1. Industrial and Hazardous Waste Easier, Better, Faster Permitting
TCEQ Environmental Trade Fair
Austin Convention Center
May 3, 2016
Adrienne Clark
Anna Lleras
Waste Permits Division
Industrial and Hazardous Wastes
Easier, Better, Faster Permitting
TCEQ Environmental Trade Fair
Austin Convention Center
May 3, 2016
Adrienne Clark
Anna Lleras
Waste Permits Division

2. Easier, Better, Faster Permitting Overview
Permit Application and Process Overview
Part A and Part B Application Submittal Deficiency Study
Presentation Overview
Permit Application and Process Overview
Part A and Part B Application Submittal Deficiency Study

3. Easier, Better, Faster Permitting Overview (continued)
Most Common Deficiencies
Potential Solutions
Questions
Presentation Overview
Most Common Deficiencies
Potential Solutions
Questions

4. Permit Application Part A (TCEQ-0283) Part B (TCEQ-0376)
Part A: Instructions and Procedural Information for Filing a Permit Application for a Hazardous Waste Storage, Processing, or Disposal Facility (TCEQ-0283)
Part B: Permit Application for Industrial and Hazardous Waste Storage/Processing/Disposal Facility with Compliance Plan (TCEQ-0376)

5. Application Review Process
Application Received
Administrative Review
Administratively Complete
Notice of Receipt of Application & Intent to Obtain Permit
Technical Review
281 Days
Industrial and Hazardous Waste (IHW) Application Process. Graphic showing the IHW permit application process starting from application preparation by the applicant to the Executive Director’s Agenda and Issuance of the permit. Approximately 334 days of the 450 day process include the application being received by the TCEQ, administrative review, administratively complete, Notice of Receipt of Application & Intent to Obtain Permit (NORI) published, beginning of public comment period, technical review, Initial Draft Permit (IDP) complete, IDP comment and Final Draft Permit (FDP) preparation, and FDP complete. The remaining 116 days of the 450 day process include the FDP being sent to the Office of the Chief Clerk (OCC), Notice of Application & Preliminary Decision published, ending of public comment period, and the Executive Director’s Agenda and permit issuance.

6. Application Review Process (continued)
Initial Draft Permit
Final Draft Permit
Notice of Application & Preliminary Decision
Executive Director’s Agenda & Issuance
169 Days
Industrial and Hazardous Waste (IHW) Application Process. Graphic showing the IHW permit application process starting from application preparation by the applicant to the Executive Director’s Agenda and Issuance of the permit. Approximately 334 days of the 450 day process include the application being received by the TCEQ, administrative review, administratively complete, Notice of Receipt of Application & Intent to Obtain Permit (NORI) published, beginning of public comment period, technical review, Initial Draft Permit (IDP) complete, IDP comment and Final Draft Permit (FDP) preparation, and FDP complete. The remaining 116 days of the 450 day process include the FDP being sent to the Office of the Chief Clerk (OCC), Notice of Application & Preliminary Decision published, ending of public comment period, and the Executive Director’s Agenda and permit issuance.

7. Deficiency Study Overview
Methodology
Results
Improvement
Deficiency Study Overview
Methodology
Results
Improvement Initiatives

8. Study Methodology FY 2014 Notice of Deficiency (NOD) Letters
Technical & Administrative
1,822 Application Deficiencies
25% of Permitted Facilities
Study Methodology
Fiscal Year 2014 Notice of Deficiency (NOD) Letters
Technical and Administrative letters were included
1,822 application deficiencies were characterized
Represented 25% of our permitted facilities

9. Deficiency Analysis Information Collected per Deficiency
Deficiencies Categorized by Error Type
Six Error Types
Deficiency Analysis
Information collected per deficiency
Deficiencies categorized by error type
Eight error types

10. Deficiency Categorization
All Deficiencies 1,822
Completeness Errors 1,216 (67%)
Omitted 748
Incomplete 442
Format 26
Content Errors 606 (33%)
Incorrect 245
Inconsistent 166
Ambiguous 195
Graphic showing the categorization of deficiency items. Out of 1822 overall deficiencies, 1216 or 67% are errors related to completeness of the application. 606 error or 33% are errors related to the content of the application. Further categorization of the completeness errors shows 748 errors of omission, 442 instances of incomplete items, and 26 items in the wrong format. Further categorization of the content errors shows 245 incorrect items, 166 inconsistencies, and 195 ambiguities.

