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August 20, 2010
A Guide to the Environmental and Hazardous Materials Transportation Plans You NEED to Have

Overview

Written environmental, health, and (EHS) plans are required under many workplace safety and health, environmental, and transportation regulations.

Environmental Protection Agency (EPA) requirements. EPA regulations require more than 60 types of written plans in at least 25 categories of activities, from asbestos management plans to underground injection closure plans. Many of the EPA-required plans apply to a relatively small universe of facilities, such as underground injection plugging and abandonment plans. Many of the plans are site-specific or permit-specific. However, several types of plans are required for a large number of industries and facilities, including oil spill prevention and stormwater control. Here are the EPA-required plans that affect the most facilities:

  • Hazardous Waste Contingency Plan
  • Oil Spill Prevention, Control and Countermeasure (SPCC) Plan
  • Stormwater: Industrial Stormwater Pollution Prevention Plan (SWPPP)
  • Hazard Communication (HazCom) Plan
  • HAZWOPER: Site-Specific Safety and Health Plan

Department of Transportation (DOT) hazardous materials transportation requirements. DOT requires written communication plans and a written security plan for companies that transport certain hazardous materials and written prevention and response plans for oil transporters.

Subscriptions to Enviro.BLR.com include access to a customizable document builder where you choose from a library of prewritten environmental plans, customize them for your facility's needs, and compile them into a collection for your own environmental plan manual. Use the Environmental Plan Builder to create environmental plans in minutes.

Required Plans

EPA topics that have plan requirements are:

DOT required hazardous materials transportation plans are:

TABLE 1: EPA REQUIRED PLANS

Topic Plan Requirements
Asbestos
School Asbestos Management Plan
40 CFR 763.93
Local education agencies must develop an asbestos management plan for each school, including all buildings that they lease, own, or otherwise use as school buildings.
Operations and Maintenance in Buildings
40 CFR 763.91
Local education agencies must implement an operations, maintenance, and repair (O&M) program whenever any friable ACBM is present or assumed to be present in a building that it leases, owns, or otherwise uses as a school building. Any material identified as nonfriable ACBM or nonfriable assumed ACBM must be treated as friable ACBM when the material is about to become friable as a result of activities performed in the school building. Back to Top
Agricultural Waste
Nutrient Management Plan
40 CFR 122.23, 122.42, and 412.4
All CAFOs must develop and implement an NMP. The NMP identifies the necessary actions to ensure that runoff is eliminated or minimized through proper and effective manure, litter, or process wastewater management, including compliance with effluent limitation guidelines as applicable.
Comprehensive Nutrient Management Plan
7 CFR 1466
The USDA expects all animal feeding operations to take voluntary actions to minimize potential water pollutants from confinement facilities and land application of manure and organix-by-products. It is expected that all AFOs develop and implements CNMPs. CNMPs identify management and conservation actions that will be followed to meet defined soil and water conservation goals, including nutrient management.
Emergency Action Plan
40 CFR 122.42
An Emergency Action Plan is required as part of a NMP for a CAFO. The plan is necessary to minimize the environmental impact of discharges and mishaps while handling manure. An Emergency Action Plan is recommended for all animal feeding operations, but is required for CAFOs. Back to Top
Air Permitting (Title V)
Compliance Assurance Monitoring Plan
40 CFR 64.3 and 64.4
Title V sources with one or more pollutant-specific emissions units subject to an emission, standard, or permit limit, uses an emission control device, and has the precontrol potential to emit equal to or greater than the Title V major source threshold must develop a CAM Plan.
The plan must be updated with the Title V permit renewal.
Compliance Plan (permit application)
40 CFR 70.5
Each Title V permit application must contain a compliance plan detailing the current compliance status of each source at the facility, and how the source will attain or maintain compliance with each applicable requirement. Back to Top
Air – New Source Performance Standards (NSPS)
Monitoring Plans (multiple NSPS sources, including steam generating units and gas turbines)
Multiple citations under 40 CFR 60, including 60.49Da, 60.49Db, 60.334
Monitoring requirements are different for each NSPS source.
Operation and Maintenance Plans (multiple NSPS sources, including storage vessels)
Multiple citations under 40 CFR 60, including 60.113a, 60.113b
Operation and maintenance plans are different for each NSPS source. Back to Top
Boilers and Industrial Furnaces
Hazardous waste combustors - Startup, shutdown, and malfunction plan
40 CFR 63.1206(c)(2)
If the source elects to comply with certain provisions of 40 CFR 270.235 to address RCRA requirements for minimizing emissions of toxic compounds, a comprehensive performance test schedule and test plan is required for periods of startup, shutdown, and malfunction. It must include a description of potential causes of malfunctions, including releases from emergency safety vents, that may result in significant releases of hazardous air pollutants, and actions the source is taking to minimize the frequency and severity of those malfunctions.

