South Dakota Department of Environment & Natural Resources (DENR)
Title V Program Review
Conducted by
United States Environmental Protection Agency (USEPA)
Region 8
September 2015
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TABLE OF CONTENTS
EXECUTIVE SUMMARY *
INTRODUCTION 1
OBJECTIVE OF THE PROGRAM REVIEW 1
PROGRAM REVIEW PROCESS 1
PROGRAM REVIEW PROCEDURE 2
FOLLOW-UP TO SECOND ROUND REVIEW 3
THIRD ROUND REVIEW'S FINDINGS AND COMMENTS 3
DENR ORGANIZATION AND STAFFING 4
TRAINING 5
FEE AUDIT 5
CONCLUSION 5
ATTACHMENT 1: TITLE V THIRD ROUND STATE PROGRAM REVIEW
QUESTIONNAIRE AND RESPONSES BY DENR
ATTACHMENT 2: STATE/LOCAL TITLE V PROGRAM FISCAL TRACKING
EVALUATION QUESTIONNAIRE AND DENR RESPONSES
ATTACHMENT 3: SOUTH DAKOTA AIR PERMITTING SECTION ORGANIZATION
CHART
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Executive Summary
In February 2015, the United States Environmental Protection Agency (EPA) conducted the third
round review of the South Dakota Department of Environment & Natural Resources' (DENR)
Title V operating permits program. This review was accomplished via a conference call with
DENR as opposed to the site visits conducted during the first two reviews. The first round of the
program review was conducted in fiscal year 2006. EPA issued the final report for the first
round in September 2006. The second round review was conducted in fiscal year 2012. EPA
issued the final report for the second round in December 2012. The third round evaluation (like
the previous evaluations) consisted of a discussion of DENR's responses to the program
evaluation questionnaire. The questionnaire was developed during the second review and
revised slightly for the third round (the first round questionnaire was more expansive than the
second and subsequent third round evaluation questionnaires). The evaluation also consisted of a
Title V program fee audit questionnaire.
The goal of the third round evaluation was to review any concerns raised by DENR or EPA in
the prior evaluation (second round), to determine how any unaddressed concerns might be
addressed, to identify any good practices developed by DENR that may benefit other permitting
authorities and EPA, document any areas needing improvement, and learn what assistance EPA
can provide.
EPA Concerns from the Second Round Evaluation:
Public Participation - EPA recommended that DENR include language indicating the date of the
last day comments will be accepted in its public notices. The EPA believed this would avert
potential issues if DENR made it clear that public comment periods end on a date certain. The
DENR clarified the issue by explaining that South Dakota's newspapers vary on publication
dates and may not publish on the days requested by DENR resulting in multiple public comment
periods. The DENR now updates its website to reflect the public notice end date to help relieve
the confusion. Since 2012, the DENR has also included the webpage link that provides the
closure date on public notices currently printed in the local papers. A brief review of the notices
indicated that some of the public notices are released without the link. The DENR is aware of
this and is correcting the notices as they arise.
Permit Format - EPA recommended that DENR format permits for large facilities with several
large emitting units be more reviewer-friendly, particularly for average citizens without formal
training in the technical field. For example, large units could be reviewed for all pollutants at
one section of the permit to prevent untrained reviewers from having to search for specific
pollutant emission limits for a particular unit throughout the permit. The DENR stated that this
comment revolved around the Hyperion Energy Center's Prevention of Significant Deterioration
permit and the "form letter" comments DENR received during those public notice periods. The
DENR does sympathize with the difficulty in understanding an air quality permit, especially in
this case where they are dealing with a large complicated facility. Since 2012, the DENR has
continuously attempted to improve the permit program and Statement of Basis to enhance the
public's ability to understand the process. An example of one such improvement involves permit
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conditions related to the federal requirements. Instead of having emission limits, recordkeeping,
reporting, etc. located with state limits, the DENR has combined the federal requirements in their
separate chapters. DENR also prepares a "statement of basis" which explains which state and federal
rules are applicable and how compliance will be determined. DENR believes the statement of basis
and recent changes to the air quality permit results in a permit both the facility and public can
understand. It is also worth noting that there has been no public comments on this issue since it
was first raised during the Hyperion Energy Center's Prevention of Significant Deterioration
permit.
Inclusion of Underlying Applicable Construction Permit Requirements in Title V Permits — The
EPA recommended that DENR include all applicable construction permit requirements into Title
V permits whenever the Title V permits are issued. This issue was highlighted because of the
past practice, allowed by ARSD 74:36:05:02, to use Title V permits in-lieu of a construction
permit. The EPA believed that the new construction permit chapter 74:36:20 would resolve this
issue. In 2010 the DENR did modify the permitting process to require construction permits as
requested by the EPA.
Need to Expand Review of Modified Permits - EPA recommended that DENR expand the scope
of review of a modification to other parts of the permit that may be indirectly affected by the
modification. For example, a source operates two units controlled by two separate bag houses
for Particulate Matter (PM) emissions and one of the units undergoes a modification (i.e.
increase in capacity resulting in corresponding increase in PM emissions). The source submits
an application for modification of the unit undergoing the expansion resulting in increased
capacity and DENR limits the review and comment to this unit only because it is the only unit
being modified. Although, this issue originates during underlying construction permit
modification, the EPA believed all the permit conditions related to the baghouses at the source
are subject to review including the baghouse for the unmodified unit. The DENR position was
that, for a modification, the DENR only opens for public comments existing permit conditions
being revised to reflect the modified operations and any new permit conditions added to the
existing permit. DENR limits the public comments just to what is being revised since the
unchanged existing permit conditions have already been through a public comment period.
DENR considered EPA's interpretation to be too broad and could be interpreted as having every
condition of the Title V permit continuously re-opened for comment during every modification
to the permit because they could be tied in some form or another to that modification. The source
being discussed (Pacer Corp. Permit No 28.1107-21) was appealed to the EPA's Administrator
on May 18, 2007, the Administrator has not taken any action. DENR has not modified their
process related to this concern. There have not been any additional public comments on this
issue since it was first raised during the Pacer Inc. permit.
Conclusions
DENR has provided all of the necessary information to EPA during this review and has
responded to issues raised by EPA. DENR's field experience and knowledge of air permitting
has assisted EPA in understanding the challenges faced by the state. No significant deficiencies
were noted during this review.
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Introduction
EPA conducted this program evaluation as part of its obligation to oversee and review state
programs that have been approved by EPA, and in response to recommendations from an audit
conducted in July 2002 by the Office of Inspector General.
The state of South Dakota operates a fully EPA approved program that allows it to implement
the requirements of Title V of the Clean Air Act (CAA), including the issuance of operating
permits. EPA has a statutory responsibility to oversee the programs it approved by performing
oversight duties, including occasional program reviews. Such responsibilities include overseeing
the activities of the State program to ensure that local, regional, and national environmental goals
and objectives meet minimum requirements outlined by the federal regulation.
