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### ARIZONA ROCK PRODUCTS 

### ASSOCIATION 

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### 916

### W-Adams 

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The psguthat Iollow may contain scnsitivc, privileged or confidential information Intended solelyfor tlic addrcsscc named abovc. Ifyou rcceivc this message and art not the agent or:crnploycc of the addrczscc, thls facsimile communication has bccn made in error. Please do not disscmin~tc or copy any or the attrclled and notily thescndcr immediately by teiephonc Yleasc also rcturn the attzchcd sheet($) ta the sender by mail.Jul 28 06 04: 53p ARPA

I, ARIZONA, ROCK PRODUCTS ASSOCIATION

July 27,2006
Daniel Blair 

### Air Quality Specialist Gila River Indian Community Department of Environmental Quality 

### P.O. Box 97 Sacaton,Arizona 85247 Dear 

### Mr. Blair, The Arizona Rock Products Association (ARPA) would like to thank the Gila River Indian Community Department of Environmental Quality (GRIC DEQ) for the opportunityto submit formal comments 

### in response tothe recently drafted Tribal Implementation Plan 

### (TIP). We would like to extend appreciation for the good faith the Gila River Indian Community has displayed by conducting workshops and maintaining communications with stakeholdersas the proposed 

### TIP was developed. We share amutual goal of fostering a regulatory structurethat results in real environmental and public health benefits while maintaining a strong and vibrant base for economic development and opportunity within the Gila River Indian Community. Further, coordinated efforts between the regulated community and the regulating agencies will continueto be necessary 

### in orderto eliminaterule ambiguity, compliance uncertainty, and

. enforcement errors. Joint efforts will also lead to the continued development of alternative approaches that facilitate compliance and protect environmental and public health. Follo\ving are ARPA7s.general and section specific comments to the 

### TIP: Sincethe final TIP and development of 

### a permitting program isoneof the lengthiest most comprehensive air quality documents ever proposed by GRIC,the continued input of the reg-dated community 

### is critical to developing 

### an effective and workableplan. ARPA, once again, appreciates the opportunity to be involved 

### in this significant process and requeststo participate in future stakeholder meetings. It is our understanding that since the 

### TIP is contingent on Reasonably Achievable Control Measures (RACM) onIy technically and economically feasible alternative control measures that satisfy the objective outlined in the TIP would be considered and incorporated into the final plan. As discussed in a meetingwith Dan Blair of GRIC 

### DEQ, some ofthe measures in the TIP contain optionsthat may not be technically or economicallyfeasible or pose implementation

916West Adarns Street

# - Phoenix. AZ 85007-2732 (602) 271-0346 Fax (602) 255-0363

# - E-Mail: arpa@prirnenet.comJul 28 06 04:54p RRPR



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challengesfrom an administrativestandpoint. Further, 

### ARPA has provided concrete information demonstrating concerns with specificmeasures and provisions ofthe TIP fiom a technical or economic standpoint. ARPA requests an Economic, Small Business, and Consumer Impact Statement. With respect to the proposed TIP the Impact Statement should provide a comprehensive economic and technical review ofthe candidate control measures necessary for compliance. For exarnple,the TIP does not identify the emission reductions expected fiom the imposition ofvarious control practices, nor does it calculate the expected reduction 

### in emissionsper dollar spent on control. Without this analysis, it is impossible to determine whetherthe proposed controls are effective at all, let alone cost-effective. It is not enough to simply include a measure used in another jurisdiction without conducting a GRIC-specific economic and technical feasibility analysis. First, considering what the measures are, there isno guarantee that other jurisdictions conducted the analyses required by Federal law when they adopted various requirements. ARPA appreciates administrative considerationof alternative emission controls. This approach will provide benefits to all because it would foster control technology innovation by allowing regulated companies to develop and implement improved control measures that address the specific and unique conditions they face. By including a provision 

### in Section 

### VII ofthe 

### TIP that includes allowances for alternativemeasures that achieve equivalent orbetter emissions control, operations areprovided with the opportunity to demonstrate why a control measure is not possible, applicable or effective 

