DSHW-2024-006625

LQG Overview, Training, Contingency Plans
Judy Moran, Environmental Scientist
[e-mail]
[phone]
Overview
○LQG Requirements
○Small Quantity Generator Training
○Large Quantity Generator Training
○Contractors
○Training Content & Delivery
○Contingency Plans
○How to prevent emergency permits
Obtain an EPA
Identification Number
Biennial
Report/Re-notify
Ship waste in 90 days
LQG
Requirements
R315-262 -17, R315-262 -18,
R315-262 -41
Container Requirements
R315-262 -17
●Compatible with the Waste and In Good Condition
●Keep Containers Closed
●Label Containers with the Words “Hazardous
Waste”
●Mark or label with an Indication of the Hazards of
the Contents
●Not Handle or Store Containers so that They
Might Rupture, Leak or Be Damaged
●Labeling -including accumulation date
●Special requirements for Ignitable & Reactive Waste
●Inspect Weekly
●Preparedness & Prevention
●Emergency Procedures
●Training
LQG Central Accumulation Area
Container Storage
R315-262 -17(a)(5)
50 Feet from Property Line Approved in Writing
Prevent Accidental Ignition or Reaction
•Protect from sources of ignition
•No Smoking signs posted
Conditions for Accumulation of Ignitable
and Reactive Wastes
R315-262 -17(a)(1)(vi)
SQG Training
R315-262 -16(b)(9)(iii)
The small quantity generator shall ensure that all
employees are thoroughly familiar with proper waste
handling and emergency procedures, relevant to
their responsibilities during normal facility operations
and emergencies.
SQG Training Content
1.Site-specific emergency
response training
2.RCRA Hazardous Waste
training
3.DOT HazMat shipping training
-general awareness,
function-specific, safety
Analysis
01
LQG Training
R315-262 -17(a)(7)
●Facility personnel must complete training within 6
months & annual refresher
●Must include hazardous waste management
procedures
●Employees must be able respond to emergencies
Job Title and
Name
LQG Training Plan R315-262 -17(a)(7)
Type and Amount
of Introductory
and Continuing
Training
Job Description
Record of
Training for Each
Employee
Training Contractors
○Contractors working at LQG sites fall under the R315-
260 -10 definition of “facility personnel.”
○At a minimum, train contractors on: evacuation routes,
emergency communications/alarms, and proper
hazardous waste handling procedures.
○See RCRAOnline (RO14180) interpretation leer
Hazardous
waste
management
procedures
Response to
emergencies
Who directs
the training?
Contingency
Plan
implementation
LQG Training
Content R315-262 -17(a)(7)(i)(B)
R315-262 -17(a)(7)(i)(C)
Training Delivery
Train -The -Trainer
○Osite or online commercial training
○Document!
On-The -Job
○Supervised
○Document content,
schedule, and
techniques
Contingency
Plan
Requirements
●Wrien contingency plan not
required
●BMP
●Content of plan in R315-262-
261
●Quick Reference Guide in
R 315-262-262
Small Quantity Generator Large Quantity Generator
Content of Contingency Plan
●Actions in response to incidents [R315-262-261(a)]
●Can use SPCC Plan with additions [R315-262-261(b)]
●Agreements with local responders [R315-262 -261]
●Names and emergency telephone numbers of all
persons qualified to act as emergency coordinator
[R315-262-261(d)]
●Emergency equipment list [R315-262-261(e)]
●Evacuation Plan [R315-262 -261(f)]
Chemical Decomposition & Reactivity Prevention
1.Chemical Inventory
2.Date of Receipt
3.Date When opened
4.Storage Conditions
5.Routine Inspections
6.Routine Disposal
Questions?
Thank you
hps://deq.utah.gov/division-waste-management-radiation -control
Judy Moran
Environmental Scientist
PHONE
[phone]
EMAIL
[e-mail]