This appendix describes the Waste Minimization Report Condition in Ohio Hazardous Waste Facility Installation and Operation Permits and describes references that can be used to complete a Waste Minimization Report. The appendix also compares the elements of a pollution prevention/waste minimization program in this guidance manual, U.S. EPA's interim final guidance to hazardous waste generators, and U.S. EPA's Facility Pollution Prevention Guide.
Owners and operators of permitted hazardous waste treatment, storage and disposal facilities are required to certify annually that they have a waste minimization program in place, and are required to include this certification in their operating record. The Ohio Administrative Code (OAC 3745-54-73 (B)(9)) states that the operating record must include:
"A certification by the permittee, no less often than
annually, that the permittee has a program in place to
reduce the volume and toxicity of hazardous waste that he
generates to the degree determined by the permittee to be
economically practicable; and the proposed method of
treatment, storage, or disposal is that practicable
method currently available to the permittee which
minimizes the present and future threat to human health
and the environment."
Ohio Hazardous Waste Facility Installation and Operation Permits contain a condition that requires a Waste Minimization Report. The waste minimization report condition is given in Table C-1. The Waste Minimization Report is a written document that the permittee must use to demonstrate compliance with the certification requirement to have a waste minimization program in place.
Ohio EPA is authorized to administer the RCRA program in Ohio, including issuing hazardous waste treatment, storage and disposal facility permits. Ohio EPA's authorized RCRA program operates in lieu of U.S. EPA's program. Ohio EPA's authority includes conditional authority for waste minimization condition in permits. For informational purposes only, facilities should note that U.S. EPA's Region V office has developed RCRA waste minimization permit language, evaluation criteria, and checklists (December, 1992). Region V has also developed two guidance documents related to their permit language. Region V's Recommended Minimum Standards, Hazardous Waste Reduction Plan/Waste Reduction Implementation Report Evaluation Criteria, is to be used by Permittees to develop plans and reports, and by permit writers to evaluate the plans and reports. Region V's Region 5 Hazardous Waste Reduction Plan/Waste Reduction Implementation Report Guidance is designed to aid the facility in the development of these documents.
Waste Minimization Report
OAC Rule 3745-54-73
(a) The Permittee shall submit a Waste Minimization Report describing the
waste minimization program required by O.A.C. 3745-54-75 (H), (I), and
(J); O.A.C. 3745-54-73 (B) (9); and, O.A.C. 3745-52-20 (B) at least once
every two years. The provisions of O.A.C. 3745-54-75 (H), (I), and (J);
and O.A.C. 3745-54-73 (B) (9) must be satisfied annually.
(b) In completing this report, the Permittee shall refer to the following
information: instructions prepared by the Ohio EPA for completing the
Waste Minimization Annual Report required by O.A.C. 3745-54-75 (H), (I),
and (J); the Federal Register notice of May 28, 1993, vol. 58, p. 31114,
"Interim Final Guidance: Guidance to Hazardous Waste Generators on the
Elements of a Waste Minimization Program"; U.S. EPA's "Facility
Pollution Prevention Guide" (EPA/600/R-92/088) May, 1992; Ohio EPA's
"Ohio Pollution Prevention and Waste Minimization Planning Guidance
Manual"; and any subsequent updates. The Waste Minimization Report
prepared by the permittee should incorporate the phases outlined in the
"Facility Pollution Prevention Guide" including planning and
organization, assessment, feasibility analysis, implementation,
measuring progress, and maintaining the program. Similar content and
additional discussion are found in Ohio EPA's "Ohio Pollution Prevention
and Waste Minimization Planning Guidance Manual."
(c) The Permittee shall submit the Waste Minimization Report to the Director
within one-hundred and eighty days (180) of journalization of this
permit, and shall submit updates to this report biennially thereafter.
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The waste minimization permit condition lists four references that permittees shall refer to when completing their waste minimization reports. These references are briefly described here.
a) Instructions prepared by the Ohio EPA for completing the Waste Minimization Annual Report required by OAC 3745-54-75 (H), (I), and (J).
The instructions include definitions for waste minimization, recycling, and source reduction, examples of waste minimization activities, and a general list of waste minimization activities (see activity codes list).
b) Federal Register notice of May 28, 1993, vol. 58, p. 31114, "Interim Final Guidance: Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program."