Objective of the Program Review
Following the completion of the first and second round reviews for states in Region 8, EPA
nationally committed to a third round of reviews. While the questionnaire used for the first
round reviews was developed by a "national workgroup" for national consistency, the second
and third round review questionnaires were developed by the Regions to emphasize Regional
priorities that were identified during the first round reviews.
Region 8 consulted with other Regions about the approach and format of the questionnaire and
the extent of the follow-up review of state programs. Region 8 concluded that the follow-up
reviews do not need to be as extensive as the first round reviews, but should build on the findings
and recommendations of the first round review.
The main objectives of the third round reviews are to conduct a follow-up to the first and second
round reviews by: 1) ensuring that areas of concern identified by EPA during the first and second
rounds have been addressed or are being addressed satisfactory; 2) ensuring that the DENR
concerns have also been addressed or are being addressed to DENR's satisfaction; 3) identifying
and documenting new good practices that can benefit other permitting authorities; 4) identifying
and documenting areas of concerns that need improvement; and 5) getting feedback on how EPA
can be of service to the permitting authorities.
Program Review Process
In February 2015, the United States Environmental Protection Agency (EPA) conducted the third
round review of DENR's Title V operating permits program. This review was accomplished via
a conference call with DENR as opposed to the site visits conducted during the first two reviews.
The first round of the program review was conducted in fiscal year 2006. EPA issued the final
report for the first round in September 2006. The second round review was conducted in fiscal
year 2012. EPA issued the final report for the second round in December 2012.
The first round review was conducted in response to the 2002 Office of Inspector General audit
recommendations that EPA: examine ways it can improve permitting authorities' Title V
operating permit programs and expedite the permit issuance rate; note and document good
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practices which other agencies can learn from; assess deficiencies in the program; and to learn
how EPA can help the permitting authorities improve their overall program. In meeting these
goals, EPA developed a questionnaire that was sent to each permitting authority and followed up
with on-site visits to conduct interviews and file reviews. The findings of DENR Title V
operating permit program's review were outlined in the September 2006 final report with the
main categories as follows: a) Summary of Good Practices b) Recommended Improvements; and
c) Title V program Fee Audit.
The second round December 2012 final report focused primarily on: a) Recommended
Improvements; b) Second Round Findings and Comments; and c) Title V program Fee Audit.
The format of the third round review differed than the first two rounds. EPA provided a standard
Title V questionnaire (Attachment 1) and fiscal tracking questionnaire (Attachment 2) to DENR
as has been done in the previous two reviews. The EPA did not perform a site visit, but did
coordinate a conference call with the DENR.
As mentioned above, a separate questionnaire was provided by EPA to DENR for the Title V fee
audit (State/local Title V Program Fiscal Tracking Evaluation Document). The purpose of the fee
audit is to determine whether the following are satisfied:
• Sources are being billed in accordance with fee requirements and are paying the
required fees;
• Division of expenses is identified by DENR between Title V and non-Title V programs;
• Features are integrated into DENR's accounting/financial management system which will
identify Title V revenue and expenditures separate from other funding, and which certify
the disposition of Title V funds;
• Title V fees collected from sources are used by DENR to pay for the entire Title V
program; and
® No such fees are used as CAA Section 105 grant matching.
During the third round review, EPA found that DENR had addressed the major issues identified
by EPA as needing improvement during the first two reviews. The issues addressed included: a)
public notices b) permit formats c) inclusion of applicable construction permit requirements; and
d) expanded review of modifications.
Program Review Procedure
EPA sent the third round review questionnaire and the Title V fee audit questionnaire to DENR
on February 26, 2015. DENR submitted an electronic copy of the completed questionnaires to
EPA on April 7, 2015. After the review of DENR's responses to both the Title V program
review and Title V fee audit questionnaires, the final conference call was held on September 3,
2015.
During the final conference call, EPA's South Dakota Air Permit Coordinator (Robert Duraski)
spoke with DENR's staff. DENR's staff in attendance was Kyrik Rombough (Air permitting and
Enforcement Manager).
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During the conference call, EPA staff began the review by briefly stating that the purpose of the
review was to conduct a follow-up to the previous reviews. EPA informed DENR that EPA's
main objectives of conducting an on-going review of States' program are twofold. First, EPA
seeks to continue to effectively perform its regulatory oversight obligation under the Clean Air
Act. Second, EPA hopes such periodic reviews will improve communication and the
relationship between the agency and DENR and thus continue to improve state's Title V
operating program. EPA and DENR then discussed topics as listed in the follow-up
questionnaire.
Follow-up to Second Round Review
As described in the Executive Summary, all the following EPA recommendations made during
the second round review were resolved:
• Public Participation
• Permit Format
• Inclusion of Underlying Applicable Construction Permit Requirements in Title V Permits
• Need to Expand Review of Modified Permits
Third Round Review's Findings and Comments
• When reviewing DENR documents, it was noted that some of the public notices
published in the local papers were missing the link to the webpage that provides the
closure date for public comments. This was discussed with DENR and is being
corrected.
• The DENR's practice of assigning a new EPA Facility Wide ID Number, also called the
AFS number, to each new owner of a facility should be reconsidered. The AFS number
is plant specific and changing numbers with each new owner could lead to confusion.
For example, when responding to a FOIA request for a site's history, the AFS number is
a common search term.
• The DENR's reason for assigning a new number is that the public is not aware that other
companies previously owned both the facility and the AFS number and that violations
committed by previous owners do not reflect the current owner's operating practices.
This confusion can result in both the DENR spending excessive time explaining the issue
and the public being misinformed about a facilities' operating history. It must be noted
that the AFS number is not a mandatory entry in the AFS database. If an AFS number is
entered, the procedures in the AFS User's Guide AF3 AFS Data Storage Version 8.1
(EPA-456YB-95-001) should be followed.
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Issues affecting the Title V program that DENR considered particularly important.
DENR stated in the questionnaire that:
"DENR is still concerned with the process EPA developed for finalizing Title V air
quality operating permits. EPA allows individuals to submit comments on a Title V
air quality operating permit during the state's public comment period and does not
require that individual to exhaust the state's permitting process before being allowed
to petition EPA on a Title V air quality operating permit. This allows individuals to
bypass the state's process which are designed to give the public an opportunity to
revise draft Title V air quality operating permits they are concerned about.
For the petitions in South Dakota, the individuals are simply repeating objections
made during the comment period in their EPA petitions. In a February 18, 2005
decision, the Environmental Appeals Board for the United States Environmental
Protection Agency denied a petition for this same reason by a facility petitioning its
Title V air quality operating permit issued by EPA (i.e., Peabody Western Coal
Company CAA Appeal No. 04-01). This same logic should hold true for individuals
petitioning Title V air quality operating permits.
