Natural disasters, fires, industrial accidents, and other calamities are tragic. When hazardous waste is involved, these tragedies can be catastrophic. Because these events can happen without warning, the US EPA requires large quantity generators (LQGs) of hazardous waste and treatment, storage, and disposal facilities (TSDFs) to have a written contingency plan and a designated emergency coordinator (EC) to implement the plan. [40 CFR 265, Subpart D]
Emergency coordinators have essential and far-reaching responsibility for emergency response: directing personnel response actions, coordinating with outside agencies, and otherwise implementing the contingency plan. It's critical that facility managers understand what the rules are and how they work, who the emergency coordinator is at their site, and the emergency coordinator's responsibilities in an emergency. The Emergency Coordinator's Responsibilities
First, and perhaps most importantly, the coordinator must be on premises or able to reach the facility within a short period of time. What constitutes "a short period of time" is not specifically defined in 40 CFR 265; appropriate response times may vary based on the site's type and quantity of waste, as well as the complexity of the processes and layout at the facility. Keep in mind that facility responders as well as outside responders such as police, fire departments, and local emergency response teams often defer to the EC's unique knowledge of the wastes and facility. Any unnecessary delay may negatively impact their ability to respond appropriately to the emergency.
The regulations at 40 CFR 265.55 state that 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 handled, the location of all records within 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."
The responsibilities for the EC are specified in detail at 40 CFR 265.56. The EC's responsibilities for implementing the contingency plan must be covered by the initial and annual training required for "hazardous waste personnel" per 40 CFR 265.16. Four Steps for Implementing Your Contingency Plan STEP 1 - Assessment
The EC must determine whether there is an imminent or actual emergency. If there is, he must immediately notify all facility personnel by activating facility alarms or communication systems. He is also required to notify appropriate State or local agencies if he determines their help is needed.
If the emergency consists of an actual release, fire, or explosion, the EC must immediately identify the released materials':
- Exact source,
- Amount, and
- Affected areas.
At the same time, the EC must assess possible hazards to human health and the environment by considering such things as the effects of any toxic, irritating, or asphyxiating gases generated and hazardous surface water run-off generated from water, chemicals, or fire-fighting agents. [40 CFR 265.56(a)-(c)] STEP 2 - Report
If the EC determines the fire, explosion, or release could have off-site impact, she must call the National Response Center at 800-424-8802 (or the governmental official designated as the on-scene coordinator for that geographical area). The report must include:
- Name and telephone number of reporter;
- Name and address of facility;
- Time and type of incident (e.g., release, fire);
- Name and quantity of material(s) involved, to the extent known;
- Extent of injuries, if any; and
- Possible hazards to human health, or the environment, outside of the facility.
In addition, if the EC believes an evacuation may be necessary, she must immediately notify local authorities and be available for assistance. [40 CFR 265.56(d)] STEP 3 - Mitigate
The EC should take measures to keep fires, explosions, and releases from occurring or reoccurring and keep them from spreading to other hazardous wastes stored on site. He may accomplish this by shutting down processes and operations, containing and cleaning up releases, or physically moving or isolating other containers.
If operations cease, the EC must monitor valves, pipes, and other equipment for leaks and ruptures, pressure buildup, and off gassing. [40 CFR 265.56(e)-(f)] STEP 4 - Follow-up
If any hazardous waste (e.g., contaminated soil or surface water) was generated from emergency response actions, the EC must provide for the appropriate treatment, storage, or disposal of that recovered waste and must ensure that cleanup procedures are completed.
Any emergency equipment, such as fire extinguishers, hoses, and decontamination equipment that were listed in the site's written contingency plan must be cleaned and/or returned to a condition making it fit for its intended use before site operations commence anew. [40 CFR 265.56(g)-(h)]
The time, date, and details of an incident requiring the implementation of the contingency plan must be noted in the site's operating records.
Finally, a written incident report must be sent to the Regional Administrator or State-approved agency within 15 days of the emergency. (For content requirements, see 40 CFR 265.56(i)(1)-(7).) In Summary
The emergency coordinator's preparedness and knowledge not only help protect the environment, but can also save lives. In the event of an emergency, it's critical that all employees at the facility, especially the emergency coordinator, are ready and able to fulfill their responsibilities.
Be confident your emergency coordinator, site managers, operators, and other personnel know their responsibilities for managing and storing waste under the Resource Conservation and Recovery Act (RCRA). The Hazardous/Toxic Waste Management Workshop
is designed to satisfy the EPA's annual training standard for hazardous waste personnel and covers the rules your team must know to ensure compliance. Fines for noncompliance with RCRA are as high as $37,500 per day, per violation.