Operating Permit Backlog Reduction Program

1. Michael Hopkins Operating Permit Backlog Reduction Program

2. Preliminaries • All DO/Laa’s hooked up to weblink? • Ask questions • Issues scribe needed for meeting • Will record meeting so others can view 2

3. Purpose of Presentation • Get everyone up-to-speed on renewal backlog project • Quick discussion on installation permits • Current Status of Operating Permits • Director’s goals • Backlog Reduction • PBR Development • Plan to deal with backlog 3

4. Preface • Installation permits first • Workload levels lowest since the mid 80’s • Currently at about 170 permits • Excellent work on everyone’s parts to bring these numbers down! • True backlog is <50 permits • Must continue keeping up with installation permits 4

5. Installation Permits Processed • 2010 Data • 530 Installation permits (GP & Non) • Included 1245 EUs • ~2 EU per installation permit • 127 avg. OEPA days (62 median) • 152 avg. Total days (includes company time) (76 median) 5

6. Installation Permits Processed 6

7. Installation Permit Goal Basis • Reduce workload to “no backlog” level • Reduce number of “old” permits • Maintain <200 permits • Meet 14-day completeness review goal • Continue timely processing of CO reviews • Process Assistant Chief identified high priority permits using “Continuous communication” process 7

8. DO/Laa 2011 Install Goals 168 8 *As of March 23, 2011; Old = DO/Laa/CO workflow >180

9. Operating Permit Status and Goals

10. *Late in this case means permits that have expired over 180 days ago. Note that most of these operating permits have been extended (i.e., continue to remain in effect) because the rules require them to remain in effect if the applicant submitted a timely renewal application. Operating Permits Current Status 1These numbers will be reduced as we clean up the list. 2Late in this case means PTIO permits that have expired over 180 days ago and Title V permits that have expired over 18 months ago. Note that most of these operating permits have been extended. Does not include grandfathered Registration permits. Also, does not include any applications that have not been entered into Stars2. 10

11. Director’s Permitting Goals • Add more PBR/GPs • One per month – 40 months (3.5 yr) • Template  GP PBR • Eliminate operating permit backlog • Group appeals to resolve in mass • Renew appealed permits w/o resolving • Use additional staff for renewals • All w/o damaging installation permit timeliness Director Scott J. Nally 11

12. Director’s Permit Goals • On 07/01/14, have zero late PTIO renewals • Expire on or before January 1, 2014 • On 07/01/14, have zero late TV renewals • Expire on or before January 1, 2013 • Develop and issue one PBR per month 12

13. Director’s Permit Goals • Note: Goals are not based on current workloads…. • Must complete current expired permits and permits that will come up for renewal in the coming years. 13

14. What can we do to achieve goals? • DO/Laas must continue to process installation permits, FESOPs, Title V permits and, what they can, non TV operating permits. • Most Laas should be able to keep up with PTIO/TV renewals • DOs need assistance to get caught up 14

15. What can we do to achieve goals? • Felt not enough staff at DO level to get caught up • Must add more person-hours to achieve • Solution: Assign CO staff to help with non TV renewals • Solution: Hire interns at DOs and CO to work on permits 15

16. Advantages • More person-hours • Spread work out • CO staff learns about permitting 16

17. Disadvantages/Issues • Challenging program to learn quickly • May be confusing to permittees • CO staff already has other work • Mistakes can be made if two parties working on same facility • Hard to coordinate • Will still mean more work and different priorities for DO staff 17

18. How will this project be organized? • Mike Hopkins, Andrew Hall, Mike Ahern will lead • CO ES III’s will be lead workers • Selected CO staff will do the work • First group of 9 staff selected • 3 staff assigned to each ES III • Plan to do second group (in June?) and probably more • Incorporate interns 18

19. How will this project be organized? • Determine high frequency EU or facility types • Assign EU/facility type to group • Group develops and/or uses terms for EU/facility type • Template terms • General Permits • PBRs 19

20. How will this project be organized? • Management provides list of EU or facility types needing renewed • DO permits listed first • Oldest first • CO staff contacts DO/Laa to determine if: • OK to work on permit • Get application, last permit, etc. scanned and added into Stars2 20

21. CO staff calls company to let them know they will be working on permit • Is it still operating? • Same unit/facility? • Other changes? • Other sources? • Discusses template/PBR/GP option • Gets OK to do template/PBR/GP • Instructs company on what they need to do. 21

22. CO staff sends info to company • Include application, past permit, qualifying criteria, terms, etc. • Deadline • Send physical application to CO, or • Can apply through Stars2 22

23. DO/Laa staff receives application • DO/Laa staff notifies CO staff electronic application received (if electronic) • DO/Laa staff assigns application to CO staff in Stars2 (if electronic) • Physical applications are entered into system by CO staff • CO staff processes application 23

24. Review process • ESIII reviews • Andrew oversight review • PIDM issues permit • In the future w/ more complex permits, will involve DO staff as needed to review 24

25. Break Time (15 min)

26. New Templates/GPs/PBRs • While group is processing permits, also developing next template/GP for next category of EU/facility • Once next template/GP ready, and done with first category of EU/facilities, then move on to next category of EU/facilities • Other staff develop Templates/GPs/PBRs through P&E 26

