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Improving the Nebraska Air Quality Construction Permitting Process for Businesses

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Title: Improving the Nebraska Air Quality Construction Permitting Process for Businesses


1
  • Improving the Nebraska Air Quality Construction
    Permitting Process for Businesses

2
  • Clark Smith, Supervisor
  • Air Quality Permitting Section
  • Air Quality Division
  • (402) 471-4204
  • clark.smith_at_ndeq.state.ne.us

3
Background
  • Recognize Improvements are Necessary
  • Program differences between states
  • Actions Department could take to improve
  • Actions Applicants could take to improve
  • Multifaceted approach

4
Action Plan
  • Evaluate Human Resources
  • Write EPA R7 about Variances On Hold
  • Participate in Iowa KAiZEN event
  • Conduct KAiZEN event in Nebraska
  • Finalize Permit-by-Rule Changes
  • Evaluate Haul Road Guidance

5
Action Plan (Cont.)
  • Short-Term Proposed Action
  • Business Process Improvement (KAiZEN process)
  • Long-Term Proposed Action
  • Electronic Permitting
  • E-Filing of applications
  • Identify grant opportunities other means of
    funding
  • Utilize template language

6
Action Plan (Cont.)
  • Long Term Proposed Action (continued)
  • Identify Future/Current Growth Sectors Through
    Planning Process
  • Identify challenges for other industrial
    categories
  • Help identify strategies for overcoming
    challenges
  • Work with DED pre-screen areas for development
  • Identify issues early in business planning
    process
  • Resolve the issues
  • Permits are then easier to obtain

7
What Is Kaizen?
  • Kaizen
  • A combination of two Japanese symbols Change and
    Good
  • Commonly translated as change is better.

8
What is a Kaizen Event?
  • Aimed at creating fast, practical solutions for
    challenges
  • A highly focused, action-oriented, 4-5 day event
  • Uses multi-functional teams who are empowered to
    make decisions and immediate changes

9
How Does a Kaizen Event Work?
  • In Kaizen a group of people come together to
    concentrate on improving one specific process
  • They create real change in five days or less
  • A good way to get instant and long-lasting results

10
Kaizen Methodology
  • Clear objectives
  • Team process
  • Tight focus on time
  • Quick simple
  • Necessary resources immediately available
  • Immediate results (new process functioning by end
    of week)
  • Use of various planning tools to accomplish
    results

11
NDEQ KAiZEN Event
  • Facilitated Business Process Improvement
    (modified-Kaizen)
  • Involved all key staff to get buy in
  • Involved outside stakeholders
  • Trained facilitator
  • Conducted week of February 14 18
  • Held in conference room at Holiday Inn
  • Focused on identified goals

12
KAiZEN Goals
  • PSD and Ethanol Greenfield Facilities
  • 180 Days Receipt of Complete Application to
    Public Notice
  • PSD Minor State Toxics BACT Facilities
  • 120 days Receipt of Complete Application to
    Public Notice
  • All Others
  • 90 days Receipt of Complete Application to
    Public Notice

13
KAiZEN Goals (cont.)
  • To Make a Decision From the Close of Comment
    Period
  • 5 Days If no comments received
  • 30 Days If comments were received
  • To Make a Decision From the Close of the Hearing,
    If One is Held
  • 30 Days If no transcript needed
  • 90 Days If transcript needed

14
KAiZEN Event Results/Recommendations
  • Require Pre- application Meetings
  • Provide more outreach efforts
  • Standardize and Clarify Permits
  • Public Involvement
  • Permitting Hotline
  • Tracking System

15
KAiZEN Event Results/Recommendations
  • Staff Training
  • Modeling Protocol
  • Guidance Documents
  • Flow Process for Permit Review
  • Checklists
  • Communication
  • Work Plan to Address Existing Load

16
KAiZEN Implementation
  • Additional Staff Being Hired
  • We have filled three of the five vacancies we had
    at the beginning of the year
  • Checklists
  • Developed checklists for different processes,
    including the pre application meeting,
    completeness reviews

17
KAiZEN Implementation
  • Permit Hotline
  • Established an 800 number for sources/consultants
    with construction permit questions
  • The number is 877-834-0474
  • Transitional Work Plan Developed
  • Developed a plan to get the work load of staff
    down to a manageable level
  • Target is to have the work load reduced by July
    1, 2005

18
KAiZEN Implementation
  • Haul Road Policy
  • Haul road emissions can be over predicted in
    models difficult to address
  • Best management practices in lieu of modeling
    must be in compliance with Chapter 32, Section
    002
  • Applicant proposes an appropriate BMP in permit
    application

19
KAiZEN Implementation
  • Permit Standardization Effort
  • Two trial efforts
  • Standardized language Ethanol plant permits
  • Standardized format
  • Ethanol plant permits
  • Developing standardized permit language for the
    various emission units
  • Two different templates depending on
    configuration of the plant
  • Permit using first template on Public Notice at
    this time

20
KAiZEN Implementation
  • Permit Standardization Effort, cont.
  • Standardized format
  • Working with AGP to develop a new format that is
    on an emission unit basis
  • All requirements associated with a specific
    emission unit will be in one section of the
    permit
  • Current format has limitations, monitoring,
    recordkeeping, etc., in separate sections of the
    permit
  • Draft format is receiving good reviews from
    permit writers and compliance personnel

21
KAiZEN Implementation
  • Website Improvement
  • Have entered into a contract with Nebraska Online
    to redesign our website
  • Taking recommendations from the Kaizen effort
    forward
  • Department wide effort to begin this month
  • Finalization of the website no later than the end
    of the year

22
KAiZEN Implementation
  • Fact Sheets and Guidance Documents Developed
  • New Fact Sheet
  • Recordkeeping for No Permit Required
  • Revised Fact Sheet
  • Construction Permits
  • Guidance Document Drafted
  • Public Participation and Air Quality Permits

23
KAiZEN Implementation
  • Emission Calculation Spreadsheets drafted (being
    reviewed)
  • Haul Roads - Boilers
  • Turbines - Composite Resins
  • Asphalt, - Stone crushing
  • Internal Combustion Engines
  • Ag processing (grain elevators, feed mills, and
    alfalfa dehydrators)
  • Emission Calculation Spreadsheets to be drafted -
    Aggregate plants, concrete batch plants, and
    surface coating.

24
KAiZEN Implementation
  • Reinstated the Air Waves Bulletin
  • This will keep industry consultants apprised of
    Air Quality Division events, regulation changes,
    program changes, etc.
  • Distributed electronically 600 sources and
    consultants. The next issue will be 8/05. All
    issues will be available on the web eventually.
  • Outreach Plan Updated
  • Internal plan for Air Quality Division
  • Covers outreach activities for the calendar year
  • Updated to include the outreach efforts described
    above

25
KAiZEN Implementation Efforts

Recommendations are in a work plan Policy-Level
managers meet weekly to discuss track
progress Developed a newsletter to keep KAiZEN
participants informed of progress
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