By requiring the individual to exhaust the state's permitting process before being
allowed to petition EPA on a Title V air quality operating permit will reduce the
state's and EPA's workload because it would eliminate frivolous petitions.
Another EPA process that can be improved upon is EPA's 45-day review period. EPA
does not have the resources to review every Title V air quality operating permit
during its 45-day review period and must pick and choose which ones to review. The
proposed permits not reviewed are essentially allowed to sit on EPA's desk until the
45-day review period ends. This process can delay economic development in a state.
Therefore, DENR recommends that EPA develop a process in which if it decides a
proposed permit will not be reviewed, EPA should notify the state there are no issues
and allow the state to issue the Title V air quality operating permit. "
If the DENR wishes to accelerate a 45 day review, they can contact the EPA and request the
permit become a high priority. The other issues, while valid, will likely require a change in the
applicable federal rule.
Permit issuance
The following data was provided by the DENR on the questionnaire.
Percent of Title V initial permits issued within the regulatory timeframe specified in 40 CFR
70.7(a)(2)- DENR reviewed the time frame from 2010 to 2014 to respond to this question. During
that time frame DENR issued three initial Title V air quality operating permits. All three (i.e., 100%)
were issued within the regulatory timeframe specified in 40 CFR 70.7(a)(2).
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Percent of Title V significant permit modifications issued within the regulatory timeframe
specified in 40 CFR 70.7(a)(2) and (e)(4)(h)- DENR reviewed the time frame from 2010 to 2014
to respond to this question. During that time frame DENR issued 26 significant permit
modifications (i.e., modification) for Title V air quality operating permits. Twenty-four of the 26
or 92% were issued within 9 months of a complete application as specified in 40 CFR
70.7(e)(4)(h). Therefore, a majority were issued within 9 months of a complete application. Of
the remaining two, both were issued with 18 months of a complete application which is in
compliance with 40 CFR 70.7(a)(2).
Percent of Title V permits expire before they can be renewed- From 2010 through 2014, there
were 85 Title V air quality operating permits up for renewal. Of those 85, 76 or 89% were
renewed within the time frame specified in 40 CFR 70.7(a)(2).
DENR Organization and Staffing
The DENR is currently fully staffed. There is a challenge with the high employee turnover rate.
In the last three years the DNER has had to replace four of their six permit engineers. The
current DENR organization chart is provided as Attachment 3.
Training
The DENR stated in their questionnaire that currently, the available training has been sufficient.
However, EPA should continue to provide funding to WESTAR for training and training through
the long distance learning network.
Fee Audit
EPA did not conduct a formal Title V operating permit fee audit during the first round review. A
fee audit was conducted during the second round review. A fee questionnaire was submitted
during the third round, but no audit was performed. In the fee questionnaire, DENR noted their
concern regarding the state's sole coal fired power plant (Big Stone) could be shut down under
the Clean Power Plan. This plant pays an annual fee of $220,000 to the Title V program, which
is 40% to 50% of the DENR's revenue from Title V fees. Should this plant close, there could be
insufficient funding in the future. The fee review indicates DENR's is currently meeting the fee
requirements of Part 70.
Conclusion
In conclusion, DENR implements an effective Title V program that continues to evolve as
challenges arise. DENR continues to communicate with EPA staff to address issues in proposed
permits. The Title Y fee review demonstrates DENR's ability to continue to operate a program
that meets the fee requirements of Part 70. DENR has provided all of the necessary information
to EPA during these reviews and has discussed issues raised by EPA. DENR's Title V program
continues to meet the requirements of the Part 70 regulations. No significant deficiencies were
noted during this review.
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Attachment 1
Title V Third Round State Program Review Questionnaire and Responses by DENR
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Title V Third Round State Program Review Questionnaire
I. General Questions and Responses to First and Second Round Program
Reviews
A. What has been done in response to EPA recommendations for
improvements from the second round program review?
EPA Region VIII conducted the second round of South Dakota's Title V air
quality operating permit program review in 2009. DENR received EPA s final
report on December 26, 2012. EPA provided five recommendations EPA
believes will improve DENR's Title V air quality permit program. The
following are EPA's recommendation and what DENR has implemented to
improve its Title V air quality operating permit program:
1. Continue to improve public participation by specifically noting in public
notices when the public comment period ends.
DENR provides the public with several avenues for the public to
participate in the public comment period. Those avenues depend on the
type of permit.
For an individual permit, the first method is the method DENR has used
since DENR took over the Air Quality Program from EPA and involves
publishing a public notice in a local newspaper where the facility is
located. The public notice identifies the public has 30 days from the date
the public notice is published to submit comments on DENR s draft
permit. In addition to placing the public notice in the local newspaper,
DENR places a copy of the statement of basis (i.e., DENR's review of the
facility's application), public notice, and draft permit on its website and
solicits comments from the public. Since there is no publication date, the
website identifies the date comments need to be submitted. In both cases,
the public is given two options. First the public can submit comments
electronically or through the mail on the draft permit. In this case, DENR
would respond to the comments and change the draft permit if appropriate.
If the individual that commented was not satisfied with DENR's response,
the individual has the ability to request a contested case hearing in front of
the Board of Minerals and Environment. In the second option, the public
can simply request a contested case hearing in front of the Board of
Minerals and Environment. DENR believes its public participation process
provides the public with every opportunity to provide comments on
DENR's draft permits.
For a general permit, the public participation process is similar to the
individual permit with two exceptions. First, since a general permit covers
that industry statewide, state law requires the public notice to be published
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in at least three newspapers. DENR exceeds this requirement by
publishing the general permits in South Dakota's 11 daily newspapers.
Second, DENR is required to submit the public notice to county officials,
city officials, and tribal officials on a general permit.
2. Continue to improve permit format to make the permits more
understandable for reviewers, particularly interested citizens.
DENR continues to strive to make its air quality permits understandable
and easy to understand by both the public and the individuals complying
with the permits. The most recent change involves the permit conditions
related to the federal requirements. Instead of having emission limits,
recordkeeping, reporting, etc. located with state emission limits,
recordkeeping, reporting, etc., DENR has combined the federal
requirements in their separate chapters. Essentially a chapter for each
federal rule the facility is applicable to. DENR also writes what is called a
"statement of basis" which is a narrative about the facility, what state and
federal rules are applicable, how compliance will be determined, etc.
DENR believes the statement of basis and recent changes to the air quality
permit result in a permit both the facility and public can understand. Even
with that DENR is always striving to make its permits better and will
make changes when appropriate.
