Authored by John D. Cain and Cherie N. McKenna in April 2019, the paper summarizes how the Hazardous Waste Generator Improvements Rule reorganized and revised contingency-plan and emergency-response rules under 40 CFR §262.16 (SQGs) and §262.17/Subpart M (LQGs).
Key flexibilities include eliminating the need to list home addresses of emergency personnel, allowing “staffed position” titles for continuous operations, clarifying equipment placement and “immediate access,” expanding posting options and contractor cleanup authority for SQGs, and confirming that satellite accumulation areas and points of generation fall under preparedness requirements.
Arrangements with local responders need only be attempted and documented (by letter, fax, or email in the operating record), with the LEPC treated as a secondary contact and a possible waiver available for facilities with their own 24-hour response capability.
The most notable new mandate is the Quick Reference Guide (QRG) that LQGs must prepare and submit to local emergency responders; new LQGs create it with their contingency plan, while existing LQGs create it when they next amend the plan. The QRG must list wastes and hazards in plain language, maximum quantities, special medical needs, facility and street maps, water supplies, alarm systems, and 24/7 emergency contacts.
The paper cautions that the QRG, combined with expanded SAA coverage, will require LQGs to update and resubmit the guide whenever a satellite accumulation area is added, removed, or relocated, adding ongoing administrative burden amid uneven state adoption of the rule.
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