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Nez Perce Tribe Experience with Enforcement and Tribal Credentials

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.

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Nez Perce Tribe Experience with Enforcement and Tribal Credentials

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

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

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

  4. 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 50.1-12; 52.1-34; 60.1-19; 63.1-15; and the introduction to 51.166 and 52.21. • Self-Study/Review of the following Guidance/Reference Materials: • CAA Compliance Monitoring Strategy, 2001 • CAA Confidential Business Information, Information Security Manual (EPA 450/B-03-001) • National Stack Testing Guidance (2/04)

  5. 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

  6. 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)

  7. Annual Training • 8-hr Health and Safety • 8-hr media specific training • Visible emissions evaluation (VEE) – aka Smoke School Some training sources NETI http://www.netionline.com ATPI http://www.epa.gov/apti/index.html CARB http://www.arb.ca.gov/training/calendar.php EPA ITEP

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