3. Continue to ensure that all underlying applicable requirements are
included in Title Vpermits that are being used as construction permits
When EPA conducted this review, DENR's Title V air quality operating
permit was both a construction permit and an operating permit. Since then,
DENR has developed a separate air quality construction permit for new
facilities and existing facilities modifying their operations and not subject
to the Prevention of Significant Deterioration preconstruction permit
program. Once the facility completes construction, they have one year
from initial startup to submit an application for an operating permit. The
requirements in the construction permit are then incorporated in the
operating permit. This process ensures requirements in the construction
permit are incorporated in the operating permit and if not, the statement of
basis identifies the reason for not including the requirement. In this case,
the construction permit is modified at the same time the operating permit
is issued and follows the same permitting process which includes an
opportunity for public comment before the permits are issued.
4. Continue to expand review of modified permits to other parts of the permit
that may be indirectly impacted by the modification.
DENR's statement of basis identifies all applicable changes that need to
be made to a permit when a modification is requested by the facility.
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5. Continue to improve the accounting system for demonstration of
appropriate use of Title V fees for the Title Vprogram implementation
only.
DENR strives to accurately track the Title V air quality operating permit
program fees to ensure the fees collected cover the expenses related to the
program.
DENR has several checks and balances in its accounting system. For the
collection of fees, the air quality program obtains the operational data
from each Title V facility, calculates the annual air emission fee, and
submits a bill to the facility. The facility submits the payment to South _
Dakota's Department of Revenue, which in turn informs both DENR's air
quality program and DENR's Division of Financial and Technical
Assistance on how much was received and by who. DENR's air quality
program reviews to make sure what was billed matches what was
received.
For the tracking of expenses, DENR uses a computerized timekeeping
system. In the timekeeping system, the air quality program has generic
funding sources identified (e.g. Title V fees, air grants). The air quality
program identifies the number of hours each days spent on a project
covered under one of the funding sources. Twice a month, the supervisor
of the program reviews and signs off on information in the time keeping
system.
DENR's Division of Financial and Technical Assistance tracks both fees
collected and expenses. This division provides the air quality program
with a monthly summary of the air quality programs funding sources,
which the air quality program then checks for accuracy.
B. What key EPA comments on individual Title V permits remain
unresolved (EPA to determine this)? What is the State's position on these
unresolved comments?
DENR is not aware of any unresolved issues related to EPA's comments on
individual Title V air quality operating permits, except for those Title V air
quality operating permits environmental groups submitted petitions on and are
unresolved. There are three Title V air quality operating permits that have
been petitioned and unresolved. The following is a list of the facilities
associated with the petition and DENR's status of the permits that were
petitioned:
1. Pacer Corporation - White Bear Mica Plant: DENR revised the Title V air
quality operating permit six times without any additional petitions and
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renewed the Title V air quality operating permit on February 2, 2010. The
renewal went through the appropriate permitting process for a Title V air
quality operating permit without another petition. Therefore, DENR
recommends EPA close this case.
2. American Colloid Company - Belle Fourche: DENR revised the Title V
air quality operating permit eight times without any additional petitions.
On February 3, 2011, American Colloid Company reduced its operations
and was issued a minor air quality operating permit. Therefore, DENR
recommends EPA close this case.
3. Otter Tail Power Company - Big Stone: The petition was related to permit
conditions in the Title V air quality operating permit which were related to
the Prevention of Significant Deterioration preconstruction permit issued
for Big Stone II. Since Otter Tail Power Company elected not to build Big
Stone II, the permit conditions in the Title V air quality operating permit
are essentially null and void since Otter Tail Power Company is no^ longer
authorized to construct or operate the equipment associated with Big Stone
II. DENR is currently in the process of reviewing Otter Tail Power
Company's application to renew its Title V air quality operating permit
and those permit conditions will be removed. Therefore, DENR
recommends EPA close this case.
C. Have any procedures in Title V changed (e.g., public participation,
petitions, communication with EPA) since the second round program
review?
No changes to the procedures related to the Title V air quality operating
permit program has changed since the second round program review.
Originally, South Dakota's Title V air quality permitting program was a
combined construction and operating permit program. In 2010, South Dakota
developed an independent construction permit program. Therefore, the
construction permit activities are included into the Title V air quality permit at
a later date.
1. If so, which ones?
Not applicable.
D. What does the state think it's doing especially well in the Title V
program?
DENR believes its statement of basis, which is a written narrative review of
the facility's application, helps the facility and the public understand what
state and federal rules are applicable to the facility, how DENR determined
the facility is currently in compliance with the requirements, and how the
facility will demonstrate compliance in the future. In addition, the changes to
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the permit format will also make it easier for the facility and the public to
determine which are state and federal requirements in the permit which will
make it easier for both to determine if the facility is in compliance with those
permit conditions.
DENR is also developing templates for each federal regulation under the New
Source Performance Standards and Maximum Achievable Control
Technology Standards. Each template identifies what the criteria are for using
the template. This has helped speed up the process in drafting a permit since
the permit conditions are already written and all the permit writer has to do is
ensure the criteria is met and then cut and paste the permit conditions in the
draft permit.
E. Are there any issues affecting the Title V program in your state right now
that you consider particularly important?
DENR is still concerned with the process EPA developed for finalizing Title
V air quality operating permits. EPA allows individuals to submit comments
on a Title V air quality operating permit during the state's public comment
period and does not require that individual to exhaust the state s permitting
process before being allowed to petition EPA on a Title V air quality
operating permit. This allows individuals to bypass the state s process which
are designed to give the public an opportunity to revise draft Title V air
quality operating permits they are concerned about.
For the petitions in South Dakota, the individuals are simply repeating
objections made during the comment period in their EPA petitions. In a
February 18, 2005 decision, the Environmental Appeals Board for the United
States Environmental Protection Agency denied a petition for this same reason
by a facility petitioning its Title V air quality operating permit issued by EPA
(i.e., Peabody Western Coal Company CAA Appeal No. 04-01). This same
logic should hold true for individuals petitioning Title V air quality operating
permits.
By requiring the individual to exhaust the state's permitting process before
being allowed to petition EPA on a Title V air quality operating permit will
reduce the state's and EPA's workload because it would eliminate frivolous
petitions.
Another EPA process that can be improved upon is EPA's 45-day review
period. EPA does not have the resources to review every Title V air quality
operating permit during its 45-day review period and must pick and choose
which ones to review. The proposed permits not reviewed are essentially
allowed to sit on EPA's desk until the 45-day review period ends. This
process can delay economic development in a state. Therefore, DENR
recommends that EPA develop a process in which if it decides a proposed
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permit will not be reviewed, EPA should notify the state there are no issues
and allow the state to issue the Title V air quality operating permit.
1. Which one would you rate as the most important?
They are all equally important. Each of these topics requires significant
resources for South Dakota's small program and its limited resources.
