Page 1 of 1 

Janet Travis 

From: cSteckel.Andrew@epamail.epa.gov> 

To: cpatricia. mariella@gric.nsn.us> 

Cc: <Mckaughan.Colleen@epamail.epa.gov>; <alpete99@comcast.net>; 

<Wamsley.Jerry@epamail.epa.gov>; <Tax.W~enke@epamail.epa.gov>; 

cMcDaniel.Doug@epamail.epa.gov>; <jtravis@gilanet.net> 

Sent: Tuesday, August 09,2005 9:38 AM 

Subject: Additional EPA comments on GRlC TIP 

Dr. Mariella: 

By letter dated July 25th, EPA provided comments on the May 20th draft Gila River Indian Community 

Tribal Implementation Plan for Air Quality Management. We also said that we would send a few 

additional comments in the near future. The remaining comments are provided below. 

Part V, Section 1.0, Open Burning 

Paragraph 3.4.A. 1: Open burning of leaves and lawn clippings often generates considerable smoke due 

to the high moisture content. We believe hs activity should be prohibited unless there is no local 

organized garbage collection service and a justification can be made for not composting. Open burning 

of tree trimmings could be permitted if the material is required to be dned for at least 30 days. 

Paragraph 4.1 .A.6: "Smaller" piles is vague and could be better described by limiting the pile 

dimensions. 

Paragraph 4.1 .B. 1 : "High" winds is vague and could be better defined as winds greater than 10 miles per 

hour. 

Part VlI, Section 2.0, Aerospace Manufacturing and Rework 

The ordinance should list specific test methods for determining compliance with the rule, such as VOC 

determination Method 25, capture and control Methods 204A-F and Guidelines document, and vapor 

pressure calculations. 
Janet Travis 

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

To: "Daniel Blair (E-mail)" <air@gilanet.net>; "janet travis (E-mail)" cjtravis@gilanet.net> 

Sent: Thursday, August 25,2005 2:04 PM 

Attach: Fw- Gila River - Secondary Aluminum (Opacity comment).eml; Re- Follow-up on Question #3 

from GRIC - contingency plans.eml; Fw- Comments on GRIC Title 17, Section 8 (NESHAPs).eml 

Subject: More "Oh Brother" 

<<Fw: Gila River - Secondary Aluminum (Opacity comment)>> <<Re: Follow-up 

on Question #3 from GRIC - contingency plans>> <<Fw: Comments on GRIC Title 

17, Section 8 (NESHAPs)>> 

Let's talk about this next week when Janet T is back - how about after the 

hnding discussion (conference call) with EPA on the 30th? 

Daniel, if you could update Janet when she comes back, that would be 

great. 

Pat Mariella 
Page 1 of 4 

Dan Blair 

From: <McDaniel.Doug@eparnail.epa.gov> 

To: "Ferland, Roger K." <RFERLAND@quarles.com> 

Cc: <air@gilanet.net>; <Mckaughan.Colleen@epamail.epa.gov>; <Wehling.Jefferson@epamail.epa.gov>; 

"Patricia Mariella" <Patricia.Mariella@gric.nsn.us>; <Tax.Wienke@epamail.epa.gov> 

Sent: Thursday, August 25, 2005 3:07 PM 

Subject: RE: Follow-up on Question #3 from GRIC - contingency plans 

No, you have to tell the farmers to all stop farming!! Ahem. Never 

mind. 

"Ferland, Roger 

K." 

<RFERLAND@quarle To 

s.com> Doug McDaniel/R9lUSEPA/US@EPAy 

Patricia Mariella 

0812512005 02:38 <Patricia.Mariella@,nric.nsn.us>, 

PM air@,,wilanet.net 

CC 

Colleen 

McKauahanlR9/USEPAlUS @,EPA, Wienke 

TaxlR9/U SEPA/US@,EPA, Jefferson 

Wehling/R9/U SEPA/US@,EPA 

Subject 

RE: Follow-up on Question #3 from 

GRIC - contingency plans 

Jeff, 

This is very helpful. Since the plan is only required for PM10, there 

are no major PMIO sources on the Community and the Community is entirely 

rural, what's really required? We'll look at the Maricopa County plan 

but my recollection is that most of the contingency measures in that 

plan just don't apply to GRIC's situation. 

