In order to facilitate the response to a potential emergency, all Large Quantity Generators (LQGs) are required to submit a Contingency Plan. According to Title 40 CFR §262.261, a “contingency plan must describe the actions facility personnel must take to comply with §§262.260 and 262.265 in response to fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water at the facility.” Requirements apply to all hazardous waste generators, but Large Quantity Generators (LQGs) have more requirements than Small Quantity Generators (SQGs).
Updates From Generator Improvements Rule
One key element of a Contingency Plan is the Quick Reference Guide. Beginning on October 28, 2016, the EPA introduced the Generator Improvements Rule (GIR), which has since been adopted by an increasing number of states throughout the US. As stated in this rule, the EPA replaced “the term ‘executive summary’ with the term ‘quick reference guide’ in order to more closely mirror the intended purpose of this document.” The reason for this name change is to allow emergency responders to more quickly evaluate the potential dangers of a situation and notify the proper contacts without having to find and read through a 20+ page document. The Quick Reference Guide is a primary example of the difference in requirements between LQGs and SQGs.
Elements of the Quick Reference Guide
There are three main components of an LQG Quick Reference Guide:
- Contingency Plan Quick Reference Guide
- Access Roads Map
- Facility Site Map
The Contingency Plan Quick Reference Guide acts as a direct summary of the Contingency Plan itself. This guide includes the names, phone numbers, and directions for contacting each of the emergency coordinators listed. As part of the GIR, the home addresses of these contacts no longer need to be listed. The guide also includes a list and description of each onsite notification system, including the type of system (i.e. intercom, facility phones, cell phones, etc.), the locations where the systems can be accessed, and directions on how to activate them. Lastly, the guide describes the types of hazardous waste(s) onsite, their associated hazards, storage locations, and the estimated maximum amount onsite. If there are any hazardous wastes that require unique or special treatment, that will also be defined in this section of the Quick Reference Guide.
The Access Roads Map is an integral part of the Quick Reference Guide as it depicts all the nearby intersections for directly accessing the facility. As is the overall purpose of the Quick Reference Guide, this is yet another element that has the potential to assist emergency personnel.
The Facility Site Map is beneficial for both emergency personnel and the people working onsite at the time of an emergency. This emergency response map includes the locations of fire extinguishers, water main supply, hazardous waste location(s), communication systems, exits, and evacuation routes.
Contingency Plans for SQGs
For an SQG, the Contingency Plan is a far simpler document. It operates primarily as an emergency contacts page. Much like the Quick Reference Guide for LQGs, the first two contacts listed are the Emergency and Alternate Emergency Coordinator who are to be contacted immediately upon discovery of a discharge or spill of hazardous material or waste. The contact information for the local police and fire departments must also be included, as well as the information for the US UPA National Response Center in the event of a release that could threaten human health outside the facility or reach surface water. Federal SQG Contingency plan requirements stipulate that this contingency plan must be posted at a phone near the hazardous waste accumulation area per §262.16(b)(9)(ii). It must also be noted that employees must be thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies.
Keeping Contingency Plans up to Date
Per §262.263, a Contingency Plan and Quick Reference Guide must be reviewed and immediately updated whenever:
- Applicable regulations are revised;
- The plan fails in an emergency;
- The generator facility changes—in its design, construction, operation, maintenance, or other circumstances—in a way that materially increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency;
- The list of emergency coordinators changes; or
- The list of emergency equipment changes.
If any of these circumstances have occurred, US Compliance will gladly assist you in updating your Contingency Plan and Quick Reference Guide.