Contingency Plan

Table of Contents

1. Purpose, Applicability and Implementation 4

1.1 Purpose (262.260(a)) 4

1.2 When the Plan Is Carried Out (262.260(b)) 4

1.3 Applicability (262.250 and 262.17(a)(6)) 4

1.4 Relationship to the SPCC Plan and Other Plans (262.261(b)) 4

1.5 Facility Description 5

2. Hazardous Wastes Handled 5

3. Preparedness and Prevention 6

3.1 Maintenance and Operation of the Facility (262.251) 6

3.2 Required Equipment (262.252) 6

3.3 Testing and Maintenance of Equipment (262.253) 7

3.4 Access to Communications or Alarm System (262.254) 7

3.5 Aisle Space (262.255) 8

4. Arrangements with Local Authorities (262.256 and 262.261(c)) 8

5. Emergency Coordinators (262.261(d) and 262.264) 9

5.1 Emergency Coordinator List 9

5.2 Coverage at All Times (262.264) 9

5.3 Qualifications and Authority (262.264) 10

5.4 Emergency Coordinator Duties 10

6. Emergency Procedures — Emergency Coordinator Checklist (262.265) 10

6.1 Step 1 — Alarm and Call for Help (262.265(a)) 10

6.2 Step 2 — Identify the Release (262.265(b)) 10

6.3 Step 3 — Assess Hazards (262.265(c)) 11

6.4 Step 4 — Required Notifications (262.265(d); 40 CFR 302.6; EPCRA 304) 11

6.5 Step 5 — Contain and Prevent Spread (262.265(e)) 12

6.6 Step 6 — Monitor Shut-Down Equipment (262.265(f)) 12

6.7 Step 7 — Recovered Waste After the Emergency (262.265(g)) 13

6.8 Step 8 — Before Restarting (262.265(h)) 13

6.9 Step 9 — Record and Report (262.265(i)) 13

6.10 Contents of the 15-Day Written Report (262.265(i)) 13

7. Evacuation Plan (262.261(f)) 13

7.1 Alarm Signals 14

7.2 Assembly Areas 14

7.3 Evacuation Routes and Alternate Routes 14

8. Emergency Equipment List (262.261(e)) 15

8.1 Communications and Alarm Systems 15

8.2 Fire Protection and Water Supply 16

8.3 Spill Control Equipment 16

8.4 Monitoring, Protective and Decontamination Equipment (ERT Room by the Control Room) 19

9. Plan Copies, Review and Amendment 19

9.1 Copies and Quick Reference Guide (262.262) 19

9.2 Amendment (262.263) 20

9.3 Training (262.17(a)(7)) 20

Appendix A — Incident Log (Operating Record Entry, 262.265(i)) 22

Appendix B — 15-Day Written Report Template (262.265(i)) 24

Appendix C — Facility Diagram 25

Appendix D — Quick Reference Guide for Responders (262.262(b)) 26

SECTION 1Purpose, Applicability and Implementation

1.1 Purpose (262.260(a))

This plan is designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water. Lake Tiberius, a navigable water, borders the campus to the south, and all campus storm inlets drain to it through Outfall 001.

1.2 When the Plan Is Carried Out (262.260(b))

The provisions of this plan are carried out immediately whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents which could threaten human health or the environment. The Emergency Coordinator decides whether an event meets that test. When in doubt, the plan is carried out.

1.3 Applicability (262.250 and 262.17(a)(6))

As a large quantity generator, Perry Industries must comply with Subpart M as a condition of accumulating hazardous waste without a permit (262.17(a)(6)). Subpart M applies to the areas of a large quantity generator where hazardous waste is generated or accumulated on site (262.250). Satellite accumulation areas operated by a large quantity generator must also meet Subpart M (262.15(a)(8)). This plan covers:

Building C (Honey Badger Logistics) does not generate or accumulate hazardous waste and is not covered, except that its employees follow the Campus EAP signals.

1.4 Relationship to the SPCC Plan and Other Plans (262.261(b))

40 CFR 262.261(b) allows a generator that already has an SPCC Plan under 40 CFR part 112, or some other emergency or contingency plan, to amend that plan to incorporate hazardous waste management provisions sufficient to comply with Part 262, and allows one contingency plan that meets all regulatory standards.

