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

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Presentation on theme: "Michael Hopkins.  All DO/Laa’s hooked up to weblink?  Ask questions  Issues scribe needed for meeting  Will record meeting so others can view 2."— Presentation transcript:

1 Michael Hopkins

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

3  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  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  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 6

7  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 Current Installation Workload* and 2011 Goals DO/LaaCurrent Workload“Old” Permits*2011 Goal 01 – CDO12030 02 - NEDO20330 03 - NWDO441130 04 - Toledo605 05 - SWDO515 06 - SEDO332130 07 - Portsmouth11910 08 - RAPCA5010 13 - Cleveland12215 14 - HAMCO8015 15 - Canton7410 16 - Akron5010 Total51200 *As of March 23, 2011; Old = DO/Laa/CO workflow >180 8 168

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10 Type of Permit Total Universe Number up for Renewal % of Universe up for Renewal Number late 2 % of Renewals Late 2 Title V58532555.6%26280.6% PTIO5722 1 3217 1 56.2%3098 1 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. 1 These numbers will be reduced as we clean up the list. 2 Late 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  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  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  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  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  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  More person-hours  Spread work out  CO staff learns about permitting 16

17  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  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  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  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  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  Include application, past permit, qualifying criteria, terms, etc.  Deadline  Send physical application to CO, or  Can apply through Stars2 22

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

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26  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  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  At some point, issue GPs from templates  At some point, issue revised PBR rule 28

29  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  Use two Stars2 reports:  For existing late renewals: ▪  For future due renewals:   Demonstrate/discuss 30

31  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  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 DO/Laa Title V Facilities, 2010 Issuance* and 2011 Goals DO/Laa 2010 Finals IssuedOriginal 2011 GoalDirector’s Goals 01 – CDO111 02 - NEDO1221 03 - NWDO1125 04 - Toledo35 05 - SWDO03 06 - SEDO016 07 - Ports23 08 - RAPCA56 13 - Cleve010 14 - HAMCO812 15 - Canton04 16 - Akron45 Total46121 *Final Title V first issue & renewal issued during 2010 33

34  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 DO/Laa 2010 PTIOs, 2011 Goals and 2014 Director’s Goals DO/Laa2010 PTIOs2011 Goal2014 Dir’s Goals*DO/Laa Status 01 – CDO3792466/7 =67 02 - NEDO3392644/7 = 92 03 - NWDO17277360/7 = 51 04 - Toledo52412/7 = 2 05 - SWDO10142 06 - SEDO952586/7 = 293 07 - Ports1751/7 = 7 08 - RAPCA574558/7 = 8 13 - Cleve5067516/7 = 74 14 - HAMCO837956/7 = 8 15 - Canton627155/7 = 22 16 - Akron54457/7 = 1 Total5176192904/7 = 415 *Does not include those that expire from 3/21/11 to 1/1/14. These also need to be processed. 35

36  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  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  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  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  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  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  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  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  (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  CO Staff Kick-off Training – April 15  Permit writing training - unknown 45

46  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  Need application letter  Other template letters  Instruction sheet for developing Template terms and qualifying criteria  SOPs for processes 47

48  Aggregate industry GPs  Engines  Aggregate processing  Material extraction  Agricultural digesters GPs  Wood Grinder GP  Marcellus shale drilling permits needs 48

49  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  Next Meetings  Training Dates  Questions? 50


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