tceq

Q&A: Can I cure, process, then dispose universal waste paint in the garbage? Asking for a friend in Texas.

Q&A: Can I cure, process, then dispose universal waste paint in the garbage? Asking for a friend in Texas.

A question from the Lone Star State August 12, 2020:

Hi Daniel,

I have a question pertaining to the PPRW. We are SQH and I have been trying to figure out if it’s ok to Cure, process, and then dispose of our paint that is classified as UW in the garbage. Some people are saying yes that this is allowed but I can not seem to find where the information and code for this is.

I would greatly appreciate your help and advice.

Note: PPRW = Universal Waste Paint and Paint-Related Waste

Note: SQH = Small Quantity Handler of universal waste
Must have been snagged by my spam filter because I didn’t reply until August 18th:

I can assist you. Question: What state are you in?

The reply:

Hi Daniel,

I am in Texas

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
Now that I was sure I could reply:

I will answer your questions below.

  • No.
  • As the generator of a waste you must determine if it is a hazardous waste.
  • If a hazardous waste, you have the option (in Texas) to manage PPRW as a universal waste.
    • Universal waste paint & paint-related waste is unique to Texas. It is not recognized by Federal regulations of USEPA. Some states have similar universal waste types, e.g., oil-based finishes in Pennsylvania, but not nearly as broad as that of Texas.
  • If you choose to manage as a universal waste instead of hazardous waste you must then manage it subject to Texas universal waste regulations.
  • Texas regulations at 30 TAC 335.261(b)(18) read: (a small quantity handler of universal waste is…) “Prohibited from diluting or treating universal waste, except when responding to releases…”
  • What you describe would be considered treatment and is not allowed.
  • Also, universal waste may only be sent to another handler or to a destination facility, not a solid waste landfill.
  • Please refer to this article I wrote summarizing the requirements for management of Paint and Paint Related Waste as Universal Waste in Texas.

I hope this helps. Please contact me with any other questions.

Conclusion:

I did not hear back from them. It may not have been the answer they wanted, but it does inform them of what they must do to comply with the regulations of the TCEQ for Texas.

Contact me the next time hazardous waste generator USEPA training is due to expire.

Though I’m based in Illinois, I conduct training all over the country and have been to Texas for training several times. If travel costs are a limiting factor (my Onsite Training includes reimbursement for my travel costs) the same training can be provided by a live interactive webinar.

TCEQ Pollution Prevention Waste Management Workshop – Registration Now Open!

The Texas Commission on Environmental Quality (TCEQ) requires Pollution Prevention plans for the following facilities in Texas:

  • Large Quantity Generator of hazardous waste.
  • Small Quantity Generator of hazardous waste.
  • Facility that submits the Toxic Release Inventory (TRI) Form R Report.

Not sure of your hazardous waste generator status?

 Take this short survey

This workshop hosted by TCEQ will provide information on programs and resources to help create, continue, and publicize a facility’s P2 and waste management efforts.

Registration:
Early Registration (through Aug. 31): $79.00
Registration (Sept. 1 – Sept.19): $159.00
Onsite Registration (Sept. 20): $179.00

Location:
J.J. Pickle Center
10100 Burnet Road, Bldg 137
Austin, TX 78758

For more information, visit the event webpage:  Pollution Prevention Waste Management Workshop

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste in Texas

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Texas Commission on Environmental Quality to Host Pollution Prevention Waste Management Workshop

A business should always be looking for ways to reduce the amount of waste it generates.  Those generators that are the status of a large quantity generator or small quantity generator are subject to the requirements of the Waste Minimization Certification which mandates certain pollution prevention efforts.

Not sure of your hazardous waste generator status?
 TAKE THIS SHORT SURVEY

The state of Texas takes this one step further by including in the Texas Administrative Code a requirement for subject facilities to comply with the Pollution Prevention Planning regulations of the Texas Commission on Environmental Quality (TCEQ) at 30 TAC 335, subchapter Q.

Texas facilities subject to the Pollution Prevention Planning regulations are:

  • Large quantity generators of hazardous waste and small quantity generators of hazardous waste that submit the Annual Waste Summary.
  • All facilities that submit the Toxic Release Inventory (TRI).

I don’t intend to summarize all of the requirements of the P2 Planning regulations here.  Instead I’ll direct you to two guidance documents from the TCEQ:

Too much?  Need help?  Don’t worry, that’s what the TCEQ is here for!

TCEQ is hosting a Pollution Prevention Waste Management Workshop on September 7, 2016 at the J.J. Pickle Research Campus, The University of Texas at Austin.

You can find more information and/or register for the workshop at the TCEQ event page:  TCEQ Pollution Prevention Waste Management Workshop

What better way to learn the requirements of the P2 Planning regulations than the agency that enforces them?

