1. Industrial & Hazardous Waste Permits Section Overview
TCEQ Environmental Trade Fair Austin Convention Center May 6, Bob Patton, Jr., Manager Waste Permits Division
TCEQ Environmental Trade Fair Austin Convention Center May 6, Bob Patton, Manager
-Very please to be here and looking forward to what we have to present because I feel it is material that all of us, especially those preparing applications and modifications will greatly benefit from going forward. Our theme today and what our presentations are directed towards is a BETTER, FASTER, EASIER PERMITTING PROGRAM. (look for nodding in the audience)
We are working on a continuous improvement strategy with our program and want to include you in this endeavor.
- Ask for show of hands: WHO ALL IN THE ROOM WORKS AT A FACILITY REQUIRING A PERMIT, WORKS ON GENERATING, REVIEWING, EDITING, APPLICATIONS FOR PERMITS, MODIFICATIONS, AND/OR NOTIFICATIONS TO THE IHW SECTION? (I HAVE A LOT OF PEOPLE TO GET TO KNOW)
-I’m new and we are doing new improvements where we need input. I’m looking forward to developing relationships with you and many have started already. I have been to some of your facilities and I am amazed at what you do. Then, I see the permit renewal and some of the more complicated modifications and have keenly been made aware of how technical and detail the RCRA program can be. I feel for ya. I’ve seen the mail deliveries of the enormous reports you must prepare to meet the requirements. I hope we can work together to help make this an easier, better, and faster process that we all will benefit from.
-We need you. We need your suggestions, advice, and help building a better product.
-Frankly, we don’t have a choice. We have more work products coming our way including the emerging issues that I will speak about later in this presentation and you will hear about from our experts during their presentations during the day. I want you to know that what we are presenting today has great potential to save all of us time, effort, and most of all multiple iterations of the documents submitted.
-I know this will be a very good take away for you today. The first improvement you will be presented with is how we are revising our NOD letters. They will be easier to review, better overall, and faster to comprehend.
-The other presentation will provide you with one specific tool that can reduce the number of overall deficiencies by 67%. Remember that number…67%. I am certain that all of us can benefit by reducing duplicate efforts by 67%.
Thank you again for attending today and I hope to see you for the remainder of the day to hear how we can help make the permitting process BETTER, FASTER, AND EASIER.
Now, I will start my presentation.

2. Brent Wade Deputy Director
Permitting & Registration Support Division
Jaya Zyman, P.E., Director
Registration & Reporting Section
Don Kennedy, Manager
Occupational Licensing Section
Russ Gardner, Manager
Remediation Division
Beth Seaton, Director
Superfund Section
Monica Harris, Manager
Voluntary Cleanup Program/Corrective Action Section
Anna Brulloths, Manager
Petroleum Storages Tank/Dry Cleaner Remediation Sections
Ken Davis, P.G., Manager
Division Support Section
Suzanne Vargas, 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
Brandy Brooks, Manager
Radioactive Materials Division
Charles Maguire, Director
Radioactive Material Licensing Section
Bobby Janecka, Manager
Underground Injection Control Permits Section
Lorrie Council, P.G., Manager
Uranium Section
Monica Sullivan, Acting Manager
Office of Waste Organization Chart

3. Waste Permits Division
Earl Lott
Director
Industrial & Hazardous Waste Permits Section
Bob Patton, Jr., Manager
Municipal solid waste permits section
Chance Goodin, Manager
Business & Program Services section
Brandy Brooks, Manager
Office of Waste, Waste Permits Division Organization Chart

4. Industrial & Hazardous Waste Permits Section
Bob Patton, Jr.
Section Manager
Industrial & Hazardous Waste Permits Section Team 1
Will Wyman, Team Leader
Technical ASSISTANCE Group
Scott Green, Work Leader
Industrial & Hazardous Waste Permits Section Team 2
Vacant, Team Leader
Office of Waste, Waste Permits Division, Industrial and Hazardous Waste Organization Chart
-We are currently interviewing for the new team leader position for team 2
Our section is primarily made up of highly technical staff with decades of experiences. Most are experts in their fields and are PEs, PGs, chemists, engineers in training, and environmental scientist

5. Industrial & Hazardous Waste Permits Section
52 Commercial
128 Non-Commercial
Post-Closure Orders: 6
Notifications, permit reports, etc.
Industrial & Hazardous Waste Permits Section
Permits: 180
52 Commercial
128 Non-Commercial
Post-Closure Orders: 6
Notifications, permit reports, etc.