Roger 
Page 1 of 1 

Janet Travis 

From: <Steckel.Andrew@epamail.epa.gov> 

To: <patricia.mariella@gric.nsn.us> 

Cc : <Mckaughan.Colleen@epamail.epa.gov>; <alpete99@comcast.net>; 

<Wamsley.Jerry@epamail.epa.gov>; <Tax.Wienke@epamail.epa.gov>; 

~McDanieI.Doug@epamail.epa.gov>; <jtravis@gilanet.net> 

Sent: Tuesday, August 09,2005 9:38 AM 

Subject: Additional EPA comments on GRlC TIP 

Dr. Mariella: 

By letter dated July 25th EPA provided comments on the May 20th draft Gila River Indian Community 

Tribal Implementation Plan for Air Quality Management. We also said that we would send a few 

additional comments in the near future. The remaining comments are provided below. 

Part V, Section 1.0, Open Burning 

Paragraph 3.4.A. 1: Open burning of leaves and lawn clippings often generates considerable smoke due 

to the high moisture content. We believe th~s activity should be prohibited unless there is no local 

organized garbage collection service and a justification can be made for not composting. Open burning 

of tree trimmings could be permitted if the material is required to be dried for at least 30 days. 

Paragraph 4.1 .A.6: "Smaller" piles is vague and could be better described by limiting the pile 

dimensions. 

Paragraph 4.1 .B. 1: "High winds is vague and could be better defined as winds greater than 10 miles per 

hour. 

Part VII, Section 2.0, Aerospace Manufacturing and Rework 

The ordinance should list specific test methods for determining compliance with the rule, such as VOC 

determination Method 25, capture and control Methods 204A-F and Guidelines document, and vapor 

pressure calculations. 
Page 1 of 2 

Janet Travis 

From: <McDaniel.Doug@epamail.epa.gov> 

To: "Patricia Mariella" <Patricia.Mariella@gric.nsn.us>; <air@gilanet.net> 

Cc: <Mckaughan.Colleen@epamail.epa.gov~; <Tax.W~enke@epamail.epa.gov>; 

~Wehling. Jefferson@epamail.epa.gov> 

Sent: Thursday, August 25, 2005 7:49 AM 

Subject: Re: Follow-up on Question #3 from GRIC - contingency plans 

Info on contingency plans 

I have done some research on this issue and found out that: 

(1) The Gila River Indian Reservation is located in regions classified 

as Priority I for CO and 03 (Maricopa County portion only), Priority IA 

for SOX (Pinal County portion only); Priority I for PM (both Maricopa 

and Pinal portions). The Reservation is located within regions 

classified as Priority I11 for NO2 (both Maricopa and Pinal portions), 

CO and 03 (Pinal County) and SOX (Maricopa County) See 40 CFR 52.12 1 

(2) Emergency episode plans (or just episode plans), where required, 

must include contingency plans, and the specific requirements for 

contingency plans differ depending on the Priority classification of a 

region. 

(3) Under 40 CFR 5 1.1 52(c), episode plans are not required for Priority 

I11 regions. 

(4) Under 40 CFR 5 1.152(d), EPA may exempt from the requirement to 

prepare and submit episode plans those portions of Priority I, IA, or I1 

regions that have been designated as attainment or unclassifiable under 

section 107 of the CAA. 

(5) So, given that Priority I11 areas are exempt and assuming that EPA 

would exercise the discretion to exempt GRIC to the extent allowed under 

40 CFR 5 1.152(d), GRIC would not be subject to the episode plan 

requirement for any pollutant for any portion of the Reservation except 

for that portion of the Reservation that lies within the Phoenix PM-10 

Nonattainment Area (which I believe includes some Reservation lands in 

both Maricopa County and Pinal County). 

(6) If GRIC wants to request EPA to correct the boundary of the Phoenix 

PM- 10 Nonattainment Area to exclude the Reservation, then they could 

just wait until we decide what to do with their request since, if we 

grant the request, then no episode plan would be required for PM- 10 

either. 

