Continuous Improvement/SUCCESS Framework
2018 State of the Environment Report (AQ)

DAQ is committed to continuous improvement to improve performance and implement innovations that advance quality, efficiency, and effectiveness. Listed below are a few of the ongoing continuous improvement/SUCCESS Framework process improvements within DAQ.

Continuous Improvement Spotlight: Air Quality Permitting

Over the past few years, DAQ has adopted process improvements to its permitting program to reduce the time between receiving a permit application and issuing a permit.

Webpage improvements were an important first step. Permitting resources are now organized on the website so the left-hand toolbar provides two-click access to all permitting resources. The Permitting Branch also developed better permitting resources, including process flow diagrams, PDF-fillable forms, and concise guidelines that are easily accessible through the website. A web link for industry lets them schedule a pre-NOI (notice of intent) meeting and receive checklists and forms to guide them through the permitting process.

The Branch developed clear permitting-process timelines and expectations. Branch management developed the “Milestone Guideline” that a project engineer can share with permittees so they know what to expect in the permitting process. The project engineer also sends an email introduction upon receipt of an NOI so the permittee knows their permit application has been received as well as the name of the engineer preparing the permit. The email also reiterates initial timelines. The project engineer routinely checks in with the source with status updates.

A “completeness checklist” is included in the introduction email. This checklist lists all information required for an application to be accepted by DAQ. As soon as the required information is submitted, DAQ accepts the application and sends an email to the permittee notifying the source of the application status along with advice on next steps. If the permittee doesn’t meet the information requirements, DAQ sends an email that lists deficiencies and provides timeframes for resolving the deficiencies.

One of the Branch’s main goals was to improve pre-application meetings (pre-NOI) between the permittee and DAQ staff. These meetings are an opportunity for DAQ engineers to share information about the project along with permitting regulations. The permitting staff has always offered sources an opportunity to attend pre-NOI meetings, but the meetings were poorly organized and ineffective. The Branch has taken a number of important steps to improve these meetings and encourage permittees to participate:

  • The permitting web page now includes a one-click link that permittees can use to schedule a pre-NOI meeting and download a packet of checklists and forms to help them complete the permit application.
  • The link asks for basic information from the source about its processes. This information helps the engineer prepare for the meeting. Pre-NOI meetings are much more effective when both parties come prepared to discuss the project.
  • The link for the pre-NOI meeting is placed prominently on the DAQ Permitting home page.

A study of permitting timelines shows that the permitting process goes faster when the initial application is complete. The Branch has developed a number of resources to help permittees submit a complete application. In addition to the pre-NOI meeting, other important resources include a completeness checklist, clear and concise guidance, and forms that prompt the permittee to supply needed information. The project engineer works off the checklist and quickly advises the permittee about missing information. As soon as the application is complete, the project engineer sends an email informing the permitted the application has been accepted and a detailed review is in process.

A new tool to allow permittees to submit their application electronically is currently in development.

Success Story: SLEIS —
A Better Method for Gathering Air-Emissions Data

DAQ is required by federal and state law to gather emissions-inventory data from sources of air pollution in Utah. Improved emissions-inventory data management is essential as DAQ policies evolve and public demand for more information increases.

The solution was the development and implementation of the State and Local Emissions Inventory System (SLEIS). This new system established an online emissions-inventory system where regulated sources can submit their air-emissions inventories to DAQ. Benefits of SLEIS:

  • Extensive built-in calculation capabilities simplify the process and reduce the workload for regulated sources required to submit an emissions inventory.
  • Extensive quality assurance/quality control (QA/QC) methods guide regulated sources as they submit their data, greatly reducing oversight required by DAQ staff.
  • A built-in tool for generating Title V Fee invoices reduces time spent (by over 50 percent) by DAQ Finance staff on invoices
  • A built-in, automated tool for uploading the inventory data to EPA’s Emission Inventory System (EIS) saves time for DAQ staff.
  • Streamlined data extraction from the system allows DAQ staff to quickly fulfill ad-hoc data requests as well as provide information for State Implementation Plans (SIPs).
  • Online training videos and information for regulated sources will save time for DAQ staff during future emissions-inventory reporting periods.

Overall, SLEIS has had an overwhelmingly positive impact on DAQ staff and the regulated community. Four Title V Major Source Facilities offer praise for SLEIS:

(We) had a good experience using the SLEIS program for the AEI reporting this year. Having the previous year’s data already loaded into the program with the required calculations simplified the reporting process for us.”
SLEIS provides a secure, online approach for handling emissions data. It is an innovative step in the right direction toward the automation of emissions data reporting. It allows for quick and efficient use of data while providing an electronic approach which can evolve and be tailored over time as new reporting needs are identified.”
The new SLEIS air-emission inventory tool will increase reporting efficiency and accuracy from our source.  The ability for the user to edit emission points as equipment is upgraded, taken off-line, etc. eliminates the need for the Division to reprogram a major source’s workbook.  Additionally, the ability to input process-specific emission factors or use updated EPA emission factors increases reporting accuracy.  Much appreciation to Division staff for implementing the change and their support in guiding us through the new process.”
I do appreciate all the work that has gone into making SLEIS work. So my Easter gift to you is … look out a window, relax and take a long deep breath and enjoy a moment knowing you have a happy customer.”

