Upload
rory
View
38
Download
0
Embed Size (px)
DESCRIPTION
Leech Lake Permit Review. Brandy Toft Air Quality Specialist Minor NSR Workshop. Leech Lake Title V Permits and area sources of Concern. 3. Area of concern 19 Title V’s. Wood products. Wood Products. 2. Great Lakes Compression Station. Paper mill. Waste incinerator. Coal EGU. - PowerPoint PPT Presentation
Citation preview
Leech Lake Permit Review
Brandy ToftAir Quality SpecialistMinor NSR Workshop
Wood Products
Waste incinerator
2
Largest MN Coal EGUWaste EGU
2
3
Wood products
Leech Lake Title V Permits and area sources of Concern
Great Lakes Compression Station
Paper mill
Coal EGU
Area of concern19 Title V’s
Title V facilities of concern to the LLAP 19 clustered Title V facilities of concern
Over 250 area sources within the Reservation Boundaries
How we go about a permit reviewDaunting task – States have multiple engineers-
Tribal Air Professionals are multi functional.
• 1st – read:• The permit notification – 1 page• The technical document – few pages• Peruse permit – 100’s of pages
• 2nd – find a tribal colleague to discuss• 3rd – call the permit engineer for the permit• 4th – chat with other interested parties (FLMs)• 5th – re-connect with tribal colleague• 6th - write comment letter It’s that easy…?
• Takes time to attain a comfort level– Technical terms– Operations and configurations– Differ types of facilities– Rules/ laws/ NAAQS– Industry trickery…
• Research processes, contact others in air field from other agencies– FLMs– Stakeholder groups (Citizen, Enviro, ect)– Tribes
Reviewing – it ain’t easy…but needed
This could be
especially beneficial
for Tribes without
good State relations…
• Most permit engineers are ecstatic that someone is taking interest in their permit
• Don’t be afraid to ask questions or for explanations
• Vampire theory – They have to be invited in…
• Always remember to ask “What question should I have asked?”
Permit Engineer Involvement
• LL Attained TAS in 2007– Currently 4 of 11 have or in process of TAS in MN
• State granted all Tribes in MN “pseudo TAS” for ease of notification of permits
• State established a guidance document – laying out notification process, – timelines for all TV permits,– Tribes indicate areas of interest.
For the Guidance to work we have to work together…
Minnesota Tribal Notification
• Permit engineer contacts the Tribe ASAP in permitting process, well before the public period
• State updates and maintains Tribal contact list and areas of interest quarterly
• Crossed over from air to include water permits and others
• Used as a guidance document for other StatesMinnesota Pollution Control Agency Guidance On Air Quality Permit Consultation with
Indian Tribal Governments
Minnesota Tribal Notification
• With precedence set in MN – wanted equal notification from R5
• Formulated a list for R5 for air, water, mining, permitting and environmental contacts
• Updated every six months
• Have yet to be contacted by EPA for a state permit in review… yet…
MN to Region V EPA
• Looking forward to adding the review of minor sources – see later case study
• Who/how do older sources register?
• How will we be notified of review and comment?
• Do and when do we take on delegation?
• Here, along side you, to learn more and gain more in the tribal network…
TV to Minor Sources
• Attend trainings, conf calls
• Facility tours– Learn the processes and equipment– Make friends/create relationships
• R5 Tribal TV Workshop Feb 1 & 2
• 1/4ly Tribal Mining meetings with the State
• NETWORKING!!!
Get Learned…
Submitting Comments• Comments can be 1 to 10 pages depending on
the permit• Can be both positive and negative• Submit via email• Sign for LL – quicker process
“We don’t want your comments, We want your participation!”
• Get involved early – EIS/EAW– Permit application
• 90% of the permit is done by public comment
• Permit engineers “hate” the 30th day comment
• Permit fast track legislation – get involved early!
Involvement vs. Comments
• Be as specific and concrete as possible
• Provide notations where found, notations of Rule
• Focus on main emission sources, combustion sources– Narrow to main pollutant emitting units and
investigate those for process and emission controls
• Your not going to catch it all… – network and practice!
Commenting
No Comment…No Recourse!
• Comment even if is short, simple – Ensures you are part of the process
• Can appeal permit to State or Federal appeals board ONLY if you commented on the permit!
• Ensure you are appealing to the correct board
Why Comment?
Leech Lake Minor Source Case Study
• Wood products sawmill with kiln• Emitting large particulates, limited opacity• Located within a city on the Reservation in a
residential area on private land• Complaints from
Residents• Work with City Mayor
and residents• School Air Toxics site
Current Minor Source issue…
Know your rights…• Contacted EPA to inspect/find out issue• Didn’t want to assist, tried to forward onto
State• Called up EPA reinforcements, sited TAR, Trust
Responsibility… called off the State• Currently in process of a potentially 3rd CAA
114 letter• Our goal is to bring facility into compliance
and see a permit registration for the facility
• Minnesota State has all permits lumped into one database without a way to query
• MPCA Currently updating system
• Some sources don’t have even State permits
• LL plans to work with the State, Feds, and facility to make a smooth transition and to be fully involved in the process
NSR from State to Federal Permit
Discussion???
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~Brandy Toft
Air Quality SpecialistLeech Lake Band of Ojibwe