Frequent Questions

What are the closure standards for hazardous waste management units at generator facilities?

Large quantity generators (LQGs) must comply with the general closure provisions in §265.111 and §265.114 and the unit-specific closure requirements (§262.34(a)(1)). Although LQGs must comply with §265.111, they are not subject to §265.111(c), which requires closure plans and financial assurance for interim status facilities. LQGs storing waste in tanks, on drip pads, or in containment buildings are subject to the unit specific closure requirements. LQGs managing waste in containers do not have unit-specific closure requirements (Monthly Report Question; December 1998 (RCRA Online #14321)). 

There are no specific closure requirements for small quantity generators (SQGs) or conditionally exempt small quantity generators, except that SQGs managing waste in tanks must remove all hazardous waste from such tanks, discharge control equipment, and discharge confinement structures upon closure (§265.201(d)). 

Additional guidance on generator closure is available in the following documents: 
Monthly Report Question; December 1998 (RCRA Online #14321
Monthly Report Question; November 1997 (RCRA Online #14130)
Monthly Report Question; April 1989 (RCRA Online #13270)

Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations. These revisions may affect the information provided in this FAQ. The final rule and additional information, including a fact sheet, frequent questions, and a webinar recording and slides, are available at www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements.

The Hazardous Waste Generator Improvements Final Rule is effective on May 30, 2017; however, implementation in a particular state depends on the state’s authorization status. A discussion of the effect that this final rule will have on state authorization is available on page 85801 of the rule. Information about how the rule will affect the requirements in this FAQ in a particular state is best obtained from the state hazardous waste program. A list of state hazardous waste programs is available at www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies.

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