EPA Standard 40 CFR 265 Subpart D

This Contingency and Security Plan has been developed to minimize hazards to human health or the environment from fires, explosions and/or any unplanned sudden or non-sudden release of hazardous waste to air, soil, or surface water in accordance to 40 CFR 265.50 – 265.56

Revision Date: 04-01-14

Contents:
Facility Identification and General Information
Emergency Coordinators
Type of Facility
Implementation of the Contingency Plan
Emergency Response Procedures for Spills, Fire, and Explosions
Emergency Equipment
Coordination Agreements and Telephone Numbers
Required Reports
Amendment of Contingency Plan

Facility Identification and General Information

Name:  Palmetto Plating Company, Inc.

Location:  510 Saco-Lowell Road, Easley, SC 29640

Owner:
John Cutchin
Address avialable by hard copy only.
Easley, SC 29640

Telephone:  
864-859-7458 (Home)
864-430-8264 (Cell)
864-859-9314 (Work)

Emergency Coordinators:

Staci Sorgee
Address avialable by hard copy only.
Easley, SC 29642

Telephone:
864-306-3785 (cell & home)
864-859-9314 (work)

Ronnie Colón
Address avialable by hard copy only.
Easley, SC 29640

Telephone:     
864-430-8790 (Cell & Home)
864-859-9314 (Work)

Brandon Bandy
Address avialable by hard copy only.
Easley, SC 29642

Telephone:
864-430-9216 (Cell & Home)
864-859-9314 (Work)

The first emergency coordinator is responsible for hazardous waste management at the site.  All emergency coordinators are thoroughly familiar with all aspects of the contingency plan, all operations and activities at the facility, the location and characteristics of waste handled, the location of all records within the facility, and the facility layout.

Type of Facility

Palmetto Plating Company, Inc. is a metal finishing company, providing a variety of electroplating and other related surface finishes to industries.  Metal finishing requires the use of alkaline solutions and Inorganic Acids.  We maintain a complete Safety Data Sheet file for each chemical we use and our employees receive safety training in the safe and proper use of chemicals.  Our employees are provided with any necessary safety equipment such as safety glasses, aprons, boots and clothing.  Our process tanks are labelled as to their contents.

Palmetto Plating Company, Inc. is a large quantity generator of hazardous waste.  Process wastewater is treated on site to render it acceptable for discharge to the Easley Combined Utility wastewater treatment plant.  We have permits from the city of Easley for these discharges.  Our discharges are monitored regularly for compliance with the federal, state, and local Utility requirements.

Our shops are equipped with dikes and sumps to contain accidental spills.

Hazardous waste are kept in secure temporary storage until they are disposed at an EPA permitted treatment facility, where they are rendered non-hazardous.

The plant has Blue Ridge Security protection, has monitoring cameras (inside and out) and has 24 hour emergency contacts.  We are located in the city of Easley and are routinely on their surveillance list at all times.  None the less, we operate at some level at the plant site 24/7.  Any suspicious activity, therefore; would be noticed.

Hazardous Wastes are generated from various processes:

  • Waste Corrosive Liquid, Acidic, Inorganic (D002, D006, D007)
  •  *Waste Cyanide Solutions / Debris (D003, F007)
  • Waste Chromic Acid Solution (D002, D007)
  • Hazardous Waste Solid (F006)
  • Hazardous Waste Solid – Debris (F006, D007)
  • Nickel Strip – Waste Corrosive Liquid, Basic, Organic (D002)

 *Palmetto Plating Company has discontinued the use of its cyanide based stripping solution process, yet some debris and sodium cyanide powder are currently on site.

Implementation of the Contingency Plan

The Contingency Plan will be implemented if an incident might threaten human health or the environment.  The emergency coordinator has full authority to make this decision.

Implementation of the contingency plan includes incidents at all hazardous waste generation and accumulation points throughout the plant.  The contingency plan must be implemented whenever an incident might involve hazardous waste anywhere on the plant property.  Depending upon the degree of seriousness, the following potential emergencies might call for the implementation of the contingency plan:

Spills

  • A spill of any on-site generated hazardous waste from containers or tanks which cannot be contained on-site resulting in off-site soil contamination and/or ground or surface water pollution.

