1. Industrial and Hazardous Waste Easier, Better, Faster Permitting TCEQ Environmental Trade Fair Austin Convention Center May 6, 2015 Adrienne Clark Cynthia Scoggins Waste Permits Division 1

2. Industrial and Hazardous Waste (IHW) Application Process 2

3. Easier, Better, Faster Permitting Overview Part A and Part B Application Submittal Deficiency Study Turn Around Time Impact Cooperation & Communication Questions & Answers 3

4. Deficiency Study Overview Methodology Results Improvement Initiatives 4

5. Study Methodology FY 2014 Notice of Deficiency (NOD) Letters Technical & Administrative 1,822 Application Deficiencies 25% of Permitted Facilities 5

6. Deficiency Analysis Information Collected per Deficiency Deficiencies Categorized by Error Type Six Error Types 6

7. Deficiency Categorization 7

8. Technical Review Deficiencies 8

9. Administrative Review Deficiencies 9

10. Improvement Initiatives Application Improvements New Tool – Electronic Checklist NOD Letter Standardization Administrative Tools 10

11. NOD Letter Standardization Table III.E.3 Emergency Equipment 1. In accordance with 40 CFR 264.32, please submit information to show that the facility has water at adequate volume and pressure to supply emergency equipment at the facility. Section IV.D – Waste Analysis Plan (Section 2.0 of the STR) 2. Section 2.1 of the STR indicates that all wastes managed are compatible with each other and the materials of their containers, and that wastes are re-characterized annually. Table IV.C does not include any annual sampling frequencies. Please explain this apparent discrepancy. If necessary, revise the application materials to ensure consistency. 3. Section 2.1.5 of the STR indicates that containerized transfer wastes will be stored in the appropriate compatible 3. area, strongly implying that not all wastes managed at the facility are compatible with each other. Section 2.1 of the STR indicates that all wastes managed are compatible with each other and the materials of their containers. Please revise the application to resolve this inconsistency, and clarify whether all waste streams proposed for management at the facility are compatible with each other. Table V.B Container Storage Area 4. The column labeled for the required “Containment Volume (including rainfall)” lists 448 gallons. This conflicts with the secondary containment amount of 884 gallons that is provided in the STR Section 1.2.2. Please clarify and revise as appropriate. 11

12. NOD Letter Standardization 12

13. Administrative Tools Development of guidance and instructional tools Involvement of multimedia Sample video 13

14. 14 Turn Around Time Impact

15. Cooperation & Communication Proxy Box IHWFixItApp@tceq.texas.gov GovDelivery http://www.tceq.texas.gov/permitting/wast e_permits/ihw_permits/ihw.html 15

16. Questions & Answers 16

17. How to Contact Us Texas Commission on Environmental Quality Industrial & Hazardous Waste Permits Section Adrienne Clark - 512-239-6623 Adrienne.clark@tceq.texas.gov Cynthia Scoggins- 512-239-3776 Cynthia.scoggins@tceq.texas.gov Section E-Mail: IHWFixItApp@TCEQ.TEXAS.GOV 17