October 26, 2017
Historically, large quantity generators of hazardous waste (LQGs) have not been required to meet the EPA’s stringent closure requirements that treatment, storage, and disposal facilities (TSDFs) have been subject to.
This has changed under EPA’s new Hazardous Waste Generator Improvements Rule, which requires LQGs to comply with two facility closure requirements: one that involves closing individual hazardous waste accumulation devices; and the other that involves closure of the entire facility.
These new requirements are at 40 CFR 262.17(a)(8), and became effective federally on May 30, 2017.
The closure requirements for large quantity generators include:
- When closing a waste accumulation unit (such as a container, tank, drip pad, or containment building), facility personnel must:
- Place a notice in their records that identifies the location of the unit within 30 days of closure, or
- Meet the conditions listed below regarding closure of the entire facility
- When an LQG closes the entire facility, they must notify EPA using form 8700-12 within 90 days after closing the facility. If needed, additional time can be requested from EPA to meet these conditions.
- This notification is to inform EPA that the generator has met certain conditions (listed below), or if they were unable to meet these conditions, they have closed the facility under the landfill closure requirements. These are the conditions that the LQG must meet when closing the facility:
- Minimize the need for further maintenance by controlling, minimizing, or eliminating the post-closure escape of hazardous constituents to the environment
- Remove or decontaminate all contaminated equipment, structures, and soil and any remaining hazardous waste residues
- Any hazardous waste generated during closure must be managed in accordance with all applicable hazardous waste regulations