Waste Reduction Policy Act WRPA Susan Palachek TCEQ
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Waste Reduction Policy Act (WRPA) Susan Palachek TCEQ Pollution Prevention & Education
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 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 (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” 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 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 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 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 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 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 ONLY
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 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 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 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 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 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 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
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: ◦ 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 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 million tons of TRI Chemicals *Results taken from the Annual Progress Reports from 1998 -2016
Need Assistance?
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. texas. gov or chase. campbell@tceq. texas. gov
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 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
www. TCEQ. texas. gov
www. TCEQ. texas. gov
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