### in a specific situation and to make a showing of 

### an equivalentor better alternativethat would meet the requirements of the rule. Specific Comments Regarding the Gila River Indian Community

### TIP in Its Current Form: PART V. Area Source Emission Limits 

### 4.0 Unpaved Parking Lots -Is there a list of dust palliatives approvedby the Department, and can Al2PA get a copy of those recommendations? 5.0 Unpaved HauVAccess Road -ARF'A requests that "apply water" be the primary dust control option in section 5.1. 10.2 Bulk MaterialHauling On-Site Within the Boundaries of the Work Site C. Trackout control device 

### -ARPA is unable to locate Table 

### 1 (Trackout 

## - IJ, 2J, 3J) ofthis section. 10.5 Open Storage Piles 10.5(B)I. - Stockpiles are active and routinely change shape or position. They cannotbe covered. ARPA requests to seea qualifier placed in this language that this option was intended for "small piles" as stated in a meeting with GRIC 

### DEQ, rather than large working stockpiles that are representative of ourindustry.During a wind event covering stockpiles would create incredible safety and logistical issues. Therock products industry does not consider this measure a viable option for our operations under any circumstances. ARPA Safety Compliance Concerns Regarding Attempting to Cover Stockpiles: 30 CRF 56157.11001- Safemeans of access shall be provided and maintained to all working places. 30 CFR 77.205(a) - Safe means of access shall beprovided and maintained to all working places. These standardsrequire that safe access beprovided to any place in or about 

### a mine where work isbeing performed. Issues to Consider in Determining Compliance: Is permanent or temporary access provided to all working places? Areminers climbing the equipment or machinery to access work places? Are fall-of-personhazards createdby a lack of a stairway, ladder, ramp, or by the "sail effect'' that might carry 

### a worker into a fall hazard event? 30 CFR 656157.15005 Safety belts and lines 

### - Safetybelts and lines shallbe worn when persons work where there is danger of falling; a second person shall tend the lifeline when bins, tanks, or other dangerous areas are entered. 30 

### CFR 477.17 10 

### (a)- Safety belts and lines where there is danger of falling; a second person shall tend the lifeline when bins, tanks, or other dangerous areas are entered. 10.5(B)2. -Apply water to maintain a soil moisture content at a minimum of twelve (12) percent isunnecessary. According to the revised AP-42 Emission Factors 

### > 1.5% moisture content is considered "controlled" material. ARPA requests the addition ofmaintaining a visible crust meets stabilization requirements in this section. 12. I (A) -ARPA has concerns with the adoption of Maricopa County Appendix C which would includetest methods that are not currently necessary for compliance with the 

### TIP. (i.e. stabilization for open areas other 

### than construction sites) Further, Modified Method 

### 9 isunder litigation and should not be considered in the 

### TIP. PART VII. SourceICategory Specific Emission Limits for Existing and New Sources 3.1 

### - Do the opacity standards for specific pieces of in this section only apply to new facilities since the numbers come from the New Source Performance Standards? Are applicable facilities in operation before 1983 exempt?Jul 28 06 04: 54p RRPR



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### 7.2 

## - ARPA members are concerned about the amount ofrecordkeeping required in this section and are not certain ofthe environmentalbenefits. 

### In the meeting with GRIC DEQ, 

### ARPA members requested GRlC 

### DEQ to consider the idea of "visual surveys" with daily checklists and quarterly Method 9's. 

### ARPA is also concerned with the amount Smoke School is currentlybeing offered and who will be conductingthe trainingin the future. Can GRIC DEQ assist with this? ARPA has also has concerns with the current compliance schedule, but understands that it is the intention of the 

### GRIC DEQ to work with companies to raise awarenessregarding TIP requirements and compliance assistance. 

### ARPA requests further flexibility, dueto control device availability, associated costs, administrative and implementationchallenges, be exercised. We once again extend our appreciation for 

### the opportunity to meet with members of the GRIC DEQ and comment on the proposed TIP. We hope our comments receive thoughtful consideration as the TIP package is finalized. Please feel free to contact us ifyou have any questions regarding this issue.

Steve ~russell' Community Relations Director