Prep4Permit Review.ppt
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Transcript Prep4Permit Review.ppt
Preparing for Permit Review
Virgil Frazier
Southern Ute Indian Tribe
Objectives
Learn
How tribes can participate
How to get information (needed) for
review
To detect common problems in reviewing
permits
How to request permit applications and
other information
2
Preview
Know your rights and how to assert them
Four components in state permit
process
Get on EPA, state, and/or local mailing
lists
Review permit (time management)
Identify issues/write comments
Follow up
3
Preparing for the Review
4
Be Informed
Get on mailing list
Agency will send you
Notification of Public Comment period
Hearing date for public meeting/hearing
Information on obtaining draft permit
Read public notice carefully for
details on deadlines and requirements
5
Ensure Access to Information
Typically, states allow tribes access to
Confidential Business Information
(CBI)
Some states do not share CBI with
tribes
Sources may try to use CBI status to
withhold information
6
Apply for
“Affected State” Status
If source is near reservation,
Affected State status helps ensure
tribal influence on permit
Affected States receive all notices
and draft permits
You may still request more detailed
information
7
Documents Likely to Be
Necessary for Review…
State’s SIP (relevant portions)
State’s Permit Program Regulations
40 CFR Part 70
NSPS
MACT
NESHAP
8
Learn Title V Requirements
Attend SIP hearings
Attend permitting review meetings
Develop contacts
EPA authorities
State authorities
Local enforcement authorities
9
Obtain the Permit Application
Ensure that facility answered
questions, supplied information
Request additional information from
permit authority
Detailed monitoring plan
Previous permits
Computer model of facility’s air impact
Enforcement history
10
Reviewing the Permit
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Determination of
Completeness
Draft permit information
Administrative
Technical
12
Common Problems
SIP requirements missing
State uses revised rules in SIP for
permit not yet approved by EPA
Draft permit lacks sufficient
monitoring to provide good
compliance data
13
Common Problems (cont.)
Recordkeeping and reporting
frequency inadequate
Information insufficient for standalone permit
Permit limits not practically
enforceable
Compliance schedule missing
14
Documents that Aid in Review
Permit application
Inspection reports
Notice of Violation
Previously issued permits
Monitoring reports
Test results
Startup, shutdown, malfunction reports
correspondence
15
Examples of Major Questions for
Permit Review (Application)
Why review?
Learn about the
basics
Source operation
Source category
Identify applicable
requirements
Adequate
monitoring?
What to LOOK for
Processes /
pollutants / control
equipment
Description &
citation for each
requirement
Applicant’s
proposed
monitoring
16
Examples of Major Questions for
Permit Review (Prior Permits)
Are all applicable
requirements
included?
What to LOOK for
Emission limits
Control equipment
requirements
Monitoring/record
keeping
requirements
17
Examples of Major Questions for
Permit Review (Monitoring Reports)
To learn about
previous
compliance
problems, history,
other information
Review reports
(show
applicability…)
Margin of
compliance
Emission-limit
exceedences
Visible emission
test results
18
Identify Issues/Write Comments
Ask pertinent questions
Work with EPA and state
Submit comments by deadline
Provide examples
Cite specific rules
Suggest a fix
19
Following Up
Make sure
Your issues are addressed
Permitting authority is contacted
Exercise your rights to request and
attend public meetings/hearings
20
Summary
Tribes have a role in Title V permit
review
Know your contacts
Request to get on PA’s mailing lists
Use regional EPA contacts
Continue commenting
21