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

One-Time Waste Shipment Program in Texas

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. (more…)

The 2015 Environmental Trade Fair and Conference Presented by the TCEQ is Approaching!

I can’t recommend enough the annual Environmental Trade Fair and Conference (ETFC) presented by the Texas Commission on Environmental Quality (TCEQ).  These two days are a conference, convention, expo, network-building, customer/client interaction, relationship building, skill improving, knowledge enhancing…great time, deep in the heart of Texas!

TCEQ training for hazardous waste personnel

TCEQ regulates hazardous and non-hazardous waste from both industrial and non-industrial facilities.

Though I missed the ETFC in 2014, I attended my first in 2013 and found it very helpful in improving the breadth and depth of my knowledge of the TCEQ regulations.  While I’m there entirely for issues related to waste management, there are exhibits and educational seminars on a variety of environmental regulatory topics.  Representatives of the TCEQ are there to answer your questions, so you know you are getting it right from the source.

With all the time spent learning from the TCEQ staff, I had to speed through the exhibit floor as fast as I could and an entire day wasn’t enough to see all the exhibitors – let alone speak with them.  The exhibitors I did speak with were from throughout the environmental industry and I came away with many good contacts  In several cases I was finally able to meet people face-to-face that I had done business with over the phone for years.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

If you go, and I advise that you do, be prepared for two full days of networking and learning.

Mark your calendars for the 2015 Environmental Trade Fair & Conference (ETFC), May 5-6 2015, at the Austin Convention Center.

Exhibit booth sales will be opening soon:

Six or more booth sales Monday, October 20th at 9:00 am CST
Four or more booth sales Tuesday, October 21st at 9:00 am CST
Three or more booth sales Wednesday, October 22nd at 9:00 am CST
*Pre-set Double booth sales Thursday, October 23rd at 9:00 am CST
One or more booth sales Monday, October 27th at 9:00 am CST

*Pre-set double booths – Designated booths will be available on Oct 23rd.

If you would like to purchase double booths not on sale on Oct. 23rd, you may purchase any available booths on October 27th.

Attendee Registration will open Monday, November 3rd at 9:00 am.

For more information on the ETFC, go to:

2015 Environmental Trade Fair and Conference

One more thing – If your Texas business generates a hazardous waste, universal waste, used oil, or a non-hazardous industrial solid waste, I advise you to attend my one-day (8 hour) training seminar held each year in Houston (January 2015, exact date TBD) and Dallas/Fort Worth (August 2015, exact date TBD).  Find me at the 2015 ETFC and I’ll give you a promotional code you can use for one of my training seminars in 2015!

Interested in a Training Seminar that covers this topic, and more?

My Training Seminar Schedule

The Identification of Solid Waste in Texas

TCEQ training for hazardous waste personnel

TCEQ regulates hazardous and non-hazardous waste from both industrial and non-industrial facilities.

Though very similar to those of the USEPA, as a state with an authorized hazardous waste program under RCRA, Texas waste regulations – created and enforced by the Texas Commission on Environmental Quality (TCEQ) – have their own state-specific nuances.  For a person in Texas subject to these regulations, slight differences between state and Federal regulations can make a big difference.  This article will look at one aspect of the waste regulations of the TCEQ in Texas:  What is, and isn’t, a Solid Waste. (more…)

The Advocate: TCEQ’s Quarterly Small Business and Local Government Assistance Rules Update

Subscription to The Advocate – either electronic or hardcopy – is a must for any small business or local government agency in Texas.

TCEQ training for hazardous waste personnel

TCEQ regulates hazardous and non-hazardous waste from both industrial and non-industrial facilities.

The Advocate is the TCEQ’s Small Business and Local Government Assistance rules update, printed quarterly, containing information regarding compliance issues and regulatory concerns that affect small businesses and local governments.

From its banner:  For and about small businesses and local governments affected by environmental regulations

Take a look at The Advocate for 3rd Quarter 2014, or access the library of issues going back to Winter of 1997!

You can receive a hard-copy edition in the mail at no charge or you can sign up to receive an e-mail alert when each new issue is available on TCEQ’s web site.  Find out how to subscribe to either electronic or hardcopy.

No matter whether state or Federal, compliance with the regulations begins with knowledge.  I recommend you take advantage of this source of information to increase your knowledge of the regulations of the Texas Commission on Environmental Quality.  And, be sure to attend my one day Training Seminar in Austin, TX on August 13, 2014.  You’ll come away with an expanded awareness of the TCEQ regulations for the management of Industrial Solid Waste, Hazardous Waste, Universal Waste, and Used Oil.

