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06/14/2007ENSURING EFFECTIVE AND RELIABLE INSTITUTIONAL CONTROLS AT RCRA FACILITIESMemo
 Description: This memorandum emphasizes the need for effective and reliable institutional controls at RCRA facility cleanups, corrective action, and closures where such controls are necessary to provide protection of human health and the environment. It sets forth a number of guiding principles and recommendations that can help EPA and state decision makers on the use of institutional controls at RCRA facilities.
 
09/24/2003OPTIONS FOR CCA WOOD TREATMENT PLANTS CONVERTING TO PRESERVATIVES THAT DO NOT GENERATE HAZARDOUS WASTEMemo
 Description: The prohibition against chromated copper arsenate (CCA) treatment of wood for residential use will require many wood treatment plants to convert to alternative preservatives and perform generator closure of hazardous waste drip pads (SEE ALSO: RPC# 12/1/1998-02, 11/1/1997-01). Three options for complying with the closure requirements are complete closure, continued operation, or phased closure. Complete closure requires owners and operators to clean close drip pads to cleanup levels determined by the implementing agency (SEE ALSO: RPC# 3/16/1998-01) or to close pads as landfills if clean closure cannot be performed. Continued operation requires no cleaning or replacement of drip pads, but owners and operators must continue to comply with the drip pad requirements and manage all wastewaters, process residuals, preservative drippage, spent formulations, and related materials as hazardous wastes via the mixture rule. Phased closure requires owners and operators to sufficiently clean drip pads, system components, and equipment and requires continued compliance with certain drip pad requirements until complete closure is performed. Methods for cleaning drip pads depend on whether pads are covered or sealed, and the methods include gritblasting, hydroblasting/water blasting, solvent washing, and steam cleaning.
 
10/01/2000LDR TREATMENT OPTIONS FOR SPENT INCINERATOR REFRACTORY BRICKQuestion & Answer
 Description: Refractory brick that contacts listed waste during incinerator’s lifetime carries listing via contained-in policy. Facility may treat brick to numerical land disposal restrictions (LDR) standards in 268.40 or employ alternative debris standards in 268.45. Implementing agency may make determination that brick no longer contains listed hazardous waste per 261.3(f)(2), exempting brick from all RCRA standards. Facility has option to obtain equivalent treatment method variance or variance from available treatment standards. Closure plan should detail incinerator closure requirements and specify treatment option.
 
05/01/2000CONTENTS OF CLOSURE PLANQuestion & Answer
 Description: When estimating the maximum inventory of wastes on site during the active life of the facility for closure plan, TSDFs must include wastes that are treated or accumulated in 90-day generator units as well as permitted units.
 
04/01/2000POST-CLOSURE PERMIT RENEWALSQuestion & Answer
 Description: Owners and operators of land-based units that receive post-closure permits must renew permits every 10 years during post-closure care period. Owners and operators must submit information specified in 270.28 for post-closure permit renewal.
 
04/28/1999POST-CLOSURE RULE OPTIONS FOR ADDRESSING GROUNDWATER MONITORING FOR REGULATED UNITSMemo
 Description: EPA increased regulatory flexibility in addressing closure and groundwater monitoring for regulated units in Post-Closure rule (63 FR 56710; 10/22/98). Provisions provide regulators discretion to set out site-specific requirements in permit or other enforceable document.
 
12/01/1998GENERATOR CLOSURE REQUIREMENTSMemo
 Description: Large quantity generator (LQG) closure standards require the minimization of need for further maintenance, the minimization or elimination of post-closure escape of hazardous waste or constituents, and decontamination or removal of all contaminated equipment, structures, and soils. LQGs storing or treating waste in tanks, drip pads, or containment buildings are also subject to unit-specific closure standards. Small quantity generators (SQG) managing waste in tanks must remove all hazardous waste, discharge control equipment, and discharge confinement structures. Conditionally exempt small quantity generators (CESQG) do not have closure requirements.
 
10/01/1998Environmental Fact Sheet: Post-Closure Permit Amendment Addresses Corrective ActionPublication
 Description: This fact sheet announces EPA's removal of impediments to cleanup at hazardous waste facilities by amending closure and post- closure care requirements to expand regulatory options available to EPA and authorized states. It describes a rule to facilitate cleanup of hazardous and solid waste management units that may be similarly situated, but were formerly subject to two different requirements.
 
11/01/1997DRIP PAD CLOSURE NOTIFICATION AND CERTIFICATION REQUIREMENTSQuestion & Answer
 Description: Owners and operators of drip pads are generators in most cases, and therefore, are not required to comply with notification and certification of closure requirements in Sections 264/265.112(d) and 264/265.115. Generators must comply with closure performance standards in Section 265.111, and disposal and decontamination of equipment, soils, and structures in Section 265.114. In addition, owners and operators of drip pads must comply with the drip pad closure requirements of Subpart W. If decontamination or removal cannot be fully accomplished during closure, the drip pad must close as a landfill.
 
04/17/1997CLARIFICATION ON USE OF FATE AND TRANSPORT MODELING DURING RCRA CLOSURE AND PUBLIC PARTICIPATION DURING RCRA CORRECTIVE ACTIONMemo
 Description: The Agency allows the appropriate use of fate and transport modeling to demonstrate, under clean closure, that materials contaminated with waste that are not removed do not present unacceptable risks. The use of modeling to make demonstration does not affect the requirements for removal of all wastes (SEE ALSO: RPC# 9/24/96-01). EPA's commitment to public participation is the same whether corrective action is implemented in the context of a RCRA permit or an enforcement order. EPA expects that non-RCRA cleanups will provide an appropriate level of public participation. The public has an opportunity to review and comment on whether it is appropriate for the Agency to defer RCRA corrective action to a non-RCRA program in certain instances.
 
02/01/1997DELAY OF CLOSUREQuestion & Answer
 Description: Owners and operators of hazardous waste surface impoundments, landfills, and land treatment units can delay the closure timetable beyond the 90-day period and allow the units to accept nonhazardous waste, if the units meet the conditions of Sections 264.113(d)/265.113(d). Owners or operators of tanks, containers, waste piles, and incinerators are not allowed to delay closure. These units must comply with all applicable closure standards before being able to accept nonhazardous waste.
 
11/01/1996Environmental Fact Sheet: Assurance Mechanisms Finalized for Local Government Owners of MSWLFsPublication
 Description: The Local Government Financial Test was proposed December 27, 1993 in response to comments from local governments requesting flexibility in meeting the financial assurance requirements of the Solid Waste Disposal Criteria promulgated on October 9, 1991. The Test allows local governments to meet their financial assurance obligations for closure, postclosure care and corrective action pursuant to the Criteria by demonstrating their financial strength. The effective date for these financial assurance requirements is now April 9, 1997 (small, dry, or remote landfills have until October 9, 1997 to comply).
 
06/01/1996DELAY OF CLOSURE FOR NON-RETROFITTED HAZARDOUS WASTE SURFACE IMPOUNDMENTS CONTINUING TO RECEIVE NON-HAZARDOUS WASTEQuestion & Answer
 Description: A surface impoundment newly subject to regulation may cease receiving hazardous waste before the four-year mandatory retrofitting deadline and thus avoid minimum technological requirements (MTR). An owner may continue receiving nonhazardous waste indefinitely without closing. The owner of a surface impoundment that ceases receiving hazardous waste does not have to begin closure activities until 90 days after the final receipt of nonhazardous waste. An impoundment not in compliance with Section 265.113(e) must begin closure within 90 days after the 4-year retrofitting period (Section 3005(j)).
 