Fires

  • A fire which could cause the release of toxic fumes from hazardous waste
  • If the fire spreads, it could ignite materials at other locations at the site or cause heat-induced explosions
  • A fire which could spread to off-site areas

 Explosions

  • An imminent danger exists that an explosion involving hazardous waste could occur, resulting in a safety hazard due to flying fragments or shock waves
  • An imminent danger exist that an explosion could ignite other hazardous waste at the facility.
  • An imminent danger exist that an explosion involving hazardous waste could result in the release of toxic material
  • An explosion has occurred

Emergency Response Procedures for Spills, Fire, and Explosions

An employee discovering a spill, fire, or an imminent danger of explosion involving hazardous chemicals that is not easily controllable with equipment and materials at hand must contact the emergency coordinator.  The emergency coordinator will immediately respond to the call and assess the situation.  If the emergency can be controlled without evacuating the plant, emergency crew members will be contacted to respond to the incident.  Emergency crew members consist of those employees that have had RCRA Hazardous Waste Management training.  If the emergency coordinator determines that the incident requires evacuation of the plant, the internal alarm (paging system) will be activated.

All employees of Palmetto Plating Company are instructed to activate the internal alarm/paging system if the incident is an obvious immediate threat to fellow employees or the environment.

In the case of evacuation, all employees hearing the alarm must close down their equipment and proceed to their nearest exit to the designated safe zone located outside the front entrance/gravel driveway on the Greenville side of the building.  Once there, they will report to their supervisor and a head count will be obtained.

 The emergency coordinator will concurrently assess the situation by identifying the character, exact source and extent of any released material, as well as, make an assessment of possible threats to human health and the environment.

 The emergency coordinator will take all necessary measures to contain the hazard within the facility property, and to prevent its spread to other nearby properties, with the assistance of the emergency crew.

 In case of a spill, pump any free liquid into DOT approved plastic drums.  Absorb any remaining liquid with speedy dry (or equivalent) and sweep and shovel into a supersack.  In case of a spill of solid material, clean up using a shovel or broom and place recovered material in a supersack.  If the spill is from a leaking or damaged container, it will immediately be placed over a containment pallet or allowed to drain into an empty tote.  Properly identify the recovered material as hazardous waste.  Labels will be obtained from the emergency coordinator.

 If any spill leaves the building of Palmetto Plating Company, immediately notify SCDHEC.

In case of a fire or explosion, emergency crew personnel are instructed that if the fire cannot be readily controlled with available equipment, the area must be immediately evacuated.

Following containment and control of the emergency, the emergency coordinator, along with the emergency crew, will provide for the collection, treatment, and disposal of the waste and contaminated soil, water, or other materials by the emergency crew or outside contractor, as appropriate.

The emergency coordinator will investigate the cause of the emergency and will take steps to prevent a recurrence of such or similar incidents.

Emergency Equipment

 Internal Communication/Alarm System
Our alarm system is our phone paging system.  Phones are located in the shop offices, lab office and outside the office in the plant area.

 Fire Control Equipment
To provide rapid response to fires, wall-mounted, hand-held fire extinguishers are centrally located throughout the plant.

Capabilities:  Response to small fires

Spill Control Equipment
A spill containment cabinet is equipped with a supply of spill absorbing materials, neutralizing chemicals (soda ash), shovel, dust pan, and brooms.  An emergency shower and eye wash station to wash off personal spills are located on each processing line.

Capabilities:  Response, containment, and cleanup of spills throughout the facility

Personal Protective Equipment
Gloves, face shields, coveralls, jackets, and aprons are available for emergency crew members.

 Capabilities: To provide emergency crew members with protection when responding to emergency spills.

First Aid
The shop office houses a first aid station

 Capabilities:  To provide first aid for minor injuries which occur during normal situations or during emergencies.

 

Coordination Agreements and Telephone Numbers

Always dial 9-1-1 first in case of an emergency

 City of Easley Fire Department    864-859-8950 (not manned 24/7, dial 911 for emergency)

 Easley Police Department    864-859-4025

 Pickens Co. Emergency Management    864-898-5945

 Baptist Easley Hospital    864-442-7621/422-7200

 SC DHEC (24-hr Response Center)    888-481-0125

 The above agencies have received a copy of the Contingency plan and have agreed to provide their services in any appropriate emergency.

Required Reports

Within fifteen (15) days of any incident requiring implementation of this contingency plan, the emergency coordinator will file a report with the SCDHEC.  The report will include the following information:

  • Name, address and telephone number of owner/operator
  • Name, address and telephone number of the facility
  • Date, time and type of incident
  • Name and quantity of material involved
  • An assessment of actual or potential hazards to human health and environment
  • Estimated quantity and disposition of recovered material that resulted from the incident

 

Amendment of Contingency Plan

The emergency coordinator will review and amend this contingency plan whenever the following situations apply:  applicable regulations are revised; the plan fails in an emergency; the faculty changes in its design, construction, operation, maintenance, or other circumstances in a way that materially increases the potential for fires, explosions, or releases; the list of emergency coordinators changes; or the list of emergency equipment changes.