Under the regulations of the Resource Conservations and Recovery Act, commonly referred to as RCRA, facilities are classified as Large Quantity, Small Quantity or Conditioanlly Exempt Small Quantity Generators of hazardous waste depending upon the type and quantity of hazardous wastes generated on a monthly basis.

Facilities that generates greater than 2200 pounds of hazardous waste per month are classified as Large Quantity Generators.  Facilities that generate less than 2200 pounds, but more than 220 pounds of hazardous waste per month are classified as Small Quantity Generators.  Facilities that generate less than 220 pounds per month of hazardous waste are classified as Conditionally Exempt Small Quantity Generators.  Applicable requirements and restrictions as the most stringent and restrictive for Large Quantity Generators and the least stringent and restrictive for Conditionally Exempt Small Quantity Generators.  The costs of hazardous waste handling are directly related to a facilities generator status.  The more waste you generate, the greater the associated costs for compliance and disposal.  So from an environmental perspective, as well as a business perspective, there is clearly incentive to minimize the amount of hazardous waste generated.

One of the major accomplishments resulting from pollution prevention (P2) efforts relates to the hazardous waste generator status of NPPD’s facilities.  Through diligent efforts to minimize the generation of hazardous waste at NPPD’s major facilities, NPPD has been able to achieve a Conditionally Exempt Generator status at all of our facilities.  One of the more significant changes in “how we do business” that has helped to achieve this milestone has been in our use of solvents associated with partswashers.  By closely examining and evaluating the types of parts we clean, the types of solvents we use, and the types of partswashers we use, we have been able to greatly reduce the amount of solvents we purchase and extend the life of the solvent we do purchase.  This has resulted in a significant reduction in the amount of hazardous solvent waste generated.

NPPD has also incorporated a philosophy of including waste minimization into our work planning, particularly as related to planning for maintenance outages at our major facilities.  By evaluating the type of work that will be done, we can anticipate the types and volumes of waste that may be generated, particularly hazardous wastes, and look for opportunities to eliminate or minimize the generation of wastes.