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Closure Plans for Surface Waste Facilities

General Closure Requirements for Surface Waste Facilities

Most permit applications require a plan for closing the facility and any pits or waste management unit when operations cease. At the time of closure, an operator may be asked to submit an updated closure plan prior to initiating closure activities.

The closure plan is different from the Closure Cost Estimate (CCE), as the closure plan describes the specific steps the operator will take to close the site, and the CCE is an estimate of the costs, that is “equal to or greater than the maximum amount necessary to close the commercial facility, at any time during the life of the permit term in accordance with all applicable state laws”.

Some older permits may not have specific closure requirements or may have closure requirements that do not meet current standards. In such a case, the operator should refer to the minimum closure requirements described on this page.

Additional closure details may be required for certain types of facilities, such as capping designs for disposal pits and post closure monitoring after the site is closed. 

The closure plan should include, at minimum, the following:

  1. All processing equipment, above-ground storage tanks, and any other non-maintenance related equipment must be cleaned and removed from the Facility. The contents of all tanks, vessels, pits, or other containers must be disposed of in an authorized manner.
  2. All concrete pads must be steam cleaned and demolished and the rubble and wash water disposed of in an authorized manner.
  3. Affected soils underlying the concrete pads must be removed and disposed of in an authorized manner.
  4. Once waste removal is completed, a soil sampling plan must be submitted to characterize the scope of contamination (if any) at the facility. Soil samples must include a minimum of four representative soil samples (grab) per acre and four grab samples from around and underneath each pit or pad.
  5. Excluding any Disposal Pits or non-contact stormwater management ponds necessary for maintenance of the facility, the entire facility must be backfilled as necessary, contoured to original grade and re-vegetated as appropriate for the geographic region.
  6. All soil samples required for closure must be analyzed for the following parameters. If sample concentrations exceed the limitations, contaminated soil must be removed from the area corresponding to that sample, and the area must be resampled to ensure that the specified limitations are not exceeded:

Table 1:  Soil Sample Requirements for Closure 


  EPA Method 9045C

6 to 10 standard units

Electrical Conductivity (EC)
  Louisiana Dept. of Natural Resources Lab Procedures for Analysis of Exploration & Production Waste or equivalent

≤ 4.0 mmhos/cm or background, if established

Total Petroleum Hydrocarbon (TPH)
  Method 5035A/TX1005

10,000 mg/kg or 1% by weight

Total Benzene, Toluene, Ethylbenzene, Xylenes (BTEX)
  EPA Method 5035A/8021/8260B

30 mg/kg

Metals (Total)
  EPA Method 6010/6020/7471A



≤ 10 mg/kg


≤ 10,000 mg/kg


≤ 10 mg/kg


≤ 100 mg/kg


≤ 200 mg/kg


≤ 10 mg/kg


≤ 10 mg/kg


≤ 200 mg/kg


General Post Closure Requirements

  1. In accordance with 16 TAC § 3.78 the permittee must maintain financial security after the facility has stopped receiving waste, met all specified closure requirements and all the disposal pits have been properly capped for the post-closure monitoring period in accordance with this permit. Prior to closure an updated post-closure cost estimate may be submitted to Technical Permitting in Austin, and any additional financial security must be filed with and approved by the RRC prior to the operating financial security being released.
  2. The site must be monitored for a period of no less than 5 years after closure of the facility and the disposal pits.
  3. Any areas showing signs of deterioration, erosion, or failure must be contoured, backfilled, repaired or reseeded.
  4. Once the facility is no longer in operation, the storm water must be handled in a manner that is consistent with the information submitted with the application.
  5. The leak detection systems and the leachate collection systems must be maintained and monitored quarterly. Any leachate detected must be collected and disposed of in an authorized manner.
  6. Post-closure care must include the quarterly inspections of the entire facility by a registered Professional Engineer currently licensed in the state of Texas to identify signs of deterioration, erosion, or failure.
  7. A summary of the results of the post-closure monitoring activity must be submitted to Technical Permitting in Austin as part of the reporting requirements.
  8. The permittee must request in writing permission to cease post-closure monitoring. Post-closure monitoring requirements may be extended by Technical Permitting based on the monitoring results.