RO 14321 EPA530-R-98-005l

SUB-9224-98-012

RCRA/SUPERFUND HOTLINE MONTHLY REPORT

DECEMBER 1998

1. Generator Closure Requirements

Under the RCRA regulation s, generators are persons who produce a hazardous waste or first cause a hazardous waste to become subject to regulation. RCRA regulates generator s 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 mo st 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 resi dues and contaminated tank system components. If this is not possi ble, the facility must close inRO 14321 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-s pecific closure requirements.

The closure standards fo r SQG waste management units are less extensive. SQGs managing waste in tanks must remove all hazardous waste from such tanks, discharge control eq uipment, 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 262.3 4(a)(1) None None

Tank Standards Sections 265.197(a) & (b) Sectio n 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