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Karen Juliussen
Erin Gorman
 Overview of recycling
 Rules and regulations
 Authorizations/Notifications
 Title 30 Texas Administrative Code Chapter 328
 Cathode ray tubes
 Common issues
 Facility Investigations
 Violation Categories
The TCEQ supports the diversion of
materials from the solid waste streams in
order to promote the economic recovery
and reuse of materials.
 Recycling -- A process by which materials that have
served their intended use or are scrapped, discarded,
used, surplus, or obsolete are collected, separated, or
processed and returned to use in the form of raw
materials in the production of new products.
 Recyclable material -- A material that has been
recovered or diverted from the nonhazardous waste
stream for purposes of reuse, recycling, or reclamation.
 Used electronics may be considered a waste if:
 Discarded or not used for their intended purpose,
 No longer recyclable, or
 Not an exempt material
 Examples of exempt materials:
 Recycled processed scrap metal
 Shredded circuit boards
 Waste Minimization and Recycling Rules
 30 TAC Chapter 328
 Municipal Solid Waste Rules
 30 TAC Chapter 330
 Industrial Solid Waste and Municipal Hazardous
Waste Rules
 30 TAC Chapter 335
 Hazardous Waste Rules
 40 CFR Parts 260, 261, and 273
 Industrial sites
 Notification for Receiving and Recycling Hazardous or
Industrial Waste – Form 0524
 Non-industrial (Municipal) sites
 Notice of Intent (NOI) to Operate a Recycling Facility –
Form 20049
 Applies to:
 anyone who receives, processes, and returns to use only nonputrescible, source-separated recyclable materials diverted
from a municipal solid waste stream.
 Government facility
 Facility receives:
 > 50% of recyclable material from any combination of
generators not affiliated with the facility, from the public, or
from haulers not affiliated with the facility;
 the facility receives no financial compensation (including
services) to accept recyclable material; AND
 the facility accumulating the recyclable material can show
that the material is potentially recyclable and has an
economically feasible means of being recycled.
 Facility smelts recyclable metals or is a secondary
metal recycler, or
 Facility owned or operated, or affiliated with, a person
who holds an MSW disposal permit
Materials are potentially recyclable and
have an economically feasible means of
being recycled
Appropriate turnover rates
Notice of Intent to Operate a Recycling
Financial Assurance for Combustible
Closure Cost Estimate
Fire Prevention & Suppression Plan
 Submit prior to commencement of
 Form provided by TCEQ
 Form 20049
 Includes:
 Type(s) of material accepted for recycling
 Any storage of material(s) prior to
 How the material(s) will be recycled
 The facility accumulating materials must show that the
material is potentially recyclable and has
economically feasible means of being recycled.
 Proof includes:
 Contracts
 Turnover Records
 Market Information
 Potential Customers
 Cost analysis to determine how much it would cost to
produce the product and how much it could sell for
 Condition of the site
 Equipment on site
 Facility must obtain if:
 Storing combustible material outdoors
 Storage of material poses a significant risk to public health
and safety (as determined by Executive Director)
 Estimate must include:
 Equal cost of closure of the facility, including:
Disposition of maximum inventories of all processed &
unprocessed materials stored outdoors at an authorized
 Based on the costs of hiring a third party that is not
affiliated with the owner or operators
Loading, transportation, and final disposition
 Based on a per cubic yards and/or short ton measure for
collection and disposition costs
 Financial Assurance Mechanisms
 Surety Bond Guaranteeing Payment
 Irrevocable Standby Letter of Credit
 Insurance
 Financial Test
 Corporate Guarantee
 Local Government Financial Test
 Local Government Guarantee
 Required Records:
 Proof of financial assurance to cover closure costs
 Reasonable effort to maintain source-separation of materials
received by the facility
Notice to customers of source-separation requirements
Training of staff in the inspection of incoming loads
Documentation of loads rejected
 Turn over rates
 50% every subsequent 6 months
 Records need to demonstrate appropriate turnover
Each material of same type
 “Except as otherwise authorized by this chapter, a person
may not cause, suffer, allow, or permit the dumping or
disposal of MSW without the written authorization of the
 30 TAC 3.2(25) defines a person as, “An individual,
corporation, organization, government or governmental
subdivision or agency, business trust, partnership,
association, or any other legal entity.”