Otherwise refer to the requirements for Startup, Shutdown, Malfunction Plans under Hazardous Air Pollutants in this section
Hazardous waste combustors - Performance Test Plan
40 CFR 63.1206(c)(5)
A performance test work plan that specifies the method that will be used to control combustion system leaks. If you control combustion system leaks by maintaining the combustion zone pressure lower than ambient pressure using an instantaneous monitor, you must also specify in the performance test work plan and Notification of Compliance the monitoring and recording frequency of the pressure monitor, and specify how the monitoring approach will be integrated into the automatic waste feed cutoff system.
Hazardous waste combustors - Safety vent operating plan
40 CFR 63.1206(c)(4)(ii)
An emergency safety vent operating plan is required. It must provide detailed procedures for rapidly stopping the waste feed, shutting down the combustor, and maintaining temperature and negative pressure in the combustion chamber during the hazardous waste residence time, if feasible. The plan must include calculations and information and data documenting the effectiveness of the plan's procedures for ensuring that combustion chamber temperature and negative pressure are maintained as is reasonably feasible.
Hazardous waste combustors - Operation and maintenance plan
40 CFR 63.1206(c)(7)
An operation and maintenance plan must describe in detail procedures for operation, inspection, maintenance, and corrective measures for all components of the combustor, including associated pollution control equipment, that could affect emissions of regulated hazardous air pollutants.

The plan must prescribe how you will operate and maintain the combustor in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels achieved during the comprehensive performance test.
Hazardous waste combustors - Particulate matter correlation test plan
40 CFR 63.1206
A particulate matter CEMS correlation test plan is required to test correlation with manual stack methods.
Boilers and industrial furnaces burning hazardous waste - Trial burn plan
40 CFR 270.66
Permit applicants must propose a trial burn plan that includes an analysis of each feed stream including hazardous waste, other fuels, and industrial furnace feed stocks, as fired, and an analysis of each hazardous waste, as fired. Back to Top
CFC Management
Chlorflourocarbon (CFC) Management—Retrofit/Retirement plans for leaking refrigeration equipment
40 CFR 82.156
These plans are dependent on the equipment that exists at individual facilities. Back to Top
Drinking Water
Emergency Response Plan (large public water systems, and medium/small)
42 USC 300i-2
Drinking water facilities serving populations of more than 3,300 are required to perform vulnerability assessments and to prepare an Emergency Response Plan that incorporates the results of the vulnerability assessment.
Wellhead Source Water Protection Plan
42 USC 300h-7
Local governments are required to develop source water protection plans in wellhead protection areas.
Wellhead Contingency Plan (hazmat spills)
42 USC 300h-7
Local governments are required to develop contingency plans in preparation for emergency conditions.
Quality Assurance Plan (sampling)
National Environmental Laboratory Accreditation Program No direct citation, but EPA follows the NELAP standards
Laboratories seeking accreditation from NELA must develop and submit a quality assurance plan for accreditation.
Sampling Plan
40 CFR 141.21
Public water systems must collect total coliform samples at sites which are representative of water throughout the distribution system according to a written sample siting plan. Back to Top
Fugitive Emissions
Dust Control Plans (multiple MACT sources)
Multiple citations under 40 CFR 63, including 63.9591, 63.1445
Many source categories are required to prepare, and at all times operate according to, a written fugitive dust emissions control plan that describes in detail the measures that will be put in place to control fugitive dust emissions from the different locations at the source.
Leak Detection and Repair Plans (NSPS and Multiple MACT sources)
40 CFR 60.482, and 40 CFR 63.9050, 63.1409, 63.1086
Many federal regulations under NSPS at 40 CFR 60 and NESHAPs at 40 CFR 61 and 40 CFR 63 require the implementation of LDAR programs. LDAR programs are generally composed of four steps:
* Identify components to be included in the program.
* Conduct routine monitoring of identified components.
* Repair any leaking component.
* Report monitoring results.

