Industrial and Hazardous Waste

Easier, Better, Faster Permitting

TCEQ Environmental Trade FairAustin Convention Center

May 6, 2015

Adrienne ClarkCynthia Scoggins

Waste Permits Division

1

2

Easier, Better, Faster Permitting Overview

• Part A and Part B Application Submittal Deficiency Study

• Turn Around Time Impact

• Cooperation & Communication

• Questions & Answers

3

Deficiency Study Overview

• Methodology

• Results

• Improvement Initiatives

4

Study Methodology

• FY 2014 Notice of Deficiency (NOD) Letters

• Technical & Administrative

• 1,822 Application Deficiencies

• 25% of Permitted Facilities

5

Deficiency Analysis

• Information Collected per Deficiency

• Deficiencies Categorized by Error Type

• Six Error Types

6

Deficiency Categorization

7

Technical Review Deficiencies

8

Administrative Review Deficiencies

9

Improvement Initiatives

• Application Improvements

• New Tool – Electronic Checklist

• NOD Letter Standardization

• Administrative Tools

10

NOD Letter StandardizationTable 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

NOD Letter Standardization

12

Administrative Tools

• Development of guidance and instructional tools

• Involvement of multimedia

• Sample video

13

14

Turn Around Time Impact

Cooperation & Communication

• Proxy Box• IHWFixItApp@tceq.texas.gov

• GovDelivery• http://www.tceq.texas.gov/permitting/

waste_permits/ihw_permits/ihw.html

15

Questions & Answers

16

How to Contact Us

• Texas Commission on Environmental Quality

Industrial & Hazardous Waste Permits Section

• Adrienne Clark - 512-239-6623Adrienne.clark@tceq.texas.gov

• Cynthia Scoggins- 512-239-3776Cynthia.scoggins@tceq.texas.gov

• Section E-Mail: IHWFixItApp@TCEQ.TEXAS.GOV

17