Lori Hanson Title V Operating Permit Supervisor (515)

Presentation Outline 2011 Kaizen & 2012 Value Stream Mapping Improvements – Improved efficiency – Maximize resources by reducing program scope Construction Permit /Title V Coordination Future Challenges Current Statistics

2011 Kaizen Process Improvement and 2012 Value Stream Mapping Events

Improved Efficiencies Title V backlog given higher profile in AQB Support from other AQB sections/TV Info Request – Construction Permit Section Draft permits sent to Title V staff during 3-day facility review period Alerts Title V staff to changes that may be needed Title V can identify inconsistencies – Compliance Section Assists in locating/interpreting stack test information – Emissions Inventory Section Conducting annual actual emissions review

Improved Efficiencies Revised Part 2 application form and instructions – Easier to fill out and faster for TV staff to draft permit – Tested by several consulting companies – Responding to comments and reviewing applications – Back to original workgroup – Respond to comments – Administrative – form numbers – Roll out and training January 2014

Reducing the Scope of the Title V Program Elimination Voluntary Operating Permit (VOP) program – 8/20/12 Executive Order 80 (EO80) requires greater public participation and stakeholder input in rulemaking process – Proposed elimination of VOP proposed for EO80 workgroup – unanimous support – Construction Permit staff working with remaining VOP permit holders to transition to other permits by spring 2014 – Rescind rules when all permits transitioned

Reducing the Scope of the Title V Program Initiative to remove low emitting sources from the program – Identify criteria for selection Actual emissions < 25 % Title V thresholds (6 may be eligible) Actual emissions < 50 % Title V thresholds (additional 13 may be eligible) Additional considerations – Select and conduct test cases by July facilities (2 from each category) Facility interest – Develop protocol and implement by December 2014

Construction Permit/Title V Coordination

CP/TV Coordination Spreadsheet of delayed Title V permits requiring action from other AQB sections Increased awareness of Title V needs Improved communication between sections Discussed in weekly staff meetings Highlights priorities/timeframes

Future Challenges

Challenges to Quick Issuance New staff NESHAPS and NSPS – Providing clear compliance requirements – Service to industry and Compliance staff – Significant effort for Title V staff Reciprocating Internal Combustion Engines (RICE) rule Boiler Maximum Achievable Control (MACT) regulations EPA review?

Current Statistics

Title V Operating Permits at a Glance Total (Initial & Renewal) Initial Permits Permits issued in 2013 (to date)466 Current backlog11227 Average turnaround time from start of technical review 225 days-- Applications received 2013 (to date)466 Additional 2013 applications expected10--

Number of Permits Issued (and Projected 2013)

Questions?