Workshop A Best Practices in Air Permitting & Compliance Amid ‘Regulatory Chaos’ … Key Strategies for Expedited Permitting, Corporate Audits and Intensive EPA Scrutiny Wednesday, July 25, 2018 1 p.m. to 2:30 p.m.
Biographical Information Todd Scarborough, Senior HES Professional, Marathon Pipe Line LLC 539 S. Main St., Findlay, OH 45840 419.429.9511 tscarborough@marathonpetroleum.com Mr. Scarborough has 27 years of experience in the air pollution regulatory field. He is now using his knowledge and experience to lead all air permitting and compliance efforts at Marathon Pipe Line LLC in Findlay Ohio. Marathon Petroleum Corporation has credited Mr. Scarborough with “moving Marathon Pipe Line’s air permitting and compliance program forward by light years.” Marathon Pipe Line has passed all full compliance evaluations with no violations since Mr. Scarborough’s arrival. Previously, Mt Scarborough worked as an Environmental Specialist 3 (Senior Environmental Specialist) with Ohio EPA’s Central District Office. His routine district office responsibilities included extensive interaction with various internal and external stakeholders while completing the review of air permit applications, drafting of air permits, performance of compliance inspections, witnessing of emissions testing and initiation and resolution of enforcement actions. While at Ohio EPA, Mr. Scarborough lead and completed complex permitting assignments, significant civil litigation, and criminal enforcement action. In addition, Mr. Scarborough was actively engaged and held leadership positions in Ohio EPA’s efforts to improve overall quality and efficiency of its processes and work environment. These efforts include DAPC’s Permitting and Enforcement Steering Committee, DEAL Review Committee and multiple Permitting Processing Efficiency Committee projects. Mr. Scarborough is a graduate of The Ohio State University (B.A. Physics) Adam Ward, Vice President Environmental Affairs, Sustainability and Energy Policy American Municipal Power, Inc., 1111 Schrock Rd. Ste. 100, Columbus, OH 43229- 614.540.0946 award@amppartners.org Mr. Ward directs the Environmental Affairs, Sustainability and Economic Development efforts at American Municipal Power, Inc. Tasked with maintaining regulatory compliance across AMP’s diverse generation fleet, his group handles all permitting, compliance measures, audits and interactions with both state and federal resource agencies. Adam spearheads the development and implementation of policies designed to minimize risks and maximize asset value. He also oversees AMP’s sustainability reporting and programs, which include a green power-purchasing program, carbon management program, REC certifications, and distributed energy resource assistance. Prior to AMP, Ward held various positions at Ohio EPA managing compliance, enforcement, permitting, and state implementation planning programs. Throughout his 22-year career, he has participated in countless improvement efforts focused on developing and implementing practical cost-conscious solutions to complicated regulatory challenges. Ward holds a bachelor’s degree from Bowling Green State University and a master’s degree from the University of Findlay.
