The Business Environmental Program provides free and confidential environmental management assistance to business and government operations in Nevada. The Program specializes in cost effective strategies to reduce hazardous materials and waste generation, conserve water and energy, minimize air emissions, and maintain compliance with environmental requirements. The program provides training, on-site consultation, assistance over the phone and through its website and publications.
Air (Washoe County)
|What is RCRA?||What is Waste Minimization?||Do I need a permit?|
|Monthly Generator Status Questions||Benefits of Waste Minimization?||Local asbestos regulations|
|Recordkeeping Questions||What is Pollution Prevention (P2)?||How do I register an air pollution complaint?|
|What is the difference between Waste Minimization and P2?|
RCRA stands for the Resource Conservation and Recovery Act of 1976. Congress outlined four major programs in RCRA, including:
Question: An individual generates 75 kg of non-acutely hazardous waste each month from January to November. Instead of shipping this waste off site for disposal, the generator accumulates the waste on site in containers. In December, the generator produces an additional 75 kg of non- acutely hazardous waste and hires a transporter to ship a total of 900 kg off site for treatment and disposal. Is this generator subject to the conditionally exempt small quantity generator (CESQG) requirements or the small quantity generator (SQG) regulations during the month of December?
Answer: This generator is subject to the CESQG regulations during the month of December because it generated no more than 100 kg of non-acutely hazardous waste in that month and accumulated no more than 1,000 kg of non-acutely hazardous waste on site at any one time (40 CFR §261.5). Generator status is based upon the amount of waste generated per calendar month and the total amount accumulated on site at any one time. The amount of waste shipped off site at any one time does not affect generator status, provided the waste is shipped off site prior to exceeding accumulation limits. If the generator accumulates more than a total of 1,000 kg of hazardous waste on site at any one time, then it would be subject to all provisions applicable to SQGs, including the § 262.34(d) accumulation standards.
In addition, this individual can generate 1 kg or less of acutely hazardous waste per calendar month and remain subject to the reduced CESQG regulations for the acutely hazardous waste, provided that no more than 1 kg of acutely hazardous waste is accumulated on site at any one time. If the amount generated or accumulated on site exceeds these thresholds, then all of the acutely hazardous waste would be subject to full regulation as applicable to large quantity generators (§261.5(e)).
Scenario: An individual operates a dry cleaning business that has been generating hazardous waste since 1980. A new owner buys the facility in June 2003 and assumes the generator responsibilities, which includes keeping records of hazardous waste activities (e.g., signed manifests) for at least three years from the time the waste was first sent off site (40 CFR Section 262.40).
Question: Must the new owner or operator keep the records from the previous generator’s activities for a period of three years or does the new owner or operator begin the recordkeeping process on the date the individual becomes the generator (i.e., June 1, 2003)?
Answer: The new owner or operator must maintain records from the previous three years of activities at the site, not three years from the date on which the individual assumes the generator responsibilities. The requirement to have generators retain records of previous site activity for three years is not an unreasonable burden since most generators opt to keep copies for their own records. These records may demonstrate proper management of the waste by the generator should there be a problem in subsequent transportation, handling, or disposal (51 FR 10146, 10159; March 24, 1986). Therefore, in this scenario, records of hazardous waste sent off site from this facility in March 2002, prior to the ownership change, should remain in the new owner’s records until March 2005
Waste Minimization is EPA’s preferred approach to protecting the environment. It refers to the use of source reduction and/or environmentally sound recycling methods prior to treating or disposing of hazardous wastes. Waste minimization includes: source reduction practices that reduce or eliminate waste generation at the source and environmentally sound recycling practices where source reduction is not economically practical. Waste minimization does not include waste treatment, i.e., any process designed to change the physical, chemical, or biological character or composition of a hazardous waste, or waste disposal. For example, compacting, neutralizing, diluting, or incineration are not waste minimization practices.
Source reduction includes any practice that reduces the quantity and/or toxicity of pollutants entering a waste stream prior to recycling, treatment, or disposal. Examples include: equipment or technology modifications, reformulation or redesign of products, substitution of less toxic raw materials, improvements in work practices, maintenance, worker training, and better inventory control.
Recycling includes the use, reuse and/or reclamation of waste residuals (that may be designated as a hazardous waste) or materials in a hazardous waste. A material is “used or reused” if it is used as an ingredient in an industrial process to make a product or if it is used as an effective substitute for a commercial product. A material is “reclaimed” if it is processed to recover a usable product, or if it is regenerated.