While all LDAR programs are similarly composed, the specifics of each program are unique depending on the source and the applicable standard; even the definition of what constitutes a "leak" varies among standards. Therefore, it is important to carefully review the requirements of the applicable standard before implementing an LDAR program. Back to Top
Hazardous Waste - Generators
Closure and Post-Closure Plan
40 CFR 270.110 to 270.120
When a hazardous waste facility or portion of the facility is no longer going to be used for treatment, storage, or disposal, the facility must be "closed." Closure requires that the facility be taken out of operation in compliance with a preapproved closure plan. Post-closure standards were developed for land disposal units that leave hazardous waste in place at closure. A disposal unit's post-closure period is typically 30 years. All hazardous waste disposal units must have a written post-closure plan.
Remedial Action Plan
41 CFR 270.79 to 270.230
A RAP is a form of RCRA permit that a facility owner or operator may obtain in lieu of a RCRA Individual Permit to authorize the treatment, storage, or disposal of hazardous remediation waste at a remediation waste management site. A RAP streamlines the permitting process for remediation waste management sites. Except in limited circumstances, a RAP may only be issued for the area of contamination where the remediation wastes to be managed under the RAP originated, or areas in close proximity to the contaminated area.
Contingency Plan for LQGs (see TSDF section, Contingency Plan)
40 CFR 262.34(a)(4) (refers to 265.50)
Permitted and interim TSDFs and LQGs that accumulate hazardous waste on-site without a permit but in accordance with RCRA's 90-day accumulation time rule must prepare and submit a written contingency plan to EPA.
Written Training Plan (LQGs and TSDFs)
40 CFR 262.34(a)(4)
Facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance. LQGs must have a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position.
Waste Analysis Plan
40 CFR 268.7(a)(5)
If a generator is managing and treating prohibited waste or contaminated soil in tanks, containers, or containment buildings regulated under 40 CFR 262.34 to meet applicable LDR treatment standards found at 40 CFR 268.40, the generator must develop and follow a written waste analysis plan which describes the procedures they will carry out to comply with the treatment standards.

The plan must be kept on site in the generator's records. The waste analysis plan must be based on a detailed chemical and physical analysis of a representative sample of the prohibited waste(s) being treated, and contain all information necessary to treat the waste(s) in accordance with the requirements of this part, including the selected testing frequency. Back to Top
Hazardous Waste - Treatment, Storage, and Disposal Facilities (TSDFs)
Contingency Plan and Emergency Procedures (TSDF and interim status TSDF)
40 CFR 264.50 to 264.56, and 40 CFR 265.50 to 265.56
Permitted and interim TSDFs and LQGs that accumulate hazardous waste on-site without a permit but in accordance with RCRA's 90-day accumulation time rule must prepare and submit a written contingency plan to EPA.

A contingency plan establishes the procedures that must be taken under RCRA to minimize hazards to human health and the environment caused by explosions, fires, or unplanned sudden or nonsudden releases of hazardous waste or hazardous waste constituents to the air, soil, or surface water. The plan must be in writing, and it must identify who will be in charge of implementation in the event of an emergency. Under the federal rules, the plan's provisions must be carried out immediately whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents that could threaten human health or the environment.

Note: The standard for implementing the contingency plan may be more stringent in some states. For example, the state may require the plan to be implemented if there is a release that could threaten air, soil, surface water, or groundwater.
Closure Plan
40 CFR 264.112 and 265.112
Permitted and interim TSDFs must have a written closure plan. In addition, certain surface impoundments and waste piles that are intended for the removal or decontamination of the hazardous waste at partial or final closure are required to have contingent closure plans. The plan must be submitted with the permit application, and approved by EPA as part of the permit issuance procedures. The approved closure plan will become a condition of any RCRA permit.
Post-Closure Plan
40 CFR 264.118
Permitted TSDFs must have a written post-closure plan. In addition, certain surface impoundments and waste piles that are intended for the removal or decontamination of the hazardous wastes at partial or final closure are required to have contingent post-closure plans. Surface impoundments and waste piles not otherwise required must also have contingent post-closure plans and must submit a post-closure plan to EPA within 90 days from the date that the hazardous waste management unit must be closed as a landfill. The plan must be submitted with the permit application, , and approved by the Regional Administrator as part of the permit issuance procedures. The approved post-closure plan will become a condition of any RCRA permit issued.

