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Tabbed activity summarizing important points associated with Title V SOP revisions (administrative, minor, significant, notifications, renewals, and reopenings)

Tab Title: Admin.

Tab Content:

· Administrative revisions only include a few specific types of changes, such as correcting typographical errors.

· A permit holder may operate the change, record the information for an administrative revision, and submit the application no later than 30 days after the anniversary date of the SOP.

· Unlike initial SOP issuance, administrative revisions are not subject to public notice and hearing requirements, affected state review, or EPA review.

· Final action on administrative permit revisions is taken no later than 60 days after receipt of the application.

Tab Title: Minor

Tab Content:

· If a change cannot qualify for an administrative revision, the change may be eligible for a minor revision.

· An example of a minor permit revision is the incorporation of newly promulgated or adopted rules into an SOP. Another example is an amendment of an NSR permit issued under Subchapter B. (Remember--NSR authorizations are applicable requirements of Title V!)

· A permit holder must submit an application for a minor SOP revision prior to operation of the change. This means that they can operate the change before the executive director takes action on the minor revision application.

· Minor permit revisions must undergo a public announcement period (which includes notice on the commission's Web site, as apposed to a newspaper notice), affected state review, and EPA review before issuance.

Tab Title: Significant

Tab Content:

· Changes requiring a significant revision include...

» a significant change in existing monitoring,

» a relaxation of reporting or recordkeeping,

» a change to a permit shield,

» a new permit shield, or

» a PSD or nonattainment permitting action.

· Changes associated with a significant permit revision may NOT be operated until the SOP revision is ISSUED.

· Significant permit revisions must go through the same procedures as an initial SOP issuance and are therefore, subject to public notice and hearing requirements, affected state review, and EPA review.

· A significant permit revision is not final until the 60-day public petition requirement is satisfied.

· In PSD or nonattainment permitting, applicants are encouraged to submit the NSR application and the significant revision at the same time. This is to ensure that the SOP is revised around the same time as the NSR action is completed.

Tab Title: Notifications

Tab Content:

· Operational flexibility and off-permit changes require notification and allow the permit holder to make changes without applying for a permit revision.

· Changes included in operational flexibility and off-permit changes are not incorporated into the permit. Instead, the permit holder is required to keep records of the notifications with the permit and include those changes when it is time to submit the SOP renewal application.

· An example of a change that only requires notification is the addition of a PBR to an SOP.

Tab Title: Renewal

Tab Content:

· All SOPs are required to be renewed at least every five years.

· A renewal is subject to the same requirements as an initial issuance of an SOP or a significant revision to an SOP. You guessed it--that includes public notice and hearing requirements, affected state review, and EPA review!

Tab Title: Reopenings

Tab Content:

· Permit revisions and notifications are initiated by the permit holder. However, sometimes, the executive director or EPA may identify a permit that needs to be corrected.

· For example--

The executive director may determine that a permit contains a material mistake or that inaccurate statements were made in establishing the permit conditions.

·The tool for making the correction is a permit reopening.

· Permit reopenings are subject to the same requirements as initial permit issuance, but those procedures only affect those parts of the permit for which cause to reopen exists.