(4) Adequate ground-water monitoring program.
Permit application assistance
(5) Communication and alarm systems.
a. The design engineer should develop a
d. Specific design features are not required by
detailed operations plan for the facility that will include
the contingency plan, however, an acceptable
preclosure, closure and post-closure operations. These
contingency plan is based on the intrinsic safety features
plans are usually required as part of the state permit
of the individual facilities. Surface impoundments require
application process. Generally such plans describe the
additional contingency planning, as well as development
characteristics of the wastes handled at the facility,
of emergency repair procedures; similar regulations are
equipment and operating procedures, site personnel,
proposed for waste piles.
and provisions for emergencies and other contingencies.
b. Typical components of operations plans
Personnel requirements, training, and safety
a. Regulations promulgated under RCRA on
May 19, 1980, require owners or operators of hazardous
waste management facilities to train their personnel.
Specifically, 40 CFR 264.16 states: "Facility personnel
Waste Handling and Control
must successfully complete a program of classroom
Management and Personnel
instruction or on-the-job training that teaches them to
Operations and Safety Training
perform their duties in a way that ensures the facility's
compliance with the requirements of this Part ..."
b. This program must be directed by a person
trained in hazardous waste management procedures and
must include instruction which teaches facility personnel
hazardous waste management procedures (including
contingency plan implementation) relevant to the
positions in which they are employed. At a minimum, the
Conservation and Recovery Act (RCRA) stipulates that
training program must be designed to ensure that facility
regulatory standards for hazardous waste facilities shall
personnel are able to respond effectively to emergencies
include "contingency plans for effective action to
by familiarizing them with emergency procedures,
minimize unanticipated damage from any treatment,
emergency equipment, and emergency systems,
storage or disposal of any such hazardous waste."
including where applicable:
b. Subpart D (Contingency Plan and
(1) Procedures for using, inspecting, repairing, and
Emergency Procedures) of 40 CFR 264.50-56 outlines
replacing facility emergency and monitoring
the required contents of the plan, personnel
responsibilities and emergency procedures. Specifically,
(2) Key parameters for automatic waste feed cutoff
the plan must be designed to minimize hazards to
human health or the environment from fires, explosions,
or any unplanned sudden or non-sudden release of
(4) Response to fires or explosions;
hazardous waste constituents to air, soil or surface
water. Section 264.52(b) of subpart D states that if the
owner/operator has a SPCC plan, "he need only amend
(6) Shutdown of operations.
that plan to comply with the requirements of this part."
c. This training must be completed within six
months from the date of employment or assignment to a
contingency plan must include the facility provisions
facility or to a new position at a facility, whichever is later.
which will aid in quick and effective emergency response
d. The regulations state explicitly that facility
procedures as well as those features that will help to
personnel must be trained and that the training must be
avoid emergency situations. These might include the
correlated to job classification. The regulations do not
provide criteria for acceptable training programs.
(1) Primary and secondary spill containment
e. For some types of activities existent at
structures and methods.
hazardous waste management facilities, personnel
(2) Structures and equipment used for the
training is required under the Occupational Safety and
containment and suppression of fires (e.g., installed
Health Act (29 CFR 1910 et seq.). However, personnel
sprinkler or foam systems, fire breaks).
training which is required under RCRA has been
(3) Location of facility:
interpreted as going beyond that designed to protect
away from active faults
workers and ex-
away from sources of ignition
away from flood zones or low-lying coastal