Emergency Preparedness in Haz Waste Satellite Areas

Posted on 2/4/2020 by Roseanne Bottone

“…the [Generator Improvement Rule (GIR)] enhances the safety of facilities, employees, and the general public by improving hazardous waste risk communication and ensuring that emergency management requirements meet today’s needs…revisions are designed to improve emergency responders’ ability to respond to events…”

– US Environmental Protection Agency

US EPA published the Generator Improvements Rule in the Federal Register on November 28, 2016 with an effective date of May 30, 2017. All authorized states are required to adopt elements of the GIR that are more stringent than their own regulations within two years.

As of February 4, 2020, about half of the states have yet to adopt the Generator Improvements Rule. Technically speaking, states that have not yet adopted the more-stringent RCRA requirements are out of compliance. If your state has not yet adopted the new rule, they will soon.   

To check the status of the Generator Improvements Rule in your state, visit EPA’s dedicated web page here.

New RCRA Emergency Preparedness Requirements 

Among the many notable changes in the revised RCRA regulations are provisions that bolster emergency preparedness requirements for both small and large quantity generators.

The small quantity generator (SQG) rules for emergency procedures at 40 CFR 262.16(b)(9) state, “The small quantity generator complies with the following conditions for those areas of the generator facility where hazardous waste is generated and accumulated.”

For large quantity generators (LQGs), §262.17(a)(6) redirects to 40 CFR Part 262, Subpart M for preparedness, prevention, and emergency procedures. Like the SQG requirements, the applicability rules in §262.250 state that “The regulations of this subpart apply to those areas of a large quantity generator where hazardous waste is generated or accumulated on site.

For both LQGs and SQGs, EPA has made clear that “where hazardous waste is generated or accumulated” includes points of generation, satellite accumulation areas (SAAs), and central accumulation areas (i.e., 180-day and 90-day storage areas).

Emergency Preparedness in Satellite Areas

In addition to posting emergency information next to the phone (for SQGs) and including satellite areas in their written contingency plans (for LQGs), all generators must now provide/install specified emergency equipment at satellite accumulation areas.

Required emergency equipment includes:
  • An internal communication or alarm system;
  • A device, such as a telephone (immediately available at the scene of operations) or a hand-held two-way radio, capable of summoning emergency assistance from local police departments, fire departments, or state or local emergency response teams;
  • Portable fire extinguishers, fire control equipment (including special extinguishing equipment, such as that using foam, inert gas, or dry chemicals);
  • Spill control equipment;
  • Decontamination equipment; and
  • Water at adequate volume and pressure to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray systems.

Where to Put Emergency Equipment

Here’s the good news: EPA says that “SQGs and LQGs may determine the most appropriate locations for emergency equipment, when it is not possible or unsafe to have the equipment located immediately next to the generating equipment" (§262.16(b)(8)(ii)/ §262.252).

That provides generators with some room for commonsense flexibility.

Lion continues to track the adoption of the Generator Improvements Rule by state.

2020 RCRA Hazardous Waste Training

For training on the latest RCRA regulations, join an expert instructor for the RCRA Hazardous Waste Management Workshop, coming soon to a city near you.
Houston, TX Feb. 10–11
San Antonio,TX Feb. 19–20
Phoenix, AZ Feb. 24–25
Denver, CO Feb. 27–28
Portland, OR Mar. 2–3
Salt Lake City, UT Mar. 9–10
Grand Rapids, MI Mar. 26–27
Chicago, IL Mar. 30–31

US EPA requires annual RCRA training for hazardous waste personnel. Lion makes it easy to meet your RCRA training mandate in a variety of formats—nationwide public workshops, convenient online courses, live webinars, and on-site training.

Browse all RCRA training options here to find the course that fits your needs, your schedule, and your learning style.

Tags: contingency planning, emergency preparedness, generator improvements rule, hazardous waste management, RCRA

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