27. New Templates/GPs/PBRs • GPs will need to be developed w/input from interested parties • PBRs will also use normal rule process • DO/Laa/CO develop template/GP/PBRs • Cheryl Suttman responsible for processing GPs 27

28. New Templates/GPs/PBRs • At some point, issue GPs from templates • At some point, issue revised PBR rule 28

29. Goal Monitoring • Will set 6 month goals for TVs and PTIOs (7, 6-month periods) • DO/Laas will need to identify which TVs will be worked on 29

30. Goal Monitoring - Reports • Use two Stars2 reports: • For existing late renewals: • <Reports><Custom Reports><Permits Status><DO/Laa><PTIO or TV PTO><Renewal><Submit> • For future due renewals: • <Reports><Custom Reports><Expiration Report><To Date (01/01/13 for Title V, 01/01/14 for non TV)><Select all><Submit> • Demonstrate/discuss 30

31. Goal Monitoring Periodic Calls • Will have a 6 month calls to check status/monitor goals • Each DO/Laa report on previous 6 month work • Each DO/Laa identifies next 6 month TV/FESOP to be worked on • DO/Laas will need to identify TVs and FESOPs for the first 6 month period (really 3 months) by Friday, April 8 31

32. Goal Monitoring Call Dates • Friday, July 1, 2011 • Report on permits issued January 1 to June 30, 2011 • Set goals for July – December 2011 • Wednesday, January 4, 2012 • Report on permits issued July 1 to Dec 31, 2011 • Set goals for Jan – June 2012 • Etcetera 32

33. Title V Goals 33 *Final Title V first issue & renewal issued during 2010

34. Title V Goals • DO/Laa’s primarily responsible for these goals • CO must support through reviews • CO may need to reduce CO review • Reports show DO/Laa of permits needing processed by January 1, 2013 (18 months before director’s goal 34

35. Renewal PTIO Goals 35 *Does not include those that expire from 3/21/11 to 1/1/14. These also need to be processed.

36. PTIO Renewal Goals • Combined responsibility DO/Laas and CO staff • CO will start with simple renewals • CO will learn and then do more complex • DO/Laas will do FESOPs 36

37. Renewal PTIO Goals • Laas will need to do theirs • Laas can do same type of EU/Facilities when CO does them • DOs can do renewals as can fit in. • No specific goals for FESOPs but grouped in with PTIO goals 37

38. Q&A • What happens w/ new sources? • Notify DO/Laa contact. • Discuss who should work on PTIs?; Can we work on it soon? • If can process template/PBR/GP, CO processes • If can’t decide, management decision. • If no template/PBR/GP, then let company know can’t process, need to submit application to DO/Laa, DO/Laa processes application. 38

39. Q&A • How do we track these permits? • Assign to-do list to those in CO when they work on them. • Must keep notes in system to track status • Utilize attachments for correspondence • Do we have a time code? – Not decided 39

40. Q&A • What happens when we run out of “easy” EU/facility categories? • By then hope to have CO staff trained • Will be able to expand their abilities • Can do case-by-case permits • DO/Laa review permit before issue? • Use of template/GP/PBR – no • More complex later – probably yes 40

41. Q&A • What about the interns? • DAPC plans to incorporate interns into this process when they arrive • Should DO/Laa’s consolidate applications? • No, let CO staff decide • Can DO/Laa decide to “keep” permit? • Yes, can keep for cause. 41

42. Initial Clean-up Work Being Done • Current PTIO renewals in Stars2 contains errors • Lots of shutdown sources • Lots of duplicate work flows • PIDM has worked to clean up • Has reduced # PTIO renewals from 5700 to, so far, 2800 42

43. What About Training? • Four initial steps: • (1) Initial kick-off training (this training) • (2) CO Staff kick-off training • Staff introduction • Organized groups • Staff EU/Facility type assignments • Training Videos 43

44. What About Training? • (3) Permit writing training • Initial basic training on how to process application for PBR/GP/Template • Combined CDO/DO lead training • Stars2 steps training • (4) Later more detailed training on how to write case-by-case permit • Mainly DO/Laa lead • Other DOs want to help? 44

45. FutureTraining • CO Staff Kick-off Training – April 15 • Permit writing training - unknown 45

46. Management Support • Will hold planning meetings as needed • Will do initial training meetings • Will do 6-month monitoring calls • ES III periodic meeting w/ CO staff • Periodic management meetings w/ ES IIIs • Possible update communication through future webinars, Stars2 webinar, P&E Committee or other communication channels. 46

47. Document Needs • Need application letter • Other template letters • Instruction sheet for developing Template terms and qualifying criteria • SOPs for processes 47

48. Current Improvement Projects • Aggregate industry GPs • Engines • Aggregate processing • Material extraction • Agricultural digesters GPs • Wood Grinder GP • Marcellus shale drilling permits needs 48

49. Project Work Estimate • Want to make an estimate of amount of work needed. • Ask each DO/Laa to give an estimate of person-hours per: • emissions unit for a case-by-case renewal • emissions unit for a GP • emissions unit for a PBR • Will do calc. total man-hours & est. of what we can accomplish 49

50. Wrap-up • Next Meetings • Training Dates • Questions? 50