USEPA regulations at 40 CFR 265, Subpart D require a large quantity generator of hazardous waste to have a Contingency Plan and to implement emergency procedures to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water.  40 CFR 265.56(d) mandates that a facility’s emergency coordinator notify both State and Federal authorities if he determines that the facility has had a release, fire, or explosion which could threaten human health, or the environment, outside the facility.  The purpose of this article is to provide some examples of scenarios that demonstrate the potential to threaten human health and the environment.

All of the following scenarios have the potential to threaten human health and the environment.  A hazardous waste generator may describe other site-specific scenarios in their Contingency Plan.  Conversely, a hazardous waste generator may use their Contingency Plan to describe how the unique nature of their hazardous waste and the conditions of its generation, treatment, accumulation, management, and off-site transportation would not be a threat to human health or the environment in certain emergency situations.  Examples include but are not limited to:

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• Any fire involving hazardous waste.
• Any explosion involving hazardous waste.
• Any uncontrolled hazardous waste reaction that produces or has the potential to produce hazardous conditions, including:
  • Noxious, poisonous, flammable, or explosive gases, fumes, or vapors.
  • Harmful dust or explosive conditions.
• Any hazardous waste release – outside of a secondary containment system – that causes or has the potential to cause off-site soil and/or surface water contamination.
• Any hazardous waste release that produces or has a potential to produce hazardous conditions, including:
  • Noxious, poisonous, flammable, or explosive gases, fumes, or vapors.
  • Harmful dust or explosive conditions.

Below are some real-world examples of emergencies that occurred at hazardous waste generators that mandated implementation of the Contingency Plan and notification of State and Federal Authorities:

• The overfill protection device on a hazardous waste tank failed leading to its accidental overfilling with an ignitable (D001) hazardous waste.  The hazardous waste filled the secondary containment area.  The pump used to transfer the hazardous waste from the secondary containment area to a tank sparked creating a fire in the secondary containment area.  CONCLUSION:  A fire occurred involving a hazardous waste.  Emergency coordinator notified, Contingency Plan implemented, State and Federal agencies notified.
• During transfer of a hazardous waste container from its satellite accumulation area to the 90-Day Storage Area (aka: Main Accumulation Area) the container is dropped and a small amount (~1 gal) of hazardous waste reaches a storm water drain before the remainder can be contained.  CONCLUSION:  A hazardous waste release, outside of a secondary containment system that – at a minimum – has the potential to cause contamination of surface waters off-site.  Emergency coordinator notified, Contingency Plan implemented, State and Federal agencies notified.
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  Access to external communication should be immediate

  Hazardous waste personnel suddenly become very ill during the loading of a hazardous waste tank.  The outside of the tank is noticed to be very hot so it is determined that a reaction is taking place inside the hazardous waste tank.  CONCLUSION:  An uncontrolled hazardous waste reaction occurred.  Emergency coordinator notified, Contingency Plan implemented, State and Federal agencies notified.

• Containers of hazardous waste in a storage area of a Treatment Storage and Disposal Facility (TSDF) catch fire.  The fire is quickly extinguished by on-site personnel.   CONCLUSION:  A fire occurred involving a hazardous waste.  Emergency coordinator notified, Contingency Plan implemented, State and Federal agencies notified.
• During a weekly inspection of a hazardous waste accumulation area a leak of hazardous waste from a container into its spill skid is noticed.  Personnel in the area report feeling sick; the area is evacuated.   CONCLUSION:  A release involving a hazardous waste has occurred that despite remaining in secondary containment has produced hazardous conditions (i.e. noxious fumes).  Emergency coordinator notified, Contingency Plan implemented, State and Federal agencies notified.

Sound familiar?  Sound possible?  No matter your hazardous waste generator status, any of the above will require notification to both State and Federal authorities and possibly municipal, county, and/or regional as well.  The regulations specify the information you must be prepared to provide when making these notifications.

That is why during my Onsite Training I encourage generators of hazardous waste to be proactive in their planning and be prepared for reporting of a hazardous waste emergency before it occurs.