The post-closure plan must identify the activities that will be carried on after closure of each disposal unit and the frequency of these activities.
Facility Inspection and Monitoring Plan
40 CFR 264.15 (general)
Permitted TSDFs must develop and follow a written schedule for inspecting monitoring equipment, safety and emergency equipment, security devices, and operating and structural equipment (such as dikes and sump pumps) that are important to preventing, detecting, or responding to environmental or human health hazards.
Facility Inspection and Monitoring Plan
40 CFR 264.1088 (air emissions from tanks, containers, surface impoundments)
Permitted TSDFs must develop and implement a written plan and schedule to perform the inspections and monitoring for air emissions from tanks, containers, and surface impoundments.
Corrective Action Plan
40 CFR 264.101
Permitted TSDFs must develop a corrective action program, which will be specified in the facility's permit. The corrective action program covers monitoring and sampling procedures for detecting a hazardous waste release. Once a release of hazardous waste is detected, the program's corrective action measures must be implemented. A TSDF's corrective action program must be maintained during the facility's operating life and post-closure period.
Inspection Plan
40 CFR 264.15(b)(1) and 40 CFR 265.15(b)(1)
TSDFs must develop and follow a written schedule for inspecting monitoring equipment, safety and emergency equipment, security devices, and operating and structural equipment (such as dikes and sump pumps) that are important to preventing, detecting, or responding to environmental or human health hazards. The schedule must identify the types of problems (e.g., malfunctions or deterioration) that are to be looked for during the inspection (e.g., inoperative sump pump, leaking fitting, eroding dike, etc.).
Waste Analysis Plan
40 CFR 264.13, 264.73, and 268.7
Permitted TSDFs are also required to obtain a detailed chemical and physical analysis of a representative sample of the wastes before treating, storing, or disposing of the waste. This analysis must be repeated as necessary to ensure that it is accurate and up to date.
Groundwater Sampling and Analysis Plan
40 CFR 265.92
TSDF owners and operators must develop and follow a groundwater sampling and analysis plan. The plan must include procedures and techniques for sample collection, sample preservation and shipment, analytical procedures, and chain of custody control.
Groundwater Quality Assessment Plan
40 CFR 265.93
TSDF owners and operators must develop groundwater quality assessment plans that specify the number, location, and depth of wells; sampling and analytical methods for those hazardous wastes of hazardous waste constituents in the facility; evaluation procedures, including any use of previously-gathered groundwater quality information; and a schedule of implementation. Back to Top
Hazardous Waste - Landfills
Landfill liner construction quality assurance plan
40 CFR 264.19 and 265.19
A construction quality assurance (CQA) program is required for all surface impoundment, waste pile, and landfill units. The program must ensure that the constructed unit meets or exceeds all design criteria and specifications in the permit. The program must be developed and implemented under the direction of a CQA officer who is a registered professional engineer.
Landfill Response Action Plan
40 CFR 264.304 and 265.303
Hazardous waste landfills must have an approved response action plan before receipt of waste. The response action plan must explain the actions to be taken if the action leakage rate has been exceeded. Back to Top
Hazardous Air Pollutants
Implementations Plans (multiple MACT sources)
Multiple citations under 40 CFR 63, including 63.5707
Various MACT sources must prepare an implementation plan for applicable operations. The implementation plan must describe the steps they will take to bring applicable operations into compliance.
Work Practice Implementation Plans (multiple MACT sources)
Multiple citations under 40 CFR 63, including 63.803, 63.3094
Various MACT sources must prepare and maintain a written work practice implementation plan that defines environmentally desirable work practices for each manufacturing operation and addresses each of the work practice standards required for the source.
Startup, Shutdown, Malfunction Plans (multiple MACT sources)
40 CFR 63.6 plus multiple other citations under 40 CFR 63 including 63.1439, 63.1111, 63.1259, 63.1367, 63.998
Various MACT sources must develop a written startup, shutdown, and malfunction plan that describes, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the relevant standard. The startup, shutdown, and malfunction plan does not need to address any scenario that would not cause the source to exceed an applicable emission limitation in the relevant standard.
Operation & Maintenance Plans (multiple MACT sources)
Multiple citations under 40 CFR 63, including 63.1510, 63.562, 63.1350, 63.1383, 63.7710, 63.9600
Various MACT sources must prepare and implement for each new or existing affected source and emission unit, a written operation, maintenance, and monitoring (OM&M) plan. The plan must be accompanied by a written certification by the owner or operator that the OM&M plan satisfies all requirements of the applicable standard.
