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TRI and P2 APR – Successfully Closing Out This Reporting Season

March reporting deadlines are still on the horizon. While you still have time, watch our uploaded January webinar and review our slides to assist in your first round of reporting. While you’re still finalizing your March reports, be mindful of the July 1st TRI and P2 Annual Progress Report just around the corner. We will host a live lunchtime webinar on March 28th to help you prepare for report requirements, report submittal and best methods for reducing waste and TRI releases. Texas’ Waste Reduction Policy Act of 1991 was adopted to prevent pollution in Texas. The Texas Commission on Environmental Quality (TCEQ) adopted the corresponding rule under 30 TAC 335 Subchapter Q, which requires small and large quantity generators of hazardous waste and TRI reporters to prepare a five-year P2 Plan and submit an Executive Summary of the plan to TCEQ. Large quantity generators and TRI reporters are also required to report annually on their activities to prevent pollution. Every 5 years, a new Executive Summary must be submitted, and the P2 Plan must be updated.

P2 Plans should address the hazardous waste and/or the TRI-reportable chemicals that are generated and “released” to the environment. The term “release” includes spills, air emissions, waste disposal, etc. and the P2 Plan should contain a separate component addressing source reduction activities and a separate component addressing waste minimization. Source reduction has a meaning that was defined by the federal Pollution Prevention Act of 1990 and is a practice which reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment (including fugitive emissions) prior to recycling, treatment or disposal. Initiatives like equipment or technology modifications, process or procedure modification, chemical substitution, inventory control, etc. are all examples of source reduction. Alternatively, waste minimization is a practice that reduces the environmental hazards of a waste, such as neutralization, reuse, or detoxification.

The Plan should contain a prioritized list of economically and technologically feasible source reduction and waste minimization projects. The progress toward the achievement of source reduction and waste minimization goals is included in the Annual Progress Report. Each year, the APR will contain the quantity of hazardous waste and/or TRI releases compared to the base year of the Plan.

On March 28th, W&M experts Lori Siegelman and Victor Cason will present the basics of preparing the TRI and P2 Annual Progress Report in our webinar: who is required to report; the meanings of source reduction versus waste minimization, methods for calculating reductions in waste and TRI releases, and using STEERS for submittal of the report. Register for our webinar below!

And if you have any questions or comments, please contact Lori Siegelman, CIH, CSP, CHMM

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