Waste Reduction Policy Act (WRPA) Susan Palachek TCEQ

Waste Reduction Policy Act (WRPA) Susan Palachek TCEQ

Waste Reduction Policy Act (WRPA) Susan Palachek TCEQ Pollution Prevention & Education WRPA Purpose Create Pollution Prevention (P2) Program

Positive impact on industry & environment Why It Works Reducing waste: Saves MONEY

Reduces regulatory burden Reduces waste materials going to landfills What is this? Recycling Aerosol Cans: A TX Case

Purchase of a filtering aerosol can puncture system Puncture the cans Capture residue Filter emissions through a carbon filter SAVED $3,230.00 per year and kept 307 pounds of metal out of the landfill. Payback time of the project was less than a year!

Reduce Regulation Hazardous waste generation. . . . LQG (> 2,200 lbs/month) = 88 requirements SQG (220 to 2,200 lbs/month) = 74 CESQG ( 220 lbs/month) = ONLY 4 What is Pollution Prevention (P2)? Pollution Prevention is a method of analyzing and modifying processes and

inputs in an effort to minimize nonproduct outputs. SOURCE REDUCTION 30 TAC 335.471(13) Occurs before a waste has been generated or created (prior to recycling) Examples Equipment and technology modifications

Procedural changes Batch scheduling Reformulation or redesign of products Raw material substitutions

WASTE MINIMIZATION 30 TAC 335.471(16) Occurs after a waste has been generated or created Examples include: Reuse Recycle Neutralization Reclassification

Waste Hierarchy Source Reduction Reuse Recycle Treatment Waste Minimization WRPA: The Rule

Who does it apply to? Who does it NOT apply to? What is required?

WRPA Applicability 30 TAC Chapter 335 Subchapter Q applies to: All EPA Toxics Release Inventory (TRI) Form R reporters Hazardous waste generators

Large Quantity Generators (LQG) Small Quantity Generators (SQG) WRPA Applicability . . . and does NOT apply to: TRI Form A reporters who are not LQG or SQG

Conditionally Exempt Small Quantity Generators (CESQG) who DO NOT report TRI Form R Sites regulated ONLY by the Railroad Commission WRPA Exemptions

Sites only regulated by the TX Railroad Commission Sites only reporting because of remediation granted on an annual case-by-case basis generally done for 1-time remediation projects Environmental Management Systems (EMS)

New EMS rules: No longer requires complicated annual reporting Entities with an eligible EMS may be approved to receive certain incentives from the TCEQ 10% Compliance History credit Single point-of-contact within the TCEQ for innovative activities Individualized technical assistance

WRPA Requirements 1. Prepare 5-year Pollution Prevention (P2) Plan: Renew every 5 years Always due on January 1st Must be kept available on site

Let more than one person know where to find it P2 Planning Process

Identify your Pollutants, Identify the Activities Prioritize Pollutants Prioritize P2 Projects Economic Technical Risks Reductions Schedule

Set Measurable Goals

Employee Awareness and Training Media Transfer Document your Plan Measure your Results WRPA Requirements 2. Submit Executive Summary of P2 Plan to TCEQ

With Certificate of Completeness and Correctness Signed by site owner/plant manager/corporate officer Keep proof of submittal with your copy of the Plan. WRPA Requirements 3. Submit Annual Progress Report LQGs and TRI Form R reporters ONLY

Annual Progress Report Due by July 1st for previous calendar year Submit online through STEERS Instructions at www.P2plan.org

or Submit hard copy via mail to: TCEQ Pollution Prevention MC - 108 P.O. Box 13087 Austin, TX 78711-3087 Annual Progress Report Due July 1, after your plan has been in place for a full year Report year covers January 1 through

December 31 of the previous calendar year Reports the amount of hazardous materials that were source reduced APR Form Screen shot of P2 Plan.org STEERS

Step By Step Instructions available on www.P2plan.org: STEERS State of TX Environmental Electronic Reporting System (STEERS) Open for submission of the Annual Progress

Report from May 15 July 1 Only way to receive an electronic submission response Allows you to enter your numbers directly to the program database No transcription by staff Outside of the reporting period you can: Access previous APR submissions Edit WRPA contacts

STEERS SQG/Non-TRI R If Small Quantity Generator & not TRI Form R No Annual Progress Report Not required in P2 Plan Employee awareness training (but a good idea) Address release of different pollutant, or media transfer

New-Comers Site that becomes subject to WRPA has 90 days to put a P2 Plan in place: First time TRI reporters First Annual Waste Summary showing SQG or LQG Keep a copy on site and send a

signed Executive Summary to TCEQ Enforcement Violations of 30 TAC Chapter 335 Subchapter Q: Failure to have complete P2 Plan available on site

Failure to submit Executive Summary of P2 plan Failure to keep the Executive Summary updated Failure to submit Annual Progress Report

Why Comply? Economic benefits Reduced regulatory burden

Protect the environment Public relations Thought of the Day Intercontinental Manufacturing Company: Metal Fabrication

Then: Used steel shot as impact material for cleaning metal cases During the process the steel shot is pulverized to dust Previously collected in a steel dumpster and sent to landfill Thought of the Day

Intercontinental Manufacturing Company: NOW: Collected in steel drums and sent to a recycler Saves 33 cubic yards of solid waste annually Saves $2,650.00 in disposal costs Annual INCOME from scrap sale between

$8,000.00 and $11,000!! WRPA Results Reductions since 1998: Over 11 million tons of Hazardous Waste

Over 700,000 tons of TRI Chemicals Need Assistance? Contact Susan Palachek, WRPA Program Coordinator Phone: 512-239-3106 Email: [email protected] or

[email protected] P2plan.org Other Contacts Chase Campbell, RENEW Phone: 512-239-2619 Email: [email protected] or [email protected]

Luke Furfey, EMS Program Coordinator Phone: 512-239-3109 Email: [email protected] [email protected] or Upcoming Training

Pollution Prevention Waste Management Workshop September 7, 2016 in the Austin Area TCEQ hosted and includes: WRPA TRI Waste Permitting Early registration opens July 1, 2015

*Keep an eye on P2plan.org for more information! Useful locations on P2Plan.org www.TCEQ.texas.gov www.TCEQ.texas.gov QUESTIONS ?

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