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GEOMATRIX 6.0 FINAL CLOSURE ACTIVITIES Closure activities will be conducted by an outside contractor under the direction of a Civil Engineer licensed in California. Throughout the implementation of this plan, all closure personnel will wear suitable safety equip- ment such as hard hats, safety glasses, cartridge or self contained breathing apparatus,gloves, and safety shoes as specified in a Health and Safety Pian prepared for the proposed closure activities. ' Any spills will be pumped into drums or absorbed using spill control pillows. Spill control pillows will also be used to catch spills or leaks from the decontamination and/or dismantling of pipes, valves, pumps, etc. All used pillows will be placed into 55-gallon drums for disposal at an approved disposal facility. ' Any work around possible flammable areas will require spark-resistant tools and posted warning signs indicating "No Smoking" and "No Open Flames." u 1.28 6.I. Closure of Tank Tank 128 is an aboveground 150,000-gallon steel tank constructed of steel. This tank is currently unused and the top has been removed. The appurtenant aboveground piping consists of approx- imately 500 feet of welded or flanged carbon steel with an inside diameter of approximately ' 4.0 inches. The majority of the appurtenant piping is currently being used as stormwater drainage piping. Closure of the piping is discussed in Section 6.3. ' This tank will be scrapped. Prior to scrapping the tank metal, it will be cleaned and sampled. Cleaning will consist of sweeping the residual rust from the tank floor. The swept-up rust material ' will be stored in drums, analyzed for hazardous waste characteristics, and disposed of as a hazardous waste, if necessary. We anticipate that the cleaned tank metal can be classified and ' handled as nonhazardous waste in accordance with Title 22, California Code of Regulations (22 CCR) 66260.10. In order to demonstrate that the tank metal does not exhibit the characteristics of a hazardous waste, the interior of the tank will be rinsed with approximately 100 gallons of ' water. The rinse water will be stored in a Baker Tank where a single sample will be collected. The pH of the sample will be analyzed to evaluate corrosivity. In addition, the toxicity of the ' sample will be evaluated by conducting analysis for DBCP and EDB using EPA Method 8011, organochlorine pesticides using EPA Method 8080, and organophosphorus pesticides using EPA Method 8140. The results of these analyses will be compared to 22 CCR 66261.22 and 66261.24 to demonstrate that the metal does not exhibit the characteristics of a hazardous waste prior to disposal as scrap metal. 7