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

2. Why bother with P2? It’s the law! Reduced regulatory burden
Economic benefits
Protect the environment
Public relations

3. 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

4. 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
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.

5. WRPA Exemptions 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.

6. 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

7. 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.

8. 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

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

10. Annual Progress Report
Due July 1, after your plan has been in place for a year
Report year covers January 1 through December 31 of the previous calendar year
Reports the amount of hazardous materials that were source reduced
Submit online through STEERS
Instructions at

11. APR Form

13. STEERS
Step By Step Instructions available on

14. 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

15. STEERS

16. 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

17. 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

18. 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

19. Why bother with P2? It’s the law! Reduced regulatory burden
Economic benefits
Protect the environment
Public relations

20. 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

21. 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.

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

23. 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

24. Waste Hierarchy Source Reduction Waste Minimization Reuse Recycle
Treatment

25. 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

26. Better Alternatives? Schick Razor Blades
Facility manufactures steel blades and tools for everything from razors to medical blades
Used TCE (Trichloroethylene) to clean the blades before shipping
Using approximately 1700 tons of TCE per year
Examined the process to look for alternatives

27. Better Alternatives? Schick Razor Blades
Replaced TCE baths with alcohol based cleaners:
Eliminated the use of TCE in the process
Removed all TCE from the property
Yearly cost reductions of $250,000
Reduce energy (no more distillation)
Reduced material costs
Reduced haz waste disposal costs
Reduced the regulatory risk!

28. Why bother with P2? It’s the law! Reduced regulatory burden
Economic benefits
Protect the environment
Public relations

29. Always Measure Results
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

30. Always Measure Results
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

31. Always Measure Results
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!!

32. Benefits Beyond Waste Reduction
Reduce and reuse latex wash water
Better batch scheduling reduces clean out waste
Inventory organization reduces bad batches and waste
Improved work flow by eliminating bottlenecks

33. Benefits Beyond Waste Reduction
Waste Disposal
Waste water reductions
Reduced raw material input
Labor savings
Total Savings:
$6,000
$17,000
$26,000
$90,000
~$139,000/year

35. Why bother with P2? It’s the law! Reduced regulatory burden
Economic benefits
Protect the environment
Public relations

36. 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

37. Why bother with P2? It’s the law! Reduced regulatory burden
Economic benefits
Protect the environment
Public relations

38. It’s Not Just Advertising Anymore
The Modern World – Increased Awareness
24-hour news coverage
International Competition
Consumer Awareness and Opinion
Data Mining/Research Companies
Social media

39. The Power of Social Media
In One Tweet, Kylie Jenner Wiped Out $1.3 Billion of Snap’s Market Value – Bloomberg Report, February 2018
“If they can be the first to react to a news event, then maybe they can get an edge over their competition.” – How investors are using social media to make money, CNBC, June 2016
“The importance of social media can’t be overstated.” – How the youngest generation is redefining work, BBC, February 2018

40. Resources

43. Useful locations on P2Plan.org

44. The New and Improved RG-409
We’ve revised our Guidance Document! Check it out!!

45. 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

46. Successful Exchange Stories
A biodiesel production company transferred 275 pounds of waste acetone to a company that recycled it for lacquer paint production. The material is typically sent to a hazardous waste disposal site that would have cost the facility $750. Helps the facility remain a CESQG!
A company that refines and markets oil and natural gas transferred 7,800,000 pounds of crude oil tank bottoms to a company who was able to reuse it saving them $236,800.

47. Need Assistance?

48. Contact Susan Palachek, P2 Program Coordinator Phone: 512-239-3106
-or-
Hector Lujan, P2 Program Specialist
Phone:
-or-

49. Other Contacts Eileen Villasenor, RENEW Phone: 512-239-2619
-or-
Small Business and Local Government Assistance (SBLGA) Hotline

50. QUESTIONS ?