United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5305W)
EPA530-R-96-023
>>EPA
RCRA, Superfund & EPCRA
Hotline Training Module
Introduction to:
Closure/Post-Closure
(40 CFR Parts 264/265, Subpart G)
Updated July 1996

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J
DISCLAIMER
This document was developed by Booz-Allen & Hamilton Inc. under contract 68-W6-0016 to EPA. It is intended
to be used as a training tool for Hotline specialists and does not represent a statement of EPA policy.
The information in this document is not by any means a complete representation of EPA's regulations or policies.
This document is used only in the capacity of the Hotline training and is not used as a reference tool on Hotline
calls. The Hotline revises and updates this document as regulatory program areas change.
The information in this document may not necessarily reflect the current position of the Agency. This document
is not intended and cannot be relied upon to create any rights, substantive or procedural, enforceable by any
party in litigation with the United States.
RCRA, Superfund & EPCRA Hotline Phone Numbers:
National toll-free (outside of DC area)
Local number (within DC area)
National toll-free for the hearing impaired (TDD)
(800) 424-9346
(703)412-9810
(800) 553-7672
The Hotline is open from 9 am to 6 pm Eastern Standard Time,
Monday through Friday, except for federal holidays.

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CLOSURE AND POST-CLOSURE
CONTENTS
1.	Introduction 							 1
2.	Regulatory Summary	 3
2.1	Closure Performance Standards 		 3
2.2	Closure Phases 					.<			 3
2.3	Closure Plan 											 3
2.4	Closure Timetable							 5
2.5	Disposal or Decontamination of Equipment, Structures, and Soils ..... 7
2.6	Certification of Closure					 7
2.7	Survey Plat 					 8
2.8	Post-Closure ...				 8
2.9	Post-Closure Care 								 9
2.10	Post-Closure Plan					 9
2.11	Post-Closure Notices 			 10
2.12	Certification of Completion of Post-Closure Care 			... 10
3.	Special Issues			....11
4. Regulatory Developments
13

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Closure and Post-Closure - 1
1. INTRODUCTION
All hazardous waste management facilities must eventually cease their treatment,
storage, or disposal activities. When these facilities cease operation, the
owner/operator must maintain them in a way that ensures that they do not pose a
future threat to human health and the environment. The Resource Conservation
and Recovery Act (RCRA) closure and post-closure regulations in 40 CFR Parts 264
and 265, Subpart G are designed to achieve this goal. Closure is the period following
active management during which hazardous wastes are no longer accepted and
owners/operators of treatment, storage, and disposal facilities (TSDFs) complete
treatment, storage, and disposal operations; apply final covers to or cap landfills; and
dispose of or decontaminate equipment, structures, and soils. Post-closure, which
applies only to land disposal facilities and facilities that cannot decontaminate all
equipment, structures, and soils ("clean close")/ is normally a 30-year period after
closure during which owners/operators conduct monitoring and maintenance
activities to preserve the integrity of the disposal system and continue to prevent or
control releases of contaminants from the disposal units.
When you have completed this training module you will know the difference
between closure and post-closure and how to apply the appropriate regulations
when assisting Hotline callers. Specifically, you will be able to:
	List the types of facilities that are subject to closure/post-closure
	Define the difference between partial and final closure
	Specify who submits a closure plan and when a closure plan must be
submitted, list the steps in the process, and state the time frame for submittal
	Identify when a closure plan must be amended and how closure plans are
amended
	Explain the time frame for notification of closure, and the deadlines for
beginning and completing closure
	Specify which facilities need contingent post-closure plans
	List the elements of post-closure and cite the requirements
	Specify the conditions and timing for amending a post-closure plan
	State who must certify closure/post-closure.
-Use,this list of objectives to check your knowledge of this topic after you complete
the training session.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.

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2 - Closure and Post-Closure
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.

