## 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 ofthe 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 ofthe 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 submittedby 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 enforceableor 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 ofhigh winds that will apply to commercial burns only (e.g., 10 mph)

### Question for Pat Were we goingto 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 (captureand control)and a formula for calculating Total VOC vapor pressure. 

### FugitiveDust 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 #31 Roger recommended adding "trips" to section4.0 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 12to 13and 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 infamousball 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 equivalentof 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 requirementsbe 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 flexabilityto fit O&M plans to specifictypes of control equipment. If we change the O&M requirementsin 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 changethis ordinance we will have to change several ofthe 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 applyingEPA 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 sampleplan 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 MariellaI 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) 498-0 118 (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 PROTECTIONAGENCY REGION lX 75 HawthorneStreet San Francisco,%A 94105

February2,2006

PatriciaMariella, Ph.D. Executive Director Gila River Indian Community 

### DepartmentofEnvironmental 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, (1Vovernber30, 

### 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 draftMOA 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 locatethe itemsthat fulfill the correspondingprogram 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 continuingto 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,

ColleenMcKaughan Associate DirectorFeb 02 06 04: 44p Colleen PloKaughan

ATTACHMENT A: COMMENTS ON GRIC

### AIR 

### QUALITYPROGRAM ORDINANCES, 

### November30,2005 version Part 

### III, Permits 

### Program CommentI One ofthe suggested comments fiom ourJuly comment letterintroduced some new language 

### which 

### is problematic. Sections

### 3.9 @age

### 37) and 2.2.C. (page 

### 29) appear to allow title 

### V sourcestojustify proposed "deviations"from conditions

### in EPA-issued 

### PSD permits in 

### their title 

### V appIications. The terms and conditions of 

### PSDpermits are applicablerequirements that 

### must be included in sources' title V 

### pennib. Failure to include one 

### ormore 

### PSD permit conditions in a proposed title V permit may be grounds for 

### EPA objection. 

### If a sourceneeds to revise conditionsin its PSD

### permit, it must apply to EPA for a permit modification But the GRIC rule 

### must not allow sourcesto circumvent this processby 

### making changes outside ofthe PSD permitting 

### process. 

### We believe this problem 

### would be a deficiencythat 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, 

### Section2 Fugitive 

### Dust Comment 2 We suggestedthat unpaved haul roads and unpaved

### parking lots should be subjectto both a 20% opacity standard and a silt content standard of 6% forroads and 8% forparking lot.andor

### a 0.33 ow. 

### ft. silt loading standard. While GRTC incorporated

### the 20% opacity 

### standard, therule does not require compliance

### with the silt content and/or silt loading standard. (7kalternative control measure options in sections 4 and 5 only 

### require compliance

### with 20% opacity.) Recommendation: that these sourcesbe subjectto 

### both a 

### 20% opacity standard

### and 

### a silt contentjsilt loading standard. Site conditionswill not alwaysbe favorableto determining complianceby the 

### 20% opacitymethod, e.g., 

### sun not 

### in theright position @asticulatly ifroad 

### runsparalIel to the 

### sun's course),not enoughtraffic at

### the 

### time the inspector

### is there (sometimes operations are 

### halted when inspectors arrive). The options in sections4 and 

### 5to apply 

### a dust palliative 

### and gravel should be required 

### to comply withthe silt content andlor silt loading standard aswell 

### as 20% opacity.

### GRIC should not assumethat dust palliativesand gravel will be applied in 

### away that achieves

### the minimum level of controlprovided by the silt contentkilt loading standard,particularly over time as the surface deteriomtes.'' F.@b 02 06 04: 44p Colleen McKaughan

Comment3 We suggested a specific definition be 

### added to the rule clari@kgwhich unpaved parking lots are subject to the rule. This comment was not incorporated. Recommendation: 

### that a definition forunpaved parking lotsbe added that 

### mirrors the unpaved hauVaccess road definition. Comment 4 We suggested that the rule incorporate surface stabilizationtests for disturbed surfaces and open storagepiles. 

### While section 12.2B incorporatesby reference one ofthe applicable stabilization tests 

### (the visible 

### crust test), compliance with 

### this test is not required. Recommendation: that the appropriate sources

### be subject to this stabilizationtest For example, this method should apply to Table 1 "Temporary StabiIization

### During Weekends, etc...". Typically, fugitive dust rules define inactive areas ofconstruction sitesas "open 

### areasn,and this 

### method would apply to open 

### areas. The visible crust test method also should apply to open storagepiles, and is the appropriatemethod to reference in section 10.5B.3 instead of subsection 3.1B. Comment

### 5 The rule lacks the appropriateopacity test meth'odto gauge dustplumes associated with 

### active dust generatingoperations (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 3ofAppendix C, Maricopa Countyregulations, be adoptedby reference 

### into section 12 

### and cross-referenced in the appropriateTable 

### 1 sourcetype control measures. Comment 6 Section 

### 2.2 ofAppendix C, Maricopa County regulations, 

### is not adopted by reference into section 12.2. Since this is part ofthe procedure for conductingtests on open area and vacant lot 

### sources, it should alsobe incorporated by reference.

, Comment 7 The rule doesnot 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



### PartVI, Section 3.0 Degreasing and Solvent Metal Cleaning Comment

### 8 Overall, the changes to this ordinancelook good, except for a confusingtypo, as foIlows. Section 5.1(A)(3)(d) - Someonetyped the number 9 instead of a left parenthesis, and the result is confusing. The section should read asfollows. d. Carbon adsorption system, with ventilation greater than or equal to fifteen (15) cubic

### meters per minuteper squaremeter nmef4)~m3/minlm2) (fifty (50) cubic feet per minute per square foot [cfm/ft2])ofairtsolventinterface (when coveris 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 

### halfofthe

### degreasersdepreaser's evaporative surfacearea.

Part VII, Section 2.0, Aerospace Comment 9 In Section5.1, the rule allows for monthly averaging to determine compliance. Allowing monthly averagingisnot consistentwith the aerospace manufacturing Control Techniques Guideline(CTG) and other aerospace manufacturing and coatingReasonably Available Control

. Technology 

### (MCT) rules within Region 9. Comment 10 We may allowmonthly averaging under severepreconditions. A state or localitymust demonstrate that the following criteriahave been met: (I) daily emission limits 

### are infeasible; (2) actual VOC emissions under monthly averagingare consistent

### withrelevant RACTBACT control levels; (3) the rule's averagingperiod is as short as possible and no longerthan 30 days; 

### and, (4) averaging will not 

### jeopardizethe NAAQS or ReasonableFurther Progressrequirements and that 

### maximum daily VOC emissionsare consistentwith the area's compliance or maintenanceplan. These conditions are described

### within "AveragingTimes 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 8hour and 24 hour compliance time frames ofthe ozoneNAAQS preclude monthly averaging, and (3) the problematicairtoxicsand environmental justice issues associated with elevated daily VOC emissions

### hm aerospace coating operations under a monthly averagingregime.