In 1991, the Texas Legislature adopted the Waste Reduction Policy Act (WRPA)1 to reduce the volume, toxicity, adverse public health, and environmental effects of hazardous pollutants in Texas. The WRPA, enforced through the Texas Commission on Environmental Quality (TCEQ), requires certain industrial facilities and businesses to notify the TCEQ of their waste activities by obtaining a Solid Waste Registration (SWR) via the Industrial and Hazardous Waste Registration and Reporting Program.
Registered generators with active SWRs in Texas must submit an Industrial & Hazardous Waste Annual Waste Summary (AWS) each year. This summary reports information on hazardous and industrial non-hazardous Class 1 waste generated or managed during the calendar year.
The AWS is a mandatory report for facilities that generate hazardous and Class 1 nonhazardous waste or operate as treatment, storage, and disposal facilities (TSDFs) in Texas.
Keep reading to learn which Texas waste generators must obtain an SWR, whether they trigger submission of an AWS report, how to do so, and how EDGE can help your facility maintain compliance under the TCEQ Industrial and Hazardous Waste Registration and Reporting Program.
Who Needs a Solid Waste Registration?
The following types of facilities/businesses that generate industrial non-hazardous Class 1 or hazardous waste must obtain a Solid Waste Registration (SWR):
- Industrial generators of more than 220 lbs. of non-hazardous Class 1 waste per month;
- Small Quantity Generators (SQG) of hazardous waste; and
- Large Quantity Generators (LQG) of hazardous waste.
Who Needs to Submit an AWS?
Facilities must submit a detailed AWS report if they:
- Generated 2,000 pounds or more of industrial non-hazardous Class 1 waste;
- Generated 2,000 pounds or more of hazardous waste;
- Generated more than 2.2 pounds of acutely hazardous waste;
- Generated more than 220 pounds of contaminated soil, water, or debris from the cleanup of acutely hazardous waste;
- Generated 220 pounds or more of hazardous waste in any calendar month, and/or
- Stored 2,200 pounds or more of hazardous waste on-site at any time; and/or
Reporting Requirements
The following types of waste must be reported on the AWS:
- Acutely hazardous waste,
- Hazardous waste, including episodically generated,
- Hazardous waste that is recycled, and
- Industrial Class 1 nonhazardous waste that is not recycled.
Wastes That Do Not Require Reporting Include
- Recycled industrial non-hazardous Class 1 wastes, and
- Universal waste.
How to Submit
There are two methods for submitting the AWS:
- Electronically using the State of Texas Environmental Electronic Reporting System (STEERS) by March 1 of the following year
- On paper, using Annual Waste Summary Form 00436 by January 25th of the following year (for non-LQGs only)
Large Quantity Generators must submit electronically through STEERS.
Additional Information
- The AWS fulfills the EPA’s Biennial Hazardous Waste Report requirement for Large Quantity Generators in Texas.
- Facilities generating less than 220 pounds of hazardous or Class 1 industrial waste per month must still submit an AWS via the STEERS program but don’t need to provide detailed waste activity information.
How Can EDGE Help?
EDGE offers a full range of services related to waste management for Texas facilities, including:
- Establishing waste management tracking and recordkeeping system for your operations;
- Sampling, classifying, and profiling the types of waste generated;
- Cleanup and closure of waste management units;
- Initial applications and updates to Industrial and Hazardous Waste Notice of Registration (NOR);
- Calculating volumes of acutely hazardous, hazardous, industrial non-hazardous Class 1, universal, and recycled waste generated by your facility; and
- Annual Waste Reporting to the TCEQ through paper reports and STEERS submissions.
For help navigating the Texas AWS reporting season and other various waste reporting requirements for all 50 states, contact a member of EDGE’s experienced waste team today!
1 Texas Health & Safety Code § 361.501 et seq. (1991)