Change Notice No. 1
Recycling and reuse are cost saving approaches to be considered prior to the
disposal of excess chemicals and chemical materials. The cost saving comes from
DOE Audit Report
not having to pay for the disposal of the materials and in not having to purchase
new chemicals for use in other projects. Savannah River Site (SRS) has realized a
cost avoidance and cost savings of over $3 million through reutilization, donations,
and sales of excess chemicals (this is one of SRS's Chemical Management Program
performance metrics.) Researchers at Pacific Northwest National Laboratory
(PNNL) achieved a cost savings for a laboratory project when they utilized a
PNNL Cost Savings
chemical mixture no longer needed by other projects.
Chemicals no longer needed to support planned activities should be removed from
the facility inventory in an expeditious manner that is documented and in
compliance with all applicable regulations. For example, disposition of unneeded
chemicals is handled through property management regulations. The final
disposition of the chemicals should be recorded, and all applicable records should
be transferred to the appropriate personnel.
Identifying a "waste"
A determination should be made as to whether a site's chemicals (materials) meet
the regulatory definition of a "waste."
A waste is any material that is discarded by being abandoned (i.e., disposed
40 CFR 261.2
of, burned, or incinerated), recycled, or considered inherently waste-like
[40 CFR 261.2].
Certain materials that are "accumulated speculatively" (i.e., accumulated
before being recycled) are designated as waste [40 CFR 261.2].
It is important to recognize that certain materials in inventory (MIN) may
meet the regulatory definition of a waste, and thus be subject to waste
management requirements. If MIN chemicals are not reused or exchanged,
they fall into the waste category and should be dispositioned [per the DOE
Office of Environmental Management's (EM) MIN Initiative].