When a hazardous waste management unit stops receiving waste at the end of its active life, it must be closed. Unfortunately, the RCRA closure process can be a complicated, drawn out, and costly endeavor. A common misconception is that RCRA closure standards apply solely to treatment, storage and disposal facilities (TSDFs) such as hazardous waste incinerators or Subtitle C landfills. When in fact, large quantity waste generators and other facilities that treated, stored, or disposed of hazardous waste without an application or permit are also required to conduct RCRA closures. Many owner/operators focus on the short term costs and fail to consider the potential long-term implications associated with some types of RCRA closures. Requirements such as groundwater monitoring, financial assurance, post-closure care, and site-wide RCRA Corrective Action can add greatly to the entire cost of closure.
Cox-Colvin has significant expertise in planning and implementing RCRA closure for TSDFs and generators of all sizes. Clients value our ability to develop tailored closure strategies including the critical evaluation of the costs and benefits of the identified closure options. Our breadth of experience includes all phases of closure from preparing closure plans; to implementing clean, risk-based, and landfill closure; to RCRA post-closure groundwater monitoring. We have successfully conducted closures of tanks, storage pads, lamp crushing facilities, surface impoundments, soil piles, and disposal areas used for treatment, storage, or disposal of both listed and characteristic hazardous wastes.
While our specialty is the planning, negotiation, and implementation of large and/or complex closure projects, we apply the same principles to the straightforward single unit closure projects.
RCRA Closure services provided by Cox-Colvin include:
- Closure plan preparation and negotiation
- Implementation of closure plans
- Closure certification
- “Contained-In” decisions for disposal of environmental media containing listed hazardous waste
- Post-closure care
- RCRA post-closure groundwater monitoring
- RCRA permit modifications
- Public participation