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Pollution Prevention Planning
• Achievement of P2 by a more efficient and rational use of hazardous
substances through the use of less-hazardous substances, substitution of
substances, or processes less prone to produce pollution
• Implementation of a soundly planned P2 program without adversely affecting the economic health of the state and those employed by the industries
that use and discharge hazardous substances
Facilities that use, process, or manufacture chemicals listed in the TRI in quantities greater than 10,000 lb, have 10 or more full-time employees, or submit at
least one federal toxic release inventory Form R or Form A to the Environmental
Protection Agency (EPA) are required to implement P2 planning and reporting at
their facility. Facilities subject to P2 planning are required to develop P2 plans every
5 yrs; these remain at the facility. These plans are required to be certified that they
are true, accurate, and complete.
P2 planning documents include a P2 Plan with two parts, a P2 Plan Summary and
a P2 Plan Progress Report.
The P2 Plan Part 1 includes an inventory of hazardous chemical use and NPO,
including the following:
• The name of a top-level company official responsible for the P2 plan and identification of at least one nonmanager employee representative. The top-level
company official must certify that the plan is true, accurate, and complete.
• Identification of the facility-wide chemicals manufactured, stored, or used
at the facility and how the substances flow through the facility. Specifically,
the plan must identify hazardous substance inputs: chemicals that are
stored on the first day of the year, brought into the facility, manufactured,
or recycled on site and reused. The plan must also identify hazardous substance outputs: chemicals stored on the last day of the year, consumed,
shipped off site as/or in product or coproduct, generated as NPO.
• Identification of each process that involves hazardous substances and a
“unit of product” for each process. A unit of product is an amount of useful
product produced. This unit of product allows the facility to report NPO
per unit of useful production. This method of reporting gives the facility
a method of determining how successful its P2 measures have been that is
independent of fluctuations in production levels.
• An inventory of the use of each hazardous substance, the generation of
NPO, the amount recycled, and the amount released for each process.
• An inventory of the wastes generated at each process and how they are handled.
• A financial analysis to evaluate costs for storage or handling; monitoring,
tracking, and reporting; treatment; transportation and disposal; hazardous waste manifesting; permit fees; liability; raw materials; and safety
and compliance.
• An evaluation of the facility-level reductions and increases (use, NPO, and
releases) of TRI substances in comparison to the facility P2 goals.
• An evaluation of process-level reductions and increases (use, NPO, and
releases) of TRI substances in comparison to the process-level P2 goals.
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