03/08/1996NEW INFLATION FACTORS FOR UPDATING FINANCIAL RESPONSIBILITY COST ESTIMATESMemo
 Description: Closure and post-closure cost estimates may be updated by using an inflation factor derived from dividing the latest GDP Implicit Price Deflator (IPD) by the deflator for the previous year. The GDP IPD has largely supplanted the GNP IPD referenced in the regulations. In January 1996, the Commerce Department published a new series of IPDs with a new base year of 1992. Cost estimates should use the new IPD values based on the new 1992 base year (NOTE: 1994 and 1995 IPD figures in this memo are incorrect).
 
01/01/1996CONVERSION OF PERMITTED OR INTERIM STATUS UNITS TO GENERATOR ACCUMULATION UNITSQuestion & Answer
 Description: Permitted or interim status units converted to generator accumulation units may delay closure until the final receipt of hazardous waste. The owner or operator must maintain financial assurance until final closure is completed.
 
02/15/1995Construction and Demolition Waste LandfillsPublication
 Description: Presents information on construction and demolition (C&D) waste landfills. Discusses the composition of C&D wastes, including any hazardous materials or constituents. Provides information on the quality of C&D landfill leachate, based on sampling data taken from landfills around the country. Contains a detailed summary of state regulations pertaining to C&D facilities. Identifies states that have regulations related to groundwater monitoring; corrective action; location restrictions; and facility design, operation, closure, and/or postclosure care; and provides the specifics of those regulations.
 
09/15/1994Technical Report: Treatment of Cyanide Heap Leaches and TailingsPublication
 Description: Provides information on cyanide treatment methods for heap leaches and tailings activities associated with cyandation operations. Discusses cyanide detoxification or treatment in terms of chemistry, duration, removal efficiencies, and advantages and limitations. Describes treatment techniques and typical closure and reclamation activities for heaps and tailings impoundments. Includes federal and state requirements that apply to cyanide operations and selected case studies. Presents treatment options without evaluating their efficiency.
 
07/25/1994CLARIFICATION OF CERTAIN CLOSURE COST ESTIMATE REQUIREMENTS APPLICABLE TO FACILITIES SEEKING A PERMIT UNDER 40 CFR 264Memo
 Description: Closure cost estimates must equal the cost of closing a facility at the point where closure would be the most expensive. Salvage value for waste, equipment, land, assets, or zero cost for hazardous and nonhazardous wastes may not be used in the estimate. A third party is a party who is neither a parent or subsidiary corporation.
 
11/15/1993Solid Waste Disposal Facility Criteria: Technical ManualPublication
 Description: This document was updated in April 1998 with a new introduction. Addresses general applicability of the Part 258 criteria, location restrictions, operating requirements, design standards, groundwater monitoring and corrective action, and closure and postclosure care for landfills. Includes the regulatory language, a general explanation of the regulations and who must comply with them, key technical issues that may need to be addressed to ensure compliance with a particular requirement, and information sources. Written for municipal solid waste landfill owners and operators.
 
06/04/1993INDEPENDENT REGISTERED PROFESSIONAL ENGINEER'S CERTIFICATIONMemo
 Description: Provides clarification of an independent registered professional engineer for closure certification. An engineer employed by a subsidiary may be able to certify the parent company's closure if certain conditions are met. Discusses the definition of majority-owned subsidiary.
 
06/01/1993CLOSURE TIMETABLE FOLLOWING TERMINATION OF INTERIM STATUSQuestion & Answer
 Description: Owners of facilities that lost interim status (LOIS) must submit a closure plan to the state or Regional office no later than 15 days after termination of interim status. The remainder of the interim status closure timetable is dictated by the date of approval of the closure plan
 
05/28/1993CLARIFICATION OF THE CLOSURE REQUIREMENTS FOR HAZARDOUS WASTE MANAGEMENT FACILITIESMemo
 Description: Due to differences in the timing of closure plan submittal, interim status facilities must identify a specific destination of closure wastes, while permitted facilities need only identify the type of unit to which their closure wastes will be sent.
 
03/15/1993Safer Disposal for Solid Waste: The Federal Regulations for LandfillsPublication
 Description: Summarizes the federal regulations covering landfill location, operation, design, groundwater monitoring and corrective action, closure and postclosure care, and financial assurance. Gives owners/operators and local officials dates for compliance and additional sources of information.
 
03/15/1993U.S. ARMY CORPS OF ENGINEERS OR INDEPENDENT REGISTERED, CERTIFIED ENGINEERSMemo
 Description: 264.115 and 265.115 do not require independent, registered, certified engineers certifying closure to be registered in the state where the facility is located. EPA has determined that U.S. Army Corps of Engineers personnel are independent and can certify closure of Army facilities. An authorized state can interpret independent, certified, professional engineer to require an engineer to be registered in the state where the facility being inspected is located (SEE ALSO: RPC# 12/21/92-01).
 
12/21/1992CLARIFICATION OF THE TERM INDEPENDENT, REGISTERED, CERTIFIED ENGINEERMemo
 Description: Authorized State can interpret “independent, certified, professional engineer” to require engineer to be registered in the state where the facility he is inspecting is located. An engineer from the Army Corps of Engineers meets the criteria for independent, qualified, professional engineer for purposes of assessments, installation, and/or testing for other federal facilities (SEE ALSO: RPC# 3/15/93-01).
 
10/01/1991TSDF CLOSURE/POST-CLOSURE AFTER LOSS OF INTERIM STATUSQuestion & Answer
 Description: An owner of a facility that has lost interim status (LOIS) must still comply with the Part 265 closure and post-closure requirements. a facility can lose interim status due to the owner’s failure to submit a certification of compliance with the groundwater monitoring and financial responsibility requirements.
 
05/02/1991CLOSURE STANDARDS FOR HAZARDOUS WASTE LAND TREATMENT UNITSMemo
 Description: Soil sampling is usually required during land treatment unit closure and post-closure as part of the unsaturated zone monitoring. If the treatment unit is removed as a part of clean-closure, the soil-core monitoring may be suspended at the completion of the closure period. Discusses guidance on intervals for, and duration of, soil sampling during closure and post-closure. There is no EPA-approved methods for determining degradation rates. Closure of a land treatment unit may take up to 360 days. Discussion of closure and post-closure standards for a land treatment units when migration of hazardous constituents has occurred. Discussion of closure standards when groundwater is contaminated at levels below alternate concentration levels specified in a facility permit. The post-closure period for a land treatment unit cannot be terminated until owner or operator has successfully demonstrates that all groundwater at the site is safe for all potential receptors. Discuses addressing migration of constituents of concern outside of the treatment zone during closure versus under corrective action. There are no regulatory provisions requiring corrective action when migratory constituent concentrations exceed regulatory levels of concern in groundwater at an interim status land treatment facility (3008(h)). Discussion of when closure is considered complete.
 
06/04/1990REGULATORY INTERPRETATION OF OBJECTION TO CLEAN-CLOSURE EQUIVALENCY PETITION FOR STEEL ABRASIVES, INC.Memo
 Description: All landfills, surface impoundments, waste piles, and land treatment units that received waste after July 26, 1982 are subject to post-closure permitting and Part 264 Subpart F standards unless the owner demonstrates that closure under the previous Part 265 standards met Part 264 closure by removal standards (SUPERSEDED: See 63 FR 56711; October 22, 1998). Under RCRA 3005(i), EPA has the authority to revisit interim status clean closures and require post-closure permits if closure does not meet closure by removal standards of Part 264. In order to demonstrate clean closure, an owner generally should remove “hot spots” of contamination.
 
