Pollution Prevention (P2)
Section 3002(b) of the Resource Conservation and Recovery Act (RCRA), as amended by the Hazardous and Solid Waste Amendments of 1984 and Section 6602(b) of the Pollution Prevention Act of 1990 direct federal agencies, including NASA, to:
- Reduce the quantity of toxic and hazardous chemicals and materials acquired, used, or disposed of by the agency,
- Increase diversion of solid waste as appropriate,
- Maintain cost-effective waste prevention and recycling programs in facilities, and
- Use sustainable practices in the acquisition of bio-based, environmentally preferable, energy-efficient, water-efficient and recycled-content products (‘Green Purchasing’).
Kennedy’s P2 Program encourages the use of environmentally preferable materials and implementing best practices that reduce the use of hazardous and non-hazardous materials. It also seeks to minimize the need for waste treatment processes. The program supports the center’s purchasing decisions, operations, maintenance, waste management and disposal methods.
The main components of the P2 Program include:
- P2 opportunity assessments
- Partnering with contractors and regulators
- Emergency Planning and Community Right-To-Know Act (EPCRA) Tier II data tracking and reporting
- EPCRA Toxic Releases Inventory tracking and reporting
- RCRA 6002 data tracking and reporting
The sustainability team coordinates performing these components with NASA-funded organizations and communicates this strategy for the center. The team collects and analyzes data, performs trend analysis, communicates lessons learned, shares information with partnering teams, and submits reports to NASA Headquarters and regulatory agencies.
Kennedy P2 Goals
Kennedy’s goals are to reduce the volume and toxicity of solid and hazardous waste to the extent economically practicable through the following program elements:
- Source Reduction – Prevention through source reduction is the practice of reducing the amount of hazardous substances, pollutants, or contaminants entering any waste stream or otherwise released into the environment before recycling, treatment, or disposal. Source reduction reduces or eliminates the hazards to employees, the public, and the environment along with the liability of regulatory compliance. Several source reduction techniques employed by Kennedy are listed below.
- Initial Environmental Design: Incorporation of environmental considerations into the initial process or facility design to limit or prevent pollution or waste generation from occurring.
- Process Efficiency Improvements: Changes to a process or facility to reduce requirements for hazardous substances, pollutants, or contaminants.
- Material Substitution: Substitution of non-hazardous or less hazardous materials into a process to reduce the toxicity of the resulting waste stream.
- Inventory Control: Control of hazardous materials in inventories to promote efficient use and to avoid shelf-life expiration and waste generation.
- Preventive Maintenance: Designing equipment for maintainability to result in detection and avoidance of equipment problems before failures and associated spills and leaks of hazardous materials occur.
- Improved Housekeeping: Maintaining clean, well-organized facilities and awareness by personnel regarding proper management and use of toxic and hazardous materials to reduce the frequency and amount of accidental spills, releases, and subsequent waste generation.
- Recycling and Waste Diversion – Recycling is the practice of using, reusing or reclaiming a waste material. A waste material is used or reused if it is employed as an ingredient in an industrial process to make a product or employed in a particular function or application as an effective substitute for a commercial product. A waste material is reclaimed if it is processed to recover a usable product or regenerated. Recycling is the most preferred method of waste minimization for those hazardous substances, pollutants, or contaminants that cannot be reduced at the source.
- Treatment – Treatment is any method that physically, chemically or biologically changes the character or composition of the waste; recovers energy or material resources from the waste; renders the waste non-hazardous or less hazardous; reduces the volume of the waste; renders the waste safer for transport, storage, or disposal; or makes the waste amenable for recovery or storage. Treatment opportunities for hazardous wastes at Kennedy may be referenced in Technical Response Package instructions (example: neutralization of corrosive wastes). Treatment options should only be employed when wastes cannot be prevented or recycled.
- Disposal – Disposal is the discharge, deposit, injection, dumping, spilling, leaking or placing of a waste into or on land or water or into the air so that hazardous constituents may enter the environment. No hazardous wastes may be disposed of at Kennedy; off-site disposal of hazardous waste is managed through specific documented processes. Disposal is utilized when the waste cannot be prevented or recycled.
Kennedy Plan for Emergency Planning and Community Right-to-Know Act (EPCRA)
Kennedy has a robust EPCRA program to improve local community access to information about chemical hazards and to improve state and local emergency response capabilities. EPCRA has three main objectives:
- Bolster local emergency planning efforts
- Improve emergency notification in the event of a release of hazardous chemicals
- Develop a baseline on routine chemical releases into the environment
To meet these objectives, EPCRA has four types of reporting obligations for facilities that store or manage specified listed chemicals. All information submitted pursuant to EPCRA regulations is publicly accessible, unless protected by a trade secret claim.
- Notification of Extremely Hazardous Substances. EPCRA §302 requires facilities to notify the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) of the presence of any “extremely hazardous substance” if it has the substance in excess of the specified “threshold planning quantity.” It also directs the facility to appoint an emergency response coordinator. Kennedy utilizes extremely hazardous substances and reports to the SERC and LEPC accordingly.
- Notification of Releases. EPCRA §304 requires facilities to notify the SERC and the LEPC in the event of a release exceeding the “reportable quantity” of a CERCLA hazardous substance or an EPCRA extremely hazardous substance. EPCRA extremely hazardous substances and reportable quantities are listed in 40 CFR 355. Kennedy keeps track of all “reportable quantity” releases and any other “non-reportable quantity” releases annually by using the Pollution Incident Report (PIR).
- Emergency Planning (EPCRA Tier II). EPCRA §311 and §312 require facilities to notify SERC, LEPC, and the local fire department of all hazardous chemicals for which the Occupational Health and Safety Administration requires safety data sheets (SDS). The facility must submit either the MSDS or a list of the substances for which an MSDS is maintained. If a list is submitted, hazardous chemical inventory forms (also known as Tier I and II forms) must also be submitted. A Tier I form provides information about hazardous chemicals grouped by hazard category. A Tier II form provides information about each specific hazardous chemical. This information helps the local government respond in the event of a spill or release of the chemical. These requirements are found at 40 CFR 370, Hazardous Chemical Reporting: Community Right-to-Know. On March 1st of each year, Kennedy submits the EPCRA Tier II Report to the Environmental Protection Agency (EPA), the SERC, the LEPC and the Kennedy Fire Department.
- Toxic Release Inventory (Form R). EPCRA §313 of Title III requires manufacturing facilities included in standard industrial classification codes 20 through 39, which have ten or more employees, and which manufacture, process, or use specified chemicals in amounts greater than threshold quantities, to submit an annual toxic chemical release report to EPA. This program is called the Toxic Release Inventory (TRI). The report, commonly known as Form R, 1) covers releases and transfers of toxic chemicals to various facilities and environmental media, 2) allows EPA to compile the national TRI database, and 3) assists in research and development of regulations, guidelines, and standards. The TRI data are used nationally to track pollution prevention progress by industry. These requirements can be found at 40 CFR 372, Toxic Chemical Release Reporting: Community Right-to-Know. On July 1st of each year, Kennedy submits the TRI Report to the EPA and the SERC.