Contingency Plan for spills and fires in hazardous waste operations

This Contingency Plan describes conditions and procedures pertaining to accidents involving hazardous waste storage and processing at Fort Lewis College.

 

By virtue of the small quantity of hazardous waste generated each month, Fort Lewis College is entitled under EPA rules to operate as a Conditionally Exempt Small Quantity Generator (CESQG).  This determines the emergency response and training requirements for the hazardous waste handling.  (While a contingency plan is not formally required for a Conditionally Exempt Small Quantity Generator, such planning is believed to be of vital importance to the safety of Fort Lewis College.)

 

Chemical Storage Building (CSB): 

This plan pertains to the room in the Chemical Storage Building that serves as the accumulation and storage facility for the campus.  (A small closet (Art Hall 174) serves as a satellite collection area for the Art Department.  This satellite site is used primarily for the temporary storage of waste paper towels from the paint studios.  No flammable liquids are stored therein.  No contingency plan is needed for this satellite.) 

 

The CSB is a one-room steel building manufactured by Safety Storage, Inc. and installed in 1999.  It is fully dry-sprinklered (annual maintenance schedule) with thermal link triggers, is alarmed into the central campus system, and is ventilation limited.  It contains no explosives.  A dormitory is located approximately 50 ft. away.  The only utilities present are electricity and water.  There is no storm sewer in the vicinity.  Normal waste operations involve only the Hazardous Materials Manager.  Egress from the CSB is by three double doors, so an occupant is at all times within 10 ft. of egress.  Standard practice is to work with nearest exterior door either open or unlatched as emergency exit.  There is no phone service in the building;  standard practice is to carry a ready-to-use cell phone on-person whenever chemical work is underway.  The CSB is equipped with a 16 lb. ABC Class II fire extinguisher (annual maintenance schedule), an emergency eyewash, sparkless electrical service and a manually-controlled ventilation fan.

 

Emergency Response by Campus Personnel

1.  Spills in the CSB:  The CSB is completely protected by a self-contained sump pit to receive all spills.  Absorbent spill clean-up materials are present on-site, with all used clean-up materials handled as regulated waste.  Any spill that breaches the built-in CSB containment will be referred to the Durango Fire and Rescue Authority (DFRA) Haz Mat Team for control of public risk and to licensed spill clean-up contractors if the clean-up is beyond the scope of campus personnel.

 

2.  Spills away from the CSB:  All transport of hazardous waste from generator sites to the CSB is done under supervision of the Hazardous Waste Manager, so that transport spills are under his direct supervision.  Secondary containers and a spill clean-up kit (with 2 gallon capacity) are used as appropriate.   All used clean-up materials are handled as hazardous waste.

 

3.  Personal Injury:  Use of appropriate Personal Protection Equipment is standard practice.  This includes cartridge respirator, chemical splash goggles, gloves, face shield, and protective clothing.  First response for a splash emergency is FLC Public Safety accessed by 911 dispatch.  

 

Local Emergency Response:

 Primary Coordinator is FLC Public Safety via 911.

1.  Fire:  First Response is FLC Public Safety and DRFA.  DFRA personnel have thoroughly inspected the CSB for fire and haz mat response and consulted with college authorities about appropriate responses.  The College recently submitted a request for a DFRA pre-planning site evaluation.  This pre-plan will include detailed written provisions for safety response, including HVAC shutdown, for the nearby dormitory. 

    
Current DFRA strategy for fire fighting is to leave the building closed and use a water spray to cool the building and knock down any smoke/fume plume.  The post-fire plan is to secure the site and seek assistance from  licensed spill clean-up contractors if the clean-up is beyond the scope of campus personnel.

 

2.  Personal Injury:  First response is FLC Public Safety and DFRA via 911.

 

Response provided by FLC Hazardous Materials Management:  Hazardous Materials Management is staffed at the .25 FTE level, with call-in every 24 hours to provide non-emergency response and consultation. This position does not provide the 24/7 emergency coordination that would be required of a Small or Large Quantity Generator.

FORT LEWIS COLLEGE      1000 RIM DRIVE DURANGO, COLORADO 81301      (877)FLC-COLO(TOLL FREE)      ADMISSION@FORTLEWIS.EDU