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Waste Reduction Policy Act (WRPA)

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

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Waste Reduction Policy Act (WRPA)

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  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 $3,230.00 per year and kept 307 pounds of metal out of the landfill. • Payback time of the project was less than a year!

  6. 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 REDUCTION30 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 MINIMIZATION30 TAC §335.471(16) Occurs after a waste has been “generated” or created Examples include: • Reuse • Recycle • Neutralization • Reclassification

  10. Waste Hierarchy Source Reduction Reuse Waste Minimization 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 appliesto: • All EPA Toxics Release Inventory (TRI) Form R reporters • Hazardous waste generators • Large Quantity Generators (LQG) • Small Quantity Generators (SQG)

  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

  14. WRPA Exemptions • 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. Environmental Management Systems (EMS) 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. 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

  17. P2 Planning Process • Set MeasurableGoals • Employee Awareness and Training • Media Transfer • Document your Plan • Measure your Results • Identify your Pollutants, • Identify the Activities • Prioritize Pollutants • Prioritize P2 Projects • Economic • Technical • Risks • Reductions • Schedule

  18. 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.

  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 • 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. 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 www.P2plan.org:

  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 • 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. Thought of the Day • 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 INCOME Annual from scrap sale between $8,000.00 and $11,000!!

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

  34. Need Assistance?

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

  36. Other Contacts • Chase Campbell, RENEW • Phone: 512-239-2619 • Email: p2@tceq.texas.govor chase.campbell@tceq.texas.gov • Luke Furfey, EMS Program Coordinator • Phone: 512-239-3109 • Email: recycle@tceq.texas.gov or luke.furfey@tceq.texas.gov

  37. Upcoming Training • Pollution Prevention Waste Management Workshop • September 7, 2016 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

  40. www.TCEQ.texas.gov

  41. QUESTIONS ?

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