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Is Your RCRA Contingency Plan Up to Snuff?

Emergency Planning
by Kelly Lagana
"A contingency plan establishes the procedures that must be taken immediately under RCRA by both owners and operators of hazardous waste treatment, storage, and disposal facilities and large quantity generators (LQGs) to minimize hazards to human health and the environment caused by explosions, fires, or unplanned sudden or nonsudden releases of hazardous waste or hazardous waste constituents to the air, soil, or surface water."

The plan must be in writing, and it must identify who will be in charge of implementation in the event of an emergency.

If you are required to have a RCRA contingency plan, here’s what you need to know.

Basic Contingency Plan Contents

Your written contingency plan must, at a minimum, describe:

  • Specific actions that facility personnel must take in response to the emergency
  • Arrangements for emergency response with local emergency response authorities (e.g., fire and police departments, hospitals, local hazmat response teams) Name, address, and home and office telephone numbers of the facility’s primary emergency coordinator
  • Name, address, and home and office telephone numbers of all other personnel qualified to act as emergency coordinator, listed in the order that each will assume responsibility as the emergency coordinator
  • Up-to-date list and location of all emergency response equipment at the facility, including a physical description of each item and an outline of its capabilities
  • Personnel evacuation plan

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Shortcut: RCRA Contingency Plan and SPCC

The RCRA contingency plan regulations state that a facility may use an already prepared Spill Prevention, Control, and Countermeasures (SPCC) plan, a National Oil and Hazardous Substances Pollution Plan, or other emergency or contingency plan, as the RCRA contingency plan if it is amended to incorporate the RCRA contingency plan provisions set forth at 40 CFR 264, Subpart D or 40 CFR 265, Subpart D.

If this applies to you, you may develop one contingency plan that meets all regulatory requirements. EPA recommends that the plan be based on the NRT’s Integrated Contingency Plan Guidance (One Plan). When modifications are made to non-RCRA provisions in an integrated contingency plan, the changes do not trigger the need for a RCRA permit modification.

If this sounds more than a little daunting, take a little help from Enviro.BLR.com and check out these customizable plan templates.


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Distribution of Copies

A copy of the TSDF’s or LQG’s RCRA contingency plan must be kept on-site. Permitted TSDFs must submit a copy to EPA. The plan also must be sent to:

  • Local fire and police departments
  • Local hospitals
  • Local emergency response team
  • State emergency response team
  • State environmental agency

Amending the Plan

Your RCRA contingency plan must be amended when:

  • The TSDF permit is revised or, for generators and interim TSDFs, applicable regulations are revised.
  • The plan fails in an emergency.
  • The facility changes its design, construction, operation, or maintenance practices, and the change materially increases the chance of a fire, explosion, or release of hazardous waste.
  • The facility changes the response necessary in the event of an emergency.
  • The list of emergency coordinators changes.
  • The list of emergency equipment changes.

It’s not good enough to just have a plan. EPA requires TSDFs, LQG’s, and hazardous waste small quantity generators to know specific preparedness and prevention procedures for an emergency response. See tomorrow’s Advisor to find out how to comply with putting your plan into action in the event of an emergency.

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