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Click on the blue carat to the left of a Topic, the list will expand to show the documents related to the selected Topic.

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06/08/2017GENERATOR IMPROVEMENTS RULE CLARIFICATIONMemo
 Description: EPA provided answers to various questions submitted by the Treated Wood Council regarding hazardous waste generators that are drip pad operators. EPA reaffirmed, as we did in the preamble of the November 28, 2016, final Hazardous Waste Generator Improvements Rule (81 FR 85732, 85768), that very small quantity generators (VSQGs) may accumulate hazardous waste on drip pads if they comply with the technical requirements of 40 CFR 265 Subpart W for drip pad operations. A generator accumulating hazardous waste on drip pads is not required to comply with Subparts G and H of 40 CFR 265 and 40 CFR 265.44(c) during closure.
 
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.
 
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