GRIC TIP Revisions in response to the 3hour conference call 

with EPA on 8-23-05 

On 8-29-05 Janet, Daniel and Michelle conducted a conference call to discuss TIP 

changes that needed to be made in response to the EPA Conference call. In addition, 

Daniel is researchng additional support documentation. Please find following a 

summary of the changes. If anyone has any other changes please let me or Michelle 

know. 

Part I1 Permit Requirements 

EPA Comment # 15: Michelle will add overall language to state that we are incorporating 

Part 70 as of the Re-notice date for the TIP. She will add place holders for the unknown 

date. It is felt that it is easier to insert this language in one place rather than listing it in 

each area where Part 70 is mentioned. 

EPA Comment # 17: Michelle will delete the first "Title V Permit" in the last sentence of 

3.9 of Part 11. 

EPA Comment (No#): Michelle will add the language submitted by EPA for sections 

7.2 and 8.0 (Part II) referencing the "Administrator" and Director of GRIC DEQ. Ths 

section will indicate that the "Administrator" will mean "Dirctor" once EPA delegates the 

NESHAPs programs. 

MOA Agreement: 

MOA is only required for NESHAPs. Part 70, NSPS and TIP are delegated through 

program approval. 

Part 70 delegation requires a more complete description of eligibility (in addition to TAS 

eligibility statement) to address the elements of 70.4 (e.g., Permit Application forms) 

MOA needs to clarify that "Administrator" means Director of GRIC in 7.2 & 8.0 only 

after the programs are approved. 

Open Burning: 

Do we need to make open burning federally enforceable or do we keep it local? 

Michelle will add a requirement to bum only dry materials in section 4.1 (A). 

Michelle will add a definition of "Smaller Piles" (e.g., 4ft x4ft) 

Michelle will add a definition of high winds that will apply to commercial burns only 

(e.g., 10 mph) 
Question for Pat Were we going to delete any reference to a burn prohbition in section 

3.1 (last sentence) and delete housing development area? I believe the decision to delete 

the reference to ban burning in housing developments came after the TIP went out for 

public comment. 

Aerospace Ordinance: 

Michelle will add testing requirements to include EPA Method 24 (VOC Content of 

Coatings), Method 25 and submethods and Method 18 (VOC content of gaseous 

emissions entering and exiting ECS), EPA method 204 A-F (capture and control) and a 

formula for calculating Total VOC vapor pressure. 

Fugitive Dust Ordinance: 

Comment #29 

Michelle was going to originally hold off on making changes to the fugitive dust 

ordinance but after much thought there would probably be an approvability problem if 

the changes were not made. So, unless anyone will have a high degree of heart burn over 

adding the silt loading requirements and test methods for unpaved roads and unpaved 

parking lots we should probably add these requirements. Any thoughts? 

Comment #3 1 

Roger recommended adding "trips" to section 4.0 to read "20 vehicle trips /dayn. 

Michelle will make this revision. 

Comment #33 

Michelle will add "in accordance with the appropriate test method in section 12.0. 

Michelle will also move the current section 12 to 13 and add the test methods from 

Maricopa County Rule 3 10 and appendix C to the new section 12. 

Comment #35 

Dan reviewed Maricopa County Rule 3 10 (table 9) and the blasting requirements include 

"discontinue blasting in winds > 25mph and pre-water and stabilizearea where vehcle 

traffic occurs. Michelle will add table 9 from Maricopa county Rule 3 10. 

Comment #37,38,39: 

Michelle and Dan will work together to add the necessary test methods to section 12.0 

from Maricopa County Rule 3 10 and appendix C. Maricopa County Appendix C is 22 

pages long and explains how to conduct each test method including the infamous ball 

drop method. Do we need to include appendix C if we add these test methods? I have 

mixed feelings about adding these test methods and thought that Tribes could sever 

things that didn't make since to implement. I don't know if EPA is considering these test 

methods as meeting RACT or RACMS. It is my understanding that Maricopa County 

Rule 3 10 is the equivalent of BACT or BACMs. They are implementing these 

requirements to meet the SIP. 
Comment #40: 

Michelle will revise the current definition in Part II and the ordinance of "owner and/or 

operator" to reflect the definition in Maricopa County Rule 3 10, section 220. 