Perry Industries keeps this contingency plan as a separate document that cross-references the Building B SPCC Plan (262.261(b)). Together with the plans below it covers Building B as follows:

Where the plans overlap, this plan governs anything involving hazardous waste. A single event can trigger more than one plan, such as a fire in the HWA that also reaches oil; the EC carries out every plan that applies.

1.5 Facility Description

Perry's Awesomeness Factory (Building B) is the chemical plant on the Perry Industries campus, 1 Perry Parkway, New Mos Eisley, on the north shore of Lake Tiberius. A residential neighborhood lies across Perry Parkway to the north, about 400 ft from the flammable tank farm. The flammable tank farm (T-1 Thunderbolt, T-3 mineral oil) is northeast of Building B; Polyjuice Base (T-2, 25% aqueous ammonia) is in a separate diked ammonia storage area east of Building B. Neither holds hazardous waste. Building B runs two shifts Monday through Friday (days 6:00 a.m.–2:30 p.m., about 42 people; nights 2:30 p.m.–11:00 p.m., about 28 people). On weekends 1 operator and 1 security officer are on site. Security staffs the Gate 2 house 24 hours a day. The facility diagram is in Appendix C (Figure C-1, Drawing PI-B-101).

SECTION 2Hazardous Wastes Handled

The facility does not generate acute hazardous waste. No hazardous waste is treated on site. All waste is shipped off site on manifest by Sheaves Environmental Response within 90 days.

Incompatible materials near the HWA

Ignitable D001 waste and corrosive D002 waste are kept apart in the HWA. The D002 tank sits inside its own curbed containment so a leak cannot reach the D001 drums. Alkaline caustic waste is listed as potentially incompatible with acids and reactive metals in Appendix V to Part 265. No acids or acid wastes are kept in Building B.

SECTION 3Preparedness and Prevention

3.1 Maintenance and Operation of the Facility (262.251)

The facility is maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water. Practices that do this include:

• Containers kept closed except when adding or removing waste; drums on containment pallets; labeled and dated.
• Weekly inspection of the HWA container area (262.17(a)(1)(v)), recorded by Dana Scully or her designee.
• Daily inspection of tank TK-HW1, its overfill controls, monitoring data and containment (265.195, via 262.17(a)(2)); see Section 3.3.
• No smoking, open flames or hot work in or near the HWA without a hot work permit. "No Smoking" signs posted at the HWA (262.17(a)(1)(vi)(B)).
• Drums of D001 grounded and bonded during transfer. Non-sparking tools in SK-1 (main aisle just outside the R-101 room door) and SK-5.
• D001 drums are kept at least 50 ft from the property line (262.17(a)(1)(vi)(A)).
• D002 tank TK-HW1 has a high-level alarm, a level gauge and curbed secondary containment.
• Floor drains in the HWA are sealed. Storm inlets SI-1 and SI-2 have drain covers staged at SK-2, SK-4 and SK-6.
• Spill kits SK-1 to SK-20 are stocked to the inventory in Section 8, inspected monthly with the SPCC checklist, and restocked after every use by Montgomery Scott (Building B), Arthur Dent (Building A) and Ellen Ripley (Building C).

3.2 Required Equipment (262.252)

The complete equipment list with location, physical description and capabilities is in Section 8 (262.261(e)).

3.3 Testing and Maintenance of Equipment (262.253)

Equipment found defective is tagged out and repaired or replaced right away. Records are kept in the operating record.

3.4 Access to Communications or Alarm System (262.254)

• Whenever hazardous waste is being poured, mixed, transferred or otherwise handled, everyone involved has immediate access to an alarm or emergency communication device: the HWA pull station and wall phone, a plant radio, or voice or visual contact with another employee who has one (262.254(a)).
• If only one employee is on the premises while the facility is operating, that employee carries a plant radio and a cell phone able to call 911 (262.254(b)). On weekends both the operator and the security officer carry radios. Still bottoms are drummed at the end of the Friday night shift batch and moved to the HWA by the night shift before leaving; no hazardous waste is handled on weekends except in an emergency.

3.5 Aisle Space (262.255)

Aisle space is kept in the HWA to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment and decontamination equipment to any area of facility operation in an emergency. Facility practice: drums are stored no more than two pallets deep with an aisle of at least 3 ft between rows, the main HWA aisle and the HWA doorways are kept clear, and nothing is stored within reach of the extinguisher, eyewash or pull station. Aisle space is checked on the weekly HWA inspection.