New RCRA Contingency Plan Rules for Satellite Areas and Emergencies

Posted on 7/21/2017 by Roseanne Bottone

 US EPA’s “Hazardous Waste Generator Improvements Rule” took effect at the Federal level on May 30, 2017. Each state authorized to oversee its own hazardous waste program must now adopt all requirements that are more stringent than the previous RCRA rules within one year (two years, if the revisions require changes to State law).

Already, the state of Georgia plans to adopt the revised hazardous waste requirements in August.

New RCRA Rules for Satellite Containers   

One of the new, more stringent RCRA requirements that your state must adopt is that containers managed under the “satellite” rules will have to be included in all preparedness, prevention, and emergency procedures at both small and large quantity generator locations. A heads-up now can help you plan ahead.
As part of a wholesale re-organization of the RCRA regulations, the rules for satellite areas have moved from 40 CFR 262.34(c) to 40 CFR 262.15.

rcraclipboard.JPGLikewise, the small quantity generator (SQG) rules for emergency preparedness and contingency planning have been expanded and moved to 40 CFR 262.16(b)(8) and (9). The large quantity generator (LQG) emergency preparedness and contingency planning requirements have been relocated from 40 CFR Part 265 to the new Subpart M in Part 262.

SQG and LQG Requirements for Hazardous Waste Satellite Areas – Preparedness and Prevention

The following requirements have always applied to central accumulation areas (i.e., 90-day and 180-day storage areas). When your state adopts the more stringent aspects of the Generator Improvements Rule, these emergency preparedness, prevention, and contingency planning rules will apply to satellite, or point-of-generation areas as well.

1. All generators must maintain and operate facilities to minimize the possibility of fire, explosions, or releases of hazardous waste. They must have an internal communications or alarm system.

2. Satellite areas will also need a device, such as a telephone or a hand-held two-way radio, available that is capable of summoning help from the police and fire departments or State and local emergency response teams. Check with your state environmental regional office about whether it will accept mobile phones carried by employees to meet this condition. Some states want a landline or dedicated mobile phone in the area at all times.

3. Portable fire extinguishers or other suitable means of fire suppression and access to water will be necessary. All equipment must be tested and maintained properly.

4. There should be adequate aisle space for the unobstructed movement of personnel and equipment in the event of an emergency. Arrangements must be made with outside authorities so that they are aware of the locations of the satellite areas, the types of wastes stored, and the potential hazards of each.

SQG and LQG Requirements for Hazardous Waste Satellite Areas – Emergency Response

hazmat-reponse.jpgBoth large and small quantity generators must have an emergency coordinator on site or on call at all times who is able to reach the site within a short period of time. He or she must be able to assess imminent or actual threats or releases and take appropriate action.

In addition, small quantity generators must post information next to telephones or in areas directly involved in the generation and accumulation of hazardous waste.

The poster must contain:
  • The name and emergency telephone number of the emergency coordinator;
  • The location of fire extinguishers, spill control material, and alarms; and
  • The phone number of the fire department.
Large quantity generators are not subject to this posting requirement. However, they must have a written contingency plan that is designed to minimize hazards to human health or the environment from fires, explosions, or releases of hazardous waste to the air, soil, or surface water. This plan, as described in 40 CFR 262, Subpart M, must include provisions for waste that is generated and stored in both 90-day and “satellite” areas.

Don’t let the dramatic changes to RCRA catch you off guard. By understanding and facilitating the changes for large, small, and very small quantity generators, you will be prepared to keep your site in compliance.

Learn the New RCRA Rules—Anytime, Anywhere

Be ready when your state adopts these historic changes to the RCRA hazardous waste rules! Lion’s RCRA Hazardous Waste Management Online Course is now updated to reflect RCRA revisions that will have a major impact on how your site manages hazardous waste.

Want live training? The RCRA Hazardous Waste Management Workshop comes to Tulsa, New Orleans, San Antonio, Houston, Dallas, Seattle, Las Vegas, and Phoenix in August 2017. Join us for expert-led RCRA training to meet EPA’s annual training mandate and get up-to-date on the big changes to the hazardous waste rules.

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