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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 1. 2. 3. 4. 5. 6. 7. Materials are potentially recyclable and have an economically feasible means of being recycled Appropriate turnover rates Notice of Intent to Operate a Recycling Facility Financial Assurance for Combustible Material Closure Cost Estimate Recordkeeping Fire Prevention & Suppression Plan Submit prior to commencement of operations Form provided by TCEQ Form 20049 Includes: Type(s) of material accepted for recycling Any storage of material(s) prior to recycling 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: an 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 facility 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 commission.” 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 authority Types Batteries Mercury containing equipment 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 Correctness Renew every five years and file above documentation with TCEQ 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 when: Continued to be used for intended purpose (repaired) Recycled within the US If Glass processing Glass manufacturing Smelting recycled, generator not subject to speculative accumulation Exported Glass removed from its housing or casing whose vacuum as been released, NOT a solid waste when: Recycled within requirements the US and meet certain Stored properly, or placed in appropriate container Labeled appropriately Transported in containers meeting requirements listed above 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 lead Exported NOT a solid waste when: Used, intact Exported for reuse Notifies EPA Documentation 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 product The processed CRT glass provides a useful contribution; The recycling process produces a valuable product or intermediate; 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 year Failure to submit Notice of Intent 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 requirements 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 investigation 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 https://www.tceq.texas.gov/about/directory Regional Offices, Waste Permits, Small Business Assistance Regulatory Guidance Checklists https://www.tceq.texas.gov/p2/nav/elec_recy_waste.h tml https://www.tceq.texas.gov/permitting/waste_permit s/msw_permits/MSW_amIregulatedrecycling.html/#f orms Karen Juliussen – DFW Region [email protected] 817-588-5848 Erin Gorman– DFW Region [email protected] 817-588-5853