(7) However, if GRIC decides not to request EPA to correct the PM-10 

Nonattainment Area boundary and decides to submit a TIP intended to 
Page 2 of 2 

address the requirements of CAA section 110(a)(2)(G), then I can point 

to two reference sources to assist them in developing an approvable 

plan: 40 CFR part 5 1, appendix L and Maricopa County Regulation VI: 

- 40 CFR part 5 1, appendix L provides guidance on regulations that 

fulfill the emergency episode plan requirement. Note that EPA has the 

discetion to limit the emission control actions required as part of the 

plan for Priority I areas to urbanized areas and to major sources (as 

defined in the PSD regs) outside of urbanized areas. So, presuming that 

the Reservation lies outside of the Phoenix urbanized area as determined 

by the 2000 Census, then the emission control action part of the 

emergency episode plan could be limited to just the sources that have 

PTEs greater than 100 tpy (specific categories) or 250 tpy 

(non-category-specific sources). 

- Maricopa County Regulation VI - Emergency Powers, Rule 600 - 

Emergency Episodes, as revised locally on July 13, 1988 and approved by 

EPA as a SIP revision on March 18, 1999 (64 FR 13351) is an example of a 

contingency plan that we have approved as meeting the applicable 

statutory and regulatory requirements. Ths SIP rule can be downloaded 

from the Region 9 website, under Air Actions, SIP collection, Arizona, 

Maricopa County. 

Jeff Wehling 

U.S. EPA, Region 9,ORC-2 

75 Hawthorne Street 

San Francisco, CA 94105 

Telephone: (41 5) 972-390 1 

Fax: (415) 947-3571 
Page 1 of 1 

Dan Blair 

From: <McDaniel.Doug@eparnail.epa.gov> 

To : "Patricia Mariella" <Patricia.lWariella@gric.nsn.us>; <air@gilanet.net> 

Cc: <Steckel.Andrew@epamail.epa.gov>; <Mckaughan.Colleen@epamail.epa.gov>; 

<Tax.Wienke@epamail.epa.gov> 

Sent: . Thursday, August 25,2005 7:45 AM 

Subject: Fw: Gila River - Secondary Aluminum (Opacity comment) 

FYI 

----- Forwarded by Doug McDaniel/lU/USEPA/US on 08/25/2005 07:44 AM ----- 

Doug7 Andy, 

After I re-reviewed Method 9 and the Secondary Aluminum rule from Gila 

River, 

I still recommend section 2.1 of the rule more clearly state the intent 

of the standard 

to remove any ambiguity. 

e.g., 

a.. they can never exceed 20% opacity "at any time" 

b. they cannot exceed 20% opacity for a certain amount of time (e.g., 3 

minutes in any hour) 

this would be similar to Bay Area 6-302 

http://www.baaqmd.~ov/dst/re~ulations/r~O60O.pdf 

c. they cannot exceed 20% opacity for 3 minutes (e.g., 12 readings at 

1 5 second intervals). 

Right now the rule states you cannot exceed 20% opacity. This could be 

interpreted 

as "at any time" - a violation if 1 reading is over 20% or 

a violation if 12 consecutive 15 second readings (i.e., 3 minutes) 

averaged exceed 20%. 

Stan 
Page 1 of 2 

Janet Travis 

From: ~McDaniel.Doug@epamail.epa.gov> 

To: "Patricia Mariella" ~Patricia.Mariella@gric.nsn.us>; <air@gilanet.net> 

Cc: cWang.Mae@epamail.epa.gov>; <Mckaughan.Colleen@epamail.epa.gov>; 

<Tax. W~enke@epamail.epa.gov>; <Steckel.Andrew@epamail.epa.gov> 

Sent: Wednesday, August 24,2005 8:40 AM 

Subject: Fw: Comments on GRIC Title 17, Section 8 (NESHAPs) 

Thanks, Mae. Pat, here are the NESHAP comments. 