DENR would like to see EPA initiate a policy in which they notify states
that they can issue a Title V air quality permit prior to the end of the 45-
day review period if EPA is not going to review it or object to its issuance.
DENR would also like EPA to maintain an open mind and dialogue as
DENR reviews and tries to streamline its permitting programs.
2. Are there any EPA policies or regulatory issues that are causing
concern?
See above.
3. How can EPA help?
See above.
II. Permit Issuance
A. Since the second round program review, what percent of Title V initial
permits have you issued within the regulatory timeframe specified in
40 CFR 70.7(a)(2)?
DENR reviewed the time frame from 2010 to 2014 to respond to this question.
During that time frame DENR issued three initial Title V air quality operating
permits. All three (i.e., 100%) were issued within the regulatory timeframe
specified in 40 CFR 70.7(a)(2).
B. Since the second round program review, what percent of Title V
significant permit modifications have you issued within the regulatory
timeframe specified in 40 CFR 70.7(a)(2) and (e)(4)(ii)?
DENR reviewed the time frame from 2010 to 2014 to respond to this question.
During that time frame DENR issued 26 significant permit modifications (i.e.,
modification) for Title V air quality operating permits. Twenty-four of the 26
or 92% were issued within 9 months of a complete application as specified in
40 CFR 70.7(e)(4)(ii). Therefore, a majority were issued within 9 months of a
complete application. Of the remaining two, both were issued with 18 months
of a complete application which is in compliance with 40 CFR 70.7(a)(2).
-------
C. What percent of Title V permits expire before they can be renewed?
DENR does not understand the relevance of this question. The federal rule
along with the state requires a Title V facility to submit its renewal application
at least 6 months prior to its expiration, and gives DENR 18 months to renew
the application. Based on this timeline, DENR prioritizes its application to
ensure new facilities and modifications to existing facilities have the highest
priority since the facility that is renewing its operating permit already has an
permit in place to ensure South Dakota is able to maintain its attainment status
for all National Ambient Air Quality Standards.
From 2010 through 2014, there were 85 Title V air quality operating permits
up for renewal. Of those 85, 76 or 89% were renewed within the time frame
specified in 40 CFR 70.7(a)(2).
1. For those permits that could not be renewed before they expired, what
are the reasons they could not be renewed prior to their expiration?
Of the nine facilities that DENR has not met the deadline, 2 have been
issued and one is in EPA's hands under its 45-day review period. The
other six are being worked on but again, the highest priority for DENR is
working on new facilities and modifications to existing facilities because
facilities with expired operating permits still have permits they need to
comply with provided the applications were submitted in a timely manner.
As demonstrated in subsection "A" and "B" of this section, DENR is
getting these application processed in a timely manner.
Probably the biggest reason for not processing these applications in a
timely manner relates to turnover. DENR in the last three years has
replaced four permit engineers, one of which has already resigned and
DENR is in the process of replacing. The fact that the permit engineers
they replaced were not here that long either compounds the problem
because it takes time to get them trained and able to review facilities with
Title V air quality operating permits.
D. Have unresolved violations created any delay in issuing Title V renewals?
No
E. Have permittees requested a hold in renewal for any reason?
No
-------
F. CAM
1. Are CAM plan requirements slowing the renewal process?
No
a. If so, what is it about CAM that's problematic?
Not applicable
2. Where CAM plans have been inadequate, what have been the main
types of inadequacies that have caused difficulties or delays in permit
issuance?
DENR has not observed any issues with inadequate Compliance
Assurance Monitoring plans.
3. What difficulties have you had in getting better plans to be
submitted?
DENR has not had any issues with Compliance Assurance Monitoring
plans.
4. Have you had to supplement the CAM technical guidance document
(TGD) with state-issued guidance?
No
5. Is CAM training adequate?
Yes
6. Are CAM applicability determinations resource-intensive or difficult?
DENR has not had any issues with Compliance Assurance Monitoring
plans because very few sources require Compliance Assurance Monitoring
plans and the majority that do are subject to a New Source Performance
Plan or Maximum Achievable Control Technology Standard that already
has the Compliance Assurance Monitoring plan requirements in the
federal rule.
-------
G. What improvements does the State believe it has made to the
management of the Title V permit program, since the second round
program review, that could be described as best practices and could be of
interest to other States?
When a facility is subject to a federal rule, DENR does not reference the
federal rule in the Title V air quality operating permit because it makes it
difficult for inspectors and the facility to determine compliance since the
federal rules are complicated with a variety of options for demonstrating
compliance.
DENR has implemented a process of developing templates for each federal
rule to speed up the permitting process. The difficulty with this is the federal
rules are complicated with multiple scenarios in which the permit conditions
related to the rule can be written. In addition, some of the federal rules are
changed frequently which requires the template to be revised. Even though
these are issues, the templates are helping speed up the process for several
reasons. First the permit writer does not have to write permit conditions; the
permit writer just has to cut and paste the correct template in the draft permit.
Second, DENR always has another more experienced individual review the
draft permit and if the template has already been approved, all the individual
has to do is make sure the correct template is used. Using the templates has
also resulted in the permit engineers being consistent with the permit
requirements.
H. What improvements does the state plan to make, if any, in the
management of the Title V permit program within the next five years?
DENR is not anticipating any changes but is always looking for ways to
improve the Title V air quality operating permit program.
1. Does the state have a set period of time for planning cycles?
No
Public Participation
A. What forms of news media do you use to maximize public participation,
for implementation of 40 CFR 70.7(h)?
DENR uses both the normal form of public notice which is a local newspaper
in the county seat in which the facility is located and each public notice is
posted on DENR's website. In fact, all environmental public notices have
been centralized to provide the public one location to find all public notices
dealing with all environmental media.
-------
1. How is the form of media chosen?
DENR uses both forms no matter the situation.
2. How do you believe public participation should be improved?
DENR believes the federal process for public participating should be
improved by requiring those that wish to petition EPA on the issuance of a
Title V air quality operating permit to first exhaust all of the state's
options for public participation (i.e., comment during the public notice
period and contest the draft permit in front of the Board of Minerals in
Environment or whatever process each state has for providing public
participation) before they are allowed to petition EPA to not issue the Title
V air quality operating permit.
DENR goes through a lot of work with the public and the facility to come
up with creative solutions that work for both parties and are within the
boundaries of the state and federal regulations. However, in some cases
there are individuals that are not satisfied with the results and the state has
a process in which they can take it in front of the Board of Minerals and
Environment to get their issues heard and possibly resolved. These
individuals should be required to go through this process before being
allowed to petition EPA.
B. Do you have a mailing list for Title V public participation for
implementation of 40 CFR 70.7(h)(1)? If so, please provide it.
