Washington State Department of Ecology: Pollution Prevention Planning Requirements

April 1992
F-WRRLC-92-117

Rule Adopted for Preparation of Pollution Prevention Plans

In 1990, the Legislature passed ESHB 2390 which established state policy and goals to encourage the reduction of hazardous substance use and hazardous waste. The primary method the law utilizes to achieve this goal is by requiring certain hazardous waste generators and hazardous substance users to prepare plans for voluntarily reducing use of hazardous substances and hazardous waste generation. Plans must consider management options based on the following priorities:

As mandated in the law, the Department of Ecology developed a rule to implement the requirements. Adopted as Chapter 173-307 WAC, the rule establishes the specific planning requirements for developing plans.

Who Must Prepare a Plan?

Facilities required to report under SARA Title III, Section 313, or who generate in excess of 2,640 pounds of hazardous waste per year are required to prepare comprehensive hazardous substance use/hazardous waste reduction plans.

What Information is Required in a Plan?

The planning requirements are detailed in WAC 173-307-030. The plan is to be organized into four parts.

Part One: Management Support/General Overview

The plan must include:

  1. A policy statement which shows management and corporate support for the planning effort
  2. Scope and objectives
  3. A description of the facility, products made or services provided, and levels of production or service activity
  4. An overview of the processes utilized
  5. Information on total annual pounds of hazardous waste generated and/or toxic releases
  6. A description of current reduction, recycling and treatment activities.

Part Two: Opportunities/Goals/Implementation

This part of the rule describes the steps and level of detail required to develop the main text of the plan. Planning requirements include the following:

  1. An identification of hazardous substances used and hazardous waste generated.
  2. A detailed description of each process in the facility.
  3. An identification of all reasonable opportunities for further reduction, recycling, and treatment activities.
  4. An evaluation of the identified opportunities.
  5. A selection of opportunities to be implemented.
  6. A policy statement that risks will not be shifted.
  7. Specific performance goals.
  8. A five year implementation schedule.

Part Three: Financial Description of the Plan

The financial description identifies costs and benefits realized from implementing the selected opportunities. A description of the accounting systems used must be included.

Part Four: Personnel and Employee Requirements

Part Four includes a description of personnel training and employee involvement programs. Employees are encouraged to provide input during the planning process.

An Executive Summary is Submitted

The plan itself remains at the facility, but must be available for review by Ecology staff. An executive summary must be submitted to Ecology by the plan completion date.

Plan Due Dates

Completion dates for the plans are:

Annual Progress Reports are Required

Progress reports must be submitted to the Department annually on September 1 following the due date of the plan. The purpose of the progress report is to provide information on quantities of hazardous waste and hazardous substances reduced in the prior twelve month period.

Plan Review Process

Department of Ecology staff may review plans, executive summaries, and annual progress reports to determine adequacy. This determination will be based solely on whether the documents are complete and prepared in accordance with the requirements. If there are deficiencies, Ecology reviewers will list them and provide notification to the user or generator. Penalties may be assessed for non-compliance.

Technical Assistance

Ecology staff are available to provide information and answer questions on these new regulations.

Contact:

Northwest Regional Office
Department of Ecology
3190 - 160th Avenue SE
Bellevue WA 98008-5452
(206) 649-7040
Eastern Regional Office;
Department of Energy
N. 4601 Monroe, Suite 100
Spokane WA 99205-5301
(509) 456-6114

Southwest Regional Office
Department of Ecology
Waste Reduction & Recycling
6101 Capitol Boulevard
(206) 664-0996
Central Regional Office
Department of Ecology
106 South 6th Avenue
Yakima WA 98902
(509) 454-7208


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Last Updated: November 1, 1995