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Closure and Post-Closure - 3
2. REGULATORY SUMMARY
The closure and post-closure regulations can be divided into two parts: (1) general
standards in Parts 264/265, Subpart G, and (2) technical standards for specific types of
hazardous waste management units found in Parts 264/265, Subparts I through X.
These combined requirements ensure that a specific unit or facility will not pose a
future threat to human health or the environment after a TSDF closes.
2.1	CLOSURE PERFORMANCE STANDARDS
Owners/operators must close each facility in a manner that minimizes the need for
care after closure; controls, minimizes, or eliminates the escape of hazardous waste,
hazardous leachate, or hazardous waste decomposition by-products; and meets the
closure requirements for each type of unit (264/265.111). For example, permitted
containers must be closed according to 264.178.
2.2	CLOSURE PHASES
RCRA facilities often have several different hazardous waste management units
that close at different times. The regulations account for this possibility by
differentiating between partial closure and final closure. Partial closure means
closure of one or more hazardous waste management units at a facility where other
hazardous waste management units remain active. The closed portion (also
"inactive portion") of a facility is defined as that portion of a facility that has been
closed in accordance with an approved closure plan and applicable regulatory
requirements, while the active portion of the facility is that portion where
treatment, storage, or disposal operations are being conducted and which is not
closed. Final closure of a facility occurs when all hazardous waste management
units at a facility are closed according to closure regulations so that waste
management activities under Parts 264/265 are no longer conducted at the facility
(260.10).
2.3	CLOSURE PLAN
All TSDFs must submit closure plans for both partial and final closure in accordance
with 264/265.112. These plans explain in detail how the owner or operator will
achieve the closure performance standard under 264/265.111. Permitted facilities
are required to submit a closure plan with the Part B permit application; the
approved closure plan then becomes an enforceable component of the facility
permit. Interim status facilities must have a written closure plan on the premises
six months after the facility becomes subject to 265.112.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to'the topic used for Hotline training purposes.

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4 - Closure and Post-Closure
CONTENTS
The closure regulations do not mandate any specific format for the closure plan.
Nor do the regulations mandate any particular level of detail, length, or supporting
documentation. Rather, the regulations provide general guidelines on the type of
information that the closure plan must include. By requiring these specific
elements, EPA hopes to force owners/operators to consider their future closure
responsibilities and consequently realize the impact of their current operating
1 practices on closure. According to 264/265.112(b), the closure plan must contain:
	A description of how each hazardous waste management unit will be closed
	A description of how final closure of the facility will be achieved
	An estimate of the maximum inventory of hazardous waste ever on-site
during the facility's active life
	A, detailed description of closure methods, including actions necessary to
remove waste and decontaminate the site, and manage removed waste
	A description of any other steps that may be necessary in order to comply with
the closure standards, such as groundwater monitoring or leachate collection
	A schedule of closure dates for each unit and for final closure, including the
amount of time that closure of each,unit and related activities will take
	The expected year of final closure for facilities that use trust funds for
financial assurance, and for facilities without approved closure plans.
AMENDING THE PLAN ,
The closure plan may be amended by either the facility owner/operator or the
Regional Administrator (RA) by following the steps in 264/265.112(c) when there
is a change in the design or operation of the facility, a change in the expected closure
date, or an unexpected event. An example of an unexpected event is the discovery
of more contamination than anticipated, resulting in the need to close a storage unit
(e.g., a tank) as a disposal unit.
Sixty days prior to a planned change, the owner/operator of a permitted facility or an
interim status facility with an approved closure plan must submit a written request
to the RA, along with a copy of the amended plan. If the change is a result of an
unexpected event, the amended closure plan must be submitted no more than 60
days after the unexpected event if it occurs before closure, and no more than 30 days
after an unexpected event if it occurs during closure. Permitted facilities must
submit a permit modification per 270.42, in addition to the written request to
amend the plan. Owners or operators of interim status facilities without approved
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.

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Closure and Post-Closure - 5
closure plans may amend the closure plan at any time prior to notification of partial
or final closure.
2.4 CLOSURE TIMETABLE
The closure regulations establish specific timetables for the initiation and
completion of closure activities. One element of this timetable is prior notification
to the RA of the commencement of closure. For permitted units the
owner/operator must notify the RA at least 60 days .prior to the date on which
he/she "expects to begin closure" of a surface impoundment, waste pile, land
treatment or landfill unit, or final closure of a facility with such a unit (264.112(d)).
The date when the owner/operator "expects to begin closure" must be no later than
30 days after the date on which the unit accepts the known final volume of
hazardous waste (264.112(d)(2)(i)). For facilities with only tanks, containers, or
incinerators, notification must occur at least 45 days prior to the date he/she expects
to begin final closure. For hazardous waste boilers or industrial furnaces,
notification must occur at least 45 days prior to partial or final closure.
Interim status units have similar notification requirements. The additional
stipulation is that closure plans must be submitted according to the dates found in
265.112(d) of the regulations (closure plans for permitted units are submitted in the
Part B application process).
Sections 264/265.113 establish deadlines for initiating and completing closure
activities. Within 90 days of receipt of the final volume of hazardous waste at a
permitted facility, the owner/operator must treat, remove from the site, or dispose
of all hazardous waste on-site. For interim status facilities, this deadline,'as well as
the deadlines for all subsequent closure activities, is based on the timing of the latter
of two events:, receipt of the final volume of hazardous waste at the unit, or
approval of the closure plan (265.113(a) and (b)). For example, the owner/operator
of an interim status facility must treat, remove from the site, or dispose of all
hazardous waste on-site within 90 days of receipt of the final volume of hazardous
waste, or within 90 days of the approval of the closure plan, whichever is later.
Figures 1 and 2 illustrate the closure timelines for permitted and interim status
facilities (with approved plans), respectively. You will see significant time
differences in requirements for land-based units and facilities with only tanks,
containers, and incinerators.
Once partial or final closure is initiated, closure activities must be completed within
180 days of receiving the final volume of hazardous waste (264/265.113(b)). For
interim status facilities, closure activities must be completed within 180 days of
approval of the closure plan, or within 180 days of receiving the final volume of
hazardous waste, whichever is later.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.