Precompliance Plans (multiple MACT sources)
Multiple citations under 40 CFR 63 including 63.1368, 63.1260
Various MACT sources must prepare precompliance plans several months before the compliance date of the standard. The Precompliance plan must include:
* Requests for approval to use alternative monitoring parameters or requests to set monitoring parameters according to the standard
* Descriptions of the daily or per batch demonstrations to verify that control devices are operating as designed
* Data and rationale used to support the parametric monitoring level(s)
* Pollution prevention demonstration summary, if applicable.
* Data and rationale used to support an engineering assessment to calculate uncontrolled emissions from process vents
Compliance Plans (multiple MACT sources)
Multiple citations under 40 CFR 63 including 63.2851
Various MACT sources must develop and implement a written plan for demonstrating compliance that provides the detailed procedures that will be followed to monitor and record data necessary for demonstrating compliance with the standard.
Testing Plans (multiple MACT sources)
40 CFR 63.7 plus multiple other citations under 40 CFR 63 including 63.1365
Before conducting a required performance test, various MACT sources must develop and, if requested by EPA, submit a site-specific test plan. The test plan must include a test program summary, the test schedule, data quality objectives, and both an internal and external quality assurance (QA) program. Data quality objectives are the pretest expectations of precision, accuracy, and completeness of data.
Sampling Plans (multiple MACT sources)
Multiple citations under 40 CFR 63 including 63.694
Various must sources must develop a site sampling plan. An example of an acceptable sampling plan includes a plan incorporating sample collection and handling procedures in accordance with the requirements specified in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication No. SW–846 or Method 25D.
Continuous Monitoring System (CMS) Performance Evaluation Plans (multiple MACT sources)
40 CFR 63.8(e) plus multiple other citations under 40 CFR 63 including 40 CFR 63.1207
Before conducting a required CMS performance evaluation, various MACT sources must develop and submit a site-specific performance evaluation test plan. The performance evaluation test plan must include the evaluation program objectives, an evaluation program summary, the performance evaluation schedule, data quality objectives, and both an internal and external QA program. Data quality objectives are the pre-evaluation expectations of precision, accuracy, and completeness of data.
Monitoring Plans (Multiple MACT sources)
Multiple citations under 40 CFR 63 including 40 CFR 63.1510 and 63.11563
Various MACT sources must develop a written site-specific monitoring plan describing all monitoring parameters and containing sufficient procedures to ensure continuing compliance with all applicable emissions limits.
Emissions Averaging Plans (Multiple MACT sources)
Multiple citations under 40 CFR 63 inlcuding 40 63.506, 63.1335, and 63.2280
Various MACT sources may opt to use emissions averaging to demonstrate compliance with certain emissions limits. Sources using emissions averaging must develop, and submit to the appropriate regulatory agency for approval, an emissions averaging plan that identifies all the emissions points and other parameters to properly carry out emissions averaging in a manner that will accurately demonstrate compliance. Back to Top
Hazard Communication Standard
Hazard Communication (significant new uses of chemicals)
40 CFR 721.72 and 29 CFR 1910.1200(e)
Where an employee could be exposed to a chemical in the workplace under normal conditions or in a foreseeable emergency, the employer must develop, implement, and maintain at each workplace a written hazard communication program that describes how the regulatory requirements for hazardous chemical labels and other forms of warning, material safety data sheets, and employee information and training will be met. Back to Top
HAZWOPER
Site-Specific Safety and Health Plan (SAHP or HASP), including Comprehensive Work Plan and PPE Program
29 CFR 1910.120(b)(4) or 1926.65(b)(4)
Safety and health plan. Develop a written plan for operations and cleanup required by government agencies at uncontrolled hazardous waste sites, corrective actions involving cleanup at Resource Conservation and Recovery Act (RCRA)-regulated sites, and voluntary cleanup at uncontrolled hazardous waste sites.
PPE program. Establish a written PPE program as part of the employer's safety and health program and part of the site-specific safety and health plan. The program must be reviewed annually.
Emergency Response Plan (ERP) for employees at uncontrolled hazwaste sites
29 CFR 1910.120(l), or 1926.65(l)
Emergency response plan. Develop a written plan for a facility that releases or threatens to release a hazardous substance (including hazardous waste treatment, storage, and disposal facilities), and where employees engage in emergency response to a release of hazardous substances at any type of facility.
