Nez Perce Tribe

Experience with Enforcement and Tribal Credentials

Mary FauciNez 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 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)

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 http://www.netionline.com

ATPI http://www.epa.gov/apti/index.html

CARB http://www.arb.ca.gov/training/calendar.php

EPA

ITEP