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6 - Closure and Post-Closure
Figure 1
CLOSURE TIMETABLE FOR PERMITTED FACILITIES and INTERIM STATUS
FACILITIES WITH APPROVED CLOSURE PLANS*
--v

o
Receive
Final
Volume of
Hazardous
w>
c
I'X,
c
i 3"
0
30
Receive Final Volume of	Expect to
5. Hazardous Waste or	Begin
i  Closure Plan Approved,	Closure"
' ST Whichever is Later	I
90
Remove
All Waste
or Dispose of
Waste On-Site
180
Complete
Closure
J
240
Certify Gosure For
all Fin
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Closure and Post-Closure - 7
EXTENSIONS
When the closure activities will take longer than 90 (or 180) days to complete, the
RA may grant extensions to the 90- and 180-day deadlines, provided the facility or
unit has the capacity to accept hazardous or nonhazardous waste (264/265.113(a)
and (b)).
DELAY OF CLOSURE
A facility meeting specific eligibility criteria under 264/265.113(d) and (e) may delay
closure of its units to receive nonhazardous waste following the final receipt of
hazardous waste. This provision is only available to certain landfills, surface
impoundments, and land treatment units. It is not available to units such as storage or
treatment tanks, container storage areas, waste piles, incinerators, land treatment units,
or units that have lost interim status.
In addition, all owners/operators of units that choose to delay closure will continue
to be subject to all applicable Subtitle C requirements and must ensure that the co-
disposal of nonhazardous waste with hazardous waste will in no way endanger
human health and the environment.
2.5 DISPOSAL OR DECONTAMINATION OF EQUIPMENT,
STRUCTURES, AND SOILS
During partial and final closure periods all contaminated equipment, structures, and
soils must be properly disposed of or decontaminated unless otherwise specified in
the unit-specific closure requirements (264/265.114). During this process an
owner/operator may become a generator of hazardous waste and therefore become
subject to the requirements of Part 262. Furthermore, hazardous waste management
units built as part of the closure process must be permitted or comply with the
generator accumulation unit provisions of 262.34.
2.6 CERTIFICATION OF CLOSURE
According to 264/265.115, the owner/operator must submit to the RA (by
registered mail) a certification that the hazardous waste management unit or facility
has closed in accordance with the specifications in the approved closure plan. This
submittal must take place within 60 days of completion of closure of each regulated
unit and within 60 days of the completion of final closure. The certification must be
signed by the owner/operator arid by an independent, registered, professional
engineer. The RA may request supporting documentation to verify the validity of
the engineer's certification.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
, but is an introduction to the topic used for Hotline training purposes.