05/28/1990FINANCIAL RESPONSIBILITY REQUIREMENTS - CERTIFYING CLOSUREMemo
 Description: Owners and operators need to record notations on the property deeds within 60 days of certifying closure. Financial assurance ends within 60 days of receiving certification of final closure.
 
05/11/1990CONOCO PART B PERMITSMemo
 Description: Pending decision on land disposal restrictions (LDR) no-migration petition, a facility may dispose nonhazardous waste in a land disposal unit undergoing delay of closure after permit modification. If a no-migration petition is denied, the unit must undergo final closure unlessthe facility can receive nonhazardous waste.
 
05/07/1990INTERIM SOIL LEAD CLEANUP LEVELS AT RCRA FACILITIESMemo
 Description: Interim guidance on establishing soil lead cleanup levels at RCRA facilities for closure and corrective action. Background levels may be appropriate as cleanup levels. Discusses the applicability of lead cleanup levels presented in OSWER Superfund directive 9355.4-02.
 
10/01/1989INTEGRITY ASSESSMENT FOR HAZARDOUS WASTE TANKS AND POST-CLOSURE REQUIREMENTSQuestion & Answer
 Description: Tanks without secondary containment must comply with the closure/post closure requirements, even if the tank’s owner and/or operator completes a successful integrity assessment. An owner and/or operator must submit a closure plan for the decontamination of a tank system and a contingency plan for post-closure care. Post-closure care is required only if decontamination cannot be performed.
 
09/07/1989PUBLIC PARTICIPATION REQUIREMENTS FOR CLOSURE PLAN APPROVALMemo
 Description: A closure plan modification that meets the criteria for a Class 2 or Class 3 permit modification is subject to public notice and participation when submitted for approval.
 
08/22/1989DELAY OF CLOSURE RULE PREAMBLE LANGUAGE, CORRECTIONMemo
 Description: Discussion of a correction to the 8/14/89 Federal Register (54 FR 33376, Delay of Closure Rule). The 264.113(d)(4) regulatory language concerning the deadline for permit modification requests is correct while the preamble language is incorrect.
 
05/16/1989DELAY OF CLOSURE PERIOD FOR HWM FACILITIESMemo
 Description: Under limited circumstances, landfills, surface impoundments, and land treatment units may remain open after the final receipt of hazardous waste in order to receive nonhazardous waste.
 
04/01/1989GENERATOR CLOSURE/FINANCIAL REQUIREMENTSQuestion & Answer
 Description: LQGs must comply with 265.111 and 265.114. SQGs need only comply with the applicable accumulation unit closure requirements. Generator tanks which cannot meet the closure performance standards must close as a landfill and comply with 265, Subparts G and H.
 
12/09/1988STAYING HSWA PERMIT CONDITIONSMemo
 Description: The state and federal portions of a joint permit may be issued at different times. The issuance of the HSWA portion of a joint permit does not terminate a facility’s interim status. 3004(u) corrective action proceedings can become effective when a permit is issued, even if all permit appeals are not completed. The Regional Administrator (RA) sometimes has the discretion to stay or delay the effective date of the HSWA portions of an appealed state permit.
 
10/15/1988SURFACE IMPOUNDMENT RETROFITTING AND TIME ALLOWED FOR CLOSUREMemo
 Description: A surface impoundment in existence on 11/8/84 must meet the minimum technological requirements by 11/8/88 or cease receiving waste and close unless given an approved exemption. A permit as a shield is not applicable to 3005(j).
 
07/19/1988EFFECT OF LAND DISPOSAL RESTRICTIONS ON TRANSFER OF WASTE DURING FACILITY CLOSUREMemo
 Description: Transferring waste between units at an active facility or during closure is land disposal and triggers the land disposal restrictions (LDR) treatment requirements. In-situ treatment or movement of waste within the unit is not placement and so waste is not subject to LDR treatment standards.
 
07/01/1988TANK REPLACEMENTQuestion & Answer
 Description: The replacement of a hazardous waste storage tank would not constitute final closure. There is no notification for the partial closure of a tank, container, or incinerator. While not specifically required, the tank and equipment should be decontaminated and the region or state implementing agency should be notified.
 
06/16/1988LAND BAN ISSUES - 1988 UPDATEMemo
 Description: A surface impoundment not meeting the minimum technical requirements (MTR) may continue to receive restricted wastes if it has a waiver under 3005(j). Units receiving waste subject to a national capacity variance or a case by case extension must meet MTR. Provides criteria for case-by-case extensions, a discussion of the soft hammer provisions, guidance on the treatment of soil, and treatment capacity information. Addresses the lack of capacity due to surface impoundment closure.
 
05/31/1988DEADLINES APPLICABLE TO PROPOSED DELAY OF CLOSURE REGULATION, GUIDANCEMemo
 Description: The proposed delay of closure rule (53 FR 20738; 6/30/88) would allow owners and operators of landfills and certain surface impoundments to delay closure to receive nonhazardous waste. Units which have lost interim status are not eligible for a delay of closure. Owners of units who wish to delay closure must obtain a permit or permit modification. Surface impoundments that are not retrofitted to meet the minimum technological requirements are subject to special requirements if the owner wishes to delay closure. Units that delay closure remain subject to Subtitle C. Units remain subject to the closure plan submission deadlines despite the proposed delay of closure rule (53 FR 20738; 6/30/88). Because the proposed rule is less stringent than the existing closure regulations, authorized states are not required to adopt the new provisions. Interim status units that cease receiving hazardous waste on 11/8/88 may continue to receive nonhazardous wastes until the closure plan is approved as well as during the closure period provided it does not impede closure.
 
05/27/1988SOIL BACKGROUND LEVELS AS CLEAN CLOSURE STANDARDS, USE OFMemo
 Description: Clean closure levels for surface impoundments, waste piles, and land treatment units must be based on EPA-recommended exposure levels or factors that have undergone peer review by EPA. Where no health-based levels exist, clean closure levels are based on background or exposure levels submitted by the owner based on toxicity data. Includes recommendations for clean closure levels for lead and cadmium. Lead background levels should be established by taking soil samples at an uncontaminated area of the facility or by using published literature data on lead levels in similar soils (SUPERSEDED: see RPC# 5/7/90-01).
 
05/12/1988DEMONSTRATING EQUIVALENCE OF PART 265 CLEAN CLOSURE WITH PART 264 REQUIREMENTSMemo
 Description: Under 270.1(c), owners of interim status surface impoundments and waste piles who clean closed under the old Part 265 closure standards may demonstrate equivalency with the 264 closure standards. Discusses the contents of the demonstration equivalency and the procedures for submittal. If an attempt at a closure equivalency demonstration does not meet the 264 standards, the owner must submit a Part B permit application. Addresses the acceptability of specific information supporting equivalency demonstrations. An owner of an interim status landfill where waste was removed at closure can reclassify it as a waste pile and demonstrate clean closure equivalency, or the owner may request a shortened post-closure care period (SEE ALSO: 63 FR 56711; 10/22/98).
 
