SOURCE REDUCTION STRATEGY MANUAL PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES BUREAU OF WASTE MANAGEMENT Robert P. Casey Arthur A. Davis Governor Secretary An Equal Opportunity iAfCimsUve Adon Employar July 1,1992 Revised May 28,1993 . TABLE OF CONTENTS INTRODUCTION .................................................. 1 ELEMENTS OF A SOURCE REDUCTION STRATEGY ............. 2 QUESTIONS AND ANSWERS ..................................... 3 BEYOND THE REGULATIONS .................................... 5 ELEMENTS OF A SOURCE REDUCTION PROGRAM .............. 5 MEASURING SOURCE REDUCTION .............................. 7 SOURCE REDUCTION OPPORTUNITY ASSESSMENT ............. 11 1. Planning and Organization ................................ 11 2. Assessment .............................................. 13 3. Feasibility Analysis ...................................... 20 4. Implementation .......................................... 21 APPENDIX A - A MATERIAL BALANCE APPROACH TO AUDITING APPENDIX B - SRS REPORTING FORMS APPENDIX C- THE REGULATIONS APPENDIX D - ADDITIONAL SOURCES OF INFORMATION Recycled Paper SOURCE REDUCTION STRATEGY MANUAL I INTRODUCTION I Source reduction provides opportunities for industry to achieve both environmental and economic benefit. There is growing awareness that we cannot continue to throw away our valuable resources. Source reduction allows us to provide for our physical needs while preserving the natural environment that is essential for all life. Pennsylvania's residual and hazardous waste regulations focus on source reduction as a means to prevent waste. In the waste management hierarchy, source reduction is of highest priority, followed by use and reclamation, treatment and, finally, disposal as a last resort. Source reduction is the reduction or elimination of waste at the source, usually within the production process. The term includes process modifi- cations, feedstock substitutions, improvements in feedstock purity, improved housekeeping and management practices, increases in the efficiency of machinery, use or reclamation within a process, or any other action that reduces the amount of waste leaving a process. The use or reclamation of waste after it leaves the industrial process is not source reduction. These activities are still preferable to treatment or disposal when conducted in an environmentally sound manner. Dewatering, compaction, or other treatment techniques that prepare the waste for disposal are not source reduction. Any activity that simply transfers the waste to another media, such as air or water, is not source reduction. There are many benefits to be gained from source reduction. Most fundamentally, the generation of waste may indicate some inefficiency or incomplete use of resources. Therefore, to reduce waste is to increase industrial efficiency. As Michael Royston explains in Pollution Prevention Pavs (1979): "Industrial operations begin to affect the environment with the investment decision which is taken internally and subject to internal criteria of financial return and technological feasibility. However, in order to become operational, technology requires resources -- water, air, land, raw materials, energy -- which are to be found in the physical environment. This inter- action between technology and the physical environment results in depletion of resources on the one hand and a build-up of wastes -- pollution -- on the other. The strategy which the modern manager must learn if he is to cope with this double problem is that of a non-waste technology, one which conserves resources, reduces pollution and saves money at the same time." A comprehensive source reduction program can have many benefits, including conservation of raw materials, reduced disposal costs, reduced environmental liability, higher product yields, enhanced corporate image, and reduced environmental compliance burden. -1- This manual has been developed for two purposes. First, it is designed to help waste generators comply with the regulatory requirements for a Source Reduction Strategy. Second, it is intended to help generators achieve substantial environ- mental and economic benefits through significant source reduction accomplishments. I ELEMENTS OF A SOURCE I REDUCTION STRATEGY The new state regulations require that generators of residual and hazardous waste prepare and implement a source reduction strategy (SRS). Generally, the SRS must include: 1. A description of the source reduction achieved during the past five years, including a quantification of the results. This is intended to provide recognition for past achievements and provide a background for the activities planned for the future. Various methods for quantifying the results will be discussed later. 2. A statement that a source reduction program has been established. This may include a statement of corporate source reduction goals or of top management’s commitment to implement the program. 3. A description of what will be done to reduce waste, when the action will be done, and what amount of reduction is anticipated. This is intended to be a simple and direct representation of the results of the assessments made within the facility and the decisions reached regarding source reduction actions that will be taken. If no source reduction action is proposed, the facility is required to submit detailed justification. This must demonstrate that a thorough internal investigation of source reduction opportunities has been completed. This information must include an extensive waste stream characterization, potential source reduction options __ considered, how these options were evaluated, and why each option was not selected. Sufficient detail must be provided to demonstrate the technical or economic barriers that prohibit reductions. The level of detail required to justify not participating in ~ source reduction is substantially greater than preparing and implementing a source reduction plan. -2- I QUESTIONS AND ANSWERS I Who mustprepare the source reduction strategy? The state residual waste regulations require that anyone who generates more than 2,200 pounds of residual waste in any calendar month must prepare a source reduction strategy. The Department has waived the SRS requirements for individual types of waste that are generated in quantities of less than 2,200 pounds per month per generating location (See 8287.51). This waiver will be reevaluated two years after the effective date of the regulations. The purpose of this waiver is to allow generators to concentrate on reducing or eliminating larger waste streams where greater economic and environmental benefits can be attained. The hazardous waste regulations exempt those who generate less than 1,000 kilo- grams of hazardous waste in each month of the year. There is no waiver for small waste streams. When must the SRS beprepared? For residual waste, there is a one year interim period during which special provisions have been made to allow the SRS to consist of a presentation of a firm’s ongoing efforts to reduce wastes. This is described as option 3 on Form 25R (see Appendix B). For example, during the first month after the regulations are published, the strategy might consist of the general information portion of the form plus a list of the members of the assessment team and what they are doing. The SRS should be regularly updated to reflect progress in developing a finished SRS. A final SRS must be available for inspection by July 4,1993. For hazardous waste, the full SRS must be prepared by January 17,1994. There is no one year interim period for the hazardous waste SRS. When must the strategy be submitted to the Department? The SRS must be available for inspection at any time and must be submitted to the Department upon request. The SRS must be submitted to the appropriate DER regional ofice with any Form U (request to process or dispose of an industrial waste at a permitted facility) or Module 1 (request to process or dispose of hazardous waste). The SRS must also be submitted with any application for a permit to treat, process, or dispose of either residual or hazardous waste. -3- How often must the strategy be updated? The SRS must be updated every five years unless an alternate schedule is established in writing by the Department. The SRS must also be updated any time there is a ~ significant change in the type of waste generated or in the manufacturing process. The update should include the progress achieved during the past five years as well as plans for the next five years. ~ Are regular progress reports required? Progress in achieving source reduction will be described as part of the biennial report for residual waste generators. Hazardous waste generators will describe the results in the EPA biennial report. Additionally, the SRS itself includes a description of past achievements. Is an SRS required for each waste stream? Generally, a separate SRS is needed for each waste stream. In some cases, it is acceptable to combine several related waste streams which are generated through the same process where the source reduction actions are the same. For example, one SRS could include plating sludge, spent plating bath solutions, and plating rinse water because they come from the same industrial process line and they can be reduced by common means. Another example is in the generation of waste laboratory reagents removed via lab packs. Although there may be 200 different waste reagents, they can all be reduced through common means such as inventory control