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8 - Closure and Post-Closure
2.7 SURVEY PLAT
The owner/operator must submit to the RA or local zoning authority a survey plat
indicating the location and dimensions of the hazardous waste units (264/
265.116). The survey plat must be submitted no later than the submission of
certification of closure of each hazardous waste disposal unit. The survey plat
provides important information on closed units in the event that the facility is sold
or abandoned.
2.8 CLEAN CLOSURE
If all hazardous waste and contaminants, including contaminated soils and
equipment, can be removed from the site or unit at closure, the site or unit can be
clean closed and post-closure care is not required. In order to demonstrate clean
closure (or closure by removal), an owner/operator must show that levels of
hazardous contaminants do not exceed EPA-recommended exposure levels, or clean
closure levels. An owner/operator who cannot clean close must close as a landfill
and obtain a permit for the post-closure period (270.1(c)).
2.9 POST-CLOSURE
EPA developed the post-closure standards for land disposal units that leave
hazardous waste in place at closure. These include landfills, land treatment units,
surface impoundments, and other units where equipment, structures, and soils
cannot be fully decontaminated (clean closed). Facilities where waste remains in
place after the completion of closure must conduct monitoring and maintenance
activities to ensure the integrity of the liners and leak detection systems and prevent
or control releases to the environment. Owners/operators of facilities that require
post-closure care must comply with both the general post-closure regulations in
264/265.117 through 264/265.120, and the unit-specific post-closure
requirements in Parts 264/265, Subparts K, L, M, N, and X. These facilities also must
obtain permits for the post-closure period and comply with the groundwater
monitoring requirements of Parts 264/265, Subpart F.
POST-CLOSURE PERMITS
Owners/operators of certain land disposal units and units that cannot clean close
must obtain a permit for the post-closure period, thus ensuring that appropriate
monitoring and maintenance activities will be conducted. Known as a post-closure
permit, this requirement applies to owners/operators of surface impoundments,
landfills, land treatment units, and waste piles that received waste after July 26, 1982,
or that certified closure (according to 265.115) after January 26, 1983, unless they
demonstrate closure by removal pursuant to 270.1(c)(5) and (6). The denial of a
permit for the active life of a hazardous waste management facility (i.e., the period
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.

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Closure and Post-Closure - 9
from first receipt of hazardous waste until certification of final closure), does not '
affect the requirement to obtain a post-closure permit under this section.
2.10	POST-CLOSURE CARE
Post-closure care consists of two primary responsibilities: groundwater monitoring
and maintaining waste containment systems (264/265.117). The post-closure
period normally lasts for 30 years after the date closure is completed, but may be
amended (either extended or shortened) by the RA. Groundwater monitoring and
reporting must be conducted in accordance with Parts 264/265, Subparts F, K, L, M,
and N.
Waste containment systems must be monitored and maintained in accordance with
the applicable regulatory requirements of Parts 264/265, Subparts K, L, M, N, and X.
Post-closure use of the property may not disturb the final cover, liners, or other
containment or monitoring systems unless such disturbance is necessary for the
proposed use or to protect human health and the environment (see unit-specific
closure requirements in Parts 264/265, Subparts I through O).
2.11	POST-CLOSURE PLAN
The post-closure plan under 264/265.118 must include:
	A description of planned groundwater monitoring activities
	A description of planned maintenance activities
	The name, address, and telephone numbers of the person or office to contact
during the post-closure period.
Post-closure maintenance activities include ensuring the integrity of the cap or final
cover and ensuring that monitoring equipment functions during the post-closure
period.
Permitted facilities must submit the post-closure care plan as part of the post-closure
permit application. An amendment to the plan requires a permit modification. An
owner/operator of an interim status facility must submit a post-closure plan to the RA
at least 180 days before the date 'he/she expects to begin partial or final closure of the
first hazardous waste disposal unit. If a facility has its interim status terminated, or
receives a judicial decree or order under RCRA 3008 to cease receiving wastes or close,
the owner/operator must submit the post-closure plan to the RA within 15 days
(265.118(e)(l) and (2)).
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.

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10 - Closure and Post-Closure
2.12 POST-CLOSURE NOTICES
.Within 60 days after closure certification (by a registered engineer or qualified soil
scientist), the local zoning or land use authority and the RA must receive a record of
the type, location, and quantity of hazardous wastes in each disposal unit
(264/265.119). For wastes disposed of prior to January 12, 1981, the owner/operator
must provide a "best estimate" for the quantity of waste in each unit.
Also within 60 days of closure certification of each hazardous waste disposal unit, a
notice must be placed in the property deed and recorded. This notice must state that
the land was used for hazardous waste management; that the use of the land is
restricted per Parts 264/265, Subpart G; and that the survey plat and record of closure
were submitted to the local zoning authority and the RA.
2.13 CERTIFICATION OF COMPLETION OF POST-CLOSURE
CARE
No later than 60 days after completion of the established post-closure care period for
each hazardous waste disposal unit, the owner/operator must submit to the RA (by
registered mail) a certification that the post-closure care period was performed in
accordance with the specifications established in the approved closure plan
(264/265.120).
The information in this document is not by- any means a complete representation of EPA's regulations or policies,
but is an introduction to'the topic used for Hotline training purposes.

