Easier, Better, Faster Permitting Adrienne Clark, Charles Brown, P.G., and Chris Shaw, P.E. Industrial and Hazardous Waste Permits Section Easier, Better, Faster Permitting May 17, 2017 Adrienne Clark, Charles Brown, P.G., and Chris Shaw, P.E. Industrial and Hazardous Waste Permits Section May 17, 2017

Overview Improved application format Update on common application deficiencies Combustion streamlining Overview Improved application format Update on common application deficiencies Combustion streamlining

Improved Application Format Presentation by Charles Brown, P.G. Charles Brown, P.G.

Background I&HW Section reviews applications for compliance with regulatory requirements Locating information in the application is vital for a complete and accurate review Inability to locate required information can lead to longer review times and deficiencies Background I&HW Section reviews applications for compliance with regulatory requirements Locating information in the application is vital for a complete and accurate review Inability to locate required information can lead to longer review times and deficiencies 2/3 of deficiencies were due to completeness errors

Objectives Provide a standard format for applications Clarify the submittal requirements Streamline the preparation process for applicants Streamline the review process for I&HW project managers Reduce deficiencies Objectives Provide a standard format for applications Clarify the submittal requirements Streamline the preparation process for applicants Streamline the review process for I&HW project managers Reduce deficiencies

Physical Format Three-ring binders Text on 8.5 X 11 white paper Drawings, tables on 11 X 17 white paper, unless otherwise appropriate Divider tabs All pages numbered and dated Physical Format [Picture of an open three-ringed binder.] Three-ring binders Text on 8.5 X 11 white paper Drawings, tables on 11 X 17 white paper, unless otherwise appropriate Divider tabs should be used All pages numbered and dated

Physical Format Table of contents with page numbers for each volume, section, appendix, attachment, figure and table Cover Page Name of facility IHW permit number SWR number EPA ID number Name of Operator or Permittee Location (City and County) Date of preparation and revision date Physical Format Table of contents with page numbers for each volume, section, appendix, attachment, figure and table Cover Page Name of facility IHW permit number SWR number EPA ID number Name of Operator or Permittee Location (City and County) Date of preparation and revision date

Application Format Divided into Sections Follows Part A and Part B applications forms Expected information listed for each section Required forms Attachments Tables Reports Drawings, figures, and calculations Professional seals and signatures Application Format Divided into Sections Follows Part A and Part B applications forms Expected information listed for each section Required forms Attachments Tables Reports Drawings and figures Professional seals and signatures

Outreach Provide draft Application Format to selected stakeholders Review stakeholder input and make necessary revisions Introductory period (Optional) Mandatory period Outreach Provide draft Application Format to selected stakeholders Review stakeholder input and make necessary revisions Introductory period (Optional) Mandatory period *Please see Bob Patton If you are interested in being selected as part of an informal stakeholder group. Speak to him after this presentation or shoot him, rather, I mean shoot him an e-mail about it.

Application format will be added to webpage when finalized Webpage Updates [Picture of TCEQ Industrial and Hazardous Waste Forms and Guidance Webpage] Application format will be added to webpage when finalized Webpage Updates Application format will be added to webpage when finalized [Picture of TCEQ Industrial and Hazardous Waste Forms and Guidance webpage]

Update on Common Application Deficiencies Presented by Adrienne Clark Adrienne Clark

FY2014 vs. FY2016 FY2014: pre-checklist FY2016: post-checklist 1,822 deficiencies 67% Completeness Errors 33% Content Errors FY2016: post-checklist Decrease in completeness errors FY2014 vs. FY2016 FY2014: pre-checklist Evaluated 1,822 deficiencies 67% Completeness Errors 33% Content Errors Primary conclusions: get more complete applications in house FY2016: post-checklist (required as of January 2016) Smaller sample set (around 400 deficiencies) Not very robust (caveat)