11. Administrative Review Deficiencies
Table showing the distribution of administrative review deficiencies. The table shows that 67% of the deficiencies are errors related to the completeness of the application. Color coding based on the number of errors in each section shows that the deficiencies are concentrated in Parts A I and B I General Information and are predominately omitted and incorrect information.

12. Technical Review Deficiencies
Table showing the distribution of technical review deficiencies. The table shows that 67% of the deficiencies are errors related to the completeness of the application. Color coding based on the number of errors in each section shows that the completeness deficiencies are concentrated in Part B Sections B III through B VII.

13. Deficiency Categories
Omitted
Incomplete
Format
Incorrect
Inconsistent
Ambiguous
Deficiency Categories
Omitted
Incomplete
Format
Incorrect
Inconsistent
Ambiguous

14. Deficiency Categories: Omitted/Incomplete
Sections
Signature Page
Closure Costs
Modifications
Deficiency Categories
Sections
Signature page [30 TAC Section ]
Closure Costs [30 TAC Section 335.7, 30 TAC Section , 30 TAC Chapter 37]
Modifications

15. Deficiency Category: Format
Outdated Forms
Tables
Attachments
Deficiency Category: Format
Outdated Forms
Tables
Attachments

16. Deficiency Category: Format
Part A, Section IV., Index of Attachments – Lists attachment names and assigned attachment letter.

17. Deficiency Categories: Incorrect/Inconsistent
Wrong or Improper Calculations
Registration/Permit Numbers
Lacks Agreement
Adjacent Landowners
Deficiency Categories: Incorrect/Inconsistent
Wrong or Improper Calculations
Registration/Permit Numbers
Adjacent Landowners [30 TAC Chapter 39]
Lacks Agreement

18. Common Deficiencies: Modifications
Class of Modification
Permit Transfers (Class 1ED Modifications)
Legal Name
Financial Capability Demonstration
Financial Assurance
Common Deficiencies: Modifications
Class of Modification [30 TAC Section ]
Permit Transfers (Class 1ED Modifications)
Legal Name
Financial Capability Demonstration [30 TAC Section (a)(4)(B)]
Financial Assurance [30 TAC Section (a)(4)(A) and 30 TAC Section 335.7]

19. Common Deficiencies: Modifications
Class 2 Modifications
Inadequate Notice
Public Meeting
Common Deficiencies: Modifications
Class 2 Modifications [30 TAC (c)]
Inadequate Notice
Public Meeting

20. Questions
Questions

21. Potential Solutions Use Current Application Pre-application Meeting
Part B Electronic Checklist
Potential Solutions
Use current Application
Pre-application Meeting
Part B Electronic Checklist

22. Potential Solutions (continued)
Application Organization
NOD Letter Standardization
Central Registry Query (Instructional Video)
Potential Solutions
Application Organization
NOD Letter Standardization
Central Registry Query (Instructional Video)

23. Part B Electronic Checklist
Instructions
Cover Page
Table of Contents
Part B Electronic Checklist
Instructions
Cover Page
Table of Contents

24. Part B Electronic Checklist (continued)
Screening
Checklist
Part B Electronic Checklist
Screening
Checklist

25. Screening Unit Operation
Unit list shows which unit types to choose from.
Operation list shows which operation types to choose from.

26. Checklist
Example of information requested in the first four columns of the Pert B Checklist.

27. Checklist (continued)
Shows columns five through nine of the checklist.

28. Checklist (continued)
Graphic showing the applicable part of the checklist separated by a yellow line showing what is not applicable depending on the screening sheet.

29. NOD Letter Standardization
Table-style NOD. Graphic showing an NOD written in a table format.

30. Central Registry Query (Instructional Video)
Placeholder for video

31. Process Time Impact Process Time Impact
Permit Review Stages and Timeframes. Graphic showing the timeline and stages of a permit review.

32. Cooperation & Communication
Proxy Box
GovDelivery
Cooperation & Communication
Proxy box
GovDelivery
Link to sign-up page with instructions:

33. Questions
Questions

34. How to Contact Us Texas Commission on Environmental Quality
Industrial & Hazardous Waste Permits Section
Main Line:
Adrienne Clark –
Anna Lleras –
Section
In conclusion, our contact information is:
TCEQ, Industrial and Hazardous Waste Permits Section
Main Line:
Adrienne Clark:
Phone:
Anna Lleras:
Phone:
Section address:
The End