Ask the Expert, Hazardous Waste Management, Q&A

Closure Plan

Q. Are there compliance issues that would prevent our installation of a compressor on a concrete slab on which our (now clean-closed) RCRA-permitted hazardous waste boiler sat? Our Closure Plan states that we will close the slab when the facility closes.

A. Your stated objective of installing a compressor on the concrete from which a hazardous waste boiler was clean closed and removed does not raise any specific compliance issues to us. However, it would be a good idea to run this plan by your environmental regulatory agency as it might conflict with some requirement of your RCRA permit. Even if it does not, it is not unusual for an environmental regulatory agency to have a policy that the agency requires be followed, despite the absence of an applicable regulatory requirement.

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