DENR has not received much interest in individuals wanting to be on a list to
receive all public notices. They are occasionally specific requests for certain
type of facility in a certain area. Probably one of the main reasons for the lack
of interest is more individuals are using internet to view public notices. DENR
has established the capability for individuals to be alerted to public notices
posted on DENR's webpage.
C. Is there a policy which outlines the response to comments procedure or
process, such as which comments are responded to, the time-frame for
responding, how the permitting authority will respond, to whom, etc.?
DENR's procedures for responding to comments are outlined in DENR's
regulations at ARSD 74:36:05:18 through 74:36:05:20.01.
1. If written, can you provide a copy? If not written, could you describe
the policy?
EPA has a copy of this already since DENR submitted as part of the
package for EPA's approval of DENR's Title V air quality operating
-------
permit program. However, if EPA cannot find the rules they are out on our
webpage at: http://legis.sd.gov/rules/DisplavRule.aspx?Rule=74:36:05
IV. Petitions
A. Since the second round program review, to what extent have Title V
petitions:
1. Changed how permits are written;
DENR has not had a petition in the 2010 through 2014 timeframe.
2. Resulted in re-openings of other permits;
DENR has not had a petition in the 2010 through 2014 timeframe.
3. Resulted in an amended permitting process, to address any issues
settled through petitions granted in full or in part?
DENR has not had a petition in the 2010 through 2014 timeframe.
V. EPA Relationship
A. Is there any EPA policy, on Title V, that is causing problems or
Confusion?
NOTE: Answer may or may not be the same as I.E.2.
The only issue DENR has with EPA's policies is when EPA considers them
equivalent to federal regulations.
B. Has the state developed any tools, strategies, or best practices that have
assisted in the inclusion of MACT subparts in Title V permits?
As stated earlier, DENR is developing templates for MACT subparts and in
some cases there are several templates for a subpart. This has helped speed up
the process and provided consistent permit conditions throughout the state.
C. Is the issue of startup-shutdown-malfunction (SSM) emissions causing
problems or confusion in Title V permit writing?
No, South Dakota has not had issues with startup-shutdown-malfunction
emissions in its Title V air quality permits. The only issue related to startup-
shutdown-malfunction is in the development of the emission limit for a certain
unit. As noted in DENR's comments on EPA's SIP call on South Dakota's
opacity exceptions for the startup, shutdown, and malfunctions, the state
-------
emission limits were based on the unit operating during normal operations;
not during startup-shutdown-mal functions. Therefore, EPA cannot just
arbitrarily assume that a unit may comply with the limit during these periods
and should not try to resolve these issues through the Title V permitting
program. Granted, there are certain units in which startup and shutdown do
not impact the emission rate and the unit should be able to meet the emissions
limit during this type of operation. But it is unrealistic to assume a unit can
meet the emission limit during a malfunction.
When EPA develops emission limits under the New Source Performance
Standards and Maximum Achievable Control Technology Standards, EPA
needs to start taking this into account and have emission limits for normal
operations and emission limits for startup and shutdown and need be
malfunctions and develop testing methods that can provide accurate
information during these types of operations for determining compliance.
These startup, shutdown, and malfunction issues should be brought up during
the development or revision of these rules and not during periods when the
rules are being incorporated into a Title V air quality permit program.
1. Has the state developed any tools, strategies, or best practices that
have alleviated problems or confusion if either exist?
No, South Dakota includes the regulations as they currently exist into the
Title V air quality permit.
D. Do you have any unaddressed training needs? What can EPA do to help?
No. Continue to provide funding to organizations like WESTAR for training
purposes.
-------
Attachment 2
State/local Title V Program Fiscal Tracking Evaluation Questionnaire and
Responses
-------
State/local Title V Program Fiscal Tracking Evaluation Document September 2,2015
Basic Questions for All
Permitting Authorities
More Detailed Questions — Factors to Support a Permitting Authority's Answer to the
Basic Questions
(Note: these are not all-inclusive, and some ideas will not apply in all cases)
Possible Resources
Available
1. Title V Fee Revenue
Can the Permitting
Authority show that
sources are being billed in
accordance with its fee
requirement(s), and that
sources are paying fees as
required?
Where are the fee collection authority and the fee rate(s) specified? Is the Permitting
Authority including reference to these fee requirements in its Title V permits?
Statutory authority is provided in South Dakota Codified Laws:
§34A-l-58
(http://le2is.sd.eov/Statutes/C0dified Laws/DisDlavStatute.aspx?TvDe=Statute&Statute=34A-
Req's/Auth.: State/local
Title V program
legislation & regulations
Permit refs: Permits
state has
written/submitted to
EPA
Fee Rate(s): State/local
Title V program
submittal, and then
verify w/ Permitting
Authority that info is
up-to-date
Billing/Payments:
Permitting Authority
records. Emission data
may be in AIRS. If
some fees are hourly,
there should be some
direct labor tracking
mechanism (see
accounting system,
below).
1-58") and
§34A-1-58.1
(http://le2is.sd.gov/Statutes/C0difIed Laws/DisDlavStatute.aspx?Tvpe=Statute&Statute=34A-
1-58.1).
Administrative authority is provided in ARSD Chapter 74:37:01 - Air Emission Fees
fhttD://legis.sd.2Ov/rules/DisplavRule.asDX?Rule=74:37:01).
Each Title V air quality operating permit has the following requirements as general permit
conditions:
2.0 Permit Fees
2.1 Annual air fee reauired
In accordance with ARSD 74:36:05:06.01, the owner or operator shall submit an annual
administrative fee and an annual fee. The fee is based on actual emissions in accordance with
ARSD 74:37.
If this is for an ethanol plant, use this language instead:
In accordance with ARSD 74:36:05:06.01, the owner or operator shall submit an annual
administrative fee and an annual fee. The fee is based on actual emissions in accordance with
SDCL 34A-1-58.1.
2.2 Annual operational report
In accordance with ARSD 74:37:01:06, the Secretary will supply the owner or operator with
an annual operational report in January of each year. The owner or operator shall complete
and submit the operational report to the Secretary by March 1 of each year. The responsible
-------
1. Title V Fee Revenue - Continued _ —
official shall sign the operational report in the presence of a notary public.
If this is for an ethanol plant, use this language instead:
In accordance with SDCL 34A-1-58.1, the Secretary will supply the owner or operator with
an annual operational report in January of each year. The owner or operator shall complete
and submit the operational report to the Secretary by March 1 of each year. The responsible
official shall sign the operational report in the presence of a notary public.
2.3 Annual air fee
In accordance with ARSD 74:37:01:08, the Secretary will notify the owner or operator of the
required annual air emission fee and administrative fee by June 1 of each year. The fees shall
accrue on July 1 and are payable to the Department of Revenue by July 31 of each year.
