Waste Reduction Policy Act WRPA Susan Palachek TCEQ

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Waste Reduction Policy Act (WRPA) Susan Palachek TCEQ Pollution Prevention & Education

Waste Reduction Policy Act (WRPA) Susan Palachek TCEQ Pollution Prevention & Education

WRPA Purpose Create Pollution Prevention (P 2) Program Positive impact on industry & environment

WRPA Purpose Create Pollution Prevention (P 2) Program Positive impact on industry & environment

Why It Works Reducing waste: Saves MONEY Reduces regulatory burden Reduces waste materials going

Why It Works Reducing waste: Saves MONEY Reduces regulatory burden Reduces waste materials going to landfills

What is this?

What is this?

Recycling Aerosol Cans: A TX Case Purchase of a filtering aerosol can puncture system

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

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 (P 2)? Pollution Prevention is a method of analyzing and

What is Pollution Prevention (P 2)? 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”

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”

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

Waste Hierarchy Source Reduction Reuse Recycle Treatment Waste Minimization

WRPA: The Rule Who does it apply to? Who does it NOT apply to?

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

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

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

WRPA Exemptions Sites only regulated by the TX Railroad Commission Sites only reporting because of remediation • granted on an case-by-case basis • Must be renewed annually • generally done for 1 -time remediation projects

WRPA Requirements 1. Prepare 5 -year Pollution Prevention (P 2) Plan: • Renew every

WRPA Requirements 1. Prepare 5 -year Pollution Prevention (P 2) Plan: • Renew every 5 years • Always due on January 1 st • Must be kept available on site • Let more than one person know where to find it

P 2 Planning Process Identify your Pollutants, Identify the Activities Prioritize Pollutants Prioritize P

P 2 Planning Process Identify your Pollutants, Identify the Activities Prioritize Pollutants Prioritize P 2 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 P 2 Plan to TCEQ • With

WRPA Requirements 2. Submit Executive Summary of P 2 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 Submit the Executive Summary via email to: P 2@tceq. texas. gov -or

WRPA Requirements Submit the Executive Summary via email to: P 2@tceq. texas. gov -or Submit hard copy via mail* to: TCEQ Pollution Prevention MC - 108 P. O. Box 13087 Austin, TX 78711 -3087

WRPA Requirements 3. Submit Annual Progress Report • LQGs and TRI Form R reporters

WRPA Requirements 3. Submit Annual Progress Report • LQGs and TRI Form R reporters ONLY

Annual Progress Report Due by July 1 st for previous calendar year • July

Annual Progress Report Due by July 1 st for previous calendar year • July 1, 2017 will be the deadline for submitting source reduction data from January 1, 2016 – December 31, 2016 Submit online through STEERS • Instructions at www. P 2 plan. org

Annual Progress Report Due July 1, after your plan has been in place for

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

APR Form

Screen shot of P 2 Plan. org

Screen shot of P 2 Plan. org

STEERS Step By Step Instructions available on www. P 2 plan. org:

STEERS Step By Step Instructions available on www. P 2 plan. org:

STEERS State of TX Environmental Electronic Reporting System (STEERS) • Open for submission of

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

STEERS

SQG/Non-TRI R If Small Quantity Generator & not TRI Form R • No Annual

SQG/Non-TRI R If Small Quantity Generator & not TRI Form R • No Annual Progress Report • Not required in P 2 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 P

New-Comers Site that becomes subject to WRPA has 90 days to put a P 2 Plan in place: • First time TRI reporters • First Annual Waste Summary showing SQG or LQG v. 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

Enforcement Violations of 30 TAC Chapter 335 Subchapter Q: • Failure to have complete P 2 Plan available on site • Failure to submit Executive Summary of P 2 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

Why Comply? Economic benefits Reduced regulatory burden Protect the environment Public relations

Thought of the Day: An APR Lesson The Tale of the Missing Reductions: ◦

Thought of the Day: An APR Lesson The Tale of the Missing Reductions: ◦ Large chemical manufacture that had been subject to P 2 Planning since the beginning. ◦ Had been implementing P 2 projects slowly over the past 20 years: updated equipment, modified processes Reported small reductions ◦ Continued disposing of waste as hazardous based on original process knowledge

Thought of the Day: An APR Lesson The Tale of the Missing Reductions: ◦

Thought of the Day: An APR Lesson The Tale of the Missing Reductions: ◦ New environmental personnel reviewed the site history ◦ New projects were started Found markets for waste streams to be sold as secondary products Resolved some long standing issues with water treatment equipment ◦ After all of the process modifications, no one thought to re-characterize the waste streams Continued disposing of waste as hazardous based on original process knowledge

Thought of the Day: An APR Lesson Reported in 2016: ◦ Reclassified a waste

Thought of the Day: An APR Lesson Reported in 2016: ◦ Reclassified a waste stream as a product with a buyer ◦ Repaired existing equipment ◦ Re-characterized the remaining waste streams Reported a 4. 5 MILLION TON REDUCTION IN ONE YEAR!! Repeated the work at a sister facility Reported a 49 THOUSAND TON REDUCTION IN ONE YEAR!!

WRPA Results Reductions since 1998*: Almost 20 million tons of Hazardous Waste Almost 5

WRPA Results Reductions since 1998*: Almost 20 million tons of Hazardous Waste Almost 5 million tons of TRI Chemicals *Results taken from the Annual Progress Reports from 1998 -2016

Need Assistance?

Need Assistance?

Contacts Susan Palachek, WRPA Program Coordinator • Phone: 512 -239 -3106 • Email: p

Contacts Susan Palachek, WRPA Program Coordinator • Phone: 512 -239 -3106 • Email: p 2@tceq. texas. gov or susan. palachek@tceq. texas. gov Ashley Bridgewater, P 2 Specialist • Phone: 512 -239 -3104 • Email: p 2@tceq. texas. gov or ashley. bridgewater@tceq. texas. gov

Other Contacts Chase Campbell, RENEW • Phone: 512 -239 -2619 • Email: p 2@tceq.

Other Contacts Chase Campbell, RENEW • Phone: 512 -239 -2619 • Email: p 2@tceq. texas. gov or chase. campbell@tceq. texas. gov

RENEW Resource Exchange Network for Eliminating Waste ◦ ◦ Free and Confidential Over 500

RENEW Resource Exchange Network for Eliminating Waste ◦ ◦ Free and Confidential Over 500 documented successful exchanges One billion pounds of materials recycled or reused $27 million in disposal costs avoided

Upcoming Training Pollution Prevention Waste Management Workshop ◦ September 27, 2017 in the Austin

Upcoming Training Pollution Prevention Waste Management Workshop ◦ September 27, 2017 in the Austin Area ◦ TCEQ hosted and includes: WRPA TRI Waste Permitting *Seats fill up fast! Keep an eye on P 2 plan. org for more information!

Useful locations on P 2 Plan. org

Useful locations on P 2 Plan. org

www. TCEQ. texas. gov

www. TCEQ. texas. gov

www. TCEQ. texas. gov

www. TCEQ. texas. gov

QUESTIONS ?

QUESTIONS ?