 Must have a plan if:
 Subject to 30 TAC 328.4 and 328.5
 Manage combustible material outside
 Must make it available to the local fire prevention
 Types
 Batteries
 Mercury containing
 Lamps
 Pesticides
 Paint and Paint-Related
Waste (Texas only)
 Can accumulate for one year
 Label Universal Waste- type
of waste
 Ex: Universal Waste-
Batteries, Universal WasteLamps
 Maintain record of
accumulation start date
 Large Quantity Handler
 Accumulates at any time ≥ 5,000
kilograms (kg)
 Must notify
 Maintain records of shipments
 Small Quantity Handler
 Does not accumulate
≥ 5,000 kg at any time
 Notification not required
 Records not required
 Conduct long-range planning to prevent pollution
 Save money, reduce liability, lessen regulatory burden
 Toxics Release Inventory (TRI) reporters
 Toxic chemicals that may pose a threat
 Large or Small Quantity Generators of hazardous waste
 Requirements
 Five-year plan
 Submit Executive Summary
 Submit a signed Certificate of Completeness and
 Renew every five years and file above documentation with
 Submit an Annual Progress Report
 Major component of older-style computer monitors and
television screens
 Funnels typically contain more lead than panel (frit seal)
 Color contains more lead than monochrome
 Due to technological advances (high-definition
televisions, flat-panel computer monitors), a high number
of CRTs will be discarded
 Recycling encouraged over land disposal
 Vacuum has not been released, then NOT a solid waste
 Continued to be used for intended purpose (repaired)
 Recycled within the US
 If
Glass processing
Glass manufacturing
recycled, generator not subject to speculative
 Exported
 Glass removed from its housing or casing whose
vacuum as been released, NOT a solid waste when:
 Recycled
Stored properly, or placed in appropriate container
Labeled appropriately
Transported in containers meeting requirements listed
Not accumulated speculatively
Compliant with use constituting disposal requirements in
Part 266 Subpart C
Processing conducted in a building with a roof, floor, and
walls, and at temperatures not high enough to volatilize
 Exported
NOT a solid waste when:
 Used, intact
 Exported for reuse
 Notifies EPA
 Exported for recycling
Notifies EPA
Receives written consent from receiving country
Complies with speculative accumulation
 Used, broken
 Exported for recycling
Notifies EPA
Receives written consent from receiving country
Complies with speculative accumulation
Meets storage, labeling, and transportation requirements
 Glass that is broken, separated, and sorted, or otherwise
managed after it has been removed from CRT monitors
 Panel, funnel, and frit line
 Not a solid waste if recycled
 Not
subject to export requirements unless it is
speculatively accumulated
 May be excluded from regulation when used as an
ingredient or as an effective substitute for a commercial
 The processed CRT glass provides a useful contribution;
 The recycling process produces a valuable product or
 The processed CRT glass is managed as a valuable
commodity; AND
 The product of the recycling process is comparable to a
legitimate product.
A solid waste when:
 Sent for disposal – either unused or used, and hazardous
waste if exhibits a characteristic
 Accumulated Speculatively
 Show that the material is potentially recyclable and has a
feasible means of being recycled
 75 percent recycled or transferred during the calendar year
 Example: a total of 100 tons of CRT glass stockpiled for
recycling on January 1 must recycle, or transfer for recycling,
at least 75 tons of CRT glass before the end of the calendar
 Failure to submit Notice of
Failure to obtain/maintain
Financial Assurance
Proprietary Information
Lack of operating records
Mercury switches, mercury
relays, and nickelcadmium and lithium
battery storage
Speculative accumulation
of CRTs
 Compliance Evaluations
 Announced
 Complaints
 Unannounced
 Contacts with local authorities, i.e., fire departments,
environmental compliance inspectors, etc.
 Citizens
 Investigations prompted by MSW Permits requesting
review of NOIs submitted by facilities
 Announced
 Entrance Interview
 Explanation of the
investigation process
 Walk-through of facility
 Observe operations
 Verify physical
 Record Review
 Review required
recordkeeping documents
 Exit Interview
 Preliminary summary of
investigation findings
 Verbal
Conducted at the end of the
on-site investigation
 Written
 Exit Interview Form
 Provided at conclusion of
on-site investigation, or
 Transmitted within a couple
of days following the on-site
 General Compliance Letter
 No violations
 Additional Issues
 Notice of Violation
 Alleged violation/required action/due date
 Final letter once compliance achieved
 Notice of Enforcement
 Alleged violation/required action/due date
 Category A
 Category B – repeat or unresolved
 Referred to Enforcement Division
 Categories of violations
 A, B, C and Area of Concern
 Category A
 Formal Enforcement – Notice of Enforcement
 Fine levied
 Examples
No financial assurance
Repeat Category B
 Category B
 Notice of Violation
 Written warning
 Example
Failure to maintain source separation documentation
 Category C
 Notice of Violation
 Written warning
 Example
Incomplete/incorrect recordkeeping
 Area of Concern
 Criteria:
Must be category C violation
Must be resolved within 14 days of the end of the investigation
Must not involve potential harm/impact
Must not have been documented in the prior 12 months
 Not reflected in Compliance History
 Additional Issue
 Not a violation, but a concern that needs to be addressed or it
may lead to a violation
Poor housekeeping
*Examples are generalized; each site is looked at on a
case-by-case basis
 TCEQ homepage
 Contact Us
Regional Offices, Waste Permits, Small Business Assistance
 Regulatory Guidance
 Checklists
Karen Juliussen – DFW Region
[email protected]
Erin Gorman– DFW Region
[email protected]