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The Independent Closure Audit


In the current economic climate facility closures are unfortunately a fact of life. For IPPC and Waste licensed sites the EPA has further developed its policy regarding the process of surrendering licenses.

A key requirement of the surrender/closure process is for the Licensee to arrange for a Closure Audit to be undertaken by an independent expert. The scope of the Independent Closure Audit (ICA) must have the prior written approval of the Agency before being conducted. The ICA report is expected to address the following;

  • Identify and document the decommissioning, rendering safe or removal for disposal/recovery, of any soil, sub-soils, buildings, plant, equipment, or waste materials or substances or any other matter that may result in environmental pollution.
  • Include a Waste Inventory/Register listing all wastes arising onsite. This should include a description, EWC Code, tonnages, permit details of hauliers, permit/licence details of final destinations and all relevant documents (WTFs, TFSs etc).
  • Where there is potential for asbestos to be present, require full identification, management and safe removal, if required, by an appropriately certified contractor.
  • Identify all underground structures including tanks, pipelines and sumps (containing or previously containing fuel, chemicals, slurry, etc.), and their integrity testing history. Where information is not available, integrity testing may be required during the ICA process.
  • Provide verification that all plant, equipment, tanks, bunds, sumps will be fully emptied, cleaned and verified as such, and that contents will be removed appropriately.
  • Include an assessment of the potential for soil/groundwater contamination: If a hydro-geological assessment has previously been conducted as part of the licence, or due to known contamination onsite, submit same. An investigation may be required to be carried out by an appropriately qualified and experienced hydro-geologist to establish whether the soil/groundwater is contaminated. The assessment should include a Source/Pathway/Receptor assessment together with a Conceptual Site Model.
  • Identify how environmental liabilities will be dealt with post-closure, and whether any remediation measures are necessary. Detail financial provisions. Submit the Residuals Management Plan/Decommissioning Management Plan/Closure Restoration and Aftercare Management Plan.
  • Proposals for revised sampling, analysis and reporting arrangements on foot of the changes on site, for agreement with the Agency.
  • Consideration of health & safety issues during decommissioning  and site security.

The timescale for completion and submission of the Independent Closure Audit Report should be agreed with the Agency. One of the most significant requirements is that the report should include a Declaration that the condition of the site is not causing, and is not likely to cause, significant environmental pollution and that all significant environmental liabilities have been addressed.

Environet has extensive experience in ICAs. If you have any questions in relation to the ICA process please contact Gerard Kelly on 058-51155.