The first deadline for submittal of this report for calendar year 2013 is fast approaching.  If you intend to submit the Annual Waste Summary to the Texas Commission on Environmental Quality (TCEQ) by hardcopy it must be received by January 25, 2014.  If you intend to complete the report using STEERS the deadline for its submittal is March 1, 2014.  See below for information about this report and to confirm if it applies to you.

What is the Annual Waste Summary?

• The Annual Waste Summary (AWS) is a report to the TCEQ from all registered generators of industrial and hazardous waste in Texas.
• It provides information on the amount of hazardous waste and Class 1 non-hazardous industrial waste a Texas facility generated or managed in the reporting year (January 1 to December 31 of previous calendar year).
• The TCEQ uses the information on the AWS to calculate a facility’s annual waste generation fee.
• It is not the same document as the P2 Annual Progress Report required by the TCEQ pursuant to Title 30 of the Texas Administrative Code 335, Subpart Q.  For questions about your facility’s pollution prevention planning requirements, contact the TCEQ Small business and Environmental Assistance Division at 512.239.3100.

When is the Annual Waste Summary due?

• There are two due dates for the AWS depending on the format of the submittal:
  • The deadline for submittal of the AWS by paper/hardcopy is January 25th.
  • The deadline for submittal by STEERS is March 1st.

Who is required to complete the Annual Waste Summary?

• Completing and submitting the AWS in some form is a requirement for all registered generators of solid waste in Texas.  This is important.  No matter what waste you generated in the reporting year, if you were registered with the TCEQ in that year you must submit an AWS.
• You are required to register with the TCEQ as a generator of solid waste if:
  • You are a Large Quantity Generator of hazardous waste.
  • You are a Small Quantity Generator of hazardous waste.
  • You are a Conditionally Exempt Small Quantity Generator of hazardous waste that also routinely generate >100 kg/mo of Class 1 non-hazardous industrial solid waste.

Who is not required to complete the Annual Waste Summary?

• If you are not a registered generator of solid waste in Texas you are not required to complete and submit the AWS.
• You are not required to register with the TCEQ as a generator of solid waste (and therefore not required to submit the AWS) if:
  • You are a non-industrial facility that is also a Conditionally Exempt Small Quantity Generator of hazardous waste.
  • You are an industrial facility that is a Conditionally Exempt Small Quantity Generator of hazardous waste that does not routinely generate >100 kg/mo of Class 1 non-hazardous industrial waste.

What if I am an industrial facility and a Conditionally Exempt Small Quantity Generator of hazardous waste that sometimes generates >100 kg/mo of Class 1 non-hazardous industrial solid waste during the reporting period?  eg. Twice in the reporting year I had unrelated spills or one-time events that resulted in the generation of >100 kg/mo of Class 1 non-hazardous industrial solid waste.

• The answer depends on whether or not you are a registered generator of solid waste in Texas.
  • If registered, then you must submit an AWS no matter the waste (hazardous or non-hazardous) you generated in the reporting year.
  • If not registered, the non-routine generation of waste (hazardous or non-hazardous) can be addressed through the One-Time Shipment Request Form.  Waste managed in this way (even more than once year, but don’t push it) must be reported using the Waste Shipment Summary, but not the AWS.

When is “No Report Required” for the Annual Waste Summary?

• Though submitting the AWS is still a requirement for all registered generators of solid waste in Texas, you may submit a much shorter version (ie. ‘√’ the box “No Report Required”) if you meet both of the following criteria:
  • You are a Conditionally Exempt Small Quantity Generator of hazardous waste, and;
  • You recycle all of the Class 1 non-hazardous industrial solid waste you generated.

 Information on page 11 of the TCEQ guidance document for the AWS:  Industrial & Hazardous Waste Annual Waste Summary Instructions (RG-151), is unclear on this issue.  Please contact TCEQ for confirmation.

What types of wastes are required to be reported on the Annual Waste Summary?

• Hazardous waste
• Class 1 non-hazardous industrial solid waste, if not recycled.
• One-time shipments of hazardous waste.
• One-time shipments of Class 1 non-hazardous industrial solid waste, if not recycled.

What types of wastes are not reported on the Annual Waste Summary?

• You are not required to include information about the following wastes in your AWS:
  • Universal Waste
  • Nonhazardous used oil that is recycled.
  • Nonhazardous used oil filters that have been drained, contain no free liquids, and are recycled.
  • Any nonhazardous waste generated by a non-industrial facility.

Must I use STEERS to complete and submit the Annual Waste Summary?

• While STEERS is recommended for all reporting facilities, it is only required for a Large Quantity Generator of hazardous waste.
• An LQG is required to use STEERS to complete and submit the AWS.
• An LQG may be granted an exemption from the requirement to use STEERS if it submits a written request to TCEQ prior to January 25th.
• The deadline for submittal of the AWS if you are using STEERS is March 1st.

What is STEERS?

• STEERS is the State of Texas Environmental Electronic Reporting System.  It is an on-line system used by the TCEQ for a variety of environmental reporting requirements.  It can be used for submittal of the Annual Waste Summary for Industrial and Hazardous Waste.  Learn more about STEERS.

What if I need to change my Annual Waste Summary after it has been submitted?

• You may either correct or add information to your previously-submitted AWS in two ways.
  • File a revised AWS.
  • File a supplemental AWS.

The instructions for completing both of these actions can be found in the TCEQ guidance document:  Industrial & Hazardous Waste Annual Waste Summary Instructions (RG-151).

What about the Biennial Hazardous Waste Report?

• Completion and submittal of the the Annual Waste Summary fulfills the requirement of Large Quantity Generators of hazardous waste to submit the Biennial Hazardous Waste Report.

Where can I find more information?

• Refer to the TCEQ guidance document:  Industrial & Hazardous Waste Annual Waste Summary Instructions (RG-151).  It includes guidance and examples of completed forms.
• Contact me with questions:  815.821.1550/www.DanielsTraining.com/Info@DanielsTraining.com
• Attend one of my one day RCRA & TCEQ Training Seminars:
  • Houston, TX January 22, 2014
  • Austin, TX August 13, 2014