Preparing a Part 75 Petition What is a petition under 40 CFR part 75? Under § 75.66, a designated representative for an affected unit may request for the Administrator (in this case, the Administrator's designee) to exercise his or her discretion to approve an alternative to any requirement prescribed in or incorporated by reference in 40 CFR part 75. What are the general contents of a complete petition? • Typical minimum general contents as provided in § 75.66(1): o Identification of the affected plant and unit(s); o A detailed explanation of why the proposed alternative is being suggested in lieu of the requirement prescribed in part 75; o A description and diagram of any equipment and procedures used in the proposed alternative, if applicable; o A demonstration that the proposed alternative is consistent with the purposes of the requirement for which the alternative is proposed and is consistent with the purposes of part 75 and of Clean Air Act § 412 and that any adverse effect of approving such alternative will be de minimis; and o Any other relevant information that the Administrator may require (see typical specific items below). • The certification statements from § 72.21 (required by § 75.66(a) for every petition). What specific items should I identify or include in the petition? • Clearly identify the facility name, ORIS code, location (i.e., street address), and unit ID(s) • List applicable programs that require part 75 monitoring (e.g., ARP, CSAPR) • Include generator nameplate and design heat input of the unit(s) • Include facility description and process diagram, if necessary • The name, phone number, and e-mail address of the facility's technical lead • All supporting data such as: o Fuel sample data (if applicable) o Photocopies of maintenance logs ------- o Graphs and charts o Calibration sheets for fuel flow monitors • A copy of the latest operating permit • Updated monitoring plan (This is very important) What are the certification statements in § 72.21? • lam authorized to make this submission on behalf of the owners and operators of the source or units for which the submission is made. • I certify under penalty of law that I have personally examined, and am familiar with, the statements and information submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment. ------- Who must sign the petition? • The Designated Representative; or • The Alternate Designated Representative. To whom do I address it? Reid P. Harvey, Director Clean Air Markets Division U.S. EPA Where do I send it? Please send an electronic copy of the petition by email to: CAMDpetitions@epa,gov A hard copy of the petition is not necessary, but if you wish to send one, please address it to the following: How do I start preparing it? • Contact the CAMP analyst for your EPA region. Talk it over and make sure that a petition is necessary before you send one. Also, if you still want to petition, ask the analyst if CAMD has ever granted or denied a petition for a similar request. • In addition, you can check the previous petition responses on the CAMD website at: Courier Delivery Regular or Certified Mail U.S. EPA Clean Air Markets Division Attn: Charlie Frushour 1201 Constitution Avenue, NW U.S. EPA Clean Air Markets Division Attn: Charlie Frushour 1200 Pennsylvania Avenue, NW Mail Code 6204M Washington, DC 20460 WJC-East Room 7334H Washington, DC 20004 https://www.epa.gov/airmarkets/part~75~petition~responses • CAMD prioritizes petitions that are complete, that concern situations similar to situations in previous petitions, and that seek the same relief previously granted. ------- |