EPA530-R-00-003e
PB2000-104 952
RCRA, SUPERFUND & EPCRA HOTLINE MONTHLY REPORT
May 2000
2. Contents of Closure Plan
Sections 264.112(b) and 265.112(b) of the RCRA regulations require the owner and operator
of a treatment, storage, and disposal facility (TSDF) to complete a written closure plan that
identifies steps necessary to perform partial and/or final closure of the facility at any point
during its active life. The closure plan must include an estimate of the maximum inventory of
hazardous wastes ever on site over the active life of the facility and a detailed description of the
methods that would be employed during partial closures andfinal closure (Sections
264/265.112(b)(3)). 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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