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Closure and Post-Closure -11
3. SPECIAL ISSUES
Interim status terminates for facilities that fail to comply with the applicable
provisions of 270.73(a)-(g)/ which establish deadlines for the submission of permit
applications. For example, an incinerator that received interim status prior to
November 8, 1984, had its interim status terminated on November 8, 1989, unless
the owner/operator of the facility submitted a Part B application for a RCRA permit
by November 8, 1986. An interim status facility that fails to meet any applicable
portion of 270.73 falls into the loss of interim status (LOIS) category. The owner or
operator of the facility must then submit a closure plan in accordance with
265.112(d) andinitiate final closure activities.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.

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12 - Closure and Post-Closure
 The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to'the topic used for Hotline training purposes

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Closure and Post-Closure - 13
4. REGULATORY DEVELOPMENTS
The closure regulatory scheme mandates post-closure care and a post-closure permit
when the owner/operator closes a disposal unit or leaves hazardous waste in place
after the facility closes. Frequently, a closing unit has caused unconfined
contamination of groundwater and soils, necessitating extensive remediation
activities during the post-closure period. Obtaining a post-closure permit and
implementing corrective action through that permit (see the module entitled RCRA
Corrective Action) is not the most appropriate remedy in all situations. In some
circumstances, the facility's post-closure needs have already been met through some
other cleanup authority. In other circumstances, the facility is legally unable to meet
the requirements to obtain a post-closure permit (see RCRA 3005(c)). EPA has
proposed a rule to remove the requirement to address post-closure care
requirements through a post-closure permit in all instances, thereby giving the
Agency the ability to use the most appropriate and efficient remedial authorities
available at a closing facility (59 FR 55778; November 8, 1994). The proposed rule
requires any alternative authority used in lieu of a post-closure permit to provide
the same level of protection and public participation as does a post-closure permit.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.

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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA530-R-96-023
4. Title and Subtitle
RCRA, SUPERFUND, AND EPCRA HOTLINE TRAINING MODULE: INTRODUCTION TO
CLOSURE/POST-CLOSURE (40 CFR PARTS 264/265, SUBPART G)
5. Report Date
JULY 1996	
7. Author(s)
8. Performing Organization Rept. No
9. Performing Organization Name and Address
I 10-
I
Project/Task/Work Unit No.
U.S. EPA
I
| 11.
Contract(C) or Grant(G) No.
OFFICE OF SOLID WASTE
| (C)

401 M STREET, SW
| (G)

WASHINGTON. DC 20460
I

12. Sponsoring Organization Name and Address
13. Type of Report & Period Covered
TRAINING - UPDATED 7/96
14.
15. Supplementary Notes

16. Abstract (Limit: 200 words)	 
ONE OF A SERIES OF MODULES, DEVELOPED AS A TRAINING TOOL FOR HOTLINE SPECIALISTS. EXPLAINS THE DIFFERENCE BETWEEN
CLOSURE AND POST-CLOSURE AISTS THE TYPES OF FACILITIES THAT ARE SUBJECT TO CLOSURE/POST-CLOSURE."' DEFINES THE DIFFER-
ENCE BETWEEN PARTIAL AND FINAL CLOSURE. SPECIFIES WHO SUBMITS A CLOSURE PLAN AND WHEN A CLOSURE PLAN MUST BE SUBMITTED,
LISTS THE STEPS IN THE PROCESS, AND STATES THE TIME FRAME FOR SUBMITTAL. IDENTIFIES WHEN AND HOW A CLOSURE MUST BE
AMENDED. EXPLAINS THE TIME FRAME FOR NOTIFICATION OF CLOSURE AND THE DEADLINES FOR BEGINNING AND COMPLETING CLOSURE.
SPECIFIES WHICH FACILITIES NEED CONTINGENT POST-CLOSURE PLANS. LISTS THE ELEMENTS OF POST-CLOSURE AND CITES THE RE-
QUIREMENTS. 'SPECIFIES THE CONDITIONS AND TIMING FOR AMENDING A POST-CLOSURE PLAN, STATES WHO MUST CERTIFY CLOSURE/POST-
CLOSURE. THE INFORMATION IN THIS DOCUMENT IS NOT A COMPLETE REPRESENTATION OF EPA'S REGULATIONS OR POLICIES, BUT IS AN
INTRODUCTION USED FOR HOTLINE TRAINING PURPOSES.	' .
17. Document Analysis a. Descriptors
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
RELEASE UNLIMITED
19.	Security Class (This Report)|	21. No. of Pages
UNCLASSIFIED	I	13	
20.	Security Class (This Page) |	22. Price
UNCLASSIFIED	 I	0.00
(See ANSI-Z39.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)

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