==== Wesleyan University, Dept. of Chemistry Hall-Atwater Laboratories Container Storage Area Contingency Plan ====
TABLE OF CONTENTS
1 Introduction 3
1.1 Location 3 1.2 Setting 3 1.3 Description of CSA 5 1.4 Waste Generation 7 1.5 Generator Status 8
2 Purpose of Plan 8
3 Scope 8
4 General Responsibilities 9
5 Emergency Coordinator (EC) 9
5.1 Function & Job Description 9 5.2 Qualifications 9 5.3 List of Emergency Coordinators 10 (See Table 1 for contact info) 15
6 Emergency Response Procedures 9
Procedure #1 Notification of CSA Emergency 21 Procedure #2 Evacuation of CSA Area 22 Procedure #3 Fire in the CSA 25 Procedure #4 Spill in the CSA 27 Procedure #5 Release to the Environment 29 Procedure #6 Power Failure in the CSA 31 Procedure #7 Reporting Emergencies and Releases 32 Procedure #8 Injuries from Chemical Exposure in the CSA 36
7 Post Emergency Recovery 10
7.1 CSA Cleanup Activities 10 7.2 Follow up Reports 11 (See Table 2 for reporting detail) 16
8 Equipment Preparedness Inspections 11
8.1 Description of Emergency Equipment 11 8.2 Emergency Equipment Inventory 12 (See Table 3 for Inventory Checklist form) 17
9 Training Program 12
9.1 Emergency Coordinator Training 12 9.2 Laboratory Instructors and all other Personnel 12
10 Arrangements with Local Authorities 12
10.1 Middletown Fire and Police Departments 12 10.2 Emergency Medical Services 13 10.3 Local Contingency Planning Committee (LEPC) 13 10.4 Spill Cleanup Contractors 13
11 Administration of the Plan 13
11.1 Amendments to the Plan 13 (See Table 4 for Form Letter) 18 11.2 Copies of the Plan 14 (See Table 5 for Address List) 19 11.3 Periodic Plan Reviews 14 (See Table 6 for Plan Review Checklist) 20 11.4 Pertinent References or Documents 14
This is a contingency plan as required under federal Resource, Conservation and Recovery Act (RCRA) regulations and analogous Connecticut hazardous waste regulations, for the Wesleyan University Hazardous Waste Container Storage Area (CSA).
The CSA is located at:
Chemistry Department Hall-Atwater Laboratory, Room 50C Lawn Ave. Middletown, CT 06457
The Hall-Atwater Laboratory is on the campus of Wesleyan University, between Church Street and Lawn Avenue on the north and south, and between High Street and Pine Street on the east and west. The CSA is on the ground floor of the building on the southwest corner of the facility, below the loading dock. The surrounding area contains University classroom buildings, science library, dormitories and residential housing. A map of the area is shown on Figure 1.
Figure 1. Hall-Atwater Laboratory (bldg. 58b) and Surroundings
A diagram of the CSA floor plan is shown on Figure 2. Room 50C is the CSA. A locked chemical storage refrigerator is located in Room 50. It is used as a CSA for hazardous waste that may be unstable at room temp. Room 50 is a foyer used as a staging area for lab packing of wastes by the disposal contractor. The hazardous waste refrigerator is inspected under the CSA protocol and inspection guide. The CSA has exhaust ventilation with floor level pickup (for vapors heavier than air) and explosion-proof lighting and electrical circuits. Fire extinguishers are located in the room 50 complex foyer and in the hall outside room 49. A direct dial phone to Public Safety is located in the hall outside Room 49. The CSA has a CO2 fire protection system. Wastes in the CSA are held for a maximum of 180 days. They are stored on racks with appropriate separation for incompatibles, and may periodically be aggregated from several containers into one. Evaporation of water from inorganic metallic sludge generated in undergraduate chemistry labs is conducted within the CSA as a waste minimization measure.
Figure 2. CSA Floor Plan and Emergency Equipment Locations
University teaching laboratories and research laboratories use a variety of reactants, solvents and other hazardous chemicals or materials. Residual reactants, unused chemicals, or chemicals past their shelf life result in generation of hazardous wastes – mainly waste liquids, spent solvents or organic and inorganic solids or sludge. The Chemistry, Biology, Molecular Biology and Biochemistry Departments (in the Hall-Atwater and Shanklin Laboratories) generate small amounts of such hazardous wastes on a regular basis. Laboratory protocols specify collection of compatible wastes in small satellite accumulation containers at the points of generation in each laboratory, as shown on Figure 3. Except for inorganic acids, which are neutralized and disposed down the sink, all lab-generated wastes are collected and retained in the CSA for pickup and disposal by a licensed hazardous waste contractor.
