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 non- product 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 Waste Minimization Reuse Recycle Treatment

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 applies to TRI Form R reporters and Large and Small Quantity (Hazardous Waste) Generators. TRI: Toxics Release Inventory, A list that contains information on more than 650 toxic chemicals that are being used, manufactured, treated, transported or released to the environments. Manufacturers are required to report the locations and quantities of chemicals stored on-site to state and local governments. LQG: 2,200 lbs (1,000 kg) or more of haz waste per month, or 2.2 lbs (1 kg) or more of acute haz waste per month SQG: 220-2,199 lbs (100-999 kg) of haz waste per month or <2.2 lbs (<1 kg) of acute haz waste per month

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 Facilities that only report TRI Form A and do not have hazardous waste or are CESQG and facilities that are CESQG only. TRI Form A: A shorter form that can be used if the chemicals are not of a certain type and the facility is reporting under a certain quantity CESQG: <220 lbs (100 kg) of haz waste per month or <2.2 lbs (<1 kg) of acute haz waste per month

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 Only true exemption to WRPA for facilities reporting LQG, SQG, or TRI are because of remediation projects only. Facilities regulated by the Railroad Commission are automatically exempted from WRPA. However, please notify us so that we can keep a record of the facility with the P2 program.

WRPA Requirements 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 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 Submit hard copy via mail* to: Submit the Executive Summary via email to: P2@tceq.texas.gov -or Submit hard copy via mail* to: TCEQ Pollution Prevention MC - 108 P.O. Box 13087 Austin, TX 78711-3087 Executive Summaries can also be sent by delivery service to the TCEQ street address: TCEQ Pollution Prevention 12100 Park 35 Circle, MC-108 Austin, TX 78753

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

Annual Progress Report Due by July 1st 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.P2plan.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 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: An APR Lesson The Tale of the Missing Reductions: Large chemical manufacture that had been subject to P2 Planning since the beginning. Had been implementing P2 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: p2@tceq.texas.gov or susan.palachek@tceq.texas.gov Ashley Bridgewater, P2 Specialist Phone: 512-239-3104 Email: p2@tceq.texas.gov or ashley.bridgewater@tceq.texas.gov

Other Contacts Chase Campbell, RENEW Phone: 512-239-2619 Email: p2@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

*Seats fill up fast! Keep an eye on P2plan.org for more information! 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 P2plan.org for more information!

Useful locations on P2Plan.org

www.TCEQ.texas.gov

www.TCEQ.texas.gov

QUESTIONS ?