Authored by John D. Cain in April 2019, the paper explains that the HWGIR (federally effective May 30, 2017) consolidates LQG closure standards for central accumulation areas, tank systems, containment buildings, and drip pads into §262.17(a)(8), while leaving satellite accumulation areas exempt.
When closing an individual unit, an LQG may either place a notice in its operating record deferring full closure until the entire facility closes or perform the applicable performance standards and notify EPA (or the authorized state) via Form 8700-12 within 90 days. Full facility closure requires 30-day advance notification, confirmation that units meet the clean-closure standards of §§265.111 and 265.114 (or will be closed as a landfill if clean closure is not achieved), details on managing residual hazardous waste, and a follow-up notification within 90 days after closure; drip pads carry additional unit-specific obligations.
Additional time for clean closure may be requested within 75 days of site closure. The paper notes that while some HWGIR changes improve clarity, these new LQG closure provisions are more stringent than prior rules and, combined with uneven state adoption timelines, will increase complexity for generators.
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