Degreasing & Solvent Metal Cleaning 

Comment #44 

EPA recommended specific requirements be added for O&M Plans. EPA sent 

recommended language to add but it does not address Comment #44. The language 

provided by EPA is more vague than the language originally in the ordinance. I 

recommend leaving the ordinance unchanged so we have flexability to fit O&M plans to 

specific types of control equipment. If we change the O&M requirements in this 

ordinance we will have to change several of the ordinances. 

Comment #45 

We have not received any guidance concerning Initial Compliance Certification. Again, I 

recommend leaving the ordinances unchanged. If we change this ordinance we will have 

to change several of the ordinances. 

Secondary Aluminum Ordinance 

Comment #46 

Michelle will add "the requirements in th~s ordinance are in addition to the federal 

MACT standards @ 40CFR, Part 63, Subpart RRR." 

Comment #54 (Visible Emissions) 

Michelle will add a statement "as determined by applying EPA Method 9 protocol." 
_.. Page 1 of 2 

Dan Blair 

From: "Patricia Mariella" cPatricia.Mariella@gric.nsn.us> 

To: "Doug McDaniel (E-mail)" cMcDaniel.doug@EPA.gov>; ~McKaughan.Colleen@epamail.epa.gov> 

Cc: "Roger Ferland (E-mail)" cRFERLAND@quarles.com>; "Daniel Blair (E-mail)" cair@gilanet.net>; "janet 

travis (E-mail)" <jtravisgianet.net; "Leroy Williams (E-mail)" ~williams@gilanet.net>; "Margaret Cook 

(E-mail)" cMargaret.Cook@gric,nsn.us>; "Russell Betsuie (E-mail)" <Rbetsuie@gilanet.net>; "Willard 

Antone (E-mail)" cwantone3@gilanet.net> 

Sent: Monday, August 22,2005 2:18 PM 

Subject: High Priority - Tentative Questions for Tomorrow's Conference Call 

Doug and Colleen, 

We weren't sure if Janet Travis was able to get these questions out 

regarding the conference call tomorrow before she left on her well deserved 

two-week vacation. Also, would it be possible for you all to call us 

tomorrow at 10:OO a.m? Or do you need us to call you? What number should 

we use, if that is the case. Also, as we remember it, we are all on the 

same time - right?? 

Questions: 

1. Is a second public hearing necessary if no one requests it? We are 

figuring that we need to do a second public comment period. 

2. EPA suggests notifying the public of exceedences as soon as they occur 

(comment 7). The air program feels that the public notification as soon as 

practically pssible would make sense. What are the minimum requirements of 

the states in R9? 

3. EPA suggests a contingency plan in an emergency situation (comment 10). 

Do you have a sample plan to illustrate this? 

4. EPA requests specifics on the 0 & M plan for solvent cleaning 

operations (comment 44) What is in the federals that we can cite or use? 

5. Where di the NESHAPS MOA come from? Will separate MOA's be required 

for Title 5 etc. or can we do all of these in one MOA? 

6. Open burning - we truly understand how desirable more specificity 

would be but we feel it is impractical in the context of Gila River 

Roger Ferland has sent out a redlined version of all the changes we made 

based on the EPA comments. The only changes that have not been made (in 

response to EPA comments) are listed above. Except we are still reworking 

the VOC ordinance and adding the testing requirements to the Aerospace 

Manufactural and Rework ordinance, per EPA comments. 
Page 2 of 2 

Th'anks! ! ! ! 

We are looking forward to talking with you. 

For some reason I do not have Wienke's email address in my address book. 

Would you forward this to her. Thanks 

Pat Mariella 
I I Fc?b 02 06 04: 44p Colleen McKaughan 

FAX 

TO: Pat Mariella, Dan Blair, Janet Travis 

520-562-2245 

FROM: Colleen McKaughan, USEPA 

(520) 498-1333 (Fax) 

(520) 498-0 1 1 8 (Phone) 

PAGES: 6, including cover 

DATE: 2/2/06 

SUBJECT: Comments on draft TIP Document 

NOTE: 
Fzb 02 06 04:44p Colleen McKaughan 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION lX 

75 Hawthorne Street 

San Francisco, %A 941 05 

February 2,2006 

Patricia Mariella, Ph.D. 