The notice is intended to provide guidance to hazardous waste generators and treatment, storage and disposal facilities about what constitutes a waste minimization program in place for certification under HSWA. An effective waste minimization program should include each of the general elements listed below, although some of these elements may be implemented in different ways depending on the preferences of individual companies. The notice provides specific explanations and examples for each of the elements. The full text of this notice is included as a part of Appendix C.
1) Top management support
2) Characterization of waste generation and waste management
costs
3) Periodic waste minimization assessments
4) A cost allocation system
5) Encourage technology transfer
6) Program implementation and evaluation
c) U.S. EPA's Facility Pollution Prevention Guide (EPA/600/R-92/088) May, 1992
U.S. EPA's Facility Pollution Prevention Guide concentrates on procedures that motivate people to search, screen, and put into practice measures involving administrative, material, or technology changes that result in decreased waste generation. The manual is also a source of concepts and ideas for developing and implementing a pollution prevention program. The manual lists several steps in a program, including planning and organization, assessment, feasibility analysis, implementation, measuring progress, and maintaining the program. The Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual uses the pollution prevention program steps (with limited modifications) outlined in U.S. EPA's Facility Pollution Prevention Guide.
d) Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual
The Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual (this document) should also be used as a reference when writing a Waste Minimization Report. Two tables are included in this manual that compare elements of different manuals and guidelines to U.S. EPA's Facility Pollution Prevention Guide (refer to Table C-2, Comparison of elements of a pollution prevention program in U.S. EPA's Facility Pollution Prevention Guide to elements of a waste minimization program in U.S. EPA's interim final guidance to hazardous waste generators; and to Table C-3, Comparison of elements of a pollution prevention program in U.S. EPA's Facility Pollution Prevention Guide to elements of a pollution prevention/waste minimization program in the Ohio Pollution Prevention and Waste Minimization Planning Guidance Manual). These comparison tables illustrate that although the names of elements and order of elements may be different, the manuals and guidelines essentially describe the same kind of pollution prevention and waste minimization programs.
The Waste Minimization Report must be specific and should include the phases outlined in U.S. EPA's Facility Pollution Prevention Guide. However, operations and processes at different facilities may be quite diverse. Because waste minimization activities are dependent on the operations and processes, waste minimization reports will vary and may be tailored to individual facilities.
Commercial treatment, storage and disposal facilities and research and development facilities have different constraints on both the type and amount of material inputs to their facilities that limit their options for pollution prevention. Commercial treatment, storage and disposal facilities are in business to take a variety of wastes from generators. Research and development facilities work with a variety of materials and the types of materials that will be used (and subsequent waste generated) in a specific project are not always identified before a project starts. Some pollution prevention projects may require changes in the facility's hazardous waste permits. The permitting process can be lengthy and may delay implementation of the pollution prevention projects.
While there are numerous pollution prevention opportunities at such facilities, their pollution prevention plans and programs should reflect the above constraints and the nature of materials input. Because of these constraints, pollution prevention plans and programs for these facilities may be less extensive than plans and programs for other business or government facilities. Pollution prevention assessments can still be conducted, giving special consideration to assessing support departments that are common to many facilities (see Chapter 12, Table 2). For basic concepts on pollution prevention options, research and development facilities can refer to Ohio EPA's Fact Sheet 16, Research and Educational Laboratory Waste, and to U.S. EPA's 1990 document Guides to Pollution Prevention: Research and Educational Institutions, EPA/625/7-90/010.
Hazardous waste treatment, storage and disposal facilities have many common activities, some required by hazardous waste regulations, that provide the opportunity for implementing and integrating pollution prevention into the operation of the facility. Several activities are listed here with suggestions for pollution prevention options. Any changes implemented as a result of pollution prevention options must be in compliance with the facility's permit and with applicable environmental regulations.
All facilities must evaluate wastes to determine their characteristics. Procedures for sampling and laboratory analysis can be designed to incorporate pollution prevention.
All facilities must train employees about the operation of the facility and hazardous waste management. Pollution prevention and waste minimization should be an integral part of the training. Employees should be encourage to provide suggestions for pollution prevention projects.
Contingency plans can be written to incorporate pollution prevention options. Plans on responding to emergencies and spills should consider responses that will address the situation and at the same time minimize the use of resources and minimize waste generation. Proactive measures against leaks and spill should be incorporated in plans for these facilities.
All facilities have general inspection requirements and emergency preparedness and prevention requirements. Facilities could use these inspections and requirements as opportunities to continually look for pollution prevention aspects of daily operations.