Figure 3. Laboratory Satellite Accumulation Area Figure 4. Radioactive Waste Decay-Out Room
Figure 5. Biomedical Waste Storage Biomedical and radioactive wastes also are generated by laboratory activities, but these are handled under different procedures and not within the CSA. Radioactive wastes (predominantly P-32 and S-35) are held in a secure decay-out room as shown on Figure 4 for 10 half-lives prior to disposal, to assure that activity has dropped below required levels. Mixed waste is rare, but if it is generated, it is first subject to appropriate decay-out, then transferred to the CSA for disposal.
Biomedical wastes are held in a separate storage area as shown on Figure 5, for pickup and disposal by a licensed biomedical waste contractor. Spills or other emergencies involving radioactive or biomedical wastes are subject to regulations other than RCRA, are handled under different procedures, and therefore are not covered in this RCRA contingency plan.
Several other University departments (Center for the Arts, Earth Sciences, Physical Plant) occasionally generate small quantities of RCRA hazardous waste, which are collected and aggregated in the CSA.
Wesleyan is classified as a small quantity generator (SQG) of RCRA hazardous wastes, but may infrequently exceed the threshold for a generator, due to clean out of obsolete chemicals that fall under the acute hazardous waste category. This occurs, for example, when a professor retires or leaves Wesleyan employment, and leaves behind small amounts of chemicals used in their specific line of research which are not useful to other researchers and must be disposed. On occasion, such acute hazardous wastes total more than one kilogram, thus episodically elevating the University into large quantity generator status. This contingency plan is intended to cover that episodic situation, in addition to the more normal hazardous waste disposal quantities, which are at the SQG level.
The purpose of this contingency plan is to minimize possible hazards to human health or the environment due to fire, explosion or release of RCRA hazardous wastes from the CSA to the interior of the Hall-Atwater building, or to the air, soil or water (via catch basins) outside.
This plan covers RCRA hazardous wastes held in the CSA (Hall-Atwater Room 50C), and emergency preparedness and response actions to be taken by Wesleyan personnel in the event of a fire, explosion or release escaping the CSA. It does not cover:
There is one primary Emergency Coordinator (EC) and two alternates. The primary EC is responsible for this plan. The EC on duty or on call at the time of the emergency is responsible for implementing this plan. All other laboratory staff personnel in the various Departments are responsible for reacting to an emergency according to the procedures prescribed in the plan, and for evacuating themselves and their students from areas near the CSA if directed by the EC, or if a hazardous condition is apparent.
In the context of the OSHA requirements, the EC (including alternates) is classified as a Hazmat Technician Level, and all other personnel are classified as a First Responder - Awareness Level.
The EC, acting at the time of the emergency, is in charge of all initial actions taken to respond to the emergency. Each EC carries a pager, and Wesleyan Public Safety has the pager numbers. The EC contains the release, keeps it from spreading, and prevents exposures. He has the authority to commit Chemistry Department resources to the degree needed to deal with the emergency. He continues in this role until the Fire Department arrives. He then relinquishes his control to the Incident Commander for the Fire Department (the senior fire official on the scene), and acts as liaison to the Incident Commander for information and advice.
The primary EC administers the plan, conducts periodic reviews of the plan to keep it current, and makes periodic inspections of emergency equipment to ensure everything needed in an emergency is available and operable.
EC’s also train laboratory staff personnel in basic emergency response actions at the First Responder - Awareness Level, during the annual safety training. The training materials for laboratory staff personnel are found in the Environmental Health and Safety Office room HA066.
Each EC must be familiar with the CSA and adjacent building layout, laboratory operations and activities generating hazardous wastes, the location and chemical nature of the wastes stored in the CSA, and their behavior in a fire. They must have at least two years experience in the safe handling of hazardous materials. They must have a respirator, be properly qualified in its use, and be fit-tested annually.
In addition to this general background, each EC must have 24 hours of initial training in hazardous materials incidents to qualify at the Hazmat Technician Level. After this initial training, they must have 8 hours of refresher training each subsequent year to maintain proficiency.
