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Tabbed activity summarizing important points associated with GOPs (ATO, public notice, criteria, and review) and SOPs (general, review, and public notice)

Tab Title: GOP - ATO

Tab Content:

· The executive director has the authority to issue GOPs to cover numerous similar sources. An owner or operator can apply for an authorization to operate (ATO) under a GOP.

· Because the subset of requirements for an ATO are predetermined and established in the GOP, and because ATOs are not subject to individual public notice, the process for granting ATOs is much more streamlined than the process for issuing a case-by-case SOP.

Tab Title: GOP - PN

Tab Content:

· The executive director fulfills the public notice and hearing requirements, affected state review, and EPA review when a GOP is issued.

· The GOP is also subject to a 60-day public petition period after the issuance date.

· An individual ATO under a GOP may be granted without further public notice or review.

Tab Title: GOP - Criteria

Tab Content:

· A GOP codifies all of the site-wide and emission unit-specific requirements for different scenarios that are likely to be found for a particular source type.

· An applicant will indicate which parts of the GOP apply to the particular site. However, a GOP can never cover site-specific requirements, such as...

» an alternate means of compliance,

» a compliance plan,

» a stringency determination, or

» a permit shield.

· If an applicant needs any one of these codified into an operating permit, or if the site has emission units subject to requirements not codified into the GOP (such as acid rain rules) an SOP must be obtained.

· If, for any other reason, a GOP cannot be used, an SOP must be obtained.

Tab Title: GOP - Review

Tab Content:

· In processing a GOP application, the permit reviewer must first determine if the application area meets the qualification criteria for the GOP.

· The permit reviewer must then verify the terms and conditions (site-wide requirements) and GOP index numbers (unit-specific) submitted by the applicant. For additional information on index numbers, see the Learn More sidebar on this page.

· In addition, the reviewer must ensure the application has proper certification.

Tab Title: SOP - General

Tab Content:

· For an SOP, the permit reviewer is required to review the application and develop the site-specific terms.

· This consists of the site-wide terms and conditions (that apply to the permitted area as a whole) and the applicable requirements summary, which codifies...

» standards,

» emission limitations,

» monitoring,

» recordkeeping, and

» reporting requirements for specific emission units.

Tab Title: SOP - Review

Tab Content:

· For an SOP, when applicable, the permit reviewer must evaluate and develop monitoring requirements specific to the site. For additonal information regarding monitoring requirements, see the Learn More sidebar on this page.

· The permit reviewer must also develop additional site-specific permit attachments, such as a permit shield, a compliance plan, or acid rain requirements, as applicable.

· The permit reviewer must work with applicants to resolve any deficiencies and develop the Working Draft Permit.

· The permit reviewer must also develop the Statement of Basis, which is a document that explains the terms of the permit and is made available during the public notice, affected state review, and EPA review periods.

Tab Title: SOP - PN

Tab Content:

· The reviewer also develops the Public Notice package, which is sent to the applicant along with the Working Draft Permit and Statement of Basis.

· The Public Notice package provides information regarding the applicant's responsibilities in publishing the notice. The permit reviewer must verify that the notice was published correctly.

· The affected state review period and EPA review period are generally concurrent with the public comment period.

· The permit reviewer must develop a response to all comments submitted and revise the permit, if necessary.

· If comments are submitted on a permit or if a hearing is requested, the EPA review period will be extended to allow EPA the opportunity to review the comments submitted, the response to comments, and any corresponding changes to the draft permit.

· The permit reviewer must address any comments identified by the EPA and finalize the permit.

· Upon issuance, a federal operating permit is subject to a 60-day petition period, during which time a person can petition the EPA to object to the permit.


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