----- Forwarded by Doug McDanielIR9NSEPAAJS on 08/24/2005 08:34 AM 

Mae 

WanglR9NSEPAAJS 

To 

08/23/2005 03: 1 6 Doug McDaniel/R9/USEPA/US@EPA 

PM cc 

Andrew Stecka9R /USEPAIUS@EPA, 

Cynthia Allen/R/USEPA/US@EPA, 

Roger Kohn/R9/USEPWS@BPA 

Subject 

Comments on GRIC Title 17, 

Section 8 (NESHAPs) 

Hi Doug - 

The following comments are related to the 8/5/05 draft language in GRIC 

Code Title 17, Section 8.2. I hnk that similar comments could be made 

about Section 7.2. As mentioned on the conference call this morning, 

these recommendations are primarily aimed at reducing potential 

confusion for sources. However, given that Sections 7 and 8 are locally 

adopted rules and federal approval is not mandatory, I don't think it's 

a deal breaker if GRIC DEQ decides not to make any changes to the 

language, as long as everyone agrees that the locally adopted language 

is not binding on EPA. The NESHAP delegation MOA will contain more 

detailed explanations of the authorities that are transferred with the 

delegation process. 

1. Sections 8.2.A and 8.2.B: GRIC DEQ may choose to have the term 

"Administrator" refer to the Director of the GRIC DEQ when implementing 

a standard as a matter of local law. However, sources should be aware 

that the Director of the GRIC DEQ does not replace the "Administrator" 
Page 2 of 2 

from a federal point of view until the GRIC DEQ has been officially 

delegated the standard. For example, if a source reports only to the 

Director of the GRIC DEQ (and not to EPA) when the applicable federal 

standard has not yet been delegated, then the source will actually be in 

violation of the federal reporting requirement. 

2. Section 8.2.C: I am not sure of the purpose of this provision. The 

reference to section 1 12(e)(3) may be out-of-date. 

Suggestions for possible text changes are presented below: 

8.2 General Provisions 

A. For any federal standards When used in 40 C.F .R. Parts 6 1 or 

63 that have been delegated to GRIC DEQ, "Administrator" 

means the Director of the Gila River Indian Community 

Department of Environmental Quality except that the Director 

shall not be authorized to make decisions regarding 

provisions that are not delegated by EPA, such as the 

authority to approve alternate or equivalent test methods or 

alternate standards or work practices, except as 

specifically provided for in Part 63, Subpart B. 

B. From the general standards identified in subsection 8.2.A, 

delete 40 C.F.R. $6 1.04. All requests, reports, 

applications, submittals, and other communications to the 

Director pursuant to this section shall be submitted to the 

Gila River Indian Community Department of Environmental 

Quality, 35 Pima Street, Sacaton, Arizona 85247. A copy of 

any notifications and reports required by federal standards 

in 40 C.F.R. Parts 61 or 63 that have not been delegated to 

GRIC DEQ must be sent to EPA. 

C. The Director shall not be delegated authority to deal with 

equivalency determinations that are nontransferable through 

Section 1 12(e)(3) of the Act. 
Page 1 of 2 

Janet Travis 

From: "Dan Blair" <air@gilanet.net> 

To: "michelle deblasi" <rndeblasi@quarles.com> 

Cc: "Janet Travis" <jtravis@gilanet.net>; "Roger Ferland" <rferland@quarles.com> 

Sent: Wednesday, September 14,2005 9:41 AM 

Subject: Fw: Comments on GRIC Title 17, Section 8 (NESHAPs) 

Michelle, 

Tlus is the language that EPA suggest revising in Section 7.2 and 8.2 of 

Part 11. I'm sure i sent it to you previously but I'm not sure that Roger 

and Janet got it. 

----- Original Message ----- 

From: <McDaniel.Do@,epamail. epa. go~> 

To: <Patricia.~ella(ijitanc.nsn.us>; ~~lmet.net> 

Cc: <Wang.Mae@epmail.eua.gov>; <Mckawhan.Colleen@ep~ail.epa.gov>; 

<Tax. Wienke@epamail.epa.gov>; <Steckel.Andrew@,epp~ail.epa~ov> 

Sent: Wednesday, August 24,2005 8:40 AM 

Subject: Fw: Comments on GRIC Title 17, Section 8 (NESHAPs) 

> Thanks, Mae. Pat, here are the NESHAP comments. 