There is one primary Emergency Coordinator, and two qualified alternates, as listed on Table 1 (page 15).
There are eight individual response procedures (pages 21-36) covering different emergency events. These procedures are attached to this plan, and are part of it. Each is kept to simple 1-page instructions per emergency event, for clarity in training and for simplicity if the plan has to be implemented.
Emergency Coordinator After the emergency has been controlled, the EC will undertake the following cleanup activities as appropriate:
Activating this contingency plan or having an actual release to the environment triggers several follow-up reporting requirements. . Send the letters to the agencies as listed in Table 2 (page 16), as appropriate.
Fire protection within the CSA is provided by an automatic overhead CO2 sprinkler system. A fire alarm sounds if the system activates. A status (pressure) indicator for the system is present. The system is inspected by the EC on a monthly basis and by the University’s insurance carrier annually.
Portable fire extinguishers (dry chemical, CO2 and Halon) are placed at selected locations around the CSA area as indicated on Figure 2. These are inspected monthly by the EC, and recharged or replaced annually by a contracted service.
Crash carts with absorbent materials, pads, pillows and socks, and a diversionary boom, are kept in multiple locations in the Hall-Atwater building. They are checked monthly and supplies are replenished as needed.
Durable personal protective equipment (full-face respirators and safety glasses) is maintained by the EC to whom issued. Disposable equipment (protective clothing and gloves) sufficient to handle a CSA emergency is kept in the spill kit outside Room 50 as well as a working copy of this plan. Extra personal protective equipment is available in the Sciences Stock Room located in Hall-Atwater room 054.
There is an emergency telephone that connects you directly to Public Safety upon lifting the receiver. It is located outside Room 50 and is checked monthly by the EC for operability.
A list of the emergency equipment is provided in Table 3 (page 17). This table is also the checklist used by the EC for monthly inspections.
All training for proper personnel response to an emergency in the CSA is specified in the Emergency Response Training Program. Briefly, the program consists of specific levels of training based on need to know. All training is documented, and records are retained.
The primary and alternate EC’s receive at least 24 hours of initial training from an outside consultant, school, course or other source qualified to teach hazardous materials emergencies. The degree of this training is consistent with the OSHA requirements for First Responder – Hazmat Technician Level. EC’s also receive 8-hour refresher training annually as needed to maintain currency. Records of training are kept in the Environmental Health and Safety Office room HA066.
Other University personnel engaged in laboratory work that generates hazardous wastes into the CSA are trained annually. This training corresponds to the OSHA First Responder - Awareness Level and is conducted by EC’s. Newly hired laboratory staff personnel and technical assistants receive this training along with basic laboratory emergency response training before being allowed to work unsupervised in any laboratory. Records of training are kept in the Environmental Health and Safety office room HA066.
Public Safety is notified of an emergency by dialing 911 or 3333 on campus phones. Public Safety may call in the Middletown Police Department and/or Fire Department as appropriate. Both these departments have been given a copy of this contingency plan.
An ambulance is called by Public Safety, on request of the Emergency Coordinator. The ambulance service is Hunter Ambulance. The service has been given a copy of this contingency plan.
The Middlesex Memorial Hospital in Middletown is the designated medical emergency room for serious injuries. The hospital has been given a copy of this contingency plan.
No emergency operations are conducted by the Middletown LEPC over and above those conducted by the Fire and Police Departments. However, notifications and preparedness planning are LEPC functions, and the Middletown LEPC has been given a copy of this contingency plan.
Hazardous materials spill cleanup contractors are available on emergency notice via the DEP or Fire Department. The university on-call Contractor for spill cleanup is American Environmental Technologies, Inc. (AET) Bethel CT. 800-562-7611. The company has been given a copy of this contingency plan.
The plan is amended when:
Minor revisions to pages are indicated by a letter after the revision number (e.g., Revision 2a), with the date of the change. Major revisions of the entire plan are given the next sequential revision number. Copies of revised pages or the entire revised plan are mailed to all holders of the plan (return receipt requested), with instructions on how to make the changes. The instruction / transmittal form is provided as Table 4 (page 18).
The agencies receiving copies of this contingency plan and changes thereto are listed in Table 5 (page 19).
The plan is reviewed annually by the primary EC for any need to amend or update it, using the checklist shown in Table 6 (page 20). Each change notice sent out to plan recipients asks them to send in any changes they have made within their own organizations or operations that should be reflected in the plan.
