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Learn how WRPA's Pollution Prevention Program saves money, reduces regulatory burden, and keeps waste out of landfills. Understand Pollution Prevention (P2) strategies for sustainable business practices. Discover key compliance requirements and benefits of EMS.
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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 • Reduces waste materials going to landfills
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!
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
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.
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
WASTE MINIMIZATION30 TAC §335.471(16) Occurs after a waste has been “generated” or created Examples include: • Reuse • Recycle • Neutralization • Reclassification
Waste Hierarchy Source Reduction Reuse Waste Minimization Recycle Treatment
WRPA: The Rule • Who does it apply to? • Who does it NOT apply to? • What is required?
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)
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
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
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
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
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
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.
WRPA Requirements • Submit Annual Progress Report • LQGs and TRI Form R reporters ONLY
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
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
STEERS • Step By Step Instructions available on www.P2plan.org:
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
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
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
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
Why Comply? • Economic benefits • Reduced regulatory burden • Protect the environment • Public relations
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
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!!
WRPA Results Reductions since 1998: • Over 11 million tons of Hazardous Waste • Over 700,000 tons of TRI Chemicals
Contact • Susan Palachek, WRPA Program Coordinator • Phone: 512-239-3106 • Email: p2@tceq.texas.gov or susan.palachek@tceq.texas.gov • P2plan.org
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
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!