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The Requirements of 40 CFR 265, Subpart D – Contingency Plan and Emergency Procedures

The Requirements of 40 CFR 265, Subpart D – Contingency Plan and Emergency Procedures

The regulations of 40 CFR 265 apply primarily to hazardous waste Treatment Storage and Disposal Facilities (TSDF’s) with interim status (interim status means the facility operates prior to issuance of a RCRA Subtitle C operating permit).  However, different aspects of these regulations may apply to the operations of hazardous waste generators as well.  For example:

  • The training requirement of 40 CFR 265.16 apply to a Large Quantity Generator of hazardous waste (LQG) pursuant to §262.34(a)(4).
  • The regulations of §265, Subpart C – Preparedness and Prevention apply to both an LQG and a Small Quantity Generator of hazardous waste (SQG) pursuant to §262.34(a)(4) and §262.34(d)(4), respectively.
  • §265, Subpart I applies to LQG’s and SQG’s that accumulate hazardous waste in containers pursuant to §262.34(a)(1)(i) and §262.34(d)(2), respectively.
  • §265, Subpart D applies solely to LQG’s.  A reference to it can be found at §262.34(a)(4), it reads:

The generator complies with the requirements for owners or operators in subparts C and D in 40 CFR part 265, with § 265.16, and with all applicable requirements under 40 CFR part 268.

This series of articles will address each section of §265, Subpart D in detail, taken as a whole, it will provide guidance on what an LQG must do to be in compliance with Subpart D or 40 CFR 265.

Contents:

As a Large Quantity Generator of hazardous waste, the requirements of Subpart D are just one part of your regulatory responsibilities.  Contact me for a free consultation of what else is required of an LQG.  Also, I can answer your questions about the regulations of the USDOT/PHMSA regarding the transportation of hazardous materials.

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