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 FORM EQP5111 ATTACHMENT TEMPLATE MODULE A

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file time: 2008-02-16

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Personnel Training, Revision ___

EPA ID. No. ___ ___ ___ ___

FORM EQP5111 ATTACHMENT TEMPLATE MODULE A10  

GENERAL INFORMATION:  PERSONNEL TRAINING 
 

The Administrative Rules for Part 111, Hazardous Waste Management, of the Michigan Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451), Rule 299.9501 (R 299.9501), R 299.9605, and Title 40 Code of Federal Regulations (40 CFR) 264.16, and 270.14(b)(12), which are adopted by reference (ABR) in R 299.11003, establish requirements for personnel training programs at hazardous waste management facilities.   

This license application module addresses requirements for a personnel training program at the hazardous waste management facility for the (Facility Name) in (City), Michigan.   This module includes personnel training requirements for construction permits and operating license applications.  The information included in the module demonstrates how the facility meets the personnel training requirements for hazardous waste management facilities. 

(Check as appropriate) 

00/font> Operating License Applicant: 

00/font> Construction Permit Applicant: 
 
 

This module is organized as follows: 
 

A10.A  Content of Introductory and Continuing Education Programs 

      A10.A(1) Outline for Introductory Training Program 

      A10.A(2) Outline for Continuing Education 

A10.B  Personnel Subject to Training Requirements 

            A10.B(1) Job Titles and Job Descriptions 

A10.B(2) Description of How Training is Designed to Meet Actual Job Tasks 

A10.C  Frequency of Required Training 

            A10.C(1) Initial Training 

            A10.C(2) Continuing Education 

A10.D  Training Director 

A10.E  Documentation and Recordkeeping 

            A10.E(1) Documentation

                        A10.E(1)(a) job titles

                        A10.E(1)(b) written job descriptions

                        A10.E(1)(c) written description of type and amount

      of training given to each position

                        A10.E(1)(d) documentation that training has been

                                    given to, and completed by, facility

      personnel 

            A10.E(2) Recordkeeping 
 

A10.A CONTENT OF INTRODUCTORY AND CONTINUING EDUCATION TRAINING PROGRAMS

    {R 299.9605 and 40 CFR 264.16(a), which is ABR in R 299.11003} 

FThe training program must consist of introductory and continuing education training      programs for personnel.  The training programs must be designed, at a minimum, to ensure that facility personnel are familiar with the Contingency Plan (Module A7) Implementation, and are able to respond effectively to emergencies.  The training programs must include instruction on hazardous waste procedures, and must enable employees to responsibly perform their duties in hazardous waste management activities.  Examples of topics which must be covered in the training programs include: 

Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment Key parameters for automatic waste feed cutoff systems Communications or alarm systems Response to fires or explosions Response to groundwater contamination incidents Shutdown of operations

A10.A(1) Outline for introductory training

Program

{R 299.9605 and 40 CFR 264.16(a)(1) and 264.16(d)(3), which are ABR

in R 299.11003} 

FInclude an outline here for introductory training program(s). 
 
 

A10.A(2) Outline for continuing education

{R 299.9605 and 40 CFR 264.16(a)(1) and 264.16(d)(3), which are ABR

in R 299.11003} 

FInclude an outline here for continuing education program(s). 
 
 

A10.B  PERSONNEL SUBJECT TO TRAINING REQUIREMENTS

            {R 299.9605 and 40 CFR 264.16(a),(d), which are ABR in R 299.11003}  

A10.B(1) Job Titles and Job Descriptions

            {R 299.9605 and 40 CFR 264.16(d)(1),(2), which are ABR in

R 299.11003} 

FIdentify by job titles, and job descriptions, who will be subject to the personnel training

program. 
 
 

A10.B(2) Description of how training is designed to meet  actual job tasks

{R 299.9605 and 40 CFR 264.16(a)(1) and (d)(3), which are ABR in

R 299.11003} 

FIdentify the type of training to be given to each affected position, and how the training

will enable the employee in that position to adequately conduct hazardous waste procedures relevant to the position. 
 
 

A10.C  FREQUENCY OF REQUIRED TRAINING

            {R 299.9605 and 40 CFR 264.16(b), (c) which are ABR in R 299.11003} 

A10.C(1) Initial Training

            {R 299.9605 and 40 CFR 264.16(b), which is ABR in R 299.11003} 

FPersonnel must complete introductory training within six months of their employment,

or assignment to a new position.  Employees must not work in unsupervised positions until they have completed the training. 

A10.C(2) Continuing Education

            {R 299.9605 and 40 CFR 264.16(c), which is ABR in R 299.11003} 

FPersonnel must take part in continuing education training annually.  

A10.D  TRAINING DIRECTOR

            {R 299.9605 and 40 CFR 264.16(a)(2), which is ABR in R 299.11003} 

FThe facility must identify who will conduct the training programs, and qualifications

which demonstrate that the training director is knowledgeable of hazardous waste management procedures. 
 
 

A10.E  DOCUMENTATION AND RECORDKEEPING REQUIREMENTS

            {R 299.9605 and 40 CFR 264.16(d), (e), which are ABR in R 299.11003} 

A10.E(1) Documentation

            {R 299.9605 and 40 CFR 264.16(d), which is ABR in R 299.11003} 

FThe facility must clearly demonstrate how the following documents and records will be

maintained: 
 

A10.E(1)(a) Job titles and names of employees filling each job

            {R 299.9605 and 40 CFR 264.16(d)(1), which is ABR in R 299.11003} 

A10.E(1)(b) Written job descriptions

{R 299.9605 and 40 CFR 264.16(d)(2), which is ABR in R 299.11003} 

A10.E(1)(c) Written description of type and amount of training given to each position

{R 299.9605 and 40 CFR 264.16(d)(3), which is ABR in R 299.11003} 

A10.E(1)(d) Documentation that training has been given to, and completed by, facility personnel

{R 299.9605 and 40 CFR 264.16(d)(4), which is ABR in R 299.11003} 

A10.E(2) Recordkeeping

            {R 299.9605 and 40 CFR 264.16(e), which is ABR in R 299.11003} 

FThe facility must demonstrate that training records will be kept for (1) current

personnel until closure of the facility; and (2) former personnel for at least three years.

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