04/19/1988CALL-IN OF STORAGE AND TREATMENT APPLICATIONSMemo
 Description: Pursuant to 3005(c)(2)(C), interim status treatment and storage facilities that were in existence on 11/8/84 must submit their Part B permit applications by 11/8/88, or their interim status will terminate on 11/8/92. A facility with only tanks, containers, or incinerators must submit a closure plan 45 days prior to the date that closure will begin.
 
04/19/1988CALL-IN OF STORAGE AND TREATMENT APPLICATIONS PRIOR TO 11/08/88 DEADLINEMemo
 Description: Pursuant to 3005(c)(2)(C), interim status treatment and storage facilities that were in existence on 11/8/84 must submit their Part B permit applications by 11/8/88, or their interim status will terminate on 11/8/92. A facility with only tanks, containers, or incinerators must submit a closure plan 45 days prior to the date that closure will begin.
 
04/01/1988EFFECTIVE DATES FOR CHARACTERISTIC & LISTED WASTES PER 03/19/87 CLEAN CLOSURE REGULATIONMemo
 Description: Clarifies the applicability of the “Clean Closure Conforming Changes Rule” (52 FR 8704; 3/19/87) in authorized and unauthorized states. HSWA 3005(i) states that all units (e.g. surface impoundments) clean closed pursuant to the 265 standards are not relieved of post-closure care obligation until the owner demonstrates equivalency with the 264 standards.
 
03/31/1988GROUNDWATER MONITORING AT CLEAN-CLOSING SURFACE IMPOUNDMENT & WASTE PILE UNITSMemo
 Description: As a part of the clean closure certification process, EPA must review groundwater monitoring data to verify that there is no groundwater contamination from the unit. Units that have already certified clean closure without assuring clean groundwater must be reexamined. Owners of some clean-closed interim status units may be able to demonstrate that the groundwater is uncontaminated without installing a groundwater monitoring system. The 3008(a) enforcement authority can be used to obtain remedies and/or penalties under 3008(g). EPA may use 3008(h), 3013, and/or 7003 to investigate and respond to releases at units that ceased receiving waste prior to 7/26/82. EPA can invoke 3004(u) at facilities otherwise requiring a permit that improperly clean-closed.
 
03/10/1988CLOSURE PLAN CONTENTS AND REQUIREMENTS FOR REVISIONSMemo
 Description: An interim status closure plan must be amended at least 60 days prior to a proposed change at a facility, or within 60 days after an unexpected event (265.112(c)(2)). A closure plan must be amended 60 days before completion and operation of the treatment unit. A closure plan need not be revised if a mobile treatment unit (MTU) is mobilized or demobilized. A closure plan must account for all units at a facility that has actually been constructed (265.112(b)(1)).
 
03/02/1988CLEANUP LEVELS FOR LEAD AND CADMIUM IN SOILS FOR CLEAN CLOSUREMemo
 Description: VERIFIED REFERENCE DOSES (RFDS) AND Carcinogenic Potency Factors (CPFs) can be used to set soil cleanup levels during clean closures of surface impoundments, waste piles, and land treatment units. Where no EPA-recommended health-based limit exists for a contaminant, a soil cleanup level may be based on background levels or by data developed by the owner to support a health-based limit. If the cleanup level cannot be established, then clean closure cannot be achieved and the unit (i.e. surface impoundment, waste pile, or land treatment unit) must close as a landfill. Provides guidance for determining the background levels for lead in soil for clean closures of surface impoundments, waste piles, and land treatment units. Discusses how to determine background levels of lead in soil.
 
02/10/1988VERTICAL EXPANSION AT U.S. ECOLOGY'S TRENCH 10, BEATTY, NEVADA FACILITYMemo
 Description: Landfill vertical expansion is limited by federal, state, and local permits in effect prior to HSWA. Vertical expansion after 11/8/84 constitutes a new unit that is subject to the minimum technological requirements (MTR). When there is no elevation limit in the permit, consider the slope of the cover at closure.
 
02/08/1988CLOSURE PERFORMANCE STANDARDMemo
 Description: EPA may use closure performance standards, post-closure permits, or 3008(h) orders to ensure effective closure. A closure performance standard can be used to require source control at a leaking surface impoundment. Closure must be consistent with future corrective action.
 
02/02/1988CLOSURE REQUIREMENTSMemo
 Description: EPA recognizes the inconsistencies between the tank and container closure requirements and plans to revise Subpart I to ensure consistency. The 3/19/87 clean closure guidance (52 FR 8704) should be applied to closure by the removal of wastes from any RCRA unit. EPA plans to allow interim status and permitted landfills to defer closure to manage nonhazardous wastes. Characteristic waste must be managed as hazardous unless it no longer exhibits any of the four characteristics. Discusses the more protective clean closure action levels v. hazardous waste identification levels. Listed wastes and any waste residues or contaminated soil or debris removed during closure are hazardous unless delisted. The concentrations of total organic carbon (TOC) and total organic halogens (TOX) cannot be used to determine if decontamination wastewater is hazardous.
 
02/01/1988CLEAN CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENT AND WASTE PILEQuestion & Answer
 Description: Surface impoundments, waste piles, landfills, and land treatment units which received waste after 7/26/82 or certified closure after 1/26/83 must either have post-closure permits or demonstrate that clean closure was equivalent to Part 264 closure (270.1(c)) (SEE ALSO: 63 FR 56711; 10/22/98). Post-closure permits for these units would include Part 264 groundwater monitoring, unsaturated zone monitoring, corrective action and post-closure care.
 
12/17/1987CLOSURE AND POST-CLOSURE ISSUES FOR INTERIM STATUS SURFACE IMPOUNDMENTSMemo
 Description: EPA may extend the time allowed for the closure of a surface impoundment to allow groundwater corrective action so that the owner can achieve clean closure. Units closing by removal under Part 265 (e.g. surface impoundments, waste piles, and land treatment units) must obtain post-closure permits unless the owner demonstrates equivalence with 264.228, 264.280(e), or 264.258 closure by decontamination standards (SEE ALSO: 63 FR 56711; 10/22/98). The owner of an interim status landfill that has closed by removal and has not triggered groundwater assessment does not have to monitor groundwater for the full list of Appendix VIII or IX constituents. Groundwater evaluation conducted as part of the 265 clean-closure demonstration should establish constituents that could reasonably be expected to exist at the impoundment. A surface impoundment that has triggered groundwater assessment may not be able to clean close.
 
12/14/1987RCRA PROGRAM DIRECTIONS - PRIORITY TO ENVIRONMENTALLY SIGNIFICANT FACILITIESMemo
 Description: Fiscal Year 1989 RCRA priorities are to focus on corrective action and closure at the entire universe of environmentally-significant facilities.
 
11/05/1987LEACHING TESTS FOR EVALUATING SOILS CONTAMINATED WITH LEADMemo
 Description: Method 1310 extraction procedure (EP) is used to determine if contaminated soils exhibit the toxicity characteristic (SUPERSEDED: see 261.24). Method 1312 for in-place soil and debris is under development. It may be appropriate for facility investigations and clean closure determinations. 1311 (TCLP) may not be appropriate for groundwater contamination of soil and debris.
 
11/01/1987CLOSURE PLAN PUBLIC COMMENT PERIODQuestion & Answer
 Description: There is no specific time-frame for the Regional Administrator (RA) to initiate the 30-day public comment period for interim status closure plans.
 
