operating permit backlog reduction program

Operating Permit Backlog Reduction Program

Michael Hopkins

Preliminaries

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

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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

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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 permits4

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)

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Installation Permits Processed

30 60 90 120 150 180 210 240 270 300 330 360 More0

20

40

60

80

100

120

140

160

180

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

90.00%

100.00%

Issued Permits vs. Ohio EPA Processing Time

2010 Data - 530 Permits*

FrequencyCumulative %

Ohio EPA Permit Processing Time (bins)Nu

mb

er

of

Insta

lla

tio

n/C

ha

pte

r 3

1

Pe

rmit

s I

ssu

ed

*Includes General Permits (87) but not Permit by Rules

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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

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DO/Laa 2011 Install GoalsDO/Laa Current Installation Workload* and

2011 GoalsDO/Laa Current

Workload“Old” Permits* 2011 Goal

01 – CDO 12 0 30

02 - NEDO 20 3 30

03 - NWDO 44 11 30

04 - Toledo 6 0 5

05 - SWDO 5 1 5

06 - SEDO 33 21 30

07 - Portsmouth

11 9 10

08 - RAPCA 5 0 10

13 - Cleveland 12 2 15

14 - HAMCO 8 0 15

15 - Canton 7 4 10

16 - Akron 5 0 10

Total 51 200*As of March 23, 2011; Old = DO/Laa/CO workflow >180

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168

Operating Permit Status and Goals

Operating Permits Current Status

Type of Permit

Total Universe

Number up for Renewal

% of Universe up for Renewal

Number late2

% of Renewals Late2

Title V 585 325 55.6% 262 80.6%

PTIO 57221 32171 56.2% 30981 96.3%

*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.

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.

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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

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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

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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.

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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

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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

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Advantages

More person-hours Spread work out CO staff learns about permitting

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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 staff17

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

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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

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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

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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.

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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

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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

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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

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Break Time (15 min)

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

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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

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New Templates/GPs/PBRs

At some point, issue GPs from templates

At some point, issue revised PBR rule

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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

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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/discuss30

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

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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

Etcetera32

Title V GoalsDO/Laa Title V Facilities, 2010 Issuance* and

2011 GoalsDO/Laa 2010 Finals Issued Original 2011 Goal Director’s Goals

01 – CDO 1 11

02 - NEDO 12 21

03 - NWDO 11 25

04 - Toledo 3 5

05 - SWDO 0 3

06 - SEDO 0 16

07 - Ports 2 3

08 - RAPCA 5 6

13 - Cleve 0 10

14 - HAMCO 8 12

15 - Canton 0 4

16 - Akron 4 5

Total 46 121*Final Title V first issue & renewal issued during 2010

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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

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Renewal PTIO GoalsDO/Laa 2010 PTIOs, 2011 Goals and 2014

Director’s GoalsDO/Laa 2010

PTIOs2011 Goal

2014 Dir’s Goals*

DO/Laa Status

01 – CDO 37 92 466/7 =67

02 - NEDO 33 92 644/7 = 92

03 - NWDO 172 77 360/7 = 51

04 - Toledo 5 24 12/7 = 2

05 - SWDO 10 14 2

06 - SEDO 9 52 586/7 = 293

07 - Ports 1 7 51/7 = 7

08 - RAPCA 57 45 58/7 = 8

13 - Cleve 50 67 516/7 = 74

14 - HAMCO 83 79 56/7 = 8

15 - Canton 6 27 155/7 = 22

16 - Akron 54 45 7/7 = 1

Total 517 619 2904/7 = 415*Does not include those that expire from 3/21/11 to 1/1/14. These also need to be processed.

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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

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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

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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.

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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

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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

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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.

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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

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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

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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?

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Future Training

CO Staff Kick-off Training – April 15

Permit writing training - unknown

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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.

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Document Needs

Need application letter Other template letters Instruction sheet for developing Template

terms and qualifying criteria SOPs for processes

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Current Improvement Projects

Aggregate industry GPs Engines Aggregate processing Material extraction

Agricultural digesters GPs Wood Grinder GP Marcellus shale drilling permits needs

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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

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Wrap-up

Next Meetings Training Dates Questions?

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