Best Practices in Air Permitting & Compliance Amid Regulatory Chaos – Key Strategies for Expedited Permitting, Corporate Audits and Intensive EPA Scrutiny 2018 MEC Conference Todd Scarborough MPL Air Subject Matter Expert
Overall Goals and Objectives • Share perspectives from two holistic experiences • Provide straightforward and simple guidance • Describe real-world examples scaling the summit • Focus on positive experiences • Empower through sharing sound strategies 2
Understanding Perspective Regulatory Function • Issue permits/review permit applications • Complaints • Provide compliance assistance –USEPA vs. States • Review routine facility reports • Perform inspections and attend stack tests • Initiate enforcement 3
Understanding Perspective Current Regulatory Environment • Significant policy changes –USEPA –States • Funding –Significant impact • Staffing levels –Retirements •Also a significant impact –Attrition –New hires • The combination of the above key factors creates/defines the challenge 4
Permitting Drives Compliance Why is the permit so important? • Identifies requirements • Identifies applicable rules • Defines compliance strategy • Where the war is won 5
Our biggest challenges in the permitting arena The three U’s: unlawful, unreasonable, unnecessary • How is PTE determined? –The least understood concept • Exactly what belongs in a Title V permit? • Synchronizing permit requirements • Applicable rules • New requirements 6
Permit Applications/Review Process The critical process • Applicant input –Who drives the bus? –A complete application is critical • Permitting process involvement is key • Many opportunities are provided for input –Propose terms and conditions –Request review of pre-draft versions –Administrative permit modifications – great for refining permit terms –Appeal rights 7
Report Review Process The most often-missed opportunity • Reports are reviewed in accordance with permit requirements –Research example reporting templates for Title V, synthetic minor and non-Title V facilities –Send draft reports for review to regulators? –Inspections are the key opportunity •Regulators will provide feedback –Relationship building 8
A1 Simple Reporting Guidance Key concepts • Reporting format: –Make it clear –Hit bullseye • Timeliness • Due diligence –Is compliance documented? –Is the process for determining compliance documented? 9
Slide 9 A1 What is the flow of the presentation of this slide? The font sizes of the second bullets make them seem like they're on a lesser tier than the first, but they all have the same level in the bulleted hierarchy. Knowing that, I can reformat to make better use of the space. Author, 6/8/2018
Routine Inspection Process Your day to shine • States schedule facility inspections • Prioritized by USEPA agreement –Title V, MACT, NESHAPs –FEPTIO, Synthetic Minor –State PTIO • Encourage communication with inspectors –Most productive use of everyone’s time 10
Routine Inspection Process Preparation is the critical factor • Full Compliance Evaluation –Have all records available/ready to go –Review reports –Monitoring personnel available –Key emission units in operation –Key control equipment operating –Demonstrate your compliance program 11
Routine Inspection Findings What makes it work? • Compliance is attained and maintained through…. –Highly trained operations and monitoring personnel –Organized compliance processes –Routine record review and follow up –Compliance calendars/reminders –Attention to detail •Constant permitting and rule updates 12
Stack Testing Findings A challenging process • Compliance is attained and maintained through…. –Planning well in advance for success –Selection of the right testing firm for the job –High level of communication between all parties involved •Operations, testing firm, compliance personnel, Ohio EPA, etc. –Organized and thorough stack test report 13
Real World #1- Fast permitting MVS- Most Valuable Skill • Key Elements –Alignment of team players •Who is on your team? –Communication •You win with people but only if they speak effectively with each other –Execution •Each team member must play like varsity 14
Real World #1- Fast permitting continued Cajun Challenge • Major project –Number of emissions units –Cost • Critical need –Success is the only option • Relationships –Never underestimate the value of meeting face to face 15
Real World #2- You need the air permit when? One-tank wonder • Expedited process –Big $$$$ • Your “A” team must be known to you –Surround yourself with great people • Short story –Sudden need –Critical need • Outcome –65 days •Done is better than perfect –Two-step process •Everything in place before first day of operation 16
Real World #3- Inspection A Change is a constant • The system matters –Creates a lasting impression • Total transparency –Drives outstanding relationships • Questions answered directly –Credibility –Are you listening to yourself • 100% compliance 17
Real World #4- A whole new kind of inspection Comprehensive at a whole new level • Multiple Inspectors –Latest technology • Program understanding –Do you know why you are doing what you are doing? • Comprehensive/detailed –9 typed pages •Described records for review •Interrogatories • Great outcome 18
Real World #5- Patience pays off A win for everyone • Over permitted –Several sites –20 plus years • Re-permitted –Reclassified •Title V to FESOP •Title V to Minor •FESOP to Minor 19
Wrap up Relationship-centric approach drives winning with people! • Compliance is achieved through….. –Outstanding relationships –Outstanding communication –Outstanding technical command of the subject matter • Results will speak for themselves!!! 20
Questions? Always glad to offer assistance Todd Scarborough (419)429-9511 21
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