TSDFs are required to minimize the possibility of a fire, explosion, or any release of hazardous waste that could threaten human health or the environment by:
- Maintaining an internal alarm system, telephone, or two-way radio to call emergency authorities; fire extinguishers and other fire control equipment (foam, dry chemicals, etc.); and adequate volume and pressure of water at the facility.
- Note: If a facility can demonstrate to the applicable EPA regional office that none of the hazards posed by certain wastes handled at the facility require a particular kind of equipment, the facility does not need to maintain that equipment.
- Regularly testing and maintaining equipment to ensure proper operation in time of emergency.
- Ensuring access to internal alarms or emergency communication devices; if only one employee, ensuring immediate access to a telephone or two-way radio capable of summoning emergency assistance.
- Maintaining required aisle space to allow the unobstructed movement of personnel, fire protection equipment, and spill control equipment, etc., during an emergency. Note: Experts recommend that facilities implement aisle space requirements in such a way that an adult can easily walk between rows of containers.
- Arranging with local authorities, appropriate for the type of waste handled at the facility.
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Large Quantity Generators (LQGs)
- Follow the TSDF preparedness and prevention procedures of 40 CFR 265.30 to 265.37.
- Develop and maintain a RCRA contingency plan on-site in accordance with 40 CFR 265.50 to 265.56.
- Comply with personnel training requirements of 40 CFR 265.16.
Are you an LQG? An LQG is a generator that generates 1,000 kilograms (kg) or more of hazardous waste or more than 1 kg of acute hazardous waste in a calendar month.
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Small quantity generators (SQGs)
Although SQGs are not required to prepare a RCRA contingency plan, they are required to follow modified personnel training requirements (i.e. ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities) and the same preparedness and prevention procedures as LQGs. In addition, SQGs must comply with these requirements:
- At least one employee responsible for coordinating all emergency response measures must be either on the premises or on call at all times.
- The name and telephone number of the emergency coordinator, location of fire extinguishers and spill control material, fire alarms, etc., and telephone number of the fire department (unless the facility has a direct alarm) must be posted next to the facility’s telephone.
- The SQG must ensure that all employees are familiar with proper waste handling and emergency procedures.
- The emergency coordinator or designee must respond to any emergencies that arise, as follows:
- In the event of a fire, call the fire department or attempt to extinguish it.
- In the event of a spill, contain the flow of hazardous waste to the extent possible, and, as soon as practicable, clean up the hazardous waste and any contaminated materials or soil.
- In the event of a fire, explosion, or other release that could threaten human health outside the facility or when the generator has knowledge that a spill has reached surface water, the generator must immediately notify the National Response Center and provide them with:
- The name, address, and U.S. EPA Identification Number of the generator
- Date, time, and type of incident (e.g., spill or fire)
- Quantity and type of hazardous waste involved in the incident
- Extent of injuries, if any, and
- Estimated quantity and disposition of recovered materials, if any.
Are you an SQG? An SQG is a generator that generates more than 100 kg but less than 1,000 kg of hazardous waste or up to 1 kg of acute hazardous waste in a calendar month.
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