CONFERENCE JUNE 11, 2020 2 What is ELMS? A system that uses Lean - - PowerPoint PPT Presentation

CONFERENCE JUNE 11, 2020

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EPA Lean Management System (ELMS)

U.S. ENVIRONMENTAL PROTECTION AGENCY | OFFICE OF CONTINUOUS IMPROVEMENT

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What is ELMS?

A system that uses Lean principles and tools, paired with routine monitoring, measurement and engagement to identify problems, solve problems and sustain improvements.

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SIPs and Air Quality Plans

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SIP Backlog Progress

50 100 150 200

• Oct. 1,

2013

• Oct. 1,

2014

• Oct. 1,

2015

• Oct. 1,

2016

• Oct. 1,

2017

• Oct. 1,

2018

• Oct. 1,

2019 May 20, 2020

135 104 90 46 29 30 23 21 30 31 29 34 39 22 22 28

Number of SIPs

R6 Air Program FY2020 Total SIPs In-House Backlogged and Not Backlogged

Backlogged SIPs SIPs Not Backlogged

165 135 119 80 68 52 45 49

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Distribution of Region 6 SIPs

5 10 15 20 25

Alb. AR LA NMED OK TX

1 1 2 1 9 7 10 1 1 2 14

SIPs

Region 6 SIPs to be Processed (May 20, 2020)

Backlogged SIPs SIPs Not Backlogged

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EPA Action on Arkansas SIPs

Regional Haze and Visibility Protection Final Rule (Phase III)

• Proposal published March 16, 2020.
• With final rule, the SIP backlog will go back to 0.
• Final rule will respond to comments received.
• Completes action on first planning period with

goal of return to natural visibility conditions by 2064

Proposal on Arkansas Infrastructure SIP for the 2015 Ozone Standard National Decisions are needed before action on the Interstate Transport SIP for the 2015 Ozone Air Quality Standard can proceed.

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SIPs and Air Quality Plans Expected from AR

Regional Haze SIP for the 2nd Planning Period

• Required from all States for reducing regional

haze in National Parks, Wildlife Refuges, and Wilderness Areas

• Due July 31, 2021

Air Quality Plans for Existing Sources (Clean Air Act 111(d) Plans)

• Municipal Solid Waste Landfills
• Affordable Clean Energy (ACE) Plans for Existing

Electric Utility Generating Units

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Air Permitting

NEW SOURCE REVIEW (NSR) AND TITLE V PROGRAM UPDATES

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New Source Review (NSR) Program Updates

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NSR Program Updates

Plantwide Applicability Limit (PAL) Guidance, Final Guidance Summer 2020

• Guidance addresses elements of the PAL

regulations that stakeholders have identified as sources of perceived risk/disincentive

Begin Actual Construction Guidance, Final Guidance Fall 2020

• Sources cannot legally “begin actual

construction” of a major source or major modification without first obtaining a major NSR permit

• Guidance would explore potential flexibilities

under the existing regulatory language to allow certain non-emitting activities to be undertaken prior to obtaining a permit.

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NSR Program Updates

Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act (Major MACT to Area, MM2A), Final Rule Fall 2020

• Withdraws 1995 memo “Once In Always In”

(OIAI) policy and reclassification issues covered

• Addresses when a major source subject to a

Maximum Achievable Control Technology (MACT) standard may be reclassified as an area source and no longer subject to MACT requirement

Project Emissions Accounting Under the New Source Review Preconstruction Permitting Program, Final Rule Fall 2020

• Proposed revisions to clarify that both

emissions increases and decreases resulting from a project are to be accounted for under Step 1 of the NSR applicability process.

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Title V Program Updates

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Title V Program Update

Revisions to the Petition Provisions of the Title V Permitting Program, Final Rule 2/5/20 Three main changes:

• 1. How to submit a petition (where to send it)
• 2. Mandatory content for petitions (tell us what

the problem is, on which permit)

• 3. Requires permitting authorities to respond in

writing to significant comments, and provide the response with the proposed permit to EPA for 45-day review,

• Permitting authorities determine what is significant, but

EPA gave guidance in final rule on what we potentially consider significant

• We have spelled out how this works with “concurrent”

review in a State like Arkansas

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Permitting Oversight Highlights

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NSR and Title V Permitting Oversight and Title V Petition Highlights

Common NSR and Title V Permitting Challenges:

• Emission and operational permitting limitations for synthetic

minor air permits.

• Ensuring practicably enforceable emission limitations for all
• perational scenarios.
• Applicability of regulatory standard in permitting

administrative record. Anticipated Title V Petition Trends:

• Increased focus on wood pellet manufacturing
• Incorporation by reference in permitting terms and

conditions

• Monitoring for synthetic minor limits
• Monitoring to determine that a limit does NOT apply

Title V Petition – NSR Interface

• Pacific Corp Hunter Order (10/16/17) and Big River Steel

Order (10/31/17)

• Exxonmobil Baytown Petition Appeal, U.S. Court of

Appeals, Fifth Circuit Decision (5/29/20)

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PSD Long- Range Transport Assessments and Alternative Model Usage

Revisions to the Guideline on Air Quality Models (40 CFR Part 51, Appendix W), Final Rule effective 5/22/17

• Included the removal of CALPUFF as a

preferred model in appendix A for long- range transport (LRT) assessments.

• CALPUFF now considered an alternative

model if chosen for a LRT assessment of NAAQS and/or PSD increment impacts.

• Alternative models require approval by the

EPA Regional Office. Regional Office approval includes consultation with the EPA’s Model Clearinghouse.

• 2017 Appendix revisions also included

the codification of a screening approach to address long-range transport.

• Use of CALPUFF in screening approach

does not require alternative model approval.

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Permitting Process Improvements

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Permitting Process Improvements

Increased use of electronic systems

• Central Data Exchange (CDX) for receipt of title V

petitions

• Electronic Permitting System (EPS)
• Currently Available:

Electronic submittal of state-issued NSR, title V, and other permits for EPA review

• Coming Soon: Electronic processing of EPA

issued NSR and title V permits

• Replacing and modernizing RACT/BACT/LAER

Clearinghouse – Coming Soon

NSR Training Opportunities

• Currently updating NSR training courses and APTI

platform

• Training modules based on NACAA input are

currently under development and will be posted on EPA permitting website.

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Trends

20

Years

60 70 80 90 100

ppb

8-hour Ozone Trends

Memphis Area; 3-year running design values

Frayser (Shelby Co., TN) Orgill (Shelby Co., TN) Crittenden Co., AR DeSoto Co., MS NAAQS Memphis NCore (Shelby Co., TN)

Questions?