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:


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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA 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.