If this is for an ethanol plant, use this language instead:
In accordance with SDCL 34A-1-58.1, the Secretary will notify the owner or operator of the
required annual air emission fee and administrative fee by June 1 of each year. The fees shall
accrue on July 1 and are payable to the Department of Revenue by July 31 of each year.
List the fee rate(s) formulae applicable for the time period being reviewed. (Include emission
based fees, application fees, hourly processing fees, etc.)
Ethanol facilities pay the following:
• One-time $ 1,000 application fee for new ethanol facilities; and
• Annual fee of $1,000 administrative fee plus $40 per ton of actual air emissions from
the previous year.
Coal-fired power plants (Big Stone):
• Flat fee of $220,000.
Other Title V air quality facilities pay the following:
® Application fee for new sources, modifications and renewals pay an application fee of
$125;
• Annual administrative and $ per ton fee based on actual emissions from the previous
year:
1. Administrative fee consists of $125 for actual emission less than 50 tons per year,
$600 for actual emission between 50 and less than 100 tons per year, and $1,000
for actual emission 100 tons per year or more;
2. $7.50 per ton of actual emissions; and
3. Minimum annual fee of $250.
-------
1. Title V Fee Revenue - Continued
® Rock crashers are permitted separately and pay a flat fee of $400
• Asphalt plants are permitted separately and pay a flat fee of $300
Does the Permitting Authority anticipate any significant changes to its fee structure?
Only if EPA's Clean Power Plan shuts down South Dakota's one coal-fired power plant.
What is the current status in States/locals with requirements to balance income &
expenditures of the Title V program annually (i.e., must rebate any overage of fees, etc.)?
Not an issue.
Examine documentation of how the annual fees for sources are determined. Audit several
sources' bills for accuracy.
« Are appropriate (actual or potential) emission records used for $/ton based fees? How
are the Permitting Authority and its sources determining actual emissions for fee
purposes?
As stated in permit condition 2.2 of every Title V air quality operating permit, the permit
holder is required to submit an annual operational report which contains all of the information
DENR needs to calculate actual air emissions.
• Are records kept (and used) for any hourly based fees?
The operational reports and spreadsheets DENR produces for calculating air emissions are
maintained electronically.
• Review similar documentation for other types of fee mechanisms.
Not applicable
Billing...
• How is the Permitting Authority notifying sources of the fees owed and due dates for
payment?
Around May of each year, the amount of air fees (billing) is sent to each facility and the
billing notifies them they have to pay the air fee by July 31 of each year.
-------
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2. Title V Expenditures - Continued
Ensure that accounting system is set up to utilize the various coding information.
® Analyze time sheets/instructions (and/or other direct labor differentiation method) for
conformance with the matrix of acceptable Title V activities
South Dakota uses direct labor and a time sheet system. Each time sheet has several line
items an individual can charge to. One of those line items is "Air Fees - Air Fees" which
represents Title V air quality fees. All Air Quality Program personnel are instructed to charge
any activities involving a Title V air quality operating permit to the "Air Fees - Air Fees" line
item.
Direct non-labor:
» Does the Permitting Authority utilize an allocation system that separates travel and
equipment costs for Title V and non-Title V functions?
« If so, are the allocations in accordance with the Permitting Authority's Title V/ non-Title
V activity separation?
• If not, axe these included as part of indirect costs? (Direct non-labor needs to be
addressed somewhere.)
For travel, the traveler identifies what percentage of the trip involves a Title V air quality
operating permit. The percentage is used to charge the vehicle, room and board, etc. to Title
V air quality fees. The rest is charged accordingly.
Indirect labor & non-labor:
• How are indirect labor & non-labor costs apportioned between Title V vs. non-Title V
accounts? (Indirect costs include parts of secretarial & managerial overhead, paper &
supplies, space, utilities, generalized computers, etc., that is not addressed as direct
labor/non-labor)
Accounting system
records showing that
administrative/ clerical
personnel costs are
accounted for in the
Title V program
Accounting system
records showing that
non-labor costs (travel,
equipment, office space
costs, etc.) are
accounted for in some
fashion and a portion is
billed to Title V.
EPA Guidance includes:
"Matrix of Title V-
Related and Air Grant-
Eligible Activities,
Information Document,"
Office of Air &
Radiation, May 31,1994
A set percentage of indirect labor and a percentage of non-labor cost is charged to Title V air
quality fees.
-------
3. Accounting System (Le., the system that provides for analysis of the Title V program revenue and expenditure information gathered
flhnvpl
Has the Permitting
Authority integrated
features into its
accounting/financial
management system
which will:
• identify Title V fee
revenues separate
from other funding?
« identify Title V
expenditures separate
from other expenses?
• produce management
reports, periodically
and as requested,
which the Permitting
Authority will be able
use to certify as to the
disposition of Title V
funds?
Describe the accounting structure that the Permitting Authority uses to differentiate Title V $
from other funds, [i.e., govt, fund, enterprise fund, etc. — for more detail on options, see the U
of MD report.]
Does the accounting system have separate categorization for Title V and non-Title V funding
and expenses?
If yes, are these features being used to track Title V monies separate from non-Title V
monies?
If no, does the Permitting Authority keep any separate records that identify Title V
monies separate from non-Title V monies? Could such information potentially be
integrated into an accounting/financial management system?
Review sample
reports/specific reports
for the time period being
reviewed.
For background:
Overview of CLEAN
AIR Title V Financial
Management and
ReDortine. A Handbook
for Financial Officers
and Program Managers.
Environmental Finance
Center, Maryland Sea
Grant College,
University of Maryland,
0112 Skinner Hall,
College Park, MD
20742, January 1997,
[Publication Number
UM-SG-CEPP-97-02]
-------
a Son*™*™ rtf Titlft V from 8105 Prant and grant match funding —
Can the Permitting
Authority confirm that
the Title V fees collected
from sources are used to
pay for the entire Title V
program, and that no
Title V fees are used as
match to the CAA
section 105 Air Program
grant?
Determine the federal §105 grant award received, and the amount of state/local funds
used during the time period being reviewed.
Determine the Title V fees collected (and Title V funds available, if carryover of Title V
fees is allowed by state/local regulations) during the time period being reviewed.
Determine Title V expenditures during the time period being reviewed.
Ensure that adequate non-Title V state/local funds were available to provide required
match to the federal grant.
Ensure that sufficient Title V funds were available to pay for the Title V program (i.e.~
Title V program is self supporting)
Title V air quality fees are separate from the 105 Air Program grant.