27% 29% 76% Administrative NODs # of Deficiencies per NOD letter 29% Completeness Deficiency Rate (Section I) 76% Completeness Deficiency Rate (Sections V-VII) [Chart depicting decreases in the number of deficiencies per NOD letter, completeness in deficiency rates in Section I and Sections V-VII, and proportion of completeness deficiencies to content deficiencies.] Administrative NODs [Chart depicting the following information]: 27% reduction in the number of deficiencies per NOD letter (11.7 ---> 8.5) 29% reduction in completeness deficiency rate in Section I (more administrative section) 76% reduction in completeness deficiency rate in Sections V-VII (look at whether the info was actually submitted – high level)

41% Technical NODs # of Deficiencies per NOD letter [Chart depicting decreases in the number of deficiencies per NOD letter, and proportion of completeness deficiencies to content deficiencies.] 41% # of Deficiencies per NOD letter Technical NODs [Chart depicting the following information]: 41% reduction in number of deficiencies per NOD letter (32 --> 19)

Conclusions FY2014: FY2016: High error rates in completion Improvement in # of deficiencies per NOD letter Application completeness Conclusions FY2014: High error rates in completion FY2016: Early evidence of improvement in # of deficiencies per NOD letter Improved application completeness (Continue to see reduction in completeness and content errors) We aggressively sought out to have an easier, better, faster permitting process; From Charles’ discussion, he mentioned objectives, which help in these areas: 1. Standardizing = easier 2. Clarifying requirements = better 3. Streamlining review process = faster Tools: checklist, NOD table, pre-app meetings, resolving more issues through phone calls/e-mails, and others We’re promoting more and better communications. We’re seeing the positive results. While we focus on the easier, better, faster side of permitting, we are still making sure to focus on ensuring the protection of our state’s public health and natural resources. For questions and feedback, contact us at IHWFixItApp@tceq.texas.gov.

Combustion Streamlining Presentation by Chris Shaw, P.E. *Survey audience for HWCs Chris Shaw, P.E.

I&HW MACT EEE Reviews [Picture of a combustion unit] Comprehensive Performance Test (CPT) Plans Confirmatory Performance Test (CfPT) Plans Notification of Compliance (CPT Report, CfPT Report) Test Waivers I&HW MACT EEE Reviews (performed by the I&HW Permits Section) [Picture of a combustion unit] Our HWC Program is the largest in the country. We have been doing combustion reviews required by 40 CFR §63, Subpart EEE, concurrently with the EPA until we received final delegation of MACT EEE in January 2015. HWC = Hazardous Waste Combustion MACT = Maximum Achievable Control Technology CPT Plans and Notification of Compliance (NOC) (e.g. CPT Report, CfPT Report) require the most agency review time. 56 combustion units in our universe = well over 100 plans and reports in a 5 year rolling period. Limited changes are anticipated in future CPT Plans EXCEPT when design or operational changes are made. Most plans won’t have to repeat DRE or D/F testing, many will use test waivers, and operating parameters have been determined. Why we are doing this: Need easier, better, faster reviews Fewer resources to do the job, and most likely less money spent Saw the benefits for I&HW permits Lack of existing tools (we surveyed other states) Only have had full delegation for last 2 years and knew there were a lack of tools for customers

