Nez Perce Tribe Experience with Enforcement and Tribal Credentials Mary Fauci Nez Perce Tribe.

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Presentation transcript:

Nez Perce Tribe Experience with Enforcement and Tribal Credentials Mary Fauci Nez Perce Tribe

Tribal Credentials & EPA Enforcement EPA retains enforcement authority Nez Perce Tribe 2 inspectors since 2006 conduct investigations and inspections

Initial Minimum Training – R10 Federal Air Inspector Credentials Basic Inspector Training Health & Safety Program-specific training On-the-job Training/Mentoring

Program-Specific Training Visible Emission reader training (i.e., smoke school) initial training, and recertification every 6 months. Self-Study/Review of the following Air regulations: 40 CFR ; ; ; ; and the introduction to and Self-Study/Review of the following Guidance/Reference Materials: CAA Compliance Monitoring Strategy, 2001 CAA Confidential Business Information, Information Security Manual (EPA 450/B ) National Stack Testing Guidance (2/04)

Program-Specific Training (cont.) Air Pollution Control Technology (CD-ROM) Review of a minimum of two completed inspection reports for each type of CAA stationary source inspection to be conducted. Principles and Practices of Air Pollution Control (APTI 452) (Completed either before or shortly after getting the credential) Knowledge of FARR, Guidance for Issuing EPA Inspector Credentials (9/30/04), and Authorization Agreement between tribe and EPA Knowledge of EPA's Guidance on the Enforcement Principles Outlined in the 1984 Indian Policy (1/17/01), the procedures outlined in the Region 10 Enforcement Procedures in Indian country (5/28/98), and FARR Penalty Guidelines

Annual Workplan Inspection of Title V (part 71) sources Compliance assistance at FARR registered sources Quarterly report (EPA Inspector Credential Authorization Agreement Inspection Plan reports) FARR complaint response, burn permit compliance, and other compliance monitoring Related activities (trainings, communication with EPA, 114 requests, NOV, permits, area source rules)

Annual Training 8-hr Health and Safety 8-hr media specific training Visible emissions evaluation (VEE) – aka Smoke School Some training sources NETI ATPI CARB EPA ITEP