Executive Director 

Gila River Indian Community 

Department of Environmental Quality 

P.O. Box 97 

Sacaton, AZ 85247 

AThank you for submitting a draft version of the Gila River Indian Community (GRIC) Air 

Quality Management Program, (1Vovernber 30, 2005 Dr@) for our review: We appreciate the 

opportunity to review this document. We appreciate the efforts you have made to make the 

document easier to read, with headers or footers on each page, as well as having each subchapter or section begin on a new page. In Attachment A to this letter, we present a few detailed 

comments for specific sections of the document. Because of revisions your sta@ made to the 

VOC storage, usage, and handling rules, we will need to submit one additional set of comments 

to you after we have reviewed those rules. We have included the fugitive dust comments, wbich 

we discussed yesterday with Dan Blair of your staff. We will need to have a separate discussion 

with you when you are ready to request NESHAPS delegation and set that procedure up. In our 

July 25,2005 comment letter, we incIuded a draft MOA for delegation 

We also request that your final submittal include an executive summary describing the package, 

identifying the CAA programs for which the Tribe is seeking approval, and describing where in 

the package we can locate the items that fulfill the corresponding program requirements. 

Again, we are extremely pleased that GRIC has embarked on the process of developing its own 

TJP and air quality program. It presents a unique opportunity for us, and we look forward to 

continuing to collaborate with you on the TIP. Please Iet us know if you would like us to arrange 

a conference call to go over these comments. 

Sincerely, 

Colleen McKaughan 

Associate Director 
Feb 02 06 04: 44p Colleen PloKaughan 

ATTACHMENT A: COMMENTS ON GRIC AIR QUALITY PROGRAM 

ORDINANCES, November 30,2005 version 

Part III, Permits Program 

Comment I 

One of the suggested comments fiom our July comment letter introduced some new language 

which is problematic. 

Sections 3.9 @age 37) and 2.2.C. (page 29) appear to allow title V sources to justify proposed 

"deviations" from conditions in EPA-issued PSD permits in their title V appIications. The terms 

and conditions of PSD permits are applicable requirements that must be included in sources' title 

V pennib. Failure to include one or more PSD permit conditions in a proposed title V permit 

may be grounds for EPA objection. If a source needs to revise conditions in its PSD permit, it 

must apply to EPA for a permit modification But the GRIC rule must not allow sources to 

circumvent this process by making changes outside of the PSD permitting process. 

We believe this problem would be a deficiency that would prevent full approval (i-e., it would 

cause us to only be able to grant interim approval). We recommend that GRlC DEQ fix this 

problem before submitting its permit program. 

Part V, Section 2 Fugitive Dust 

Comment 2 

We suggested that unpaved haul roads and unpaved parking lots should be subject to both a 20% 

opacity standard and a silt content standard of 6% for roads and 8% for parking lot. andor a 

0.33 ow. ft. silt loading standard. 

While GRTC incorporated the 20% opacity standard, the rule does not require compliance with 

the silt content and/or silt loading standard. (7k alternative control measure options in sections 

4 and 5 only require compliance with 20% opacity.) 

Recommendation: that these sources be subject to both a 20% opacity standard and a silt 

contentjsilt loading standard. Site conditions will not always be favorable to determining 

compliance by the 20% opacity method, e.g., sun not in the right position @asticulatly if road 

runs paralIel to the sun's course), not enough traffic at the time the inspector is there (sometimes 

operations are halted when inspectors arrive). The options in sections 4 and 5 to apply a dust 

palliative and gravel should be required to comply with the silt content andlor silt loading 

standard as well as 20% opacity. GRIC should not assume that dust palliatives and gravel will be 

applied in a way that achieves the minimum level of control provided by the silt contentkilt 

loading standard, particularly over time as the surface deteriomtes. 
'' F.@b 02 06 04: 44p Colleen McKaughan 

Comment 3 

We suggested a specific definition be added to the rule clari@kg which unpaved parking lots are 

subject to the rule. This comment was not incorporated. 