Be sure to contact me with any questions you may have about the Texas regulations for the management of waste.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

 

TCEQ Webpage: Air Monitoring Data for Eagle Ford Shale Geological Area

The Bullet:

The Texas Commission on Environmental Quality (TCEQ) has created a new website to provide data to interested parties on the air emissions at the Eagle Ford Shale Geological Area in southeast Texas.

Who:

The Texas Railroad Commission or Railroad Commission of Texas (RRC) and the Texas Commission one Environmental Quality (TCEQ).

What:

The Eagle Ford Shale is a hydrocarbon-producing geological formation extending over 26 Texas counties.

The TCEQ webpage contains near real-time air monitoring data from the agency’s Auto GC monitor, sampling results and health effects evaluations by county and links to the Texas Air Monitoring System (TAMIS).  More information about the monitoring method can be found on the webpage.

Where:

The Eagle Ford Shale Geological Area stretches from the Mexican border between Laredo and Eagle Pass up through counties east of Temple and Waco.

When:

The TCEQ webpage was launched June 6, 2014.

How:

The Texas Railroad Commission has primary responsibility for rail and gas facilities in Texas.  The role of the TCEQ is limited to regulating air emissions and ensuring air quality.

Conclusion:

Refer to the TCEQ webpage: Eagle Ford Shale Geological Area for more information.

Due to the unique arrangement of the TCEQ and the RRC in Texas, the generation of waste during the exploration and production of oil and natural gas is subject to RRC regulations and not those of the TCEQ.  However, this authority changes for wastes that are generated “above the hole” during the transportation and processing of oil and natural gas.  Contact me with any questions you may have about the generation of waste within Texas and the applicability of the regulations of the TCEQ or the RRC to your operations.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

 

Pioneer Natural Resources in Amarillo, TX is Awarded the Texas Environmental Excellence Award

By taking an innovative approach to its pigging operations Pioneer Natural Resources earned for itself a 2014 Texas Environmental Excellence Award (TEEA). Using a three-tiered approach, Pioneer was able to reduce its operational emissions by 90 percent.  For its efforts, Pioneer was recognized with other winners’ projects at a banquet held on the last night of the TCEQ Environmental Trade Fair and Conference in Austin, TX.  BTW, I wasn’t able to make the TCEQ conference even though I had already registered and paid.  I highly recommend attendance at the conference in 2015 for anyone who does business in Texas.

So what did Pioneer do?  Well, you can read a short summary below, but much more information about the project and a short video summary is available here:  http://teea.org/winners/2014/pollution-prevention/pioneer-natural-resources

First, Pioneer installed larger barrels for pig launching and receiving.  These larger barrels held more pigs – natch! – resulting in less venting of natural gas to the atmosphere when valves are opened to add or remove them.

Secondly, the pressure in the barrels was reduced from 100 pounds of pressure to 1 pound prior to opening.  The result:  Less venting of natural gas to the atmosphere.

And finally, Pioneer installed suction drain lines to route accumulated natural gas liquids back into production.  This differs from standard industry practice which is to drain the liquids into open-air tubs that evaporate into the air.  Yikes!  Really?  That’s “standard industry practice”?

What is pigging?

Pigging is a standard industry process involving running a spherical ball, called a pig, through a pipeline to sweep out accumulated produced liquids and debris.  Loading and retrieving pigs into and from a pipeline often requires opening several hatches and valves that allow small amounts of natural gas to vent into the atmosphere.

Interested in snagging a TEEA for your company in 2015?  The 2015 Application Cycle will open August 2014. Visit the TEEA site to apply. http://teea.org/texas-environmental-excellence-awards

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

I’ve been conducting Training Seminars and Onsite training in Texas for several years now on the topics of Hazardous Material transportation and Waste Management.  And though they are more strict and more broad than  those of the USEPA and most other states (California being the exception) the regulations of the TCEQ for the management of hazardous waste, Used Oil, Universal Waste, and Non-Hazardous Industrial Solid Waste can be understood.  It just takes good training.

The Identification of Industrial and Non-Industrial Waste in Texas

TCEQ training for hazardous waste personnel

TCEQ regulates hazardous and non-hazardous waste from both industrial and non-industrial facilities.

As a state that operates its own hazardous waste program under the authority of the Resource Conservation and Recovery Act (RCRA), Texas has its own unique requirements for the regulation of both hazardous and non-hazardous waste.  An essential requirement of compliance with the TCEQ (Texas Commission on Environmental Quality) regulations is the determination of the source of the waste, either industrial or non-industrial.  The purpose of this article is to explain the difference between an industrial solid waste and non-industrial solid waste in regard to the waste regulations of the TCEQ.

(more…)