June 13, 2012

Preparedness and Prevention Requirements for TSD Facilities

EPA recently made available a guidance document offering recommendations to RCRA permit writers and permittees on satisfying the preparedness and prevention and contingency planning requirements of Part 264/265, Subparts C and D. [RO 14832] The memo was issued in response to recommendations by the U.S. Chemical Safety and Hazard Investigation Board (CSB) following the investigation of an October 2006 fire at a permitted TSD facility. The CSB and EPA recommend that RCRA permits explicitly require owners and operators of permitted and interim status TSD facilities to maintain current and thorough preparedness and prevention information (PPI). The availability of up-to-date PPI and contingency plans are vital for a focused, effective response to an incident involving hazardous waste.

The guidance does not directly address large quantity and small quantity generators who are subject to the PPI provisions of Part 265, Subparts C and D. However, we believe it may be useful to generators when developing and updating PPI and contingency plans.

The CSB and EPA recommend facilities:

Ensure that state and local authorities and emergency responders receive written information regarding the type, approximate quantities, and locations of hazardous wastes currently at the facility.
Periodically update waste inventory information.
Maintain contingency plans and PPI in electronic format for ease of distribution, integration, storage, and retrieval.
Include PPI as an appendix to contingency plans.
Submit written PPI to local police departments, fire departments, hospitals, and state and local emergency response teams, so that local responders have in-hand the specific information they need for prompt and effective response.

McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.

Disclaimer

Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.