6. Industrial & Hazardous Waste Permitted Facilities & TCEQ Regions
Map of Texas containing Texas county outlines, TCEQ regions outlined and numbered, and locations of IHW Permitted Facilities

7. Permitted Units by Type
Graphic pie chart of types of units that are permitted.
Boiler/Industrial Furnaces 4.3%
Container Storage Areas 23.1%
Containment Buildings 0.9%
Incinerators 1.3%
Landfills 2.2%
Land Treatment Units 0.2%
Miscellaneous Units 6.0%
Surface Impoundments 2.8%
Tanks 59.2%
Waste Piles 0.1%

8. Permitted Hazardous Waste Combustion Units
23 sites have 56 combustion units
13 Incinerators
34 Liquid-Fired Boilers
8 Halogen Acid Furnaces
1 Sulfuric Acid Furnace
MACT – EEE delegated to the State of Texas and the TCEQ in January 2015.
We are working with facilities who had on-going work with the EPA before the delegation and letting them know we are taking over
Have received very good comments from industry about this becoming a state delegated program
Our Combustion Program Plans
Our Section SME (Billy Spiller) is doing weekly training with all our staff with engineering backgrounds (9 total PMs working in the Combustion program)
With two chemist for a total of 11 staff out of our 21 that work projects are now also working in the Combustion Program to ramp up our skills, knowledge, abilities
Billy is doing an amazing job and is very well known across many circles that he is the expert in Combustion Program Rules

9. FY 2014 Document Reviews 112 Major & Minor applications:
2 New
20 Renewal
5 Class 3
28 Class 2
25 Class 1 ED
32 Class 1
112 Major & Minor applications:
2 New
20 Renewal
5 Class 3
28 Class 2
25 Class 1 ED
32 Class 1

10. FY 2014 Reports Reports 376 total reports Combustion Completions: 10
(including plans and results)
Reports
376 reports total
Including all Group 3s and 4s (monitoring, waste minimization, etc.)
CCR report highlights:
1 CPT plan
3 CfPT plans
5 CPT results
1 CfPT result

11. Technical Analysis Group
410 audits
281 special waste authorizations
1 variance - GCMC
88 recycling activity notifications
16 DSW exclusions
30 QA/QC data sets reviewed
Technical Analysis Group
410 audits
281 special waste authorizations
1 variance - GCMC
88 recycling activity notifications
16 DSW exclusions
30 QA/QC data sets reviewed

12. Developing Improvements
Deficiency study
Standardized notice of deficiency (NOD) letter
Guidance and instructional tools in progress (e.g. videos)
Developing Improvements
Deficiency study (all 2014 NOD letters reviewed, classified the deficiencies, of the 1,882 deficiencies 67% were due to completion errors)
Standardized notice of deficiency (NOD) letter (presentation to follow, much better process and documentation)
Guidance and instructional tools in progress (e.g. video)

13. Developing Improvements Cont.
Application form improvements
Electronic checklist
Communication tools
Developing Improvements Cont.
Application form improvements (Part B)
Electronic checklist (This is the homerun. Potentially saving numerous iterations and efforts all around. Thousands of areas of the permit immediately identified as areas not to review.
Communication tools (new GovDelivery used for dissemination of new information and updates from IHW)
New IHWFixItApp proxy box – we want to hear from you, how can we make this Easier, Better, Faster

14. EPA Coal Combustion Residual Waste Rule
Federal Rule published in Federal Register April 17, 2015
States not required to adopt but facilities are required to comply with federal standards
Congressional legislation introduced advancing HR 1734 (Improving CCR Regulation Act of 2015)
Emerging issues: 1) CCR Rule
Not well received by the states through ASTSWMO and ECOS
Congressional hearings and testimonies
Rule is not clear in many instances
No Enforcement by the EPA, Citizen law suits to act as enforcement
Congressional legislation introduced to improve the rule – the name alone tells you how they feel
A more detailed presentation by Will Wyman later this morning

15. EPA Definition of Solid Waste
Revised federal rule will become effective July 13, 2015
Adds new definitions and exclusions
Improves existing definitions and criteria
Minimal impact to existing exclusions
State will begin adoption process summer 2015
Jesse Boultinghouse is presenting on this updated rule later today.
Does generate more work for IHW
We will begin our adoption process this summer.
Curious to hear back from you about how the new DSW impacts you

16. Solvent Contaminated Wipes
Rule effective January 9, 2015 :
Reusable wipes excluded from definition of solid waste
Disposable wipes excluded from definition of hazard waste
(§30 TAC §§335.1(140)(A)(iv) & § and § )
Solvent Contaminated Wipes
January 9, 2015 solvent contaminated wipe rule went into effect at §30 TAC §§335.1(140)(A)(iv) & § and §
Exclusion from definition of solid waste for reusable wipes
Exclusion from definition of hazard waste for disposable wipes
We have received good feed back for this new rule
Cynthia Palomares to present on this new rule later today.

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Building relationships through communication, transparency, and good will.
We plan to provide you with
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18. How to Contact Us Texas Commission on Environmental Quality
Industrial & Hazardous Waste Permits Section
P. O. Box MC-130
Austin, TX
Phone:
Fax:
In conclusion, we provide the following contact information: mail should be sent to TCEQ, Industrial and Hazardous Waste Permits Section, mail code 130, P.O. Box 13087, Austin, Texas Thank you.

19. Questions
Bob Patton, Jr. Industrial & Hazardous Waste Waste Permits Division (512)
Bob Patton, Jr.
Industrial & Hazardous Waste
Waste Permits Division
(512)
Please feel free to contact me at anytime. I will be happy to meet with you to discuss any suggestions you may have for improvements or just to talk about your facilities.
We are looking for continuous improvement. There is no end to continuous improvements. We will always be searching for ways to improve. Therefore this is a dynamic time for us and we are looking forward to working with you to help make our program requirements Easier, Better, and Faster.