General Chemistry

CII - Trace Metals

01 - Organics by GC

011 - Organics by GC-MS

R - Radiochemistry

M - Microbiology

B - Bioassay

S - Sediments

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