Many states have enacted legislation that is not voluntary, particularly those states with an aggressive ecological pres ence. Facilities should consult the pollution prevention legislation in their states on (1) goals, (2) affected chemicals, (3) affected sources, (4) reporting requirements, (5) exemptions, (6) performance measurement basis, (7) deadlines, and (8) other unique features.
Any company responding to the pollution prevention legislation in its state should consider a coordinated approach to satisfy the requirements of the federal programs as follows:
EPA Form R data and state emission data should be carefully reviewed, compared, and reported consistently. Scheduling activities for compliance should be integrated with the EPA's 33/50 program and the CAAA's Early Reduction Program prior to MACT for source reduction to be effective.
The Pollution Prevention Act contains new tracking and reporting provisions. These provisions require companies to file a toxic chemical source reduction and resource recycling report file for each used chemical listed under SARA 313 for TRI reporting under the Federal Emergency Planning and Community Right-to-Know Act (EPCRA). These reports, which do not replace SARA Form R, cover information for each reporting year including:
• The amount of the chemical entering the waste stream before recycling, treatment, or disposal
• The amount of the chemical that is recycled, the recycling method used, and the percentage change from the previous year
• The source reduction practice used for the chemical
• The amount of the chemical that the company expects to report for the two following calendar years
• A ratio of the current to the previous year's chemical production
• Techniques used to identify source reduction opportunities
• Any catastrophic releases
• The amount of the chemical that is treated onsite or offsite
• Optional information about source reduction, recycling, and other pollution control methods used in previous years
In addition, the appropriate state environmental protection agency should be contacted for detailed information on reporting requirements, including the pollution prevention plan (PPP) and PPP summary.
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