Section Overview and Emerging Issues Bob Patton, Jr., Manager Industrial and Hazardous Waste Permits Section Section Overview and Emerging Issues May 15, 2018 Bob Patton, Jr., Manager Industrial and Hazardous Waste Permits Section May 15, 2018

Waste Permits Division Brent Wade Deputy Director Permitting & Registration Support Division Jaya Zyman, P.E., Director Registration & Reporting Section Don Kennedy, Manager Occupational Licensing Section Linda Saladino, Manager Remediation Division Beth Seaton, Director Superfund Section Monica Harris, P.G., Manager Voluntary Cleanup Program/Corrective Action Section Merrie Smith, P.G., Manager Petroleum Storages Tank/Dry Cleaner Remediation Sections Kenneth Davis, P.G., Manager Division Support Section Craig Watts, Manager Waste Permits Division Earl Lott, Director Industrial & Hazardous Waste Permits Section Bob Patton, Manager Municipal Solid Waste Permits Section Chance Goodin, Manager Business & Program Services Section Gene Muller, Manager Radioactive Materials Division Charles Maguire, Director Radioactive Materials Section Bobby Janecka, Manager Underground Injection Control Permits Section Lorrie Council, P.G., Manager

Industrial & Hazardous Waste Permits Section Bob Patton, Jr. Section Manager Industrial & Hazardous Waste Permits Section Team 1 Will Wyman, Team Leader Industrial & Hazardous Waste Permits Section Team 2 Sarah Schreier, Team Leader Technical ASSISTANCE Group Scott Green, Work Leader COAL COMBUSTION RESIDUALS PROGRAM Kara Denney, Technical Specialist Industrial & Hazardous Waste Permits Section Rules Coordinator Jarita Sepulvado, Technical Specialist

Programs in the I&HW Section Hazardous Waste Permitting Industrial Solid Waste Permitting Hazardous Waste Combustion Program Coal Combustion Residuals (CCR) Program (Brand new)

Programs in the I&HW Section 5) Rule Writing Team 6) Solid Waste Variances 7) Recycling 8) Analytical Data Audits 9) QA Data Validation

Additional I&HW Updates

EPA Updates CCR Rule E-Manifest Definition of Solid Waste Rule Generator Improvement Rule

Applicant Toolbox [In background, image of a toolbox with the following labels: Part B Electronic Checklist, Standardized NOD Letter, Guidance Documents and Tools, Pre-Application Meetings, Listserv – E-mail Updates.] [In foreground, image of an open toolbox with the following text: “Easier, Better, Faster Permitting”.] Developing improvements guided by application deficiency studies and the Part B electronic checklist. Applicant Toolbox Developing improvements guided by application deficiency studies and the Part B electronic checklist. [In background, image of a toolbox with the following labels: Part B Electronic Checklist, Standardized NOD Letter, Guidance Documents and Tools, Pre-Application Meetings, Listserv – E-mail Updates.] [In foreground, image of an open toolbox with the following text: “Easier, Better, Faster Permitting”.]

Permitting Process (120 Days)

Administrative: Completeness vs. Content 67% / 33% 53% / 47% Talking Points and Details: FY2014: 1,822 deficiencies identified from 68 total NOD letters (20 administrative, and 48 technical) FY2016: 294 deficiencies identified from 25 total NOD letters (17 administrative, 8 technical) Only studied those deficiencies which were part of applications which used the Part B electronic checklist This study showed evidence of improvement in the number of deficiencies per NOD letter, as well as an overall reduction in the amount of completeness and content errors FY2017: 247 deficiencies identified from 13 total NOD letters (6 administrative, 7 technical) This study continued to show evidence of improvement in the number of deficiencies per NOD letter, as well as an overall reduction in the amount of completeness and content errors. However, there were increases in the amount of completeness errors identified in comparison to the FY 2016 Study. This increase can be attributed to several factors, including: The submittal of larger applications with more information, as the Part B checklist shows the applicant what is required for their application; and The ability of permit writers to complete a more thorough review with the use of the Part B electronic checklist. From year to year, we continue to see positive results in application completion and content from the use of the Part B electronic checklist and other improvement tools. These graphs show a steady decrease in the proportion of completeness errors to content errors in administrative NOD letters. Completeness Errors Content Errors

Technical: Avg. # of Completeness Errors Details This graph compares the average number of completeness errors in Sections III-VII of the Part B application for FY2014, FY106, and FY2017. These application sections were identified in the FY2014 study as containing the majority of completeness errors identified in technical NOD letters. The average numbers of errors generally decreased per each section in FY2016; however, the averages increased in FY2017.

