TRANSFORMATION Air Permit Review & Process Frank Steitz Air Quality Permitting Program

2 ITEMS DISCUSSED Permit Format Permit Format Streamlining of Compliance Plans Streamlining of Compliance Plans Level of Monitoring Level of Monitoring Level of monitoring as it relates to enforcement History Level of monitoring as it relates to enforcement History Permit application supplemental information Permit application supplemental information Redefining insignificant sources in NJ Title V program Redefining insignificant sources in NJ Title V program

3 ITEMS DISCUSSED Hold on-site pre/post application meetings Hold on-site pre/post application meetings Offer Plant-wide Applicability Limits (PAL) Offer Plant-wide Applicability Limits (PAL) Develop General Operating Permits Develop General Operating Permits Shortening Permit Processing Time Shortening Permit Processing Time Classify More significant Modifications as Minor Modifications Classify More significant Modifications as Minor Modifications Like-kind Replacement of Equipment Like-kind Replacement of Equipment Minimize the number of appeals Minimize the number of appeals

4 IMPLEMENTATION General Permits (GPs & GOPs) General Permits (GPs & GOPs) –Combined Heat & Power (Engines & Turbines) – Available 9/19/11 –Emergency Generators GOP – in progress Pre-application Checklists – in progress Pre-application Checklists – in progress –Administrative & Technical Completeness Pre-application Meetings – on-going Pre-application Meetings – on-going –On-site if necessary

5 IMPLEMENTATION Streamlining of Compliance Plans – in progress Streamlining of Compliance Plans – in progress –Templates for Federal Rules Policy Guidance – on-going Policy Guidance – on-going –NOx RACT Clarification –Construction, Repair & Maintenance Permit Review Procedures – on-going Permit Review Procedures – on-going –PSD Review –Hearing Requests –Sensitive Projects –Common Control

6 PERMIT PROCESS - LEAN Produced results in manufacturing industry Produced results in manufacturing industry Identified OP Sig. Mod. Process Identified OP Sig. Mod. Process Review Process Fairly Efficient Overall Review Process Fairly Efficient Overall Info Requests Throughout Rev. Process Info Requests Throughout Rev. Process –Due To Application Incompleteness –Missing/Incomplete Info Identified Late in Review Process Moving Completeness Review To Front of Review Process Will Improve Efficiency Moving Completeness Review To Front of Review Process Will Improve Efficiency

7 PILOT PROJECT Six-month Project (OP Sig. Mods initially) Six-month Project (OP Sig. Mods initially) Pre-application Meetings Pre-application Meetings –On-site if necessary Completeness Checklists Completeness Checklists –Rule Applicability/Compliance Demonstrations –Process Description/Air Flow Diagram –Emission Calculations/Supporting Documentation –Need for Modeling/Risk Assessment –Level of Public Interest & Outreach Full Applicant Cooperation Full Applicant Cooperation

8 Other Projects In Development Additional Web Based Submittals Additional Web Based Submittals –Non-Technical Amendments (PCP) –RADIUS Imaging of Pre-1998 Preconstruction Permits Imaging of Pre-1998 Preconstruction Permits