09/17/1987LAND DISPOSAL FACILITIES NOT ON A PERMITTING OR CLOSURE SCHEDULEMemo
 Description: Certain facilities lack a multi-year strategy for permitting or closure. EPA plans to resolve the regulatory status of these facilities as soon as possible.
 
09/01/1987CERTIFICATION OF CLOSUREQuestion & Answer
 Description: An engineer employed by a contractor conducting closure activities can certify closure. An “independent” engineer cannot be directly employed by the owner or operator of the unit being closed.
 
08/07/1987MTR COMPLIANCE DATES FOR SURFACE IMPOUNDMENTS (THERMEX ENERGY)Memo
 Description: The loss of a temporary exclusion is the same as being a newly listed waste for purpose of complying with minimum technical requirements (MTR) for surface impoundments (SIs). There is a conflict between the Section 3005(j)(1) and Section 3005(j)(6) MTR dates. Part B permit application for an interim status facility is due when requested by the State or Regional office. Implementation of closure must begin either 90 days after the SI stops receipt of waste or when the closure plan is approved. The time allowed for closure implementation or completion may be extended.
 
08/07/1987PERMIT REQUIREMENTS, THERMEX ENERGY/RADIANMemo
 Description: The loss of a temporary exclusion is the same as being newly listed for the purpose of complying with the minimum technical requirements (MTR) for surface impoundments (SIs). Addresses the conflict between the 3005(j)(1) and 3005(j)(6) MTR dates. Part B permit applications for interim status facilities are due when requested by a state or Regional office. A facility must initiate closure either 90 days after the SI stops receiving waste or when the closure plan approved. The time for closure implementation or completion may be extended.
 
07/17/1987DEACTIVATION (POPPING) FURNACES AS INCINERATORSMemo
 Description: Popping furnaces meet the definition of an incinerator since the process that occurs in the enclosed units is controlled flame combustion. Interim status for incinerators terminated 11/8/89 if a Part B permit application was not submitted by 11/8/86 per 270.73(f) (memo inaccurately cites 11/19/86 and 11/19/89 - should be 11/8/86 and 11/8/89).
 
06/26/1987ADJACENT WASTE PILES INTO REGULATED SURFACE IMPOUNDMENT, PLACEMENT OF (CIBA-GEIGY)Memo
 Description: The placement of adjacent waste soil piles in a regulated surface impoundment as part of closure is permissible. The placement of hazardous waste beyond the boundary of a regulated unit constitutes lateral expansion and must meet minimum technological requirements (3004(o)(1)).
 
06/01/1987CLEAN CLOSUREQuestion & Answer
 Description: EPA interprets contaminated subsoils to include contaminated groundwater. Contaminated groundwater must be removed or decontaminated to achieve clean closure at a surface impoundment.
 
05/01/1987APPLICABILITY OF CONTINGENT CLOSURE AND POST-CLOSURE PLANSQuestion & Answer
 Description: Contingent closure and post-closure plans are required for all tanks that do no have secondary containment until secondary containment meeting 264.193 or 265.193 is installed.
 
04/15/1987SURFACE IMPOUNDMENT RETROFITTING REQUIREMENTSMemo
 Description: Permits issued to existing surface impoundments must require retrofitting within four years. The regulations force closure of all impoundments that do not retrofit. Permitted impoundments forced to close must follow the closure plan in the permit. Interim status impoundments must follow 265.113.
 
04/01/1987CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENTSQuestion & Answer
 Description: Addresses the difference between the clean-closure standards prior to and after the 3/19/87, ruling (52 FR 8704). Wastes from clean-out must be managed as hazardous wastes unless they no longer meet the definition of hazardous waste. Impoundments which held characteristic waste may be required to be cleaned below characteristic levels.
 
03/30/1987SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTSMemo
 Description: A native soil foundation does not constitute a liner for the purposes of the 3005(j)(2) waiver. A 264.282 compatibility demonstration applies to both hazardous and nonhazardous waste. Addresses HSWA waste minimization requirements (3002(b)) and the application of sludge to land treatment units. The identification of principal hazardous constituents for land treated wastes must include all constituents that may enter the waste stream. A land treatment unit performance evaluation must include the unit’s ability to treat and degrade organic constituents, as well as its ability to immobilize heavy metals. Provides guidance on the frequency of soil pore liquid sampling at land treatment units (unsaturated zone monitoring) and guidance on screening groundwater monitoring wells. QA/QC methodology at a land treatment unit should include verification of the organic constituent analysis by gas chromatography/mass spectroscopy (GC/MS). Includes guidance on the content of construction quality assurance plans. A person who conducts quality assurance measures for surface impoundments, waste piles, and landfills should be independent of the construction contractor. Discusses the use of Method 9090 for compatibility testing of liner materials with waste or leachate. All man-made materials that contact waste or leachate should be subjected to the immersion test portion of 9090. A sample of waste or leachate used in compatibility testing must be representative of the actual waste or leachate managed in the surface impoundment, waste pile, or landfill. A concrete pad cannot be equivalent protection. If the design slope of a final landfill cover exceeds 3-5%, the applicant must demonstrate that soil erosion will not be excessive and may need to perform a slope stability analysis. Waste and soil settlement must be included in calculations for the final landfill cover design to be substituted for a waste pile liner as equivalent protection under 3015(a). A flexible membrane liner should not be used in a final cover when the landfill is unusually deep and slopes are steep. Clean, not contaminated, soil should be used for the final cover. A leachate collection system design should be based on realistic infiltration rates. Geogrid and geotextile materials used in place of conventional drainage materials for a landfill must have an equivalent drainage capacity of a one-foot layer of compacted sand. Berms constructed of manufactured slag should not contain hazardous constituents. For landfills, the use of a composite primary liner below the primary synthetic liner is allowable. An owner of a land treatment unit who cannot establish vegetative cover may use an alternate closure procedure. A facility cannot extend closure in order to receive nonhazardous waste (SUPERSEDED: see current 264.113(d)). Addresses the role of the Agency for Toxic Substances and Disease Registry (ATSDR) in exposure information and evaluation. The review of Exposure Information Reports should be coordinated with ongoing RCRA Facility Assessments.
 
01/15/1987RCRA Guidance Manual for Subpart G Closure and Postclosure Care Standards and Subpart H Cost Estimating RequirementsPublication
 Description: This document assists regions and states with implementation of closure and post-closure care and cost estimate regulations and helps owners and operators prepare plans and cost estimates to satisfy the regulations. The document also discusses site-specific factors that may affect closure and post-closure care activities and provides closure and post-closure checklists to assist in preparing and reviewing plans.
 
12/10/1986PERMITTING UNITS OR FACILITIES THAT HAVE LOST INTERIM STATUSMemo
 Description: Facilities that have lost interim status may apply for a Part B permit. EPA should review closure plans of facilities that have lost interim status without regard for pending permit applications. Discusses EPA policy for implementation of closure regulations for units pending permit approval or denial. Minimum technological requirements (3004(o)) may apply to a unit that lost interim status, closed, and reopened under a Part B permit.
 
12/01/1986EXISTING UNITS AND MIMIMUM TECHNOLOGY STANDARDSQuestion & Answer
 Description: Removing waste from a landfill, stabilizing it, and replacing it is not reuse or replacement of a landfill provided it is part of closure and no new waste is added. The landfill is still an existing unit and is not subject to the minimum technology standards of section 3004(o) (SEE ALSO: 57 FR 3464-3465; 1/29/92).
 