This plan is written to conform to the requirements of various state and federal regulations dealing with hazardous materials and hazardous wastes. These requirements (and interpretations thereof) are not part of this plan, but are maintained separately by the EC for reference.
The following additional references were used in the preparation of this plan:
Table 1 LIST OF EMERGENCY COORDINATORS (EC)
ATTENTION ALL CHEMISTRY DEPARTMENT STAFF: IF THERE IS AN EMERGENCY AFTER NORMAL WORKING HOURS, DIAL 911 or 3333. THIS CONTACTS THE WESLEYAN PUBLIC SAFETY DISPATCHER. THEY WILL LOCATE THE EMERGENCY COORDINATOR ON CALL.
Public Safety Dispatcher: Page a Chemistry Department Emergency Coordinator in the sequence below, until one responds. Call office or home phone numbers if there is no response to the page.
|Name||Pager||Office Phone||Home Phone||Home Address|
|Don Albert||860-279-7201||860-685-2729||860-345-4367||Morris Hubbard Road Higganum, CT 06441|
|Jeff Gilarde||860-279-7208||860-685-3473||860-267-7601||P.O. Box 321 Cobalt, CT 06414|
|Bill Nelligan||860-842-2599||860-685-2732||860-434-7089||22 Blood StreetLyme, CT 06371|
Table 2 LIST OF AGENCIES FOR EMERGENCY FOLLOWUP LETTERS
|Agency Getting Letter||Deadline for Letter||Content of Letter||For Details See|
|DEP, copy to LEPC and SERC||Within 24 hours||• Prescribed DEP form (see Figure 9)||CGS 22a-450|
|LEPC, copy to SERC and NRC||“as soon as practicable” after release •||Facility/respondent identification• Date, time, type of incident• Response actions taken• Health risks from release• Medical treatment needed||40 CFR 355.40 (b)(3)|
|DEP, copy to EPA Region 1||Within 15 days||• Facility/respondent identification• Date, time, type of incident• Name/quantity of material• Extent of any injuries• Assessment of actual or potential hazards to health or environment• Quantity/disposition of recovered material• Statement that emergency plan was implemented||40 CFR 265.56(j);22a-449©-105(a)(2)|
|EPA Region 1, copy to DEP||Before resuming operations||• Facility/respondent identification• Date, time, type of incident• Cleanup is complete• No incompatible hazardous wastes are stored together• The plant emergency equipment is all back in operation||40 CFR 265.56(i)|
Note 1: LEPC = Local Emergency Planning Committee DEP = Department of Environmental Protection NRC = National Response Center SERC = State Emergency Response Commission
Note 2: The DEP 15-day letter can also satisfy the LEPC / SERC / NRC requirement. Make sure the regulation is properly referenced and the information is complete.
Table 3 CSA EMERGENCY EQUIPMENT INVENTORY AND MONTHLY CHECKLIST
|Item||Description / Function||Location||StatusOK NOK||Date Inspected||By|
|CO2 system||Kidde CO2 / Fire Suppression System||Ceiling valves, cylinders Rm. 50||q q|
|First aid station||First Aid Kit / Basic first aid||Inside “Spill response box” outside Rm. 49||q q|
|Spill cleanup kit||Kit of various absorbent materials, including booms, pads etc. / spills||In “Spill response box” outside rm. 49||q q|
|Alternate #1 Spill cleanup kit||Kit of various absorbent materials, including booms, pads etc. / spills||Crash Cart, gr.fl. Inside Rm. 31|
|Alternate #2 Spill cleanup kit||Kit of various absorbent materials, including booms, pads etc. / spills||Inside “Spill Response Box”,1st fl. Loading dock|
|Portable Fire Extinguisher||CO2 20lb / Fire Suppression||Wall Mount in rm. 50||q q|
|Portable Fire Extinguisher||CO2 20lb / Fire Suppression||Wall Mount Outside rm. 49||q q|
|Emergency Phone||Direct line to Public Safety / 911||Wall Mount Outside rm. 49||q q|
Table 4 CONTINGENCY PLAN TRANSMITTAL FORM LETTER
|To:||——————||Transmittal #: ———||————–|
Re: Revision to Wesleyan University Hazardous Waste CSA Contingency Plan
|—–||Please insert into your copy of the Contingency Plan the enclosed page(s) marked Revision ——, and remove and discard the pages they replace.|
|—–||Please discard your entire copy of the Contingency Plan, and replace it with Revision —— enclosed.|
Please sign the receipt below and return it to us to indicate you have received the material. Thank you.
|To:||Donald Albert Chemistry Department Wesleyan University Middletown, CT 06457|
I have received your transmittal number ——-,dated ———-,providing revisions to the Wesleyan University Hazardous Waste CSA Contingency Plan.
