Lori HansonTitle V Operating Permit Supervisor

(515)725-9525lori.hanson@dnr.iowa.gov

www.iowacleanair.com

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 2014• 4 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) 46 6

Current backlog 112 27

Average turnaround time from start of technical review 225 days --

Applications received 2013 (to date) 46 6

Additional 2013 applications expected 10 --

Number of Permits Issued (and Projected 2013)

Questions?