11/20/1986POST-CLOSURE PERMIT REQUIREMENTS (ARMCO STEEL)Memo
 Description: The owner of a facility that ceased receiving hazardous waste on 1/26/83 and certified closure in 9/84 must obtain a post-closure permit (SUPERSEDED: See 63 FR 56711; 10/22/98).
 
11/01/1986TERMINATION OF PERMITSQuestion & Answer
 Description: A summary of reasons for which EPA can terminate a facility’s permit. If the owner or operator of facility has certified closure for all units and wants to terminate the permit before its expiration date, he/she should request a major permit modification (SEE ALSO: RPC# 10/1/86-05).
 
10/12/1986HAZARDOUS WASTE LISTING FOR F006 WASTEMemo
 Description: The F006 listing does not cover chemical conversion coating, electroless plating, or printed circuit board manufacturing (unless the circuit board operation involves a F006-covered process, such as chemical etching). Chemical conversion coating includes chromating, phosphating, immersion plating, and coloring. The F006 listing covers sludges from anodizing and etching processes. Facilities that handle only wastes from excluded processes have never managed a hazardous waste, do not need a permit or interim status, are not subject to corrective action, and are not subject to closure. A F006 delisting petition is unnecessary for sludges from excluded processes.
 
10/08/1986CLOSURE AFTER CESSATION OF RECEIPT OF HAZARDOUS WASTEMemo
 Description: The goal of EPA’s closure regulations is to minimize the formation and migration of leachate to adjacent subsurface soil, groundwater, and surface water. EPA relies principally on the final cover to provide post-closure protection of groundwater.
 
10/01/1986POST-CLOSURE PERMITSQuestion & Answer
 Description: Post-closure permits are required at facilities that closed after 1/26/83 (SEE ALSO: 63 FR 56711; 10/22/98). Units are considered closed when a certification of closure is received, not when the unit ceases receiving hazardous waste (SEE ALSO: current 270.1(c)).
 
10/01/1986RETROFITTING SURFACE IMPOUNDMENTSQuestion & Answer
 Description: Surface impoundments not meeting the minimum technological requirements (3004(o)) cannot receive wastes after 11/8/88, unless the owner has obtained a variance. Closure does not have to occur by 11/8/88. The closure notification for an interim status unit is due by 6/8/88 (3005(j)).
 
09/05/1986SURFACE IMPOUNDMENT RECEIVING NON-HAZARDOUS WASTE AFTER HAZARDOUS WASTE W/O RETROFITTINGMemo
 Description: The HSWA and the legislative history do not state whether surface impoundments may receive nonhazardous waste after the final receipt of hazardous waste, EPA’s decision found in a 5/2/86 rule (SUPERSEDED: see 264.113(d), 265.113(d), and 54 FR 33376; 8/14/89).
 
09/01/1986HAZARDOUS WASTE TANK CLOSURE AND POST-CLOSUREQuestion & Answer
 Description: If the owner or operator closing a hazardous waste tank after 1/12/87 cannot remove and decontaminate all soil, etc. he/she must close the tank as a landfill, and comply with the post-closure and financial responsibility requirements. EPA may issue a section 3008(h) corrective action order if necessary.
 
08/01/1986CLOSURE PLANS - APPEALSQuestion & Answer
 Description: No provisions under RCRA allow an owner or operator to appeal the final closure plan issued by the Regional Administrator (RA). In order to appeal, the owner or operator would have to pursue legal recourse outside of RCRA.
 
07/28/1986HOLDING, TEMPORARY, PERIOD, STORAGE, AND DISPOSAL (DEFINITIONS)Memo
 Description: Holding is not defined in RCRA, but means the containment in a storage unit. A discussion of the definition of storage and disposal. A temporary period is not defined in RCRA, but it is related to closure and financial assurance. A pipe, funnel, or hose used to transfer waste to or from a storage unit is regulated as part of the unit.
 
07/01/1986INTERIM STATUS CORRECTIVE ACTIONQuestion & Answer
 Description: Section 3008(h) corrective action can apply to interim status surface impoundments that have certified clean closure, because the facility remains in interim status. Certification of clean closure does not terminate interim status. A list of four ways interim status can be terminated.
 
06/01/1986FINANCIAL REQUIREMENTS/CLOSURE COSTSQuestion & Answer
 Description: The procedures for determining the pay-in period for units with different closure dates at a facility that uses a trust fund to comply with the closure financial assurance requirements.
 
05/23/1986LIME SLUDGE IMPOUNDMENT SLUDGE, DELISTING OFMemo
 Description: A lime sludge surface impoundment containing K049 and K051 may be subject to permitting and closure requirements even if no waste management occurs based on a Regional interpretation.
 
05/12/1986DEIONIZATION ACID REUSED, NOT A WASTEMemo
 Description: Corrosive materials (deionization acid) that are beneficially reused as effective substitutes for a virgin material, meet relevant specifications for contamination levels, and used under controlled conditions are not solid waste. Discussion of the retroactive application of exclusions from the definition of solid waste. A surface impoundment holding waste which has never been solid waste need not be closed.
 
05/08/1986CLOSURE/POST-CLOSURE REGULATIONS/PARTIAL CLOSURE (EMELLE,AL)Memo
 Description: EPA modified the procedural requirements for partial closures and subsequent post-closure responsibilities in the May 2, 1986 Federal Register (51 FR 16422).
 
04/09/1986NEUTRALIZATION SURFACE IMPOUNDMENTS, GROUNDWATER MONITORING FOR CLOSURE OF INTERIM-STATUSMemo
 Description: Interim status surface impoundments may close per section 265.228(b) without groundwater wells but remain subject to a post-closure permit (SEE ALSO: 63 FR 56711; 10/22/98), close per section 265.288(c) and install wells when a post-closure permit is called, or close per section 265.228(b) with wells and show closure by removal (SUPERSEDED: see 3/19/87; 52 FR 8704).
 
04/02/1986CLOSURE OF A DOE SURFACE IMPOUNDMENT THAT LOST INTERIM STATUSMemo
 Description: A waste from a surface impoundment that lost interim status may be removed, treated, and placed back in the unit at closure. The replacement of waste from the same surface impoundment for closure does not constitute reuse. When unable to remove all constituents from the unit the owner or operator should follow section 265.310 closure as a landfill requirements.
 
01/31/1986RCRA CORRECTIVE ACTION PROCEDURES AND AUTHORITIESMemo
 Description: Discusses the procedures for terminating interim status. The applicability of corrective action to land disposal units receiving hazardous wastes after 7/26/82. The applicability of and authorities for corrective action and monitoring requirements for facilities undergoing closure with continuous releases. Guidance on fuels as a hazardous wastes (SEE ALSO: 59 FR 55778; 11/8/94).
 
12/23/1985RD&D PERMITS - POLICY GUIDANCEMemo
 Description: Research, development, and demonstration (RDD) permittees must manifest unused/reduced waste to a permitted facility (SEE ALSO: 260.10, definition of designated facility). Explains no set of requirements for RDD information reporting. RDD permit can cover activities which may potentially occur. Discusses the partial closure of a RDD facility. Discusses that sold equipment should be decontaminated. Discusses that there is no policy on expediting permitting mobile treatment units (SEE ALSO: 264 Subpart X).
 
