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EPA Region 7 and 4 States—National Pollutant Discharge Elimination System (NPDES)

Kaizen Event Case Study

Summary

Implementation of the permitting and enforcement processes of the National Pollutant Discharge Elimination System (NPDES) program was the subject of a kaizen event in August 2008. This event included EPA Region 7, and the Region 7 States of Iowa, Nebraska, Missouri and Kansas. It included discussions on the permitting process, related technical issues, and enforcement activities, including formats for planning and conducting inspections.

The objective of the week-long event was to improve the effectiveness and efficiency with which all parties implement the NPDES program, and to learn how best to work together and resolve issues quickly. The event resulted in redesigned processes that clarified how to better address critical technical issues, plan and conduct inspections, and collaborate between the agencies.

Results

The event yielded a process design which will result in:

  • An 82% decrease in processing time to resolve technical issues that delay permits (from 5.5 months to 1 month).
  • A 67 % decrease in total number of steps for EPA to review a state wastewater program (from 39 steps to 13 steps).
  • A 75%-68% decrease in processing time for EPA to review a state wastewater program (from 4-19 months to 1-6 months).
  • Increased collaboration between EPA and States to improve planning.

Participating Agencies

Participants in the kaizen event included:

  • EPA Region 7
  • EPA Headquarters (Office of Wastewater Management, Office of Civil Enforcement, Office of Compliance, and Water Permits Division)
  • Iowa Department of Natural Resources
  • Kansas Department of Health & the Environment
  • Missouri Department of Natural Resources
  • Nebraska Department of Environmental Quality

Method Implemented: Kaizen event (5-day event)
Year Conducted: 2008
Consultant Support: TBM Consulting Group


Scope of the Lean Project

Project Scope

This event examined the implementation process for the EPA Region 7 NPDES program from the time the States and Region negotiate and agree on performance criteria and measures to when EPA completes a performance report.

Goals

The goal of the Lean event was to design a process to better implement the NPDES program where:

  • Program review and follow-up processes are unified and clearly defined;
  • 100% of state wastewater programs exceed the minimum level of performance established by EPA in the annual planning process;
  • Zero permits merit objection or significant comments from EPA;
  • 100% of priority permits are completed, with excellence as a goal, not perfection; and
  • 100% compliance for Significant Non Compliance (SNC) is achieved.

Process Changes and Results

Goals and objectives for the event were set during a pre-event meeting. Participants subsequently were assigned and completed homework that described their portion of the process. This information was shared with all parties prior to, and provided the foundation for, the main kaizen event. During the event, participants developed “current state” and “future state” maps of the processes. New processes were designed for three aspects of the implementation process: annual strategic planning, resolution of technical issues, and EPA oversight. Key process changes are identified below.

  • Annual Planning. During the planning process, performance criteria and measures for evaluating state wastewater enforcement programs are established. Under the new design, process steps were added as participants decided good planning and communication up front would help to create performance criteria and measures that better reflect State and EPA priorities and save time in the long run.
  • Resolution of Technical Issues. In the old process, there were tough technical issues that delayed permits. In the new process, technical issues are identified before a permit comes in and the right people are brought in to deal with them before the permit application is submitted.
  • Oversight. Oversight refers to EPA performance reviews of state wastewater programs. Previously the permit and enforcement reviews were conducted separately. This lead to communication gaps surrounding the reviews. The new process will coordinate permit and enforcement reviews, and eliminate non-value added process steps.

Figure 1: Current State Map

Figure 1: Current State Map

The kaizen event yielded a process design which will result in:

  • An 82% decrease in processing time to resolve technical issues that delay permits (from 5.5 months to 1 month).
  • A 67 % decrease in total number of steps for EPA to review a State NPDES program (from 39 steps to 13 steps).
  • A 75-68% decrease in processing time for EPA to review of State NPDES program (from 4-19 months to 1-6 months).
  • Increased collaboration between EPA and States to improve planning and aspects of program implementation.

Figure 2: New Process Map – Annual Strategic Planning (Click to enlarge in new window.)

Figure 2: New Process Map – Annual Strategic Planning

Figure 3: New Process Map – Resolution of Technical Issues (Click to enlarge in new window.)

Figure 3: New Process Map – Resolution of Technical Issues

Figure 4: New Process Map – Oversight (Click to enlarge in new window.)

Figure 4: New Process Map – Oversight

Implementation

Participants also developed implementation plans for the three new processes. Key implementation actions included:

  • Prepare earlier and have broader stakeholder participation in the yearly planning and follow-up meetings;
  • Have active participation by EPA in stakeholder meetings when States request it;
  • Reduce data reporting requirements for state programs;
  • Automate data reporting by facilities;
  • Conduct a training needs assessment and development of a training implementation plan;
  • Create a checklist for permit development and review; and
  • Hold workshops on important NPDES issues (first one planned for spring 2009).

Since the kaizen event, participants have been working on implementation. A follow-up meeting took place in December 2008 and another one is scheduled for June 2009. Iowa and Nebraska plan to conduct smaller spin-off events on the NPDES permit-rider process. Region 7 is sharing the results of the event and considering whether some of the outcomes are transferrable on a national scale for the NPDES program.

For More Information

Contact Person:
Glenn Curtis
Chief Waste Water & Infrastructure Management Branch
Water Wetlands & Pesticides Division EPA Region VII
913-551-7726
curtis.glenn@epa.gov

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