Recommendation: that a definition for unpaved parking lots be added that mirrors the unpaved 

hauVaccess road definition. 

Comment 4 

We suggested that the rule incorporate surface stabilization tests for disturbed surfaces and open 

storage piles. 

While section 12.2B incorporates by reference one of the applicable stabilization tests (the 

visible crust test), compliance with this test is not required. 

Recommendation: that the appropriate sources be subject to this stabilization test For example, 

this method should apply to Table 1 "Temporary StabiIization During Weekends, etc...". 

Typically, fugitive dust rules define inactive areas of construction sites as "open areasn, and this 

method would apply to open areas. The visible crust test method also should apply to open 

storage piles, and is the appropriate method to reference in section 10.5B.3 instead of subsection 

3.1B. 

Comment 5 

The rule lacks the appropriate opacity test meth'od to gauge dust plumes associated with active 

dust generating operations (e-g., for scraper activity, backhoeing, loading/unloading bulk 

materials, and other active operations aside Wrn unpaved haul road and unpaved parking lot 

use). We recommend that section 3 of Appendix C, Maricopa County regulations, be adopted by 

reference into section 12 and cross-referenced in the appropriate Table 1 source type control 

measures. 

Comment 6 

Section 2.2 of Appendix C, Maricopa County regulations, is not adopted by reference into 

section 12.2. Since this is part of the procedure for conducting tests on open area and vacant lot 

sources, it should also be incorporated by reference. , 

Comment 7 

The rule does not spec* how long records must be kept (see section 13). We recommend that 

records be maintained for 2 years. 
F*ib 02 06 04:44p Colleen McKaughan 

Part VI, Section 3.0 Degreasing and Solvent Metal Cleaning 

Comment 8 

Overall, the changes to this ordinance look good, except for a confusing typo, as foIlows. 

Section 5.1 (A)(3)(d) - Someone typed the number 9 instead of a left parenthesis, and the result is 

confusing. The section should read as follows. 

d. Carbon adsorption system, with ventilation greater than or equal to fifteen (15) 

cubic meters per minute per square meter nmef4) ~m3/minlm2) (fifty (50) cubic feet per 

minute per square foot [cfm/ft2]) of airtsolvent interface (when cover is open),. 

< 

Also, there is one minor typo in Section 5.2(A). The word "degreasers" should have an 

apostrophe, as follows. 

A. Workloads shall not occupy more than half of the degreasers depreaser's 

evaporative surface area. 

Part VII, Section 2.0, Aerospace 

Comment 9 

In Section 5.1, the rule allows for monthly averaging to determine compliance. Allowing 

monthly averaging is not consistent with the aerospace manufacturing Control Techniques 

Guideline (CTG) and other aerospace manufacturing and coating Reasonably Available Control . 

Technology (MCT) rules within Region 9. 

Comment 10 

We may allow monthly averaging under severe preconditions. A state or locality must 

demonstrate that the following criteria have been met: (I) daily emission limits are infeasible; 

(2) actual VOC emissions under monthly averaging are consistent with relevant RACTBACT 

control levels; (3) the rule's averaging period is as short as possible and no longer than 30 days; 

and, (4) averaging will not jeopardize the NAAQS or Reasonable Further Progress requirements 

and that maximum daily VOC emissions are consistent with the area's compliance or 

maintenance plan. These conditions are described within "Averaging Times for Compliance 

with VOC Limits: SIP Revision Policy," John O'Connor, USEPA/OAQPS, dated January 20, 

1984. 

We speculate that states and localities have not pursued monthly averaging-within aerospace 

rules because (1) they cannot meet these criteria, (2) the 8 hour and 24 hour compliance time 

frames of the ozone NAAQS preclude monthly averaging, and (3) the problematic air toxics and 

environmental justice issues associated with elevated daily VOC emissions hm aerospace 

coating operations under a monthly averaging regime.