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RCRA - Storage/Disposal Details 

Emergency Preparedness and Response

Facilities designated as Small Quantity Generators (SQGs) storing hazardous waste must comply with the following "Preparedness and Prevention" requirements (40 CFR 262.34(d)(4):

  • At all times at least one employee with responsibility for coordinating emergency response measures must be either at the facility or on call and able to reach the facility in a short time (40 CFR 262.34(d)(5)(i)). This employee is the "emergency coordinator."
  • The following information must be posted next to telephones (40 CFR 262.34(d)(5)(ii)):
  • The name and telephone number of the emergency coordinator
  • Locations of fire extinguishers, spill control material, and the fire alarm
  • The telephone number of the fire department, unless the facility has a direct alarm
  • All employees must be thoroughly familiar with proper waste handling procedures and emergency response procedures that are relevant to their responsibilities (40 CFR 262.34(d)(5)(iii)).
  • The facility must have the following equipment, unless this equipment would not be needed to control the hazards posed by the waste at the facility (40 CFR 265.32):
  • An internal communication or alarm system (voice or signal)
  • Telephones or a hand-held, two way radio at locations where hazardous waste is used or stored
  • Appropriate fire control equipment, spill control equipment, and decontamination equipment
  • An adequate volume of water for fire fighting
  • All equipment listed above must be tested and maintained as necessary to ensure that it will function properly in time of emergency (40 CFR 265.33).
  • Personnel handling hazardous waste must have immediate access to an internal alarm or emergency communication device (40 CFR 265.34(a)). An employee working alone on the premises must have immediate access to a means of summoning external emergency assistance (40 CFR 265.34(b)).
  • Aisle space must be maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency, unless aisle space is not needed for any of these purposes (40 CFR 265.35).
  • To the extent warranted by type of hazardous waste handled at the laboratory and the potential need for emergency services, the laboratory must attempt to familiarize police, fire departments, and emergency response teams with facility operations and the wastes handled at the facility, and must attempt to familiarize local hospitals with the properties of the waste and the injuries and illnesses that could result from fire, explosion or waste discharge at the facility (40 CFR 265.37).
  • The emergency coordinator or a person designated by the emergency coordinator must:
  • In the event of a fire, call the fire department or attempt to extinguish the fire using a fire extinguisher (40 CFR 262.34(d)(5)(iv)(A)).
  • In the event of a spill, contain the flow of hazardous waste to the extent possible and clean up the waste and any contaminated materials or soil as soon as possible (40 CFR 262.34(d)(5)(iv)(B)).
  • In the event of a fire, an explosion, a spill that has reached surface water, or any other release that could threaten the health of people outside the facility, immediately notify the National Response Center (NRC) at 800-424-8802. The following information must be provided: the name, address, and identification number of the generator; the type of incident and the date and time of the incident; the type and quantity of hazardous waste involved; a description of any injuries; the quantity of materials recovered and the disposition of the materials. (40 CFR 262.34(d)(5)(iv)(C))

    In addition, hazardous waste generators who experience a release of a "hazardous substance" under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) or an "extremely hazardous substance" under the Emergency Planning and Community Right-to-Know Act (EPCRA), including hazardous waste streams that meet these definitions, must report such releases. Reportable quantities for hazardous substances are given in 40 CFR 302. Reportable quantities for extremely hazardous substances are given in 40 CFR Part 355, Parts A and B. Facilities must notify State Emergency Response Committees (SERC) and Local Emergency Planning Committees (LEPCs) immediately of releases that go beyond the facility boundaries and provide subsequent written notification and/or follow up to the releases. For CERCLA and EPCRA releases that stay within the facility boundaries, then only the NRC must be notified (see previous paragraph).

Contingency Plans for Large Quantity Generators

In addition to complying with the requirements for SQG facilities described above, LQG facilities storing any quantity of hazardous waste must meet the following requirements for contingency plans:

The facility must develop a contingency plan that is designed to minimize hazards to people and the environment from fires, explosions, and releases of hazardous waste or constituents of hazardous waste (40 CFR 262.34(a)(4), 265.51(a)).

The plan must be implemented whenever there is a fire, explosion or release of hazardous waste or hazardous waste consitituents which could threaten human health or the environment. (40 CFR 264.51(b))

The hazardous waste contingency plan must include the following elements (40 CFR 265.52):

  • Actions facility must take to respond to fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water.
  • If a Spill Prevention Control and Countermeasures Plan or another contingency plan has been prepared by the facility, then that plan only need be amended to incorporate the hazardous waste management provisions of this part.
  • A description of the arrangements agreed to by local police departments, fire departments, hospitals, contractors, and state and local emergency response teams to coordinate emergency services.
  • Current names, addresses and phone numbers (home and office) of all persons qualified to act as emergency coordinator; primary and alternate emergency coordinators must be identified whenever more than one person is listed; others must be listed in order of which they will assume responsibility.
  • An up-to-date list of all emergency equipment at the facility and decontamination equipment (where this is required), including the location and a physical description of each item and an outline of its capabilities.
  • An evacuation plan for facility personnel where there is a possibility that evacuation could be necessary, including signals to be used to begin evacuation, evacuation routes, and alternate evacuation routes.

Copies of the contingency plan and all revisions to the plan must be kept at the facility. In addition, copies of the contingency plan must be submitted to all local police, fire departments, hospitals, and emergency response teams that may be called upon to provide emergency services (40 CFR 265.53).

The plan must be reviewed and immediately amended if necessary whenever (40 CFR 265.54):

  • The facility permit is revised
  • The plan fails in an emergency
  • The facility changes in a way that materially increases the potential for fires, explosions, or releases of hazardous wastes or hazardous waste constituents, or changes the response necessary in an emergency
  • The list of emergency coordinators or the list of emergency equipment changes

At all times, there must be at least one employee either at the facility or on call (i.e., able to reach the facility in a short time) who has responsibility for coordinating all emergency response measures. This employee is the emergency coordinator. The emergency coordinator must be thoroughly familiar with all aspects of the facility's contingency plan, all operations and activities at the facility, the location and characteristics of waste stored or handled, the location of all records at the facility, and the facility layout. In addition, this person must have the authority to commit the resources needed to carry out the contingency plan. (40 CFR 265.55)

Procedures for alarm activation; released material characterization; assessment of the hazards of the material to either human health or the environment; if necessary, reporting to state or local agencies and the National Response Center; released material containment; monitoring leaks, pressure buildup, etc.; recovered waste management; and cleaning of emergency equipment prior to reuse. (40 CFR 265.56)

The facility must ensure that implementation of the contingency plan is fully noted in the operating log. (40 CFR 265.56)

For the complete text of the regulations (40 CFR 262 and 265), click here:

40 CFR 262
40 CFR 265

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