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

2. WRPA Purpose Create Pollution Prevention (P2) Program
Positive impact on industry & environment

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

4. What is this?

5. 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, per year and kept 307 pounds of metal out of the landfill.
Payback time of the project was less than a year!

6. 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

7. 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.

8. 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

9. WASTE MINIMIZATION 30 TAC §335.471(16)
Occurs after a waste has been “generated” or created
Examples include:
Reuse
Recycle
Neutralization
Reclassification

10. Waste Hierarchy Source Reduction Waste Minimization Reuse Recycle
Treatment

11. WRPA: The Rule Who does it apply to? Who does it NOT apply to?
What is required?

12. 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 ( kg) of haz waste per month or <2.2 lbs (<1 kg) of acute haz waste per month

13. 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

14. 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.

15. 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

16. 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

17. 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.

18. WRPA Requirements Submit hard copy via mail* to:
Submit the Executive Summary via to:
-or
Submit hard copy via mail* to:
TCEQ Pollution Prevention
MC - 108
P.O. Box 13087
Austin, TX
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

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

20. 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

21. 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

22. APR Form

23. Screen shot of P2 Plan.org

24. STEERS
Step By Step Instructions available on

25. 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

26. STEERS

27. 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

28. 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

29. 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

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

31. 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

32. 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

33. 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!!

35. 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

36. Need Assistance?

37. Contacts Susan Palachek, WRPA Program Coordinator
Phone: or
Ashley Bridgewater, P2 Specialist
Phone: or

38. Other Contacts Chase Campbell, RENEW Phone: 512-239-2619or

39. 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

40. *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!

41. Useful locations on P2Plan.org

44. QUESTIONS ?