09/25/1985POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATED UNITSMemo
 Description: A land disposal unit that stopped receiving waste prior to 7/26/82 and closed after 1/26/83 is subject to post-closure permitting requirements but is not subject to 264 Subpart F groundwater monitoring (SUPERSEDED: see 270.1(c) and 63 FR 56711; 10/22/98). If the unit is closed under interim status, 265 groundwater monitoring applies. A land disposal unit in interim status post-closure is subject to 3008(h) for groundwater contamination. An interim status unit at facility which has another unit requiring a permit is subject to 3004(u) corrective action authority.
 
09/25/1985POST-CLOSURE PERMITTING REQUIREMENTS FOR NON-REGULATED UNITSMemo
 Description: A land disposal unit that stopped receiving waste prior to 7/26/82 and closed after 1/26/83 is subject to post-closure permitting requirements but is not subject to 264 Subpart F groundwater monitoring (SUPERSEDED: see 270.1(c) and 63 FR 56711; 10/22/98). If the unit is closed under interim status, 265 groundwater monitoring applies. A land disposal unit in interim status post-closure is subject to 3008(h) for groundwater contamination. An interim status unit at facility which has another unit requiring a permit is subject to 3004(u) corrective action authority.
 
09/11/1985PERMITTING UNITS CREATED FOR FACILITY CLOSUREMemo
 Description: An owner of facility who adds units to facilitate closure process must modify permit or submit change in interim status. The cost of adding new unit at interim status facility cannot exceed reconstruction limit.
 
08/30/1985EXISTING UNITS UNDER HSWA-APPLICABILITY OF MTR TO EXPANSIONSMemo
 Description: The existing unit definition applies to units that received waste by 11/8/84 and were fully operational on that date. The boundaries of existing units are limited by operating or closure plans or permits that were applicable on 11/8/84. A lateral expansion after 11/8/84 is considered new unit.
 
08/27/1985GROUNDWATER QUALITY AT CLOSUREMemo
 Description: Groundwater quality is an integral part of closure for surface impoundments and waste piles. Post-closure permits, 3008(h) corrective action orders, and 3004(u) corrective action can be used to supplement interim status regulations. The approval and completion of closure by removal does not preclude the use of 3008(h) or 3004(u). A summary of 3005(i), 3004(u), and 3008(h) authorities as they pertain to surface impoundments and waste piles.
 
07/25/1985INTERPRETATION OF 3005(J)(1)Memo
 Description: An interim status surface impoundment that is not meeting 3005(j) minimum technical requirements by 11/8/88 must certify closure or demonstrate that technical closure requirements are met.
 
06/28/1985POST-CLOSURE PERMITSMemo
 Description: The post-closure permit and groundwater monitoring applicability for an interim status facilities are based on the date of the final waste receipt (SEE ALSO: 63 FR 56711; 10/22/98). Closure by removal does not preclude 3008(h) or 3004(u). Summary of closure by removal requirements. Discussion of Part B post-closure permit contents (SEE ALSO: 270.28).
 
06/01/1985PARTIAL CLOSUREQuestion & Answer
 Description: Owners and operators are required to submit a permit modification to address the partial closure of units not identified in the original closure plan.
 
03/01/1985CLOSURE CERTIFICATIONQuestion & Answer
 Description: There is no time limit for the submission of closure certification (SUPERSEDED: see current 264.115, 265.115).
 
03/01/1985WASTE DISPOSAL RECORDSQuestion & Answer
 Description: Owners and operators need to submit to the Regional Administrator (RA) and local land authority records of waste disposal locations and quantities within 60 days of certifying closure. The requirement in 264.74(c) to submit operating records corresponds to 264.119.
 
01/01/1985FINANCIAL REQUIREMENTS FOR INACTIVE SURFACE IMPOUNDMENTSQuestion & Answer
 Description: An owner of a TSDF with an inactive surface impoundment must maintain both sudden and nonsudden liability insurance until closure is certified, even if the unit is not currently used to store hazardous waste.
 
01/01/1985TREATMENT SURFACE IMPOUNDMENTS LOSING INTERIM STATUS BECAUSE OF NON-COMPLIANCE WITH GWM AND FINANCIAL RESPONSIBILITY REQUIREMENTSQuestion & Answer
 Description: Owners and operators of interim status land treatment units were required to submit a Part B application, certify compliance with groundwater monitoring, and obtain financial assurance by 11/8/85 (3005(e)(2)). Land disposal units include all land-based hazardous waste management systems.
 
12/03/1984FACILITY'S OPERATING LIFE, DETERMINATION OFMemo
 Description: A trust fund pay-in period must be calculated for the operating life of an entire facility, not each unit. A facility’s operating life ends in the year in which the owner or operator expects to close the facility. Salable recycled wastes cannot be deducted from closure cost estimates.
 
12/01/1984TERMINATION OF INTERIM STATUSQuestion & Answer
 Description: A facility that has had its interim status terminated remains subject to the interim status standards for closure, post-closure, and financial responsibility.
 
09/18/1984CLOSURE PLAN COMMENTS/ISSUES (CRUCIBLE STEEL)Memo
 Description: The requirement for a final cover at the closure of a landfill should not be delayed to allow continued disposal of nonhazardous waste. A delay of closure must be related to the need for extra time to complete closure activities or to a transfer of the operation to new parties (SUPERSEDED: see current 265.113(d)). A landfill’s final cover may be covered by nonhazardous waste only if it is necessary to the proposed use of the property and if it will not increase potential hazards.
 
09/01/1984TANKS USED FOR COLLECTING SPILLSQuestion & Answer
 Description: A tank used on a predictable basis for collecting hazardous waste spills must be addressed in the closure plan. A tank used to collect hazardous waste spilled from a manufacturing process unit is subject to the generator or TSDF standards.
 
08/07/1984CLOSURE ISSUES RELATED TO WOOD PRESERVING PLANTSMemo
 Description: Grounds for extensions to 180 days are normally allowed for closure after the final receipt of waste. Closure should be based on proven techniques, not on concepts still in the research and development stage. The addition or creation of new processes during interim status may be allowable under changes during interim status.
 
08/01/1984OWNER AND OPERATOR RESPONSIBILITIES DURING OPERATING LIFE AND CLOSUREQuestion & Answer
 Description: If they are separate persons, both the owner and operator are “permittees” on a permit. The operator frequently assumes the responsibility for meeting permit conditions. Both parties are liable during the operating life and for closure/post-closure of the facility. The owner may take control and full liability later if the permit is modified.
 
07/09/1984REPORTING WITHDRAWALS IN SPMS AS FINAL PERMIT DETERMINATIONSMemo
 Description: Guidance is provided on how to report permit withdrawals in the Strategic Planning and Management System (SPMS). The procedure for deciding when a final permit determination has been made is discussed. For purposes of SPMS, a permit application is considered withdrawn when a closure plan has been approved after facility inspection, public notice, and response to comments.
 
06/06/1984FINANCIAL ASSURANCE INSTRUMENTSMemo
 Description: Financial assurance instruments should be reviewed regardless of the adequacy of a facility closure plan and a closure cost estimate.
 
05/01/1984PARTIAL CLOSUREQuestion & Answer
 Description: There is no set policy on deadlines for submission of a partial closure plan, whether partial closure must be certified by a professional engineer, and whether public notice for partial closure is required.
 
04/01/1984CHANGE IN OWNERSHIP AND CLOSURE AT INTERIM STATUS FACILITYQuestion & Answer
 Description: An interim status facility that has submitted a closure plan and intends to cease hazardous waste management retains its interim status until it is terminated under Part 124 procedures. If part of a property with no units is sold, that portion has no interim status. Changes in ownership at interim status facilities may be made if the new owner or operator submits a revised Part A permit application no later than 90 days prior to the scheduled change as outlined under changes during interim status.
 