Waste minimization not only protects the environment; it also makes good economic and business sense. For example, reducing waste generation through waste minimization has helped some companies change their RCRA regulatory status from large quantity generators (1000 or more kilograms of hazardous waste generated per month) to small quantity generator (between 100 and 1000 kg of hazardous waste generated per month), or to conditionally exempt small quantity generators (up to 100 kg of hazardous waste generated per month). Some have managed to eliminate the generation of hazardous waste and avoid RCRA regulatory requirements altogether.
Source reduction and/or environmentally sound recycling, reuse, and reclamation practices have helped many organizations reduce:
At the same time, waste minimization can improve:
Pollution Prevention, often called P2, means source reduction, or preventing pollution at its source, before it is generated. It includes any practice that reduces the quantity and/or toxicity of pollutants entering a waste stream prior to recycling, treatment, or disposal. Examples include equipment or technology modifications, reformulation or redesign of products, substitution of less toxic raw materials, improvements in work practices, maintenance, worker training, and better inventory control.
Waste Minimization is a term found in the Resource Conservation and Recovery Act (RCRA) that refers to source reduction and environmentally sound recycling of RCRA hazardous waste. Pollution Prevention is a term found in the Pollution Prevention Act of 1990 that refers to source reduction of all toxic wastes, including those released to air, water and land resources. Source reduction includes any practice that reduces the quantity and/or toxicity of pollutants entering a waste stream prior to recycling, treatment, or disposal. Examples include equipment or technology modifications, reformulation or redesign of products, substitution of less toxic raw materials, improvements in work practices, maintenance, worker training, and better inventory control.
Environmentally sound recycling includes the use, reuse and/or reclamation of residuals that may be designated as a hazardous waste, or materials in a hazardous waste. A material is “used or reused” if it is used as an ingredient in an industrial process to make a product or, or if it is used as an effective substitute for a commercial product. A material is “reclaimed” if it is processed to recover a usable product, or if it is regenerated.
Is Waste Minimization required by law?
In 1984, amendments to RCRA established the following national policy, making waste minimization the nation’s preferred hazardous waste management practice: “the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of so as to minimize the present and future threat to human health and the environment.” (RCRA Sec.1003[b], 1984.)
RCRA requires facilities that generate or manage hazardous waste to certify that they have a waste minimization program in place that reduces the quantity and toxicity of hazardous waste generated to the extent economically practicable.
In 1990, passage of the Pollution Prevention Act expanded the nation’s waste prevention policy beyond a RCRA-only framework, to minimizing or eliminating toxic releases to all environmental media and natural resources: “The Congress hereby declares it to be the national policy of the United States that pollution should be prevented or reduced at the source whenever feasible; pollution that cannot be prevented should be recycled in an environmentally safe manner, whenever feasible; pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner.” (PPA, Section 6602[b].)
The Pollution Prevention Act has encouraged many organizations to expand their focus from RCRA-only to a multimedia pollution prevention focus. EPA offers a variety of information sources on multimedia pollution prevention.
Many states have also enacted laws that require facilities to complete certain waste minimization activities. Most of these states require facilities to complete a waste minimization plan.
Normally, a business which emits 2 pounds or more per day of “criteria” air pollutants or 1 pound per day or more of “toxic” air pollutants will require a permit to operate. Different types of air pollution control devices are also required for different processes depending upon the size of the operation for compliance with the AQMD regulations. Applications may be obtained by downloading from the District Health Department Web site. For further information, please contact one of our environmental engineers who will help you with the necessary information for application submittal.
The local asbestos regulations essentially mirrors the federal requirements. If you own a commercial building and want to do some remodeling, an asbestos survey will need to be completed by a certified consultant to determine the presence or absence of any asbestos materials. If present, a certified abatement contractor will need to remove the asbestos before the project can proceed. In addition, the property owner will need to obtain an “asbestos acknowledgment” form from the AQMD prior to obtaining a building permit from the local building departments. For further information, please call (775) 784-7200.
Just call (775)784-7200 (24 hours per day) and your complaint will be logged onto an official AQMD complaint form. After that, an air quality specialist will immediately investigate your concerns and determine if there is a violation of the AQMD regulations. If a violation exists, the person or business will be required to correct the problem. A Notice of Violation may also be issued.