Waste Reduction Policy Act (WRPA)

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Waste Reduction Policy Act (WRPA)

• Susan Palachek
• TCEQ Pollution Prevention Education

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Outline

• WRPA Background
• Brief history
• Why WRPA works
• WRPA Requirements
• Applicability
• Required submissions

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WRPA History

• 1990 Federal Pollution Prevention Act
• 1991 Texas Senate Bill 1099 WRPA
• Title 30 Texas Administrative Code Chapter 335,
  Subchapter Q
• (335.471-480)

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WRPA Created

• Government in cooperation with
• Industry representatives
• Public interest groups
• Educational organizations

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WRPA Purpose

• Create Pollution Prevention (P2) Program
• Positive impact on industry environment

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Why It Works

• Reducing waste
• Saves MONEY
• Reduces regulatory burden

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Reduce Regulation

• Hazardous waste generation. . . .
• LQG (gt 2,200 lbs/month) 88 requirements
• SQG (220 to 2,200 lbs/month) 74
• CESQG ( 220 lbs/month) ONLY 4

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Waste Hierarchy

• Source Reduction
• Waste Minimization
• Reuse
• Recycle
• Treatment

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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

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WASTE MINIMIZATION 30 TAC 335.471(16)

• Occurs after a waste has been generated or
  created
• Examples include
• Reuse
• Recycle
• Selling
• Neutralization
• Reclassification

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WRPA The Rule

• Who does it apply to?
• Who does it NOT apply to?
• What is required?

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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)

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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

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WRPA Exemptions

• Sites regulated by the Railroad Commission only
• Sites only reporting because of remediation
• granted on an annual case-by-case basis
• generally done for 1-time remediation projects

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Environmental Management Systems (EMS)

• Previously
• WRPA exemption for Gold and Platinum members of
  Clean Texas
• Exempted facilities reported annually through
  Clean Texas
• Now
• No EMS exemption from WRPA
• No procedure for reporting annually except
  through WRPA

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Sites with an 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

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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 it is

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P2 Planning Process

• Identify your Pollutants,
• Identify the Activities
• Prioritize Pollutants
• Prioritize P2 Projects
• Economic
• Technical
• Risks
• Reductions
• Schedule

• Measurable Goals
• Employee Awareness and Training
• Media Transfer
• Document your Plan
• Measure your Results

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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.

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WRPA Requirements

• Submit Annual Progress Report
• LQGs and TRI Form R reporters ONLY

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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 - 113
• P.O. Box 13087
• Austin, TX 78711-3087

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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

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APR Form
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STEERs

• State of TX Environmental Electronic Reporting
  System
• 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

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STEERS

• Step By Step Instructions available on
  www.P2plan.org

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STEERS
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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

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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

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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

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Why Comply?

• Economic benefits
• Reduced regulatory burden
• Protect the environment
• Public relations

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WRPA Results

• Reductions since 1998
• Over 10 million tons of Hazardous Waste
• Over 655,000 tons of TRI Chemicals

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Contact

• Susan Palachek, WRPA Program Coordinator
• Phone [phone]
• Email p2_at_tceq.texas.gov or susan.palachek_at_tceq.te
  xas.gov

• P2plan.org

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Other Contacts

• Stephanie Cunningham, HHW Program Coordinator
• Phone [phone]
• Email p2_at_tceq.texas.gov or stephanie.cunningham_at_t
  ceq.texas.gov
• David Greer, EMS Program Coordinator
• Phone [phone]
• Email david.greer_at_tceq.texas.gov

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• QUESTIONS ?