1. Susan Palachek TCEQ Pollution Prevention & Education

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

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

5.  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!

6. 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. 1. Source Reduction 2. Waste Minimization Reuse Recycle Treatment

8.  Pollution Prevention is a method of analyzing and modifying processes and inputs in an effort to minimize non- product outputs.

9. 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

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

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

12. 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)

13. ... 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

14.  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

15. 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

16. 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

17.  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

18. 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.

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

20.  Due by July 1 st for previous calendar year  Submit online through STEERS Instructions at www.P2plan.org or  Submit hard copy via mail to: TCEQ Pollution Prevention MC - 108 P.O. Box 13087 Austin, TX 78711-3087

21.  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

23. Screen shot of P2 Plan.org

24.  Step By Step Instructions available on www.P2plan.org:

25.  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

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

31.  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

32.  Intercontinental Manufacturing Company: ◦NOW:  Collected in steel drums and sent to a recycler  Saves 33 cubic yards of solid waste annually  Saves $2,650.00 in disposal costs Annual from scrap sale between $8,000.00 and $11,000!!

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

35.  Susan Palachek, WRPA Program Coordinator Phone: 512-239-3106 Email: p2@tceq.texas.govor susan.palachek@tceq.texas.gov P2plan.org

36.  Neal Anderson, P2 Specialist Phone: 512-239-2619 Email: p2@tceq.texas.govor neal.anderson@tceq.texas.gov  Luke Furfey, EMS Program Coordinator Phone: 512-239-3109 Email: luke.furfey@tceq.texas.gov

37.  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!

38. Useful locations on P2Plan.org

39. www.TCEQ.texas.gov

41. QUESTIONS ?