Process Improvements & Workload Reduction Projects Application and Draft Permit Processing Work Group Historical Knowledge Work Group Review Streamlining 4) Process Enhancements New employee generation gap. Called “The Great Generational Shift” by Bruce Tulgan, 2017. Percentages of first wave millennials (1978-1989) and second wave millennials (1990-2000). First wave and second wave 2017 = 48% of workforce First wave and second wave 2020 est 51% of workforce Impact to IHW (FY2019 – 52% eligible to retire) Succession Planning is not an option We must make positive changes to provide for better resources to learn, comprehend, and produce at much earlier stages of a person’s career Must capture as much institutional knowledge as possible Must make the application process easier, faster, and better for both the applicant and the reviewer Historical Knowledge Implemented monthly internal technical forum to retain and share institutional knowledge on a wide range of topics Working on Site Information sheets, to ease transition between permit writers, allowing more flexibility in assignments, improving efficiency of reviews Application and Draft Review Evaluated whether information could be deleted from the application using the rule, and a line-by-line risk assessment of the Part B checklist. (Note: we were not able to remove items after determining that low risk information was required to be part of the application by rule) Working on reformatting the application to clarify instructions, improve readability, and provide clear locations for providing each piece of information. Process Enhancements Inventoried and evaluated existing SOPs, prioritizing them for systematic updates. Also updated all template letters for ease of use by both the technical and administrative staff. Working on gathering tips and tricks from staff to incorporate into SOPs as “best practices” Reviewing Streamlining Developed a new format for Class 1 modifications which will not require the use of a cover letter and will standardize templates for other permit modifications Working on evaluating reports and applications using results from risk assessment study, work groups, rules, and policies to determine extent of review and for streamlining opportunities to improve efficiency and consistency

Report Format Standardized Combustion Program submittals CPT Plans and Reports Cover Sheet Checklists Future standardization of other industrial and hazardous waste reports Report Format Standardized Combustion Program submittals CPT Plans and Reports Cover Sheet Checklists Future standardization of other industrial and hazardous waste reports

New for 2018 For all new site applications, renewals, and Class 3s: Coordinate efforts with the applicant to work together prior to submitting the application Plan is to have the application in mint condition prior to officially submitting it

Topics Covered Today Programs within the I&HW Section Brand new CCR Program Updates on the next I&HW Rule Writing efforts Process Improvements & Workload Reduction Workgroups

Today’s Presentations 10:30 Exemptions from Industrial and Hazardous Waste Permitting Requirements (Chris Shaw, P.E.) 1:00 Waste Classification Presentation and Workshop Part 1 (Sheila Meyers) 2:15 Waste Classification Presentation and Workshop Part 2 (Sheila Meyers) 4:00 RCRA Requirements for Land-Based Units (Charles Brown, P.G. and Michael Pimentel, P.E.)

Sign Up for GovDelivery [Pictures of the first and second pages of the Spring 2017 I&HW Quarterly Highlights.] Receive the I&HW Quarterly update, and notification of IHW forms, rule, guidance, and procedure updates: http://www.tceq.texas.gov/ permitting/waste_permits/i hw_permits/signupihw Sign Up for GovDelivery Receive the I&HW Quarterly update, and notification of IHW forms, rule, guidance, and procedure updates: http://www.tceq.texas.gov/permitting/waste_permits/ihw_permits/signupihw [Pictures of the first and second pages of the Spring 2017 I&HW Quarterly Highlights.]

How to Contact Us Bob Patton, Jr., Manager Industrial & Hazardous Waste Permits Section (512) 239-2277 bob.patton@tceq.texas.gov How to Contact Us Bob Patton, Jr., Manager Industrial & Hazardous Waste Permits Section (512) 239-2277 Bob.patton@tceq.texas.gov