Susan Palachek TCEQ Pollution Prevention & Education

 Create Pollution Prevention (P2) Program  Positive impact on industry & environment

Reducing waste:  Saves MONEY  Reduces regulatory burden  Reduces waste materials going to landfills

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

Hazardous waste generation.... ◦LQG (> 2,200 lbs/month) = 88 requirements ◦SQG (220 to 2,200 lbs/month) = 74 ◦CESQG (≤ 220 lbs/month) = ONLY 4

1. Source Reduction 2. Waste Minimization Reuse Recycle Treatment

 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

Occurs after a waste has been “generated” or created Examples include:  Reuse  Recycle  Neutralization  Reclassification

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

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)

... 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

 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

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

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

 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

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.

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

 Due by July 1 st for previous calendar year  Submit online through STEERS Instructions at or  Submit hard copy via mail to: TCEQ Pollution Prevention MC P.O. Box Austin, TX

 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

Screen shot of P2 Plan.org

 Step By Step Instructions available on

 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

 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

 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

 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

 Economic benefits  Reduced regulatory burden  Protect the environment  Public relations

 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

 Intercontinental Manufacturing Company: ◦NOW:  Collected in steel drums and sent to a recycler  Saves 33 cubic yards of solid waste annually  Saves $2, in disposal costs Annual from scrap sale between $8, and $11,000!!

Reductions since 1998:  Over 11 million tons of Hazardous Waste  Over 700,000 tons of TRI Chemicals

 Susan Palachek, WRPA Program Coordinator Phone: P2plan.org

 Neal Anderson, P2 Specialist Phone:  Luke Furfey, EMS Program Coordinator Phone:

 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!

Useful locations on P2Plan.org

QUESTIONS ?