New RCRA Rule: Contingency Plan Quick Reference Guide
EPA’s Generator Improvements Rule added many more-stringent requirements for hazardous waste generators.
One new recordkeeping requirement relates to contingency plans and goes above and beyond what was traditionally required for large quantity generators. EPA now requires large quantity generators to create, maintain, and submit a Quick Reference Guide that summarizes the broader contingency plan.
8 Items for Contingency Plan Quick Reference Guides
In some ways, the requirements for the quick reference guide are more specific than the contingency plan contents listed at 262.261. The quick reference guide must include:
1, The types or names of hazardous waste in layman’s terms and the hazards associated with each hazardous waste present at any one time (e.g. “toxic paint waste”, “spent ignitable solvent”, “corrosive acid”);
2. The estimated maximum amount of each hazardous waste that may be present at any time;
3. Identification of any hazardous waste where exposure would require unique or special treatment by medical or hospital staff;
4. A map of the facility showing where hazardous wastes are generated, accumulated, and treated - and routes for accessing these wastes;
5. A street map of the facility in relation to surrounding businesses, schools and residential areas to understand how best to get to the facility and evacuate citizens and workers;
6. Locations of water supply (e.g. fire hydrant and its flow rate);
7. The identification of on-site notification systems (e.g. fire alarm that rings off site, smoke alarms); and
8. The name of the emergency coordinator and the 24/7 emergency response phone number or the number of an emergency coordinator who is continuously on duty.
(40 CFR 262.262)
The quick reference guide is required for all new contingency plans and must be added if your existing contingency plan is updated. Whenever you amend your contingency plan in the future, the quick reference guide must be updated as well. Generators must submit their contingency plan, along with the quick reference guide, to local emergency responders like police departments, fire departments, hospitals, and State or local response teams.
An incomplete or inadequate contingency plan is a common violation of the RCRA standards. By keeping your contingency plan and quick reference guide complete and up-to-date, you will be better prepared for emergency events and make informed decisions that minimize the risk of a release or other incident.
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