ERP (all employers and employees that respond to emergencies)
29 CFR 1910.120(q)
Emergency response plan. Develop a written plan for a facility that releases or threatens to release a hazardous substance (including hazardous waste treatment, storage, and disposal facilities), and where employees engage in emergency response to a release of hazardous substances at any type of facility. Back to Top
Incineration of Wastes
Hazardous Waste Incinerator—Trial Burn Plan
40 CFR 270.62
Hazardous waste incinerator permit applicants must propose a trial burn plan. The plan must include an analysis of each waste or mixture of wastes to be burned. The plan must include:
* An analysis of each waste or mixture of wastes to be burned.
* A detailed engineering description of the incinerator.
* A detailed description of sampling and monitoring procedures.
* A detailed test schedule for each waste for which a trial burn is planned.
* A test protocol for each waste, including temperature ranges, feed rate, etc. that will be varied to affect the destruction and removal efficiency of the incinerator.
* A description and planned operating conditions of emissions control equipment.
* Procedures for rapidly stopping waste feed, shutting down the incinerator, and controlling emissions in the event of an equipment malfunction.
Materials Separation/Waste Management Plans for MWC, CISWI, HMIWI, and other incinerators
40 CFR 60.57b, 40 CFR 60.55c, 40 CFR 60.1050 to 1105, 40 CFR 60.2055 to 2065, and 40 CFR 60.2899 to 2901
Incinerators must develop materials separation plans that identify both a goal and an approach to separate certain components of municipal solid waste for a given service area in order to make the separated materials available for recycling. A materials separation plan may include elements such as dropoff facilities, buy-back or deposit-return incentives, curbside pickup programs, or centralized mechanical separation systems. A materials separation plan may include different goals or approaches for different subareas in the service area, and may include no materials separation activities for certain subareas or, if warranted, an entire service area.
Monitoring plan for control devices at sewage treatment plants
40 CFR 60.153
Sludge incinerators other than a multiple hearth, fluidized bed, or electric incinerators or any sludge incinerators equipped with a control device other than a wet scrubber must submit to EPA a plan for monitoring and recording incinerator and control device operation parameters. Back to Top
Medical Waste
Medical Waste Management Plan
40 CFR 60.55c
HMIWI must prepare a waste management plan. The waste management plan must identify both the feasibility and the approach to separate certain components of solid waste from the health care wastestream in order to reduce the amount of toxic emissions from incinerated waste. The American Hospital Association publication entitled “An Ounce of Prevention: Waste Reduction Strategies for Health Care Facilities” must be considered in the development of the waste management plan. Commercial HMIWI companies must conduct training and education programs in waste segregation for each of the company's waste generator clients and ensure that each client prepares its own waste management plan. Back to Top
Oil Spills Prevention and Management
Oil Spill Prevention Control and Countermeasures (SPCC) Plan (non-bulk facilities)
40 CFR 112.1 to 112.12
Nontransportation-related facilities with a total aboveground oil storage capacity of greater than 1,320 gallons or buried oil storage capacity greater than 42,000 gallons, and that because of their locations could reasonably be expected to discharge oil into navigable waters of the United States or adjoining shorelines, must develop an SPCC plan.
Facility Response Plan (FRP)
40 CFR 112.20, 112.21, and Appendix F
Non-transportation-related onshore facilities that, because of their location, could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines must prepare and submit to EPA an FRP.
Oil or Hazardous Substances Bulk Transfer Facility Response Plan
33 CFR 154.1010 to 154.1075
Marine-transportation related facilities that could reasonably be expected to cause substantial harm or significant and substantial harm to the environment by discharing oil into or on the navigable waters, adjoining shorelines, or exclusive economic zone must develop a Facility Response Plan to respond to oil spills. Back to Top
Underground Storage Tanks
Underground Storage Tank (UST) Corrective Action Plan
40 CFR 280.66 and 280.67
EPA may require USTs to develop and submit a corrective action plan for responding to contaminated soils and ground water. The plan must provide for adequate protection of human health and the environment. Back to Top
Used Oil Management
Contingency Plan (used oil processors and refiners)
40 CFR 279.52
Used oil processing and re-refining facilities must have a contingency plan for the facility. The contingency plan must be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of used oil to air, soil, or surface water.
If the facility already has prepared an SPCC Plan or some other emergency or contingency plan, the plan need only be amended to incorporate used oil management provisions.

