Hazardous Waste Facility Closure

A large quantity generator (LQG) who no longer generates or manages hazardous waste at a site must close the site in a manner that:

  • Minimizes the need for further maintenance by controlling, minimizing or eliminating, to the extent necessary to protect human health and the environment, the post-closure escape of hazardous waste, hazardous constituents, leachate, contaminated run-off, or hazardous waste decomposition products to the groundwater or surface waters or to the atmosphere;
  • Removes or decontaminates all contaminated equipment, structures and soil and any remaining hazardous waste residues from short-term storage areas including containment system components (e.g., pads, liners, etc.), contaminated soils and subsoils, bases, and structures and equipment contaminated with waste.
  • If the generator demonstrates that any contaminated soils and wastes cannot be practicably removed or decontaminated, then the short-term storage area is considered to be a landfill and the generator must close the area and perform post-closure care in accordance with the closure and post-closure care requirements that apply to landfills (40 CFR § 265.310).

Note: an extension to the 90-day closure period may be granted on a case-by-case basis.

At least 30 -days prior to commencement of partial closure activities and 60 days prior to commencement of final closure activities, the LQG must complete a Pre-closure Notification Form

Based on the information provided in the Pre-closure Notification Form, a Closure Plan may be required. The Closure Plan must identify all portions of the facility that are subject to closure including short-term storage areas, equipment, and structures to be removed and/or decontaminated, and Locations at the facility where discharges of hazardous waste or releases of hazardous materials are likely to be encountered. The Closure Plan shall provide a schedule for all closure activities and identify how each portion of the facility identified will be closed, methods for removing transporting, treating, storing or disposing of hazardous waste, criteria for determining extent of decontamination necessary, procedures for removing and decontaminating, the sampling and analytical testing methods that will be used to evaluate the effectiveness of decontamination procedures, and any other activities. 

Within 90 days of completion of closure, a LQG must notify that the closure performance standard has been met using a revised Hazardous Waste Handler Site Identification Form (EPA Form 8700-12). If the closure performance standard cannot be met, the LQG will need to notify that it will close as a landfill under 40 CFR § 265.310 using the same form.  LQGs with container, tank or containment building unit(s), or drip pads, will need to notify that it will close under the standards of 40 CFR § 265.445(b) using the same form.

On a case-by-case basis, the Secretary may also require certification by an independent professional engineer licensed in Vermont that closure has been completed.

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Agency of Natural Resources
Department of Environmental Conservation
Waste Management and Prevention Division

Davis Building - 1st Floor
One National Life Drive
Montpelier, VT 05620-3704
802-828-1138