Waste Reduction Policy Act (WRPA)

Susan PalachekTCEQ Pollution Prevention &

Education

Create Pollution Prevention (P2) Program

Positive impact on industry & environment

WRPA Purpose

Reducing waste: Saves MONEY

Reduces regulatory burden

Reduces waste materials going to landfills

Why It Works

What do you see?

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!

Recycling Aerosol Cans: A TX Case

Hazardous waste generation. . . .

◦ LQG (> 2,200 lbs/month) = 88 requirements

◦ SQG (220 to 2,200 lbs/month) = 74

◦ CESQG (≤ 220 lbs/month) = ONLY 4

Reduce Regulation

1. Source Reduction

2. Waste Minimization• Reuse• Recycle• Treatment

Waste Hierarchy

What is Pollution Prevention (P2)?

Pollution Prevention is a method of analyzing and modifying processes and inputs in an effort to minimize non-product outputs.

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

SOURCE REDUCTION30 TAC §335.471(13)

Occurs after a waste has been “generated” or created

Examples include: Reuse Recycle Neutralization Reclassification

WASTE MINIMIZATION 30 TAC §335.471(16)

Who does it apply to?

Who does it NOT apply to?

What is required?

WRPA: The Rule

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 Applicability

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

WRPA Exemptions

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

Environmental Management Systems (EMS)

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 it

is

WRPA Requirements

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

P2 Planning Process

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

WRPA Requirements

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 PreventionMC - 108P.O. Box 13087Austin, 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

Annual Progress Report

APR Form

Screen shot of P2 Plan.org

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 and 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

STEERS

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

SQG/Non-TRI R

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

New-Comers

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

Enforcement

Economic benefits

Reduced regulatory burden

Protect the environment

Public relations

Why Comply?

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

Thought of the Day

Annual from scrap sale between

$8,000.00 and $11,000!!

INCOME

Reductions since 1998:

Over 11 million tons of Hazardous Waste

Over 700,000 tons of TRI Chemicals

WRPA Results

Need Assistance?

Susan Palachek, WRPA Program Coordinator• Phone: 512-239-3106• Email: p2@tceq.texas.gov or

susan.palachek@tceq.texas.gov

Contact

P2plan.org

Neal Anderson, P2 Specialist• Phone: 512-239-2619• Email: p2@tceq.texas.gov or

neal.anderson@tceq.texas.gov

Luke Furfey, EMS Program Coordinator• Phone: 512-239-3109• Email: luke.furfey@tceq.texas.gov

Other Contacts

Pollution Prevention Waste Management Workshop◦ September 30, 2015 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!

Upcoming Training

Useful locations on P2Plan.org

www.TCEQ.texas.gov

www.TCEQ.texas.gov

QUESTIONS ?