The regulations of the Texas Commission on Environmental Quality (TCEQ) divide Texas waste generators into two categories: industrial and non-industrial. TCEQ regulates the hazardous waste generated by both industrial and non-industrial facilities and the non-hazardous waste generated by an industrial facility; nonhazardous waste generated by a non-industrial facility is not regulated by TCEQ. Non-hazardous waste generated by an industrial facility is classified as either Class 1 (almost hazardous), Class 2 (plant trash and empty containers), or Class 3 (inert, harmless, and rare).
Depending on the type and amount of waste generated a facility may need to register with TCEQ to obtain a Federal EPA ID number and/or a Texas Solid Waste Registration Number and apply determine the 8-digit Texas waste code for its waste.
The purpose of this article is to identify and explain the requirements of the One-Time Shipment (OTS) Program for waste generators in Texas.
First of all, the OTS Program is designed for Texas businesses who are not and should not be registered with the TCEQ. This includes the following:
- Non-industrial facility that generates no more than 100 kg (220 lbs) of hazardous waste per calendar month. i.e. a Conditionally Exempt Small Quantity Generator of hazardous waste or CESQG.
- Industrial facility that is a CESQG for hazardous waste and generates no more than 220 lbs/month of non-hazardous Class 1 waste.
- A formerly registered facility whose registration has become inactive.
If any of the above facilities were to generate an amount of waste that requires registration (i.e. >100 kg of hazardous waste or >220 lbs of Class 1 non-hazardous industrial waste) as a one-time event it may take advantage of the OTS Program as an alternative to becoming a registered waste generator. For the applicable facilities that complete and submit the OTS Request form (TCEQ-0757) the OTS Program provides the following:
- Temporary Texas registration number.
- Temporary 8-digit Texas waste code.
And, if necessary…
- Temporary USEPA ID Number.
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The following should already be registered with the TCEQ and can not utilize the OTS Program:
- Any business (industrial or non-industrial) that routinely generates more than 100 kg (220 lbs) of hazardous waste in a calendar month. i.e. a Small Quantity Generator for >100 to <1,000 kg/mo or a Large Quantity Generator for equal to or more than 1,000 kg/mo.
- An industrial facility that routinely generates more than 220 lb/mo of non-hazardous Class 1 waste.
Further, the OTS Program should not be used for the following:
- A registered facility that wishes to add a new waste stream. Complete Part II of the Notification for Hazardous or Industrial Waste Management Form (TCEQ-00002).
- A non-industrial facility that only generates non-hazardous waste. Just throw it in the trash.
- A non-industrial CESQG whose hazardous waste generation never exceeds – not even one time – 100 kg/mo. Assign an 8-digit Texas waste code with “CESQ” as the sequence number. Assign a Texas registration number: “CESQG”. And, assign an EPA ID Number: “TXCESQG”
- An industrial CESQG whose hazardous waste generation never exceeds – not even one time – 100 kg/mo and whose Class 1 non-hazardous waste generation never exceeds – not even one time – 220 lb/mo. Assign an 8-digit Texas waste code with “CESQ” as the sequence number. Assign a Texas registration number: “CESQG”. And, if the waste is hazardous, assign an EPA ID Number: “TXCESQG”
The completed OTS Request Form (TCEQ-0757) must be submitted by fax (512.239.6410) or mail (TCEQ / Permitting and Remediation Support Division / Registration and Reporting Section / PO Box 13087 MC 129 / Austin, TX 78711-3087). Electronic submission is not allowed.
Normal processing time of a OTS Request is 2-3 working days. This may be too long for some one-time generators, so a request for expediting may be submitted with the TCEQ-0757 form for one of the following reasons:
- Delay will cause endangerment to human health or the environment.
- Waste removal is mandated under a governmental order (Federal, state, or county). A copy of the order must be submitted with the request.
- Delay will result in temporary or permanent closure of business, bankruptcy, layoff of personnel, &etc.
Wastes managed under the OTS Program must be considered when determining the following:
- Your facility’s hazardous waste generator status.
- Your waste generation fee.
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One final note…
The TCEQ webpage for the One-Time Waste Shipment Program contains good information and links to the necessary forms, but is also a little misleading in its language. Based on the following excerpts one might be led to think – at least I initially did – that the OTS Program applies to Class 2 or Class 3 non-hazardous waste (it doesn’t) or that a non-industrial facility can generate a non-hazardous industrial waste that is regulated by the TCEQ (it can’t).
- “To obtain a temporary registration complete the One-Time Shipment Request for Texas Waste code for Shipment of Class 1, 2, 3, and EPA Hazardous Waste Form (TCEQ-0757).” No registration temporary or otherwise is required for a Class 2 or Class 3 non-hazardous waste.
- “Nonindustrial conditionally exempt small quantity generators (CESQGs) that generate less than 220 pounds of Class 1 waste…” A non-industrial facility can’t generate a Class 1 non-hazardous waste which can only be generated by an industrial facility.
- “The completed OTS form must be faxed to 512/239-6410.” Part 4 of the instructions on the OTS Form allows it to be mailed to TCEQ.
- “Wastes managed under the OTS Program are…included in determining your generation fee–if the waste is hazardous or Class 1.” Waste must be hazardous or Class 1 non-hazardous generated by an industrial facility in order to be subject to the OTS Program.
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If you are not able to take advantage of the OTS Program because you are registered with TCEQ as a generator of either hazardous waste or Class 1 non-hazardous waste you would benefit from my Onsite TCEQ Hazardous Waste Personnel Training which covers all waste generation and management (hazardous; non-hazardous class 1, 2, & 3; universal; and used oil) in Texas.