———————— —————————- ——————- Print Name Signature Date
Table 5 LIST OF AGENCIES RECEIVING THE PLAN
|Wesleyan Public Safety||208 High Street Middletown, CT. 06459 Attn: Director of Public Safety|
|Middletown Police Department||Office of Emergency Coordinator Cross Street Middletown, CT. 06457|
|Middletown Fire Department||Middletown Fire Marshall Middletown Fire Headquarters 533 Main St. Middletown CT. 06457|
|Middletown LEPC||Local Emergency Planning Committee C/O Middletown Fire Dept. 533 Main Street Middletown, CT. 06457|
|Hunter’s Ambulance Service||Emergency Coordinator Washington Street Middletown, CT 06457|
|Middlesex Memorial Hospital||Emergency Coordinator Middlesex Hospital 28 Crescent Street Middletown, CT. 06457|
|American Environmental Technologies(Spill Contractor)||2666 State Street Hamden, CT. 06517 Attn: Ellen Lucas|
Table 6 ANNUAL CONTINGENCY PLAN REVIEW CHECKLIST
Date of this review: ———- Reviewer: ———-
|CRITERIA (Did any of these occur in the past year?)||CHANGE Yes No|
|The list of Emergency Coordinators changed, or other key contact changed. This includes phone and address changes, as well as names of personnel.||– –|
|The list of emergency equipment changed.||– –|
|The plan failed in an emergency.||– –|
|The regulations governing the scope and extent of the plan were revised.||– –|
|A significant change was made in the physical layout of a process or a portion of the plant.||– –|
|A change was made in plant operations or maintenance practices that substantially increases the risk or extent of an emergency.||– –|
|A circumstance arose that could increase the risk or extent of an emergency.||– –|
—— There are no changes since the last emergency plan review.
—— Changes have occurred, and the plan must be modified as follows:
Emergency Response Procedure 1 NOTIFICATION FOR A CSA EMERGENCY
Emergency Coordinator (EC)
Emergency Response Procedure 2 EVACUATION OF THE CSA AREA
Emergency Coordinator (EC)
Laboratory Staff Personnel
Figure ERP2-1. Interior Evacuation Routes from CSA Area
Figure ERP2-2: Rally Points for Evacuation from CSA Area
Emergency Response Procedure 3 FIRE IN THE CSA WITH POSSIBLE OR ACTUAL CONTAINER INVOLVEMENT All Personnel
Emergency Coordinator (EC)
Laboratory Staff Personnel
Emergency Response Procedure 4 SPILL CONTAINED INSIDE THE CSA
Emergency Coordinator (EC)
Laboratory Staff Personnel
Emergency Response Procedure 5 RELEASE TO THE ENVIRONMENT All Personnel
Emergency Coordinator (EC)
Emergency Response Procedure 6 POWER FAILURE IN THE CSA AREA All Personnel
Emergency Coordinator (EC)
Emergency Response Procedure 7 REPORTING EMERGENCIES AND RELEASES
Emergency Coordinator (EC)
|Type of Emergency||LEPC 911 (Dispatch)||DEP 424-3338||NRC 1-800-424-8802||SERC 424-4856|
|Fire with no hazardous material/waste involvement||Immediately call Middletown 911 if help is needed. If not, report to non-emergency number as a courtesy.|
|Fire or explosion involving hazardous materials/wastes||Mandatory immediate report||Mandatory immediate report, if any release gets outside building (including airborne)||Mandatory report within 24 hours, if any release gets outside building and exceeds reportable quantity (RQ)||Mandatory immediate report, if any release gets outside building (including airborne)|
|Large spill, but totally contained inside CSA or building||Discretionary immediate report (activated Emergency Plan)||Discretionary immediate report (report if release is possible)|
|Release of hazardous materials/wastes to environment||Mandatory immediate report||Mandatory immediate report||Mandatory report within 24 hours, if release exceeds reportable quantity (RQ)||Mandatory immediate report|
What to Say Example Entries
Emergency Response Procedure 8
INJURIES FROM CHEMICAL EXPOSURES IN THE CSA