Frequent Questions

Is the owner and operator required to address wastes that are treated or accumulated in ninety-day generator accumulation units in the closure plan as part of the maximum inventory?

Facility owners and operators are required to include wastes that are treated or accumulated in ninety-day generator units in estimations of the maximum inventory of hazardous wastes ever on site over the active life of the facility for purposes of the closure plan. EPA promulgated requirements for more detailed closure plans in response to concerns that poorly detailed plans were accompanied by inadequate cost estimates. The purpose of increased detail in the closure plan is to ensure that a third party could conduct closure in accordance with the plan if the owner and operator fails to do so, as well as to ensure accurate cost estimates for closure (51 FR 16426; May 2, 1986). Consequently, EPA intended for the maximum inventory of wastes on site during the active life of the facility to include hazardous wastes accumulated in generator accumulation units as well as permitted units.

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