Success Story: Asbestos/Lead-based Paint Database (ALBoP)

DAQ’s Asbestos and Lead-Based Paint programs require individuals and companies/firms dealing with asbestos and lead be certified and notify the program of regulated projects when they occur, The programs previously only accepted paper copies of certification applications and project-notification forms. Section members determined that it would increase their efficiency if the section put all of its previous databases, programs, and spreadsheets into a single location. This consolidation produced the Asbestos/Lead-Based Paint database, or ALBoP 1.0.  This database has a front facing, web-based portal that allows those regulated by the Asbestos and Lead-Based Paint programs to submit certification applications and project-notification forms and pay for those documents online 24-hours a day, 365 days a year.

The Utah Asbestos and Lead-Based Paint programs have been working closely with the Department of Technology Services and Weber State University to develop and launch ALBoP 2.5 in January 2019.  This new version of ALBoP will increase efficiencies thanks to input from program staff and regulated entities that use ALBoP. The new version of ALBoP will continue to allow the regulated community to apply for certification and provide the Asbestos and Lead-Based Paint programs with notification of projects at any time of the day, but it will also provide efficiencies to section staff by leveraging keystrokes and allowing inspectors to check on notification forms remotely by laptop, tablet, or mobile phone while in the field.

Ongoing Continuous Improvement Projects

Statewide Oil and Gas Inspections

DAQ adopted process improvements to its inspection program to increase statewide compliance with oil and gas regulations. Improvements include:

  1. Prioritizing inspections on the basis of risk and compliance history.
  2. Mapping facility locations so that inspections can be grouped to maximize field work time and minimize travel time.
  3. Using tablets for travel (maps of locations) and inspection notes, eliminating duplication of effort and cutting the time spent transcribing and inputting notes back at the office.
  4. Using an infrared camera to detect leaks at tank batteries during inspections.

Operating Permits

DAQ improved its permitting process to reduce the number of Title V permits extended beyond their five-year term. After five years, the source is allowed to operate according to the existing permit conditions under “application shield” provisions, as long as the facility has applied for a permit renewal in an appropriate and timely manner. In 2009, permits beyond the five-year term soared to 35. Since then, DAQ has been able to substantially reduce that number, and currently has the lowest number of permits beyond the five-year term in EPA Region 8.

New Source Review Permits

DAQ adopted process improvements to its permitting program to reduce the time between receiving a completed new source review permit application and permit issuance. Improvements include:

  • Holding pre-meetings before a permittee submits a Notice of Intent (NOI) to answer questions and ensure permit applications are complete before submission.
  • Providing guidance documents online to assist permittees in filling out the permit application.
  • Starting the permit time clock when a complete application is received, not before.

Success Story: Oil and Gas Inspections

Site inspections at oil and gas facilities ensure that equipment works properly and operators meet the emissions limits in their permits. But with over 1,000 oil and gas sites scattered around the state, the three (and one half-time) DAQ inspectors who examine these facilities were finding it difficult to visit them in a timely fashion. Travel time to sites far exceeded the time spent at each well, and it was difficult to coordinate full inspections with oil and gas operators. Full inspections include a review of the permit, a records search, and an onsite inspection with the operator present. As a result, each inspector was only able to complete 48 full inspections per year.

DAQ heard that its counterpart in Colorado had experienced a similar problem and found an effective solution. Rather than performing full inspections, the Colorado inspectors conducted partial inspections using an infrared (IR) camera. An IR camera can spot equipment leaks that are invisible to the naked eye. These types of leaks are the primary source of volatile organic compound (VOC) emissions at well pads and can generally be fixed quickly and easily.

DAQ inspectors decided to also switch to partial inspections using an IR camera, and the benefits were immediate. DAQ inspectors could visit the sites, contact the operator if they discovered a leak, and within three to five days — sometimes the same day — the leaks were fixed. The video from the camera pinpoints the leaking component(s), allowing operators to go directly to the source of the leak to repair it.

Under the new system, DAQ’s inspection rate jumped from four full inspections over two days to 10 partial inspections in one day. Inspectors have discovered numerous equipment leaks since starting the program a few years ago. These leaks that would have gone undetected for a longer period of time under the previous inspection schedule. Inspectors also paired the new inspection regimen with a tablet app containing a one-page checklist to complete onsite and send back to the office with the push of a button.

The new system reduces VOC emissions, saves product from escaping into the air, and helps inspectors visit more sites each year. Inspections jumped from 48 inspections for each inspector each year to 60 per year. That figure jumped to 75 per year per inspector in the second year. Multiplied by three and a half inspectors, the number of inspections per year increased from 168 to 262. DAQ hopes to continue to increase inspection frequency using the IR camera and tablet app.

2018 Division of Air Quality Dashboard

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