Grant files - FSR's for
applicable years. (See
appropriate EPA
Region grant & project
manager staff)
Permitting Authority
accounting system
reports showing
revenue and
expenditure summaries
for Title V, grant, and
other activities
-------
Black Hills Power
~Check if changes to mailing address, email or
phone number entered on back of form
Please make check or money order payable to:
BLACK HILLS POWER
PO BOX 1440
RAPED CITY, SD 57709-1440
li It 111 iitli 111 > 1111 mil 1 if 111111
DEPTOFENVNATRES
SCHULTZBRAD
523 E CAPITOL AVE
PIERRE SD 57501-3182
¦ 111 j 1111
iJ111 ¦ 111i I ml
Current amount
due 05/04/09:
$76.56
Account balance:
#76.56
AMOUNT ENCLOSED:
Account Number: 08 01 070085 01
Please return top portion with payment. If paying in person please bring entire bill.
Energy Usage Billed 04/13/09
Service From: 03/11/09 TO 04/13/09
Service Address: 5627 PEACEFUL PINES RD
BLEKJ 1/2 BLACK HAWK SD
Service For: AIR QUALITY PROGRAM
Statement Date: April 14,2009
Billing Period: 33 days
Web ID: 311507
Account Number: 08 01 070085 01
Meter Rate
Number Code
98344 20
Present
Reading
47726
Previous
Reading
47037
Difference
689
Multiplier
1
Usage
689
Units
kWh
Previous Billing
Credits
Payment—March 26,2009
Balance Forward
Charges
Energy Charge—kWh
Energy Cost Adjustment
Account Billing Information
$35.29
35.29-
.00
74.28
2.28
ACCOUNT BALANCE
$76.56
Pay account balance before May 09,2009 to avoid a late payment charge.
Customers are responsible for payment of their electric bill. Please call us at (605) 721-2660, or visit
your local BHP office when you have questions or concerns.
7c>
Thank You Foi being Our Customer!
30 Y0 4^
Y//6 /206f
RECEIVED
APR 15 20©
AIR QU/'UTV
PROGRAM
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-------
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Employee Information
Name: Rombough. Kyrik N
Title: Ntrl Resources Bigring Dir
EmpS: 1
Ti rnestudy: Timestudy Rules
Unofficial Leave Balances for 08^23/2003
Vfec iKBHHMiHB Personal |
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Pay
Work
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Sun
Mon
Tue
Wed
Thu
Fri
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Period
Period 1
Period 2
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Description
08/09/09 08/10/09
08/11/09
08/12/09 08/13/09
08/14/09
08/15/09 08/1?
Total
Total
Total
Total
Hours Worked
0.0
8.0
8.5
8.5
8.5
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0.0
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0.0
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8.5
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0.0
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33.5
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Manager
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(Ready
-------
PayCode DistRule
Task Name
Start Date End Date
ALL
ADMINBLZ
ADMIN BLIZZARD
11/08/2005 06/30/2020
ALL
ADMINFLD
ADMIN FLOOD
05/08/2007 06/30/2020
ALL
AIR QUAL
AIR QUALITY
01/25/2002 06/30/2020
ALL
AMBAIR08
AMBIENT AIR 08
03/24/2008 06/30/2020
ALL
CDSTIMUL
CLEAN DIESEL STIMULUS
06/30/1998 06/30/2020
ALL
CLDIESEL
CLEAN DIESEL GRANT
06/30/1998 06/30/2020
ALL
IND COST
FEDERAL INDIRECT COST
11/08/2005 06/30/2020
ALL
M &. M
MINERALS & MINING
12/16/2006 06/30/2020
ALL
RADON 09
RADON PPG 09
10/16/2008 06/30/2020
Total Tasks: 9
Cancel I OK
-------
SOUTH DAKOTA TRAVEL REQUEST
BOA FLEET & TRAVEL MANAGEMENT
SFN 01239-0002
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Traveler Sana)**®
Date
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AGENCY TRAVEL COORDINATOR USE
Coordinator NamB
Date of Entry
Mode
Comments
Ride Share Contact
Office Phone
Home Phone
FLEET AND TRAVEL MANAGEMENT USE - FOR HIGH MILEAGE REQUEST ONLY
Approval Signatures UB,B
Comments
Authorization Number
-------
.1IUJSL
SOOTH DAKOTA TRAVEL REQUEST
BOA FLEET & TRAVEL MANAGEMENT
SFN 01239-0002 •
Bureau or Department
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Out-ri-StatB
! (Personal Vehicle)
Home Phone
License Number
£&
^ )&
JOURNEY INFORMATION
Joumwjumber Origin ,
(¦¦ ¦?'C$0/''] "3 & "/
Odomattr neadi'tig
DepartuieXlate, j
vmloq
Departure Time
Cc?
Circle One:
d^>M
Segment
1.
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/ .
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4.'
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AM/$£p
5,
/j )/7 Do
t
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6.
l/V"5
3
. 7
AM/PM
'ft
AM/PM
REQUIRED: Return to Origin
Final Odometer Reading
/a
. AMjjgj?
Comments/Vehid^'Problems/Repairs
White - Heat andTtavBl toertagemeM; YeEow •' Agency ,.
COST ESTIMATES FOR OUT OF STATE TRAVEL
Transportation
$
Meals
$
Misc, Fees
S
total
$
General Funds
$ '
Federal Funds
Othai Fuflds'
I :
Non-Stata'Funda
$ • ,
¦ NOTE: Driver MUST siga to certify he/she holds a
SKiNATUHtb, tralirf driver license
AGENCY TRAVEL COORDINATOR USE
FLEET AND TRAVEL MANAGEMENT USE - FOR HIGH MILEAGE REQUEST ONLY
Date .
Autaeafcn Number
Carrimehts
-------
Attachment 3
South Dakota Air Permitting Section Organization Chart
-------
DEPARTMENT OF ENVIRONMENT &
NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL
SERVICES
AIR PROGRAM
BfnAftfGUSTAFSCN,PE
EHGfNSERfNG MANAGS* I!
PMrre
T19 200003
KYRfK ROMBOUGH
ENGINKING MANAGER t
Rwre
MARLYSHBDT
&JGINEHR IB
KHTH GESTKJNG
ENGINEER H
VennSticn
ASHLEY BRAKKE
BIGWEERU
Rerre
401181
BRADLEYSCHULTZ
ENV SCI04TKT MANAGE t
PSerre
200354
RICK BODOfCKB*
ENVSciENnsrrin
Rata
JONEPP
ENGINE IN
Rapid City
200350
BARB REGYNSKl
BWSCtStfTSTM
PtefTB
200232
ROBERT ROGmS
ENVSCtENTtSTtl
SkwcFdb
200342
KYLEHSMERL
BivsciamsTu
Rerre
200233
EARLBERG
BJGINEERI
R«tc
JOHN CON KLIN
E3JGJNEER!
Ptor®
200041
SAMANTHAELUOTT
ENGINE I
Rerra
4C0790
PAGE 14
govdenropx
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