Note: SPCC and Contingency Plans would be applicable here.
Used Oil Analysis Plan
40 CFR 279.55
Used oil processing and re-refining facilities must develop and follow a written analysis plan describing the procedures that will be used to comply with the analysis requirements of 40 CFR 279.53 (rebuttable presumption) and, if applicable, 40 CFR 279.72 (on-site specification of used oil). Back to Top
Pesticides
Fumigant Management Plans
Requirement is outlined in the Reregistration Eligibility Decision (RED) for the specific fumigant
Owners and operators of fields that use certain fumigants must develop Fumigant Management Plans to protect workers and bystanders near the fields that are fumigated. Back to Top
Risk Management Program
Risk Management Plan (RMP)
40 CFR 68.150 to 68.195
Any facility that has a listed substance above the threshold quantity in any single process at the facility must develop and risk management plan (RMP). The listed substances contain 77 toxic chemicals with thresholds ranging from 500 pounds (lb) to 20,000 lb and 63 flammable substances with a threshold quantity of 10,000 lb.

The RMP is a summary of the program that details how facilities will prevent accidental chemical releases. The type and extent of the plan required is determined by the program level of the plant processes.
Emergency Response Plan
40 CFR 68.95
Facilities subject to the Risk Management Program requirements must develop an emergency response plan that includes:
* Procedures for informing the public and local emergency response agencies about accidental releases
* Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures
* Procedures and measures for emergency response after an accidental release of a regulated substance
Operating plans & emergency procedures
40 CFR 68.69
Facilities subject to RMP Program Level 3 requirements must develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. The operating plan must include:
* Steps for each operating phase, including initial startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and startup following a turnaround or emergency shutdown.
* Operating limits, including the consequences of deviation and the steps to correct or avoid deviation.
* Safety and health considerations associated with the process and the chemicals used in the process.
* Safety systems and their functions
Management of change plan
40 CFR 68.75
Facilities subject to RMP Program Level 3 requirements must establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process. The plan will ensure the following are addressed before the change occurs:
* The technical basis for the change
* The impact of the change on health and safety
* Necessary modifications to operating procedures
* Necessary time period for the change
* Authorization requirements for the change Back to Top
Stormwater Pollution Prevention Plan (SWPPP)
Industrial Multi-Sector General Permit (MSGP)
40 CFR 122.26
Facilities regulated under the MSGP-2008 must develop and implement an SWPPP before the submission of an NOI for permit coverage. If a permittee has a prepared SWPPP for coverage under a previous NDPES permit, it must be reviewed and updated to implement all provisions of the MSGP-2008 before an NOI is submitted.