Proposed Streamlining Approaches Comprehensive Performance Test Plans Cover Sheet, Checklist, and Redline/Strikeout for Subsequent Plans Performance Test Report Suggested Report Format Proposed Streamlining Approaches In November we met with the Coalition for Responsible Waste Incineration and presented the new guidance to that stakeholder group. “Cover Sheet” contents include: General Information, Source Type, Requested Alternative Standards, Data-In Lieu-Of (DILO), and Testing Waivers Alternatives Requiring EPA or TCEQ Approval, Air Pollution Control (APC) Equipment, Continuous Emission Monitors (CEMs) Approved Alternative Monitoring Applications Cover Sheet uses include: (can anyone think of a better name?) Summary of which Regulatory Requirements are applicable, Identifies Alternatives Requiring EPA or TCEQ Actions Screen CPT Plans for Internal Review Assignment, Customize Internal Review Checklists Generate General Information Database on Regulated Sources Acts as a front-end filter The CPT Checklist: Follows Regulatory Requirements for CPT Plan Contents including the Quality Assurance Project Plan (QAPP) Requests whether the Regulatory Requirements are Addressed in the CPT Plan or are Not Applicable Requests the Location in the CPT Plan where the specific Regulatory Requirement is Addressed CPT Checklist Uses: To Ensure that all Required Information is Included in the CPT Plan Identify which Regulations are Applicable and Not Applicable to the Source As a Guide to Quickly Locate Specific Information Within the CPT Plan NOC Format: Standardizes the Report Format for All Sources Reduces the Probability of Significant Report Content Omissions Reduces Time by Reviewers in Locating Information Within Large Reports QA/QC Checklist required for raw test data. Already required to be sent to us electronically. Plan electronic checklist is in development and is coming soon. It will be posted in the same location as the other tools. Moving forward, redline/strikeout will be requested for all repeat test plans. If you would like to get information on future HWC program changes write your email on the back of a business card and hand it to me after the presentation. If you were invited to the November Beaumont meeting we already have your contact information.

Combustion Web Additions [Screenshots of the TCEQ Industrial and Hazardous Waste Main page, pointing to Hazardous Waste Combustion Program section.] Combustion Web Additions [Screenshots of the TCEQ Industrial and Hazardous Waste Main page, pointing to Hazardous Waste Combustion Program section] This location will eventually have a link to a preferred report format and will also eventually have the electronic plan checklist (similar to our RCRA Part B electronic checklist currently in use). The next slide contains a screenshot of our proposed test plan electronic checklist.

Checklist Preview [Foreground: Picture of the screening questions for the Comprehensive Performance Test (CPT) Plan Review Checklist; Background: Picture of the content of the CPT Plan Review Checklist.] Checklist Preview At the November meeting we received comments that it would be nice to have a checklist like the Electronic Part B checklist. We’re in the process of testing a new electronic plan checklist and hope to make it available sometime this summer [Foreground: Picture of the screening questions for the Comprehensive Performance Test (CPT) Plan Review Checklist; Background: Picture of the content of the CPT Plan Review Checklist.]

Online TCEQ Resources For Hazardous Waste Combustion Tools and Resources: http://www.tceq.texas.gov/permitting/waste_permits/ ihw_permits/ihw.html For Hazardous Waste Permitting Information: http://www.tceq.texas.gov/permitting/waste_permits Questions, Comments, or Feedback? Email us at: IHWFixItApp@tceq.texas.gov Online TCEQ Resources To reiterate…. Several links for materials under the heading “Hazardous Waste Combustion Program” at the bottom of the webpage, including: Cover Sheet for submittal with CPT Plans; Checklist for submittal with CPT Plans; QA/QC Checklist required for Notification of Compliance (NOC) Reports; and A link to the rule text, requirements table, and flow chart for 40 CFR Part 63, Subpart EEE. We plan to add additional tool and resources to this webpage in the near future. For now, we recommend that HWC Program members begin using the materials available on this webpage. We welcome comments or suggestions on how to improve these materials. If you have questions, comments, or feedback, please email us at IHWFixItApp@tceq.texas.gov To our knowledge, this is the most comprehensive set of tools for HWC plans and reports in the U.S.

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.] There is possibility for adding subgroups to the listserv (for example, rulemaking or combustion groups).

RCRA Permit Closure Cost Estimates Martin Torres TCEQ, Industrial and Hazardous Waste Permits Section Drew Corson AECOM Promotion of next presentation: “RCRA Permit Closure Cost Estimates”: Martin Torres, TCEQ, Industrial and Hazardous Waste Permits Section Drew Corson, AECOM Presenting at 1:00. At 1:00 Next Presentation

How to Contact Us Industrial & Hazardous Waste Permits Section (512) 239-2335 ihwper@tceq.texas.gov How to Contact Us Industrial Hazardous Waste Permits Section (512) 239-2335 ihwper@tceq.texas.gov