Requirements for contingency plans

• SQGs must prepare and implement basic contingency plans, while LQGs must prepare and implement full contingency plans.

Small quantity generators (SQGs) must prepare and implement basic contingency plans. Large quantity generators (LQGs) must prepare and implement full contingency plans.

A contingency plan describes the actions facility personnel must take to comply with the Resource Conservation and Recovery Act (RCRA) regulations in response to fires, explosions, or any unplanned release of hazardous waste at the facility.

In addition, the plan must contain the following:

• A description of the actions facility personnel must take in response to fires, explosions, or any unplanned sudden or non-sudden releases of hazardous waste constituents to air, soil, or surface water.
• A description of the arrangements made with local authorities to coordinate emergency services.
• Names, addresses, and phone numbers — both office and home — of all persons qualified to act as the emergency coordinator (This list must be kept up to date.). Where more than one person is listed, one person must be designated as the primary contact and the others must be listed in the order in which they will assume responsibilities as alternates.
• A list of all emergency equipment at the facility (such as fire extinguishing systems, spill control equipment, communications, and alarm systems). The location and physical description of each item on the list, and a brief outline of its capabilities.
• An evacuation plan for facility personnel (where there is a possibility an evacuation could be necessary). This plan must describe signal(s) to be used to begin evacuation, evacuation routes, and alternate evacuation routes (in cases where the primary routes could be blocked by releases of hazardous wastes or fires).

Copies of the plan must be maintained at the facility and submitted to local authorities.

Revise the plan if:

• The regulations that apply are revised;
• The plan failed in an emergency;
• There is a change in the facility design, construction, operation, maintenance, or other circumstances in a way that increases the potential for fires, explosions, or releases of hazardous waste – or changes the response measures necessary in an emergency;
• The list of emergency coordinators changes; or
• The list of emergency equipment changes.

If a facility already has a Spill Prevention, Control, and Countermeasures (SPCC) Plan to meet the requirements of the Clean Water Act (CWA) or has some other emergency or contingency plan prepared, the Environmental Protection Agency (EPA) says a facility only has to amend that plan to add hazardous waste management plans to meet the RCRA requirements.

One plan

Optionally, a facility may develop one contingency plan that meets all regulatory standards (CWA, Emergency Planning and Community Right-to-Know Act (EPCRA), RCRA, etc.). EPA recommends that the plan is based on the National Response Team’s Integrated Contingency Plan Guidance, also called “One Plan.”