04/01/1984ESTIMATED CLOSURE DATES IN PART B PERMIT APPLICATIONSQuestion & Answer
 Description: A Part B permit application must include a closure date even if the company has no plans for closure in the near future. If the closure date changes, the closure plan can be amended via a minor permit modification.
 
03/01/1984TANKS AND SURFACE IMPOUNDMENTS HOLDING DE MINIMIS SPILLSQuestion & Answer
 Description: A tank or surface impoundment used to contain de minimis spills of commercial chemical products (CCPs) prior to the promulgation of the 261.3(a)(2)(iv)(D) mixture rule exemption is subject to interim status standards until 11/17/81, including closure requirements.
 
02/01/1984INTERIM STATUS CLOSURE CERTIFICATIONQuestion & Answer
 Description: Closure under Part 265 does not require a 270.1(d) certification because closure is not a permit application or a permit report.
 
01/17/1984ESTIMATED CLOSURE DATES IN PERMIT APPLICATIONSMemo
 Description: The expected date of closure required in a permit application is only an estimate that allows EPA to determine if the closure financial assurance is adequate.
 
01/12/1984CLOSURE COST ESTIMATES BASED ON THIRD PARTY COSTSMemo
 Description: A closure cost estimate for a recycling facility may reflect the owner or operator’s own costs of carrying out his closure plan. Continued recycling at a recycling facility is a form of treatment and is a legitimate closure activity (SUPERSEDED: See current 264.142, 265.142)).
 
01/01/1984POST-CLOSURE REQUIREMENTS FOR SURFACE IMPOUNDMENTS LOCATED IN A 100 YEAR FLOOD PLAINQuestion & Answer
 Description: The floodplain requirement under 264.18(b) applies even during post-closure of a surface impoundment. If dikes are lowered to reduce the height of a closure cap, the owner or operator must demonstrate that the design will be protective.
 
12/09/1983CLOSURE COST ESTIMATESMemo
 Description: Provides an explanation of the financial test criteria. The “ratios” test, a predictor of bankruptcy, requires networking capital of at least six times the sum of the closure and post-closure cost estimates. The “bond rating test” assures the viability and credit-worthiness of a company.
 
09/01/1983LEASING SITE PRIOR TO CLOSURE CERTIFICATIONQuestion & Answer
 Description: A property owner can lease a site to a second lessee before the first lessee has certified closure or had a closure plan approved, as long as the owner, operator, or original operator assumes responsibility for carrying out closure.
 
08/01/1983CLOSURE COST ESTIMATEQuestion & Answer
 Description: Closure cost estimates cannot include possible profits from the recycling of waste or the sale of equipment or property in order to reduce closure costs. The closure plan and closure cost estimate must be based on the point in the facility’s life where closure would be the most expensive.
 
06/14/1983APPLICATION WITHDRAWALS AND TERMINATIONS OF INTERIM STATUS AS COUNTED IN AMAS AND TOWARD CALL-IN COMMITMENTSMemo
 Description: Protective filers that were never regulated under Part 265 can be removed from interim status data in the EPA database after confirmation that no activity subject to permitting was conducted. Interim status facilities that withdraw a permit application are subject to the 265 closure requirements.
 
05/01/1983USING IMPLICIT PRICE DEFLATOR TO CALCULATE INFLATION FACTORQuestion & Answer
 Description: Discusses the calculation of the inflation factor for closure cost estimates using 1981 and 1982 implicit price deflators.
 
02/01/1983CLOSURE/POST-CLOSURE COST ESTIMATEQuestion & Answer
 Description: The annual inflation adjustment for closure cost estimate should be based on the May 19 schedule even if the first estimate was prepared earlier or later than May 19, 1981, unless a change in capacity led to a mid-year revision (SUPERSEDED: see current 264.142, 265.142).
 
01/11/1983CLOSURE & POST-CLOSURE REQUIREMENTS REGARDING HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIESMemo
 Description: Recontouring a final cover and adjusting in-place waste is not considered receipt of hazardous waste at a closed facility. Closure and post-closure plans are to account for vegetation and liquid inputs. Landfill closure standards require a final cover to minimze the migration of liquids through the closed landfill. Discussion of the addition of liquids during versus after closure (may be allowed during closure, including leachate recirculation, if part of closure plan). The recirculation of leachate during operation is not a closure activity. Receipt of hazardous waste after 1/26/83 causes impoundment or landfill to be a regulated unit, but redeposit of treated waste during closure does not make the unit regulated unit. If a landfill is a series of separately lined trenches, each trench is a separate waste management unit.
 
12/01/1982CLOSURE PLAN MODIFICATIONQuestion & Answer
 Description: If the closure regulations change after a closure plan is approved, the EPA Region will decide on a case-by-case basis if the plan needs to be modified.
 
09/01/1982DISADVANTAGES TO CLOSING PRIOR TO PERMIT ISSUANCEQuestion & Answer
 Description: If a regulated unit is closed prior to obtaining a permit, but after 1/26/83, EPA may still request a Part B permit application. A permit would consist of Part 264, Subpart F, groundwater monitoring, including corrective action (SEE ALSO: 63 FR 56711; 10/22/98).
 
05/15/1982Financial Assurance for Closure and Post-Closure Care; Requirements for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities; A Guidance ManualPublication
 Description: This document communicates information to ensure that adequate financial responsibility is provided for proper closure and post-closure care of hazardous waste facilities. The introduction provides a general background for understanding financial requirements and manual organization. An overview of requirements is included in Chapter II and subsequent chapters deal with trust funds, surety bonds, letters of credit, insurance, financial test and corporate guarantee, state-required mechanisms, and assumption of responsibility.
 
12/22/1980GUIDANCE ON CLOSURE AND POST-CLOSUREMemo
 Description: EPA has no specific form for certification of closure by an engineer. The guidance document Closure and Post Closure-Subpart G gives examples of closure plans and engineer certifications.
 
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Show details for Small Quantity Generators (SQG)Small Quantity Generators (SQG)
Show details for Solid WasteSolid Waste
Show details for SolventsSolvents
Show details for Source ReductionSource Reduction
Show details for Special WastesSpecial Wastes
Show details for State Programs (RCRA)State Programs (RCRA)
Show details for StorageStorage
Show details for Surface ImpoundmentsSurface Impoundments
Show details for TanksTanks
Show details for Test MethodsTest Methods
Show details for Toxicity CharacteristicToxicity Characteristic
Show details for TransportersTransporters
Show details for TreatmentTreatment
Show details for TSDFsTSDFs
Show details for U-wastesU-wastes
Show details for Underground Storage Tanks (UST)Underground Storage Tanks (UST)
Show details for Universal WasteUniversal Waste
Show details for Used OilUsed Oil
Show details for VariancesVariances
Show details for Waste Determinations for Combusted Non-Hazardous Secondary MaterialsWaste Determinations for Combusted Non-Hazardous Secondary Materials
Show details for Waste MinimizationWaste Minimization
Show details for Waste PilesWaste Piles
Show details for Waste ReductionWaste Reduction
Show details for Wood Preserving WastesWood Preserving Wastes
Show details for (Not Categorized)(Not Categorized)
For more information on commonly used environmental terms please visit the Terms of the Environment EPA Home Page

 

 
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