Frequent Questions

Our facility is a LQG and a TSDF. How do we close our hazardous waste accumulation tank? How will this affect our permit?

An LQG is exempt from the requirements in subparts G and H of 40 CFR Part 265, except for §§265.11 and 265.114.  The owner or operator must close the facility in a manner that minimizes the need for further maintenance and controls future threat to human health and the environment.  All contaminated equipment, structure, and soil must be properly disposed of or decontaminated.
LQG closure standards require minimization of need for further maintenance, 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 are also subject to unit-specific closure standards. 40 CFR §§264/265.112(b)(1) require an owner/operator of a TSDF to include in the closure plan a description of how each hazardous waste management unit (HWMU) must be closed.  It is currently unclear whether or not the term HWMU, as defined in §260.10, includes a generator's 90-day accumulation units, and whether a TSDF that generates hazardous waste must addres 90-day accumulation units in the closure plan.  Refer to your state's contact regarding the interpretation of this provision. 

Facilities that previously filed a RCRA permit application that included units that are no longer used for hazardous waste accumulation should notify  the Regional Office (or authorized State) about the change in operation so the Agency will not include this activity in the permit. Check with your state to learn more information specific to your state.
Related Material: 
Monthly Call Center Report Question; December 1998 (RCRA Online 14321)
Monthly Call Center Report Question; April 1989 (RCRA Online 13270)  

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