Sun 29 Oct 2006
Hazardous Waste Spill Reports [40 CFR 265.196]
There are several requirements for reporting releases of hazardous waste, which differ depending on whether the release came from a tank or a container, the quantity released, and whether the release came from a large or small quantity generator of hazardous waste. Moreover, some states have reporting requirements that are more stringent than the federal EPA requirements. According to 40 CFR 265.196(d), releases to the environment from hazardous waste tanks must be reported to the EPA regional office within 24 hours of detection, unless the release is less than one pound and it was immediately contained and cleaned up. However, if the release amount is at least its Reportable Quantity per 40 CFR 302.4, it must be reported immediately to the National Response Center. Reporting to the National Response Center satisfies the 40 CFR 265.196 reporting requirement.
A somewhat similar reporting requirement applies to both tanks and containers at sites that are large quantity generators. The accumulation time regulations at 40 CFR 262.34 (a)(4) require large quantity generators to comply with 265 Subpart D, which encompasses 265.56(d). This rule states that whenever there is a release, fire, or explosion that could threaten health or the environment outside the facility, the emergency coordinator must immediately notify the on-scene coordinator for the geographical region or the National Response Center.
At sites classified as small quantity generators, according to 40 CFR 262.34(d)(5)(iv)(C), the emergency coordinator must immediately notify the National Response Center in the event of a fire, explosion, or other release which could threaten human health outside the facility or when the generator has knowledge that a spill has reached surface water.
Consider this scenario: A large quantity generator had a release of 4000 lb of methyl ethyl ketone waste, which found its way to a storm drain. The 40 CFR 302.4 RQ is 5000 lb. Must the spill be reported? Yes, because the release to the storm drain could endanger health or the environment off-site. Moreover, such a large quantity would probably have come from a tank and it exceeded the one pound threshold for tanks.
The Compliance Resource Center will create a HazWoper class(40, 24 or 8 hour) specific to your site. We can also write or assist you in writing an On-Site Emergency Response Plan for a hazarodus spill at your site(s). Each plan will be unique for the hazardous waste you have and your facility