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Instructions for the P2 Annual Progress Report Paper Form

Online Instructions for the Pollution Prevention (P2) Annual Progress Report (APR) paper form.

Here are detailed instructions for completing the pollution-prevention (P2) annual progress report required by the Waste Reduction Policy Act.

For more information on what you need to complete the form, take time to review our Examples.

The form has three sections:

Facility Description

Facility Name—Enter the name of the facility as it appears on the Notice of Registration (NOR). This is usually the company name unless there are multiple facilities under one company name.

Mailing Address, City, State, and Zip Code—Enter the mailing address of the pollution-prevention contact. Use the five-digit ZIP code and enter the four-digit extension (#####-####) if known.

Pollution Prevention Contact—Enter the name of the person who can answer questions about the facility’s pollution prevention-program from the public, the TCEQ, or other parties.

Telephone, Fax—Enter the area code, telephone number, and fax number for the pollution prevention contact. Formatting is not an issue; the online form will automatically format it correctly.

Email Address—Include your email address or the email address of the Pollution Prevention Contact. We may need to notify you by email if we have any problems receiving your report.

TCEQ Solid Waste Registration Number (SW Reg #)—This number will be automatically displayed, based on the number entered on the opening screen.

Toxics Release Inventory (TRI) Identifier—This number will be automatically displayed, based on the number entered on the opening screen.

EPA (RCRA) Identifier—Enter the 12-character identification code. Most EPA Identifiers will begin with TXD or TXR, followed by nine numbers.

P2 Program Identifier (Pnumber)—This is the Pollution Prevention Program assigned to the WRPA facility. It will be in the format "PXXXXX". Example: P00008

SIC Code—Enter the four-digit number that best describes the principal product or service at the facility. The code should match the number on TRI Form R or the number provided on the Solid Waste Notice of Registration for the facility.

NAICS Code—Enter the four to six-digit number that best describes the products or services at the facility, according to the North American Industrial Classification System (NAICS).

Number of Employees—Enter the estimated total of all full-time employees at all sites of the company. For the purposes of this form, full-time employment means at least 2,000 work hours per year. The number may be estimated based on employee hours in a workweek. Forty work hours is considered equivalent to one full-time employee. If the facility is owned by an extremely large company, a general estimate of "1000" may be entered.

Is your company independently owned or operated?—If the company is part of a larger company, a subsidiary of another company, or operated by another company, the answer is “no.”

First Year of Your Current Plan—(Please read this section carefully.) The first year of the planning cycle is the first year of the plan. For example, if the first year of the P2 five year plan was 2008 and you are reporting in the year 2010, then 2008 is the "First Year of Your Current Plan."

This year is important, since you are evaluating the plan's progress over a five-year period. In general, most facilities list this year on the cover of the P2 Plan for easy reference.

Exception: If a new P2 Plan was initiated on January 1st of this year, you need to look at your previous five-year plan to get the "First Year of Your Current Plan". This is because the fifth year results, of the previous plan, will be submitted this year. For Example, if the plan began January 1, 2006, the fifth year would be 2010 and the next plan begins January 1, 2011. The P2 annual progress report due July 1, 2011, will be for the calendar year of 2010 and 2006 would be listed as the "First Year of Your Current Plan."

The results for the calendar year of 2011 will be reported in 2012 and 2011 will be listed as the "First Year of Your Current Plan" at that time.

  • The P2 Annual Progress report is a way of measuring your progress toward goals set in the facility's P2 plan.
  • You are required to keep a five-year P2 plan on site and available for an inspector.
  • The TCEQ does not usually keep a copy of your plan because the Executive Summary is the only piece of the P2 Plan that is required to be submitted.
  • The P2 Plan and the Executive summary are required to be renewed once every five years for as long as the Waste Reduction Policy Act applies to the facility.

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Projected Amounts for Goal Year

In this section, describe the goals for the facility. These numbers are all projections based on the goals stated in the current five-year P2 plan.

Goal Year—This is the fifth year of the facility's current plan and is automatically displayed based on the year entered on the “facility description” screen as the “First year of Planning Cycle.”

Projected Amount of HW Generation or TRI Releases/Transfers in the Goal Year (Tons)—Enter estimates for the amounts of hazardous waste to be generated and TRI chemicals to be released, transferred, or both for the goal year. In other words, when the plan is complete, how many tons of HW will have been generated? What will the TRI releases and transfers have been?

Source Reduction Anticipated over the Five-Year Period—Enter the amount of source reduction expected to be achieved through implementation of pollution-prevention projects, based on the pollution-prevention plan.

