"Contingency plan" is the term used by RCRA to describe a particular RCRA-required document that sets out how treatment, storage, and disposal facilities (TSDFs) and certain generators of hazardous waste will respond to an emergency at their facilities.
A RCRA contingency plan is one of many emergency plans a facility may be required to keep, but it does not represent the sum total of all emergency response planning required of a TSDF or generator. Consequently, a TSDF or generator may be required to comply with one or more of these other plans. Other standards in relation to emergency situations may also have to be followed. For example, TSDF owners and operators (and hazardous waste generators) must also complete a TSDF "preparedness and prevention plan," which details what response equipment and personnel will be available in the event of a fire, explosion, or release.
The Integrated Contingency Plan
The National Response Team (NRT) (with the EPA as the chair) developed a guidance document for consolidating the multiple plans that facilities are required to prepare into one functional emergency response plan or "integrated contingency plan" (ICP or One Plan). NRT‘s ICP Guidance outlines how you can consolidate several or all of the multiple plans you many need to keep into one plan and how to demonstrate compliance with the applicable regulations.
One Plan is Optional
If you are an owner/operator of a facility of oil and hazardous substances, you know there are often multiple and overlapping federal requirements for facility emergency response plans. NRT developed the Integrated Contingency Plan (One Plan) Guidance to provide a mechanism for consolidating into one functional emergency response plan, or "integrated contingency plan," the multiple plans that various federal regulations require facilities to prepare. Use of the One Plan is purely optional. Facilities can continue to maintain multiple plans to demonstrate federal regulatory compliance; however, the NRT and EPA believe that an integrated plan prepared in accordance with the One Plan Guidance document is a preferable alternative.
The One Plan Guidance document does not address state emergency response planning requirements to which a facility may be subject. You should coordinate development of your facility’s One Plan with relevant state and local agencies to ensure compliance with applicable state regulations.
One Plan Philosophy
The intent of the One Plan is to minimize duplication in preparing and training staff on using several emergency response plans. The One Plan Guidance document is designed to save time and money. It provides a facility with an alternative way to meet the emergency response requirements under nine different federal regulations and five federal agencies. Although the One Plan Guidance document does not relieve facilities from their current regulatory obligations, it has been designed specifically to help meet those obligations. NRT believes that using the One Plan concept yields many advantages, including:
- Eliminating confusion for facility first responders who often must decide which of their plans is applicable to a particular emergency
- Providing a highly functional document for use in varied emergency situations while providing a mechanism for complying with multiple agency requirements
- Improving coordination between facility response personnel and local, state, and federal emergency response personnel
- Facilitating integration within a facility in the event that facilities may need to prepare separate plans for distinct operating units
Tomorrow’s Advisor will have detailed tips for putting your ICP together.
Pros & Cons
I’ve been talking to many Enviro.BLR.com subscribers lately about how they manage their emergency response plans and have been hearing the opposite! Many of these EHS managers are converting their ICP’s back to individual, stand-alone emergency plans because it makes for a long, confusing document that is, in fact, more difficult to keep updated.
Maintaining an ICP in theory sounds like a time-saver, but is it really in practice?