208
Toxic Chemicals
The P2 plan must contain
• A list of all hazardous wastes and TRI chemicals
• The activities that generate the waste or TRI chemicals
• An explanation of P2 projects
• An implementation schedule
• The measurable P2 goals
• An employee awareness program
• A P2 plan executive summary
The TCEQ offers technical assistance with Waste Reduction Policy Act (WRPA)
applicability, planning, and reporting requirements, including a planning tool that
provides step-by-step assistance in developing and printing a complete P2 plan.
The tool includes the option to select from a list of P2 practices that TCEQ has seen
work at other facilities (TCEQ 2009).
MINNESOTA
The Minnesota Toxic Pollution Prevention Act (TPPA) requires that most companies subject to TRI Form R reporting must write plans for reducing the emissions
of Form R chemicals. P2 plans are also required of companies participating in the
Minnesota Pollution Control Agency (MPCA) Environmental Auditing (Green Star
Award) Program (Minnesota Technical Assistance Program 2008).
The P2 plan must contain the following:
• A policy statement expressing management support for eliminating or reducing the generation or release of toxic chemicals (pollutants) at the facility
• A description of the current processes generating or releasing toxic chemicals specifying the types, sources, and quantities of toxic chemicals being
generated or released by the facility
• A description of the current and past practices used to eliminate or reduce
the generation or release of toxic pollutants at the facility and an evaluation
of the effectiveness of these practices
• An assessment of the technically and economically feasible options available to eliminate or reduce the generation or release of toxic chemicals at
the facility, including options such as changing the raw materials, operating techniques, equipment, and technology; personnel training; and other
practices used at the facility
• Objectives and a schedule for achieving those objectives
The TPPA requires companies to express objectives in numeric terms if technically and economically feasible. Otherwise, nonnumeric objectives can be stated;
however, they must include a clearly stated list of actions designed to lead to establishing numeric objectives as soon as they become feasible. Facility P2 plans must at
a minimum contain objectives for each chemical for which a facility submits a TRI
Form R report. The plan must also include
Précédent

- 235/352

Suivant