Waste Minimization Plans

In 1989, the California Legislature adopted legislation that requires hazardous waste generators subject to the Hazardous Waste Control Law to consider source reduction as the preferred method of managing hazardous waste.  This law, proposed in Senate Bill 14 (SB 14) as the Hazardous Waste Source Reduction and Management Review Act of 1989, promotes source reduction over recycling and treatment because it avoids the generation of hazardous wastes and its associated management liability.  Hazardous waste generators must determine if they are captured by SB 14 every four years (1990, 1994, 1998, etc.)

Who is affected?
To determine if your operation must comply with the source reduction planning requirements, ask yourself the following questions:

  1. Did my facility generate 12,000 kg/yr or more of hazardous waste or 12 kg/yr or more of extremely hazardous waste in 2014?
  2. Is this waste routinely generated from ongoing operations? (One-time waste streams such as demolition debris from decommissioning a production line are excluded.)
  3. Does my business generate aqueous hazardous waste that undergoes on-site treatment prior to discharge to the sewer? (If you produce over 3,100 gallons/yr you are captured by SB 14.)

If you answer yes to questions 1 and 2, or yes to question 3, you are subject to the SB 14 planning requirements, which include a plan, report and a summary progress report.

What are the Plan, the Report and the Summary Progress Report?

SB 14 requires the preparation of waste minimization documents every four years for those facilities that meet the waste generation thresholds in the reporting year. Generators are required to prepare three documents. The first document is the Hazardous Waste Source Reduction Evaluation Review and Plan (Plan). The Plan is a forward-looking document in which a generator evaluates potential source reduction/waste minimization measures for each “major” waste stream (waste streams that constitute greater than 5% of the total waste generated). The second document is the Hazardous Waste Management Performance Report (Report) and is a backward-looking document that must assess the effect of each source reduction measure implemented since the baseline year (i.e. 1998) on waste generation. The third document, the Summary Progress Report (SPR), consists of two tables and a comment page that summarizes the results of past waste minimization measures and any new waste minimization opportunities that will be implemented in the next four years.

DATES TO REMEMBER:

Plans and reports are to be completed no later than Sept 1, 2015.  The DTSC does have waste generation records based on submitted manifests and does follow up on facilities that failed to file. Don’t let a “failure to file” letter end up on your desk.  Don’t delay, CDMS does offer discounts for those that contract early in the year.

 

The evaluation and documentation required by this regulation are not minor. DTSC requires facilities to go through a specific evaluation process EVERY REPORTING YEAR, and document the evaluation. Simply updating a previous year’s plan does not meet the requirements.

Contact CDMS today for help in:

  • Determining whether or not your facility must comply with SB 14 requirements
  • Determining which waste streams must be included in the Plan
  • Preparing your Plan, Report and Summary Progress Report documents in a professional and efficient manner