A Survey of Emergency Response Planning as Practiced in Boiler/industrial Furnace Facilities Burning Hazardous Waste Derived Fuels

By Johnson, David L.; Sullivan, Susan P. et al. | Journal of Environmental Health, July-August 1996 | Go to article overview

A Survey of Emergency Response Planning as Practiced in Boiler/industrial Furnace Facilities Burning Hazardous Waste Derived Fuels


Johnson, David L., Sullivan, Susan P., Jones, Glen W., Journal of Environmental Health


Introduction

The Oklahoma Department of Environmental Quality is the permit-granting authority for construction and operation of hazardous waste treatment, storage, recycling, and disposal facilities within the state. State regulations require existing facilities wishing to begin hazardous waste handling to submit an emergency response plan as part of their permit application (1). This requirement is in addition to and different from the federal requirement that facilities handling specific quantities of hazardous waste submit a contingency plan with their application (2,3).

Emergency response plans and contingency plans are not the same. Contingency plans are designed to specify industry procedures for incidents that occur within the fence line of a facility, while emergency response plans extend beyond the fence line into the surrounding community. Emergency response plans as defined in the Oklahoma regulations include the provisions of federally-mandated contingency plans, in keeping with the primacy policies of the United States Congress and the permitting policies of the United States Environmental Protection Agency. The objective of the Oklahoma regulations was, in essence, to extend the scope of planning to ensure a community-specific emergency response at each facility.

Emergency response plans as defined in the Oklahoma regulations are broader in scope than contingency plans required by federal regulations. They must be designed to minimize hazards to health and property (environment) of each parcel of land owned by affected property owners within one mile of the proposed permit boundary, and a submitter must obtain approval of the plan by a majority of the affected property owners. (An exception involves operational Boiler/Industrial Furnace [BIF] facilities which propose to begin receiving hazardous wastes from off-site for treatment, storage, recycling, or disposal. These facilities - which include cement kilns proposing to begin burning hazardous waste derived fuels [HWDF] such as waste solvents - are not required to obtain prior approval from affected property owners.) The plan must be submitted as part of the permit application and is subject to public comment during the permit process. In developing specific guidelines to be used by permit applicants in structuring their plans, and by application reviewers in evaluating the plans, a study was conducted to identify current emergency response planning practices. A component of the study was a national survey of emergency response plans for BIF facilities burning HWDF.

Survey Methods/Approach

The survey focused on identifying emergency planning requirements and state-of-the-art practices for BIF facilities burning HWDF. Twenty-eight operational (permit-approved or interim status) facilities burning HWDF were identified from industry publications, and were contacted by telephone and in writing to request copies of their emergency response plans and any associated risk assessments. The documents subsequently provided were reviewed in detail with special attention to provisions for the prevention and assessment of potential hazards to adjacent communities, and the associated response actions. Provisions related to hazards arising from spills, fires, and explosions were of primary interest. Planned or unplanned releases from process combustion gases were beyond the scope of the study and were therefore not considered.

Emergency plan elements of the reviewed documents were categorized as "General Requirements," "Emergency Procedures," "Post-Emergency Procedures," and "Items Observed in Plans but not Discussed in Regulatory Guidelines." In developing guidelines for plan content, these elements were further categorized as (1) "Must Have," i.e., mandated by a state or federal regulatory requirement, (2) "Should Have," i.e., a "standard practice" provision commonly seen in permit-approved and interim status BIF facility plans, or recommended by several sources or by a regulatory agency, or (3) "Could Have," i. …

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