Environmental Management System
Pollution Prevention Regulations and Policies
The following table provides direct legal and policy drivers that require the implementation of Pacific Northwest's Pollution Prevention Program and its elements.
| Function | Driver | Effect |
|---|---|---|
| Federal Procurement Guidelines | Resource Conservation and Recovery Act (RCRA) 40 CFR 247 | Requires procurement of recovered materials by federal facilities and contractors |
| Hazardous Waste Generator Manifest Certification | RCRA 40 CFR 262, 264-265 | Requires generator to put in place a hazardous waste minimization program |
| Hazardous Waste Generator Biennial Report Certification | RCRA 40 CFR 262, 264-265 | Requires generator to put in place a hazardous waste minimization program |
| Hazardous Waste Part B Permit Conditions | RCRA 40 CFR 270 | Requires generator to put in place a hazardous waste minimization program |
| Toxic Release Inventory Reporting | Emergency Planning and Community Right-to-Know Act
(EPCRA)
40 CFR 372 |
Establish reporting requirements for the use, storage, and on-site and off-site transfers of hazardous and toxic chemicals |
| National Pollution Prevention Policy | Pollution Prevention Act (PPA) 42 USC 13101 | Requires federal facilities to deploy pollution prevention as the first choice in environmental management |
| Toxic Release Inventory Reporting | PPA 42 USC 13106 | Expands EPCRA reporting requirements to include source reduction and recycling information |
| Clean Fuel Fleet Program | Clean Air Act (CAA)
40 CFR 88 |
Requirement to meet clean-fuel fleet vehicle emissions standards |
| Protection of Stratospheric Ozone | CAA 40 CFR 82 | Phase-out of CFCs, halons, and carbon tetrachloride; limit on emissions of ozone-depleting substances during the servicing, use and disposal of equipment containing those substances |
| Radiation Protection Programs | 10 CFR 835 | Requires the establishment of goals and performance indicators for the minimization of radioactive waste. It also requires a waste minimization program that will reduce the generation of radioactive waste and spread of contamination from Contamination, High Contamination or Airborne Radioactivity Areas. |
| Storm Water Pollution Prevention Plan | Clean Water Act (CWA) 40 CFR 122 | Requires that industrial Storm water discharge facilities have an on-site pollution prevention plan |
| Spill Prevention, Control, and Countermeasures Plan | CWA
40 CFR 110.112 |
Direct dischargers must have plans to prevent and respond to spills. |
| Environment, Safety, and Health Policy for DOE | DOE Order 450.1 | Requires Pollution Prevention Plans, Annual Waste Reduction Reports, and a Pollution Prevention Awareness Program |
| Radioactive Waste Management | DOE Order 435.1 | Requires Waste Management Plans including actions to minimize radioactive waste generation. Requires each DOE LLW generator preparing a design for a new process or process change to incorporate principles into the design that will minimize the generation of LLW. |
| Federal Fleet and Transportation Efficiency | Executive Order (EO)
EO 13149 (April 21, 2000) |
Requires reductions in the amount of petroleum fuel used in federal fleet vehicles, including contractor-operated vehicles. |
| Leadership in Environmental Management | EO 13148
(April 21, 2000) |
Requires reductions in use of specified toxic chemicals, development of environmental management systems, and environmental performance measures. |
| Developing and Promoting Biobased Products and Energy | EO 13134
(August 12, 1999) |
Directs increased federal planning and research on biobased products and calls for demonstration projects and private sector incentives. |
| Efficient Energy Management | EO 13123
(June 3, 1999) |
Requires energy audits, procurement of Energy Star products, purchase of electricity from renewable sources, and achievement of energy use reductions per unit floor space for federal facilities. |
| Waste Prevention, Recycling, and Federal Acquisition | EO 13101 (September 14, 1998) | Requires procurement of environmentally-preferable products and services and establishment of pollution prevention and recycling programs |
| Dangerous Waste Regulations | WAC 173-303 | Requires generator certification that a waste minimization program is in place for dangerous and extremely hazardous waste. |
| Pollution Prevention Planning | WAC 173-307 | Requires submission of plan describing efforts made to modify products and processes to reduce reliance on hazardous materials and generation of waste. |
| DOE Pollution Prevention and Energy Goals | Secretary of Energy Memorandum
November 12, 1999 |
Sets Complex-wide pollution prevention and energy efficiency goals and requires that site-specific goals be established and progress tracked. |
| DOE Pollution Prevention Program Guidance | DOE Pollution Prevention Program Plan, 1996 | Provides contractors with specific guidance on meeting DOE HQ pollution prevention expectations. |
| Sewage System Discharge | City of Richland Sewage Discharge Permits | Limits materials that can discharged in sinks and drains, or that might otherwise enter the Richland sewage system. |
| Air Releases | WAC 173-480 | Establishes emissions limits for air releases, including radionuclides. |
| Conduct of Operations | DOE RL Contract
DE-AC06-76RL01830 |
Requires that PNNL perform activities in conformance with environmental commitments, including pollution prevention. |
| Additional Incentives for Pollution Prevention at PNNL | ||
| CERCLA Financial Liability | Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) | Generators reduce future liability by reducing waste |
| National Environmental Policy | National Environmental Policy Act (NEPA)
10 CFR 1021 |
Requires environmental review of all federal actions, including federal contractors. |
| National Energy Policy | Energy Policy Act | Promotes energy conservation and efficiency and promote renewable energy. |
| Handling and Transportation Requirements | Hazardous Materials Transportation Act (HMTA)
49 CFR 171-180 |
Safety requirements raise costs of handling and transporting waste |
| Handling Requirements | Occupational Safety & Health Act (OSHA)
29 CFR 1910 |
Safety requirements raise costs of handling and transporting waste |
| Environmental Taxes | Revenue Reconciliation Act (RRA) | Taxes on ozone-depleting chemicals |
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