> ----- Forwarded by Doug McDaniel/R9/USEPAlUS on 08/24/2005 08:34 AM 

> ----- 

> 

> Mae 

> Wang/R9/USEPA/US 

> To 

> 08/23 12005 03 : 1 6 Doug M@-~.eBE/USEPA/USBEPA 

> PM cc 

> Andrew Steckel/R9/USEPA/US@BPA, 

> Cynthia Allen/R9/USEPA/US@EEA, 

> Roger Kohn/R9/USEPA/US@EPA 

> Subject 

> Comments on GRIC Title 17, 

> Section 8 (NESHAPs) 

> 

> 

> 

> 

> 

> 

> 

> 

> 

>Hi Doug - 

> 

> The following comments are related to the 8/5/05 draft language in GRIC 
Page 2 of 2 

> Code Title 17, Section 8.2. I think that similar comments could be made 

> about Section 7.2. As mentioned on the conference call ths morning, 

> these recommendations are primarily aimed at reducing potential 

> confusion for sources. However, given that Sections 7 and 8 are locally 

> adopted rules and federal approval is not mandatory, I don't think it's 

> a deal breaker if GRIC DEQ decides not to make any changes to the 

> language, as long as everyone agrees that the locally adopted language 

> is not binding on EPA. The NESHAP delegation MOA will contain more 

> detailed explanations of the authorities that are transferred with the 

> delegation process. 

> 

> 1. Sections 8.2.A and 8.2.B: GRIC DEQ may choose to have the term 

> "Administrator" refer to the Director of the GRIC DEQ when implementing 

> a standard as a matter of local law. However, sources should be aware 

> that the Director of the GRIC DEQ does not replace the "Administrator" 

> from a federal point of view until the GRIC DEQ has been officially 

> delegated the standard. For example, if a source reports only to the 

> Director of the GRIC DEQ (and not to EPA) when the applicable federal 

> standard has not yet been delegated, then the source will actually be in 

> violation of the federal reporting requirement. 

> 

> 2. Section 8.2.C: I am not sure of the purpose of this provision. The 

> reference to section 112(e)(3) may be out-of-date. 

> 

> Suggestions for possible text changes are presented below: 

> 

> 8.2 General Provisions 

> 

> A. For any federal standards When used in 40 C.F.R. Parts 61 or 

> 63 that have been delegated to GRIC DEQ, "Administrator" 

> means the Director of the Gila River Indian Community 

> Department of Environmental Quality except that the Director 

> shall not be authorized to make decisions regarding 

> provisions that are not delegated by EPA, such as the 

> authority to approve alternate or equivalent test methods or 

> alternate standards or work practices, except as 

> specifically provided for in Part 63, Subpart B. 

> 

> B. From the general standards identified in subsection 8.2.A, 

> delete 40 C.F.R. 561.04. All requests, reports, 

> applications, submittals, and other communications to the 

> Director pursuant to this section shall be submitted to the 

> Gila River Indian Community Department of Environmental 

> Quality, 35 Pima Street, Sacaton, Arizona 85247. A copy of 

> any notifications and reports required by federal standards 

> in 40 C.F.R. Parts 61 or 63 that have not been delegated to 

> GRIC DEQ must be sent to EPA. 

> 

> C. The Director shall not be delegated authority to deal with 

> equivalency determinations that are nontransferable through 

> Section 1 12(e)(3) of the Act. 
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. 
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 II 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 11) referencing the "Administrator" and Director of GRIC DEQ. This 

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 clarifl 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 bums only 

(e.g., 10 mph) 
Question for Pat Were we going to delete any reference to a burn prohibition 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 /day" 

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 #3 5 

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 vehicle 

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 I1 and the ordinance of "owner andlor 

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 ordnances. 

