1. 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

2. 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

3. 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

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

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

6. Additional I&HW Updates

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

8. 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 – 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 – Updates.]
[In foreground, image of an open toolbox with the following text: “Easier, Better, Faster Permitting”.]

9. Permitting Process
(120 Days)

10. 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

11. 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.

12. 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 ( ) and second wave millennials ( ).
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

13. 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

14. 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

15. 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

16. 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.)

17. Sign Up for GovDelivery
[Pictures of the first and second pages of the Spring I&HW Quarterly Highlights.]
Receive the I&HW Quarterly update, and notification of IHW forms, rule, guidance, and procedure updates:
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:
[Pictures of the first and second pages of the Spring 2017 I&HW Quarterly Highlights.]

18. How to Contact Us
Bob Patton, Jr., Manager Industrial & Hazardous Waste Permits Section (512)
How to Contact Us
Bob Patton, Jr., Manager
Industrial & Hazardous Waste Permits Section
(512)