Percent Waste Minimization for the Goal Year—Enter the percentage of waste you generate at the end of the five-year planning cycle that will be recycled, burned for energy recovery, treated, or subject to other waste-minimization practices.

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Source Reduction Activities

Year Reported Here—The P2 annual progress report is due on July 1, and reports your activities from the previous year (January to December). So, if you are reporting in July of 2010, your report year is 2009.

This section contains information on the facility source reduction activities. In it, estimate the amount of waste that would have been generated if a pollution-prevention activity had not been implemented during the reporting year.

For each source-reduction project:

  • Report the estimated quantity (tons) of hazardous waste that was not generated (“HW” column). (Note: This column will not be visible if a Solid Waste ID or EPA ID was not reported on the first page.)
  • Report the estimated quantity (tons) of TRI chemicals that were not released or transferred (“TRI” column). (Note: This column will not be visible if a TRI ID was not reported on the first page.)

Select the category that most closely describes this project. The facility may have data to report under either one or the other, or both, categories.

If you report for TRI, you may have already reported some source-reduction activities in Section 8 of the TRI Form R.

One method of estimating source reduction is to compare the annual waste-summary totals from the previous year to this year. If a source reduction P2 project was implemented at the facility, and if all other factors are equal, then any decrease can be reported as source reduction.

However, other factors can affect the reported source-reduction totals, such as:

  • production
  • plant shutdowns
  • changes in reporting
  • weather (especially with air emissions)

For instance, if production triples at the facility, but hazardous-waste generation stays constant due to good operating practices, then there have been source reductions. In this case, the source reduction quantities, for the reporting year, can be determined by measurement or can be estimated using activity or production indexing.

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Source-Reduction Activities by Category

The following lists group source-reduction activities by category. Refer to this list to determine the category that most closely describes each facility project to complete the “Source Reduction Activities” section. If you report on the EPA TRI Form R, some source-reduction activities may have been reported in Section 8 that form.

Good Operating Practices

  • Segregate types of hazardous waste to make them more amenable to recycling
  • Segregate hazardous and nonhazardous wastes
  • Improve maintenance scheduling, record keeping, or procedures
  • Change production schedule
  • Make other changes in operating practices

Inventory Control

  • Institute procedures to reduce outdated material
  • Test outdated material
  • Eliminate shelf-life requirements for stable materials
  • Institute better labeling procedures
  • Institute a clearinghouse for exchanging waste materials
  • Make other changes in inventory control

Spill and Leak Prevention

  • Improve storage and stacking procedures
  • Improve procedures for loading, unloading, and transfer operations
  • Install overflow alarms or automatic shutoff valves
  • Install secondary containment
  • Install vapor recovery systems
  • Implement inspection or monitoring program of potential spill and leak sources
  • Make other changes to prevent spills and leaks

Raw-Material Modifications

  • Increase purity of materials
  • Substitute different raw materials
  • Institute closed-loop recycling
  • Modify equipment, layout, or piping
  • Use of different process catalyst
  • Institute better controls on operating conditions
  • Change from small-volume to bulk containers
  • Make other modifications to processes

Process Modifications

  • Institute recirculation within a process
  • Modify equipment, layout, or piping
  • Use a different process catalyst
  • Institute better controls on operating bulk containers to minimize discarding of empty containers
  • Change from small-volume to bulk containers to minimize discarding of empty containers
  • Make other modifications to processes

Cleaning and Degreasing

  • Modify stripping or cleaning equipment
  • Change to mechanical stripping or cleaning devices (from hazardous solvents)
  • Change to aqueous cleaners (from hazardous solvents or other materials)
  • Reduce number of solvents used, to make waste more amenable to recycling
  • Modify containment procedures for cleaning units
  • Improve draining procedures
  • Redesign parts racks to reduce drag-out
  • Modify or install rinse systems
  • Improve rinse-equipment design
  • Improve rinse-equipment operation
  • Make other modifications to cleaning and degreasing

Surface Preparation and Finishing

  • Modify spray systems or equipment
  • Substitute coating materials used
  • Improve application techniques
  • Change from spray to other system
  • Make other modifications to surface preparation and finishing

Product Modifications

  • Change product specifications
  • Modify design or composition of product
  • Modify packaging
  • Make other product modifications

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For Help

For assistance completing this report, to request a paper form, or for other questions about the Waste Reduction Policy Act, please contact us by:

Phone: 512/239-0010
Office Hours: Monday through Friday, 8 a.m. through 5 p.m., Central Standard Time