Secondary Aluminum Ordinance 

Comment #46 

Mchelle will add "the requirements in this ordinance are in addition to the federal 

MACT standards @ 40CFR7 Part 63, Subpart RRR." 

Comment #54 (Visible Emissions) 

Michelle will add a statement "as determined by applying EPA Method 9 protocol." 
Summary of Comments and Responses on the GRIC TIP 

submitted by Maricopa County Environmental Health Services 

The GRIC DEQ Air Quality personnel met with the new Director and personnel from 

Maricopa County Environmental Health Services On June 28,2005 to gather comments 

on the GRIC TIP. Maricopa County Air Quality personnel reviewed the proposed GRIC 

TIP and provided numerous comments on the ordinances. A summary of the comments 

and responses are included below. 

Maricopa County suggested that GRIC revise the Table of Contents to ensure that the 

name of the Part listed in the Table of Contents match the heading in each of the Parts 

throughout the document. The GRIC Air Program will review and revise headings and 

Table of Contents as appropriate. 

The format of the heading in Part I should be revised to match the heaQngs in Parts IIVII. Air quality personnel will review and revise as appropriate. 

The County suggested several grammatical and format revisions throughout the TIP 

ordinances. The Air Program will review and revise the TIP as appropriate. 

Maricopa County suggested revising Part I, Section 2.3 "Incorporated Materials" to 

include a revised date for referencing amended provisions of 40 Code of Federal 

Regulations. The Air Program will revise this section from July 1,2001 to May 13, 

2005. In addition, the Air Program will include references to the new 40 CFR's 

promulgated up to May 13,2005 in sections 7 and 8 of Part 11. 

Maricopa County personnel suggested that GRIC change the adoption date in Part 11, 

Section 7.1 (B) from November 1,2004 to a more current date and include all the New 

Source Performance Standards (NSPS) in 40CFR, Part 60. The GRIC Air Program will 

revise Section 7.1 (B) to include the adoption date of May 13, 2005 and include any new 

NSPS provisions or any provisions that were not included in the draft Part 11, Section 7.0. 

Maricopa County also recommended deleting Part 11, Section 7.1 (B) (9) since it is a 

federal register notice that applies to medical waste incinerators and not a federal rule. 

The GRIC Air Program will delete Part 11, Section 7.1 (B) (9). 

Maricopa County personnel suggested that GRIC change the adoption date in Part 11, 

Section 8. I (A) and (B) from November 1,2004 to a more current date and include all the 

National Emissions Standards for Hazardous Air Pollutants (NESHAPs) in 40CFR, Parts 

61 and 63. The GRIC Air Program will revise Section 8.1 (A) and (B) to include the 

adoption date of May 13,2005 and include any new NESHAPSs provisions or any 

provisions that were not included in the draft Part 11, Section 8.0. 

Maricopa County personnel suggested that GRIC revise Part VI, Section 2.0 (VOC 

Usage, Storage and Handling ordinance) and Section 3.0 (Degreasing and Solvent metal 

Cleaning ordinance), to include the recently revised EPA definition of Volatile Organic 
Compound (VOC). The GRIC Air Program will replace the definition of VOC in the 

draft VOC Usage, Storage and Handling ordinance and the Degreasing and Solvent Metal 

Cleaning ordinance with the updated EPA definition. 

Maricopa County personnel suggested that GRIC revise Part VI, Section 2.0 (VOC 

Usage, Storage and Handling ordinance), Section 3.0 (Degreasing and Solvent Metal 

Cleaning ordinance) and Part VII, Section 2.0 (Aerospace Manufacturing and Rework 

Operations), to include the revised definition of Non-Precursor Organic Compound 

which includes exclusions promulgated by EPA on November 29,2004. The GRIC Air 

Program will replace the definition of Non-Precursor Organic Compound in the draft 

VOC Usage, Storage and Handling ordinance, the Degreasing and Solvent Metal 

Cleaning ordinance and the Aerospace Manufacturing and Rework Operations ordinance 

with the updated EPA definition. 

