August Mack Newsletter | April, 2019

RCRA Contingency Plans
by Thomas Utter

Applicability and Purpose

The Resource Recovery and Conservation Act (RCRA) Contingency Plans (40 CFR262.260 through 262.265) are documents required by generators that follow the Large Quantity Generator (LQG) exemption.  RCRA Contingency Plans are designed to outline procedures that are designed to minimize threats to human health or the environment from unplanned releases of hazardous materials to soil, air, or surface water, fires, or explosions.

Content of the Contingency Plan

A RCRA Contingency Plan must contain several pieces of information at a minimum, including:

  • Actions expected from facility personnel in response to a fire, explosion, or an unexpected or sudden release of hazardous waste;
  • Arrangements agreed to by local police & fire departments, hospitals, contractors, and state and local emergency response teams;
  • Names, addresses, phone numbers (office & home) of all persons qualified to act as an emergency coordinator;
  • Emergency equipment (fire extinguishers, sprinkler systems, spill kits, communications, and alarms), and
  • An evacuation plan, outlining signals used to begin evacuation, routes, and alternate routes
 

A copy of this plan must be maintained at the facility and submitted to all local police & fire departments, hospitals, and state and local emergency response teams that may be called upon in the event of an emergency at the facility.

Contingency Plan Quick Reference Guide

LQG’s are required to develop and submit a quick reference guide alongside their full Contingency Plan document.  This requirement to create a quick reference guide applies to any LQG who first became subject to the LQG rules after May 30, 2017, or has amended their Contingency Plan after May 30, 2017.  The quick reference guide is required to include the following information:

  • The types and names of hazardous wastes (in layman’s terms) and associated hazard associated with each hazardous waste present at any one time (i.e., toxic paint wastes, spent ignitable solvent, corrosive acid);
  • The estimated maximum amount of each hazardous waste that may be present at any one time;
  • The identification of any hazardous wastes where exposure could require unique or special treatment by medical or hospital staff;
  • A map of the facility showing where hazardous wastes are generated, accumulated, and treated and routes for accessing these wastes;
  • A street map of the facility in relation to surrounding business, schools, and residential areas in order to understand how best to get to the facility and evacuate citizens and workers;
  • The locations of water supply (e.g., fire hydrant and flow rate)
  • The identification of on-site notification systems (e.g., a fire alarm that rings off-site, smoke alarms); and
  • The names and telephone numbers (office & home) for all responsible emergency coordinator(s)
 

Amending a RCRA Contingency Plan

A facility’s RCRA Contingency Plan must be reviewed and immediately amended and redistributed to all emergency services in the event of:

  • Applicable regulations being revised;
  • The Contingency Plan fails in an emergency situation;
  • The facility changes in a way that increases its potential for fires, explosions, or releases of hazardous waste
  • The list of emergency coordinators (or their contact information) changes; or,
  • The list of emergency equipment changes
 

Note that Generators must also update quick reference guides whenever the Contingency Plan is updated and submit the updated guide to all applicable local emergency responders.

It is important for your contingency plan to hold accurate information in case of an emergency. An emergency can happen at any time so it is imperative to be prepared when an unforeseen disaster happens. If you have additional questions about RCRA contingency plans then do not hesitate to contact us and we are happy to assist you. 


Thomas Utter is a Compliance Specialist at August Mack Environmental, Inc. in its Indianapolis, Indiana office. He has experience in preparing air permit applications, storm water pollution prevention plans, spill prevention, containment and countermeasure (SPCC) plans, and conducting industrial hygiene sampling. Thomas can be reached at 317.916.3188 or via e-mail at tutter@augustmack.com.


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