Michael Hopkins

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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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

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

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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6

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 Current Installation Workload* and 2011 Goals

DO/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

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

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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

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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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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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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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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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 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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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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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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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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At some point, issue GPs from templates

At some point, issue revised PBR rule

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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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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

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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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

*Final Title V first issue & renewal issued during 201033

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

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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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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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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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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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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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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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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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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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(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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CO Staff Kick-off Training – April 15

Permit writing training - unknown

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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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Need application letter Other template letters Instruction sheet for developing Template

terms and qualifying criteria SOPs for processes

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Aggregate industry GPs Engines Aggregate processing Material extraction

Agricultural digesters GPs Wood Grinder GP Marcellus shale drilling permits needs

48

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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Next Meetings Training Dates Questions?

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