If you are an owner or an operator of a facility that generates 25 tons or more per year of hazardous wastes, or a Generator who is required to hold a Part 373 hazardous waste storage, treatment or disposal permit, you may be subject to the New York State Department of Environmental Conservation (NYSDEC) regulations that require Initial Hazardous Waste Reduction Plans (HWRPs), Biennial Updates (BUs) and Annual Status Reports (ASRs) to be prepared and submitted no later than July 1st, 2018.

The HWRP program was established to facilitate reduction of volume or quantity and toxicity of waste in accord with Section 27-0908 of the Environmental Conservation Law (ECL), which states that it is in the best interest of the State to require facilities that release hazardous wastes and toxic substances into the environment to reduce, to the maximum extent possible, the volume or quantity and toxicity of waste.

Hazardous wastes generated by the following are not included in the calculation of the 25 ton threshold quantity:

  1. a corrective action for a release from a hazardous waste treatment, storage, or disposal facility; or
  2. the remediation of an inactive hazardous waste disposal site; or
  3. the cleanup of a release to the environment reported pursuant to Articles 17, 37 and 40 of the ECL; or
  4. demolition and construction debris; or
  5. one-time wastes, which are otherwise subject to the requirements of Section 27-0908 of the ECL.

waste reduction plan

The HWRP will be reviewed for acceptance by the NYSDEC. The HWRP shall establish opportunities to reduce hazardous waste through implementing technically feasible and economically practical waste reduction technologies, process or operational changes, material substitutions, or by other means. It must be reported on an annual basis and updated biennially. All hazardous wastes emitted into the air, discharged into waters, or treated and disposed of in an on-site or off-site permitted facility, including hazardous wastewaters, are covered by this law.

The facility’s Hazardous Waste Generation Summary and Hazardous Waste Reduction Program Summary must be updated annually and submitted in the ASR, which also describes the generator’s progress in achieving the schedule for implementing technically feasible and economically practicable waste reduction alternatives. The ASR must be submitted annually by July 1st beginning the year after the HWRP is submitted. The BU must be submitted every two years.

Walden Staff

To learn more and to obtain professional assistance with preparation of the required reporting documentation, please do not hesitate to give Walden a call at 516-624-7200.