An SWPPP must contain all of the following items:
* Stormwater pollution prevention team
* Site description
* Summary of potential pollutant sources
* Description of control measures
* Schedules and procedures
* Documentation to support eligibility considerations under other federal laws
* Signature requirements
Construction GP
40 CFR 122.26
EPA’s CGP permit regulates the discharge of stormwater from construction sites that disturb 1 acre or more of land, and from smaller sites that are part of a larger, common plan of development. The CGP requires operators of such construction sites to implement stormwater controls and develop SWPPPs to prevent sediment and other pollutants associated with construction sites from being discharged in stormwater runoff.

The SWPPP must include:
* Site evaluation, assessment, and planning
* Erosion and sediment control BMPs
* Good housekeeping BMPs
* Selecting post-construction BMPs
* Inspections
* Recordkeeping and training
* Final stabilization
* Certification and notification
SWMP Municipal (large and medium)
40 CFR 122.26
Large and medium MS4s are required to develop stormwater management plans, which may reference SWPPPs for specific municipally-owned facilities (garages, transfer stations, etc.). Most of these plans were developed in the early 1990s.
SWMP Municipal (MS4 small)
40 CFR 122.32
Small MS4s are required to develop stormwater management plans, which may reference SWPPPs for specific municipally-owned facilities (garages, transfer stations, etc.). Back to Top
Solid Waste - Municipal Solid Waste Landfills
Plan for excluding hazardous waste
40 CFR 258.20
MSWLFs must implement a program at the facility for detecting and preventing the disposal of regulated hazardous wastes and polychlorinated biphenyls (PCB) wastes.
Landfill Gas Remediation Plan
40 CFR 258.23
If methane gas levels exceeding the limits specified 40 CFR 258.23(a) are detected, the MSWLF must, among other measures, Within 60 days of detection, implement a remediation plan for the methane gas releases within 60 days of detection. The plan must describe the nature and extent of the problem and the proposed remedy.
Groundwater Monitoring
40 CFR 258.53
MSWLFs must develop a ground-water monitoring program that includes consistent sampling and analysis procedures that are designed to ensure monitoring results that provide an accurate representation of ground-water quality at the background and downgradient wells installed.
Closure Plan
40 CFR 258.60
MSWLFs must prepare a written closure plan that describes the steps necessary to close all MSWLF units at any point during their active life in accordance with the cover design requirements, as applicable. The closure plan, at a minimum, must include:
* A description of the final cover and the methods and procedures to be used to install the cover
* An estimate of the largest area of the MSWLF unit ever requiring a final cover at any time during the active life
* An estimate of the maximum inventory of wastes ever onsite over the active life of the landfill facility
* A schedule for completing all activities necessary to satisfy the closure criteria
Post-closure Plan
40 CFR 258.61
MSWLFs must prepare a written post-closure plan that includes:
* A description of the monitoring and maintenance activities for each MSWLF unit, and the frequency at which these activities will be performed
* Name, address, and telephone number of the person or office to contact about the facility during the post-closure period
* A description of the planned uses of the property during the post-closure period Back to Top
Wastewater
Pretreatment Enforcement Response Plan
40 CFR 403.8(f)(5)
POTWS must develop and implement an enforcement response plan. The plan must contain detailed procedures indicating how a POTW will investigate and respond to instances of industrial user noncompliance.
Pretreatment Slug Control Plan
41 CFR 403.8(f)(2)(vi)
If a POTW decides that a Significant Industrial User needs a slug control plan, then plan must be developed that contains:
* Description of discharge practices, including non-routine batch Discharges
* Description of stored chemicals
* Procedures for immediately notifying the POTW of Slug Discharges, including any prohibited discharge with procedures for follow-up written notification within 5 day
* If necessary, procedures to prevent adverse impact from accidental spills, including inspection and maintenance of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site run-off, worker training, building of containment structures or equipment, measures for containing toxic organic pollutants (including solvents), and/or measures and equipment for emergency response
Thermal Plan of Study
40 CFR 125.72(b)
NPDES dischargers requesting a variance from thermal effluent limitations must submit a detailed plan of study which the discharger will undertake to support its variance demonstration within 60 days after the application is submitted to EPA.

The plan must specify the nature and extent of the following type of information to be included in the plan of study: Biological, hydrographical and meteorological data; physical monitoring data; engineering or diffusion models; laboratory studies; representative important species; and other relevant information. Back to Top
Underground Injection
Closure Plan
40 CFR 146.71(a)
Class I hazardous waste injection wells must have a detailed closure plan as part of the permit applications and demonstrate financial responsibility.
Post-closure Plan
40 CFR 146.72(a)
Class I hazardous waste injection wells must have a detailed post-closure plan as part of the permit applications and demonstrate financial responsibility.
Plugging and Abandonment Plan
40 CFR 144.51(0), 40 CFR 144.52(a)(6), and 40 CFR 146.10
Class I, II or III permits must include and a Class V permit may include a plugging and abandonment plan to insure that plugging and abandonment of the well will not allow the movement of fluids into or between USDWs. Back to Top
Other
Pulp and Paper Mills—Best Management Practices Plan
40 CFR 430.03(d)
Pulp and paper mills that that discharges or may discharge process wastewater pollutants to the waters of the United States, or that introduce or may introduce process wastewater pollutants into a publicly owned treatment works must prepare and implement a BMP Plan.
The BMP Plan must be based on a detailed engineering review and must specify the procedures and the practices required for each mill to meet the requirement to implement BMPs, the construction the mill determines is necessary to meet those requirements including a schedule for such construction, and the monitoring program (including the statistically derived action levels) that will be used to meet the monitoring requirements. The BMP Plan also must specify the period of time that the mill determines the action levels established may be exceeded without triggering specified responses.

TABLE 2: DOT HAZARDOUS MATERIALS TEANSPORTATION REQUIRED PLANS

Topic Plan Requirements
Communications Plan
49 CFR 385.407(b)(2)
As a condition for obtaining a FMCSA safety permit, motor carriers must submit a communications plan that allows for contact between the commercial motor vehicle operator and the motor carrier to meet the periodic contact requirements (the beginning and end of each duty tour, and at the pickup and delivery of each permitted load). Back to Top
Transportation Facility Oil Spill Response Plan 49 CFR 130.31 Transporters of liquid petroleum oil in packaging of a capacity of 3,500 gal, or nonpetroleum oil greater than 42,000 gal, are required to have a written oil spill response plan. Transporters of oil in quantities greater than 42,000 gal are required to have a more comprehensive plan. Back to Top
Security Plan
49 CFR 172.800, .802, .804
Transporters of certain hazardous materials must develop and adhere to a security plan for hazardous materials. The security plan must include an assessment of possible transportation security risks for shipments of the hazardous materials and appropriate measures to address the assessed risks. Back to Top
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