1. 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

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

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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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 about it.

10. 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]

11. Update on Common Application Deficiencies
Presented by Adrienne Clark
Adrienne Clark

12. 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)

13. 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 ( > 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)

14. 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)

15. 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/ s, 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

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

17. 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

18. 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 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.

19. 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.

20. 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.]

21. Online TCEQ Resources
For Hazardous Waste Combustion Tools and Resources:
ihw_permits/ihw.html
For Hazardous Waste Permitting Information:
Questions, Comments, or Feedback? us at:
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 us at
To our knowledge, this is the most comprehensive set of tools for HWC plans and reports in the U.S.

22. 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:
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.]
There is possibility for adding subgroups to the listserv (for example, rulemaking or combustion groups).

23. 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

24. How to Contact Us
Industrial & Hazardous Waste Permits Section (512)
How to Contact Us
Industrial Hazardous Waste Permits Section
(512)