Pollution Prevention Requirements for Hazardous Waste Generators

Some states require that all generators of hazardous waste who are required to pay a fee under the Resource Conservation and Recovery Act (RCRA) submit a written description of any program to minimize or reduce the volume and quantity or toxicity of such wastes. A specific summary of some of the major points follows.

Federal RCRA Waste Minimization Requirements

40 CFR 262.41 (a)(6) & (7) requires annual description of efforts and achievements to reduce the volume and toxicity of the waste generated. 40 CFR 262.20 This Manifest Certification requires the generator to certify that there exists a "program in place" to reduce the volume or toxicity of waste generated to economically practical degree. Similar requirements exist for operators of hazardous waste treatment, storage, and disposal facilities (TSD facilities).

Compliance Procedures for Large and Small Quantity Generators

Large Quantity Hazardous Waste Generators: Annual Reporting Requirements: Currently, the annual waste minimization reporting requirements are fulfilled through the EPA Hazardous Waste Report that generators submit. This form includes questions on waste minimization assessments, source reduction and recycling activities, quantities of waste managed, and factors that inhibit waste minimization activities. Waste Inspection Requirements: A large quantity generator is generally expected to demonstrate during a hazardous waste inspection a written waste minimization plan and visual evidence that plan components are being implemented in a "program in place." Generators are usually encouraged to use EPA's interim final guidance (Federal Register, May 28, 1993) to enhance their program, but most state programs do not require the generator to explicitly follow this EPA guidance. The program must be updated annually. Small Quantity Hazardous Waste Generators: The hazardous waste manifest also contains a certification that the small quantity generator has made a good faith effort to minimize waste (40 CFR 262.20 Manifest Certification).

Other Pollution Prevention Requirements
Pollution Prevention Requirements for Air Quality

Many states require that any business which is required to hold a permit submit a written description of current and projected plans to reduce the emission or air contaminants under the permit by source reduction or recycling. Existing facilities quite often must submit a summary of activities related to source reduction and recycling, a quantification of air emissions reduced and material recycled during the previous year, and a summary of plans for further source reduction and recycling; or, for a new facility, the industry must provide a summary of activities related to and plans for source reduction and recycling.

Pollution Prevention Requirements for Wastewater Discharges

Many states also require that any business that is required to hold a permit submit to the a written description of current and projected plans to reduce the discharge of waste and pollutants by source reduction or recycling. Also, the Industrial Pretreatment Rule authorizes directors of publicly owned treatment works (POTW's) to require Significant Industrial Users (SIUs) to develop a waste reduction plan and implement waste reduction techniques and technologies.

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