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CA Generator Improvements FAQ: LQG Closure Requirements

Posted on 8/19/2024 by Lion Technology Inc.

California DTSC has released an FAQ to help hazardous waste generators comply with revised and re-organized State regulations in effect as of July 1, 2024.

FAQ #8 on the California Generator Improvements Rule webpage answers questions about new large quantity generator closure requirements to help generators comply with new and revised standards in effect now.

View the FAQ on DTSC's website.

Need update training or your annual refresher? 
Don't miss the last California Hazardous Waste Management Workshops of the year in Los Angeles, San Diego, and San Jose in September 2024.

California Generator Improvements Rule FAQ 

New large quantity generator Closure requirements – 66262.17(a)(8)

1. What are new LQG containers closure requirements?

All LQGs accumulating hazardous wastes in containers must meet one of the following closure conditions:

  1. Place a notice in the operating record within 30 days after container closure identifying the location of the container within the facility; or

  2. Meet the closure performance standards as summarized below:

    1. The generator must minimize the need for further maintenance to protect human health and the environment.

    2. Remove or decontaminate all contaminated equipment, structures, soil and hazardous waste residues.

    3. Any hazardous waste generated during closure must be managed properly within 90 days of generation.

    4. If contaminated soil cannot be removed or decontaminated, the waste accumulation unit is to be considered a landfill and the generator must perform post-closure care that applies to landfills.

  3. Follow the facility closure notification procedures.

2. What are new LQG facilities closure notification requirements?

LQGs that generate RCRA hazardous waste must notify DTSC using U.S. EPA form 8700-12:

  1. No later than 30 days before facility closure.

  2. Within 90 days after facility closure noting that closure performance standards have been complied with. If closure performance standards cannot be met, then DTSC must be notified using U.S. EPA form 8700-12 that the facility will close as a landfill.

  3. Within 75 days after the date provided in the first closure notification (no later than 30 days before facility closure), when additional time is requested to clean close the facility.

EPA form 8700-12 shall be completed electronically from the U.S. EPA’s RCRAInfo webpage.

3. Do closure requirements for containers apply to generators of both RCRA and Non-RCRA hazardous waste?

Yes, closure requirements for containers apply to generators of RCRA and/or non-RCRA hazardous wastes.

4. Do facility closure notification requirements apply to generators of both RCRA and non-RCRA hazardous waste?

No, facility closure notification requirements only apply to LQGs of RCRA hazardous waste.

5. How will Unified Program Agencies be notified when DTSC receives a closure notification?

DTSC is working with its information technology to provide closure notification information to Unified Program Agencies through the Hazardous Waste Tracking System (HWTS) and other means. Future updates on this subject will be provided.

Lion Members: Visit Lion.com/Members for more detail about important changes to California's hazardous waste laws and regulations now that the Generator Improvements Rule is in effect. 

California Hazardous Waste Training (Title 22/RCRA)

Get your annually-required hazardous waste training with Lion for an extra edge in 2024: Lion instructors are well-versed in the Generator Improvements Rule and how it affects California's already complex regulations. 

All of Lion's hazardous waste training programs have been updated and refined continuously to address new requirements since US EPA enacted the "GIR" in 2016.

Find an upcoming instructor-led training (workshops and live webinars) to get up to speed ASAP.

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