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

CONFERENCE JUNE 11, 2020

2

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. EPA Lean Management System (ELMS) U.S. ENVIRONMENTAL PROTECTION AGENCY | OFFICE OF CONTINUOUS 3 3 IMPROVEMENT

SIPs and Air Quality Plans 4

SIP Backlog Progress R6 Air Program FY2020 Total SIPs In-House Backlogged and Not Backlogged 165 Backlogged SIPs SIPs Not Backlogged 200 135 30 119 150 Number of SIPs 31 29 80 100 68 52 135 49 34 45 104 39 90 50 22 28 22 46 30 29 23 21 0 Oct. 1, Oct. 1, Oct. 1, Oct. 1, Oct. 1, Oct. 1, Oct. 1, May 20, 2013 2014 2015 2016 2017 2018 2019 2020 5

Distribution of Region 6 SIPs Region 6 SIPs to be Processed (May 20, 2020) 25 20 14 15 SIPs 2 10 10 9 5 7 0 1 1 2 1 1 1 0 Alb. AR LA NMED OK TX Backlogged SIPs SIPs Not Backlogged 6

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 EPA Action on goal of return to natural visibility conditions by Arkansas SIPs 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. 7

Regional Haze SIP for the 2 nd Planning Period ◦ Required from all States for reducing regional haze in National Parks, Wildlife Refuges, and SIPs and Air Wilderness Areas Quality Plans ◦ Due July 31, 2021 Expected Air Quality Plans for Existing Sources (Clean Air Act 111(d) Plans) from AR ◦ Municipal Solid Waste Landfills ◦ Affordable Clean Energy (ACE) Plans for Existing Electric Utility Generating Units 8

Air Permitting NEW SOURCE REVIEW (NSR) AND TITLE V PROGRAM UPDATES 9

New Source Review (NSR) Program Updates 10

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 NSR Program Begin Actual Construction Guidance, Final Guidance Fall 2020 Updates • 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. 11

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 NSR Program source and no longer subject to MACT requirement Updates 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. 12

Title V Program Updates 13

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 Title V the problem is, on which permit) Program 3. Requires permitting authorities to respond in writing to significant comments, and provide Update 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 14

Permitting Oversight Highlights 15

Common NSR and Title V Permitting Challenges: • Emission and operational permitting limitations for synthetic minor air permits. • Ensuring practicably enforceable emission limitations for all operational scenarios. • Applicability of regulatory standard in permitting administrative record. NSR and Title V Permitting Anticipated Title V Petition Trends: • Increased focus on wood pellet manufacturing Oversight and • Incorporation by reference in permitting terms and Title V conditions • Monitoring for synthetic minor limits Petition • Monitoring to determine that a limit does NOT apply Highlights 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) 16

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- PSD Long- range transport (LRT) assessments. Range • CALPUFF now considered an alternative model if chosen for a LRT assessment of Transport NAAQS and/or PSD increment impacts. Assessments o Alternative models require approval by the EPA Regional Office. Regional Office and approval includes consultation with the EPA’s Model Clearinghouse. Alternative • 2017 Appendix revisions also included Model Usage the codification of a screening approach to address long-range transport. o Use of CALPUFF in screening approach does not require alternative model approval. 17

Permitting Process Improvements 18

Increased use of electronic systems • Central Data Exchange (CDX) for receipt of title V petitions • Electronic Permitting System (EPS) o Currently Available: Electronic submittal of state-issued NSR, title V, and other permits for EPA review Permitting o Coming Soon: Electronic processing of EPA Process issued NSR and title V permits • Replacing and modernizing RACT/BACT/LAER Improvements 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. 19

Trends 20

8-hour Ozone Trends Memphis Area; 3-year running design values 100 90 ppb 80 70 60 91-93 93-95 95-97 97-99 99-01 01-03 03-05 05-07 07-09 09-11 11-13 13-15 15-17 17-19 Frayser (Shelby Co., TN) Years Orgill (Shelby Co., TN) Crittenden Co., AR DeSoto Co., MS NAAQS Memphis NCore (Shelby Co., TN)

Questions?