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EPA530-R-98-005l 

SUB-9224-98-012 

RCRA/SUPERFUND HOTLINE MONTHLY REPORT 

DECEMBER 1998 

1. Generator Closure Requirements 

 Under the RCRA regulations, generators are persons who produce a 

hazardous waste or first cause a hazardous waste to become subject to 

regulation. RCRA regulates generators in three categories depending on 

how much waste they produce within a calendar month. These categories 

are large quantity generators (LQGs), small quantity generators (SQGs), 

and conditionally exempt small quantity generators (CESQGs). Each of 

these three categories has detailed provisions in 40 CFR Parts 261 and 

262 for the management of hazardous waste during facility operation. On 

the other hand, Parts 261 and 262 do not contain specific provisions 

outlining requirements for closure of waste management units at such 

generator facilities. What are the closure requirements for hazardous 

waste generator waste management units? 

 The specific generator closure provisions depend on the status of the 

generator and the types of accumulation units that the facility used to 

store or treat hazardous waste. 

 LQGs are subject to the most stringent requirements, which include 

general closure provisions and unit-specific ones. The general closure 

requirements appear in Section 265.111 and Section 265.114 (Section 

262.34(a)(1)). These standards require the minimization of the need for 

further maintenance of the site, and the minimization or elimination of 

post-closure escape of hazardous waste or constituents into the 

environment. These regulations also provide for the decontamination or 

removal of all contaminated equipment, structures, and soils. While 

LQGs must comply with Section 265.111, they are not subject to the 

Section 265.111(c), which pertains to requirements for closure plans and 

financial assurance. 

 LQGs storing or treating waste in tanks, on drip pads, or in 

containment buildings are also subject to closure requirements specific 

to these types of units. Generators managing waste in tanks must 

decontaminate or remove all waste residues and contaminated tank system 

components. If this is not possible, the facility must close in 
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accordance with landfill closure requirements and perform post-closure 

care (Sections 265.197(a) and (b)). Similar provisions apply to 

generator closure of drip pads (Section 265.445(a) and (b)) and 

containment buildings (Section 265.1102). LQGs managing waste in 

containers do not have unit-specific closure requirements. 

 The closure standards for SQG waste management units are less 

extensive. SQGs managing waste in tanks must remove all hazardous waste 

from such tanks, discharge control equipment, and discharge confinement 

structures (Section 265.201(d)). SQGs managing waste in containers do 

not have unit-specific closure requirements. 

 CESQGs waste management units do not have closure requirements. 

 The table below fully outlines the closure requirements applicable 

to each category of generator. 

CLOSURE REQUIREMENT LQGs SQGs CESQGs 

General Standards 

Sections 265.111(a) & (b) Section 262.34(a)(1) None None 

General Standards 

Section 265.114 Section 262.34(a)(1) None None 

Tank Standards 

Sections 265.197(a) & (b) Section 262.34(a)(1)(ii) Section 265.201(d) None 

Drip Pad Standards 

Sections 265.445(a) & (b) Section 262.34(a)(1)(iii) None None 

Containment Building Standards 

Section 265.1102 Section 262.34(a)(1)(iv) None None