All facilities receive waste and manage waste in containers, tanks, or pipelines. Standardized practices for preventing pollution can be incorporated in loading/unloading procedures, storage procedures, and daily operations of waste management units.
Treatment, storage and disposal activities should be assessed as unit processes by following the steps outlined in Chapter 9 of this manual. Treatment, storage and disposal activities are the "production" processes of a hazardous waste facility and can be evaluated in a similar manner. For example, a different flocculent could be used in a wastewater treatment operation that may result in less solids being generated for later management or disposal.
The following example illustrates some of the challenges facing a commercial solvent reclaimer. The spent solvent waste generators may determine, to a large extent, the amount of waste generated by the solvent reclaimer when processing a given waste stream. The annual volume of hazardous waste generated by the reclaimer is dependent on the percentage of reclaimable material in the hazardous waste and the total hazardous waste received for the year. The reclaimer's annual receipts are dependent on the generators' reduction of generated spent solvent waste and the reclaimer's competitive market position for that business year.
The reclaimer can work to improve operating efficiencies and improve reclamation processes at the reclamation facility as part of a pollution prevention program. For example, the reclaimer could survey the entire process, look for areas and equipment that might have fugitive emissions, and institute equipment and operating practices to reduce or eliminate emissions. The reclaimer could use statistical process control techniques to determine the optimum operating conditions for distillation equipment. The reclaimer might also want to work with the generators to educate them on ways to consolidate waste streams and reduce waste generation in an effort to maximize recovery of spent solvent. Although working with customers to reduce waste at the source might be very desirable from the reclaimer's and customers' points of view and is strongly encouraged by the State of Ohio, this activity is not required for hazardous waste treatment, storage and disposal facilities.
The following example illustrates some of the challenges facing a specialty chemicals research and development facility. The "products" of the research and development facility are knowledge (formulations for new chemical products) and waste. Experimental products developed during the research process cannot be sold; they must be managed as waste. Research and development of new chemicals is a constantly changing field and highly individualized. Constantly changing experiments make it difficult to define production units. It is also difficult to meaningfully determine a waste per unit product index when the product undergoes frequent changes.
Research and development facilities might define "research" as a process, and concentrate on how to make pollution prevention, particularly source reduction, part of and integrated into the design of research processes. Engineers and chemists can work with statisticians to design experiments to reduce waste. Procedures for procuring raw materials can be established. Information about past experiments can be made easily accessible by computer so that research chemists do not repeat old work. Computer modelling can help to predict experimental outcomes and product performance.
| Facility Pollution Prevention Guide Pollution Prevention Program | Hazardous Waste Generators Waste Minimization Program |
|---|---|
Establish the pollution prevention program
| Top management support
|
Organize the program
| Top management support
|
Do preliminary assessment
| Characterization of waste generation and waste management costs |
Write program plan
| "The generator or treatment, storage, or disposal facility should document its program (in writing)..." (see note 3) |
Do detailed assessment
| Periodic waste minimization assessments
|
Define pollution prevention options
| Periodic waste minimization assessments |
Do feasibility analysis
| Encourage technology transfer Periodic waste minimization assessments
|
| Write assessment report | "The generator or treatment, storage or disposal facility should document its program (in writing)..." (see note 3) |
Implement the plan
| Top management support
|
Measure progress
| Program implementation and evaluation |
| Maintain the pollution prevention program | Top management support
|
Notes:
| Facility Pollution Prevention Guide Pollution Prevention Program | State of Ohio Pollution Prevention/Waste Minimization Program |
|---|---|
Establish the pollution prevention program
| Establish the pollution prevention program
|
Organize the program
| Organize the pollution prevention program
|
Do preliminary assessment
| Do a preliminary assessment
|
Write program plan
| Write the pollution prevention program plan
|
Do detailed assessment
| Do a detailed assessment
|
Define pollution prevention options
| Define pollution prevention and waste minimization options
|
Cost considerations
| |
Do feasibility analysis
| Do feasibility analysis
|
| Write assessment report | Write the assessment report |
Implement the plan
| Implement the pollution prevention plan
|
Measure progress
| Measure progress: Program and project evaluation
|
| Maintain the pollution prevention program | Maintain the pollution prevention program |
Notes:
This reference is not included here in this Web version. You may check the U.S. EPA Web site for it.