Maricopa County suggests adding test method language to Subsection 5.0, of Part VII, 

Section 2.0 for determining VOC content in coatings. The GRIC Air Program will 

include the following language, "Coatings: The VOC content of coatings (less water and 

less nonprecursor organic compounds) as applied shall be determined by manufacturer's 

supplied data or Method 24 of 40 CFR part 60, Appendix A. If there is a discrepancy 

between the manufacturer's formulation data and the results of the Method 24 analysis, 

compliance shall be based on the results from the Method 24 analysis. For waterborne 

(water-reducible) coatings, only manufacturer's supplied data can be used to determine 

the VOC content of each formulation". 

Maricopa County recommends adding a fence line standard to Part VII, Section 3.0 

(Nonmetallic Mineral Mining ordinance). This requirement was added to the revised 

Maricopa County Rule 3 16 to meet the Salt River SIP requirements because monitoring 

indicates a direct contribution to violations of the NAAQS from Non-Metallic Mineral 

Mining operations in the Salt River area. Since GRIC is a rural Community very different 

from the Maricopa County metropolitan area and monitoring does not indicate any 

impact on the NAAQS from particulate matter emissions generated by Non-metallic 

mineral mining operations at GRIC, the Community does not see any air pollution benefit 

from implementing this requirement. If future conditions change at GRIC and emissions 

from Non-Metallic Mineral Mining do begin to show an impact, GRIC may revise the 

ordinance to include a fence line standard. 
Summary of Comments from Outreach Efforts on the 

Draft Non-metallic Mineral Mining Ordinance 

Rock Solid Meeting (Craig Tanner GM) 

+ 1.0 Applicability (Per DEQ) After section 1.0 add Prohibitions (e.g., no cutback 

asphaltic materials, No off specification fuels) 

+ 2.15 Elaborate on definition of "Fugitive emission" 

+ 3.1 A. 5 Add "Any other operation or source" after or crusher 

+ 3.1 C Add Rock Solids control system (e.g., Sprinklers on stock piles) 

+ 3.1 C Add "Except for wet products with sufficient moisture control to prevent dust" 

+ 3.2 A. Applicability - Mineral filler should be changed to read "add mixture or Lime 

and flyash" 

+ 3.2 A Delete "rule" in the applicability section 

+ 3.4 A Last sentence add "or NSPS" after Rule E Section 1.0 

+ 4.0 Rock Solid personnel asked if an O&M plan was required for the small 

baghouses on their fly ash and cement silos. GRIC personnel respondes "yes" 

+ 4.1 A End of Paragraph per DEQ change language to read "or required by an air 

pollution control permit" 

+ 5.1 Change 10 years to 5 years 

+ 5.1 B 1, d) Change to state "Volume and mass of raw materials used to make final and 

intermediate products produced per day, deliveredlday, volume of mixes (asphalt) 

+ 5.1 B 1. h) Delete "For dry mix concrete plants:" 

+ 5.2 Add "in accordance with the provisions of 40 CFR, Part 60, Appendix A" 
Gila River Sand and Gravel (Tony Enos, Llyn Fulmer, GM and Board members) 

+ Met with the Gila River Sand and Gravel Board to discuss the proposed ordinance on 

March 17,2003. 

+ Can we provide a list of consultants for due diligence when they take over additional 

facilities (e.g. United Metro and future plant on the west side) -possible-will check. 

+ board requested a copy of the Compliance and Enforcement policy and the Med Waste 

ordinance for the purpose of reviewing the administrative procedures. 

+ The board indicated that there may be additional tenants in the future not just United 

metro. 

+ How will GRIC DEQ handle permitting with two different operators but one 

landownerllease? GRIC answered that each operator must acquire their own permits and 

be responsible for their respective operations (e.g. stockpiles, vehicle traffic). 

+ How will GRIC DEQ handle portable hot plants? Recommended that GRIC DEQ add 

language for hot plants. 

+ Do GRIC Sand and Gravel personnel have to get opacity training? Responded "Yes". 

Can GRIC S&G get a reduced rate and a training at GRIC? 

+ Recommended that the record retention time frame of 10 years be changed to 5 years 

(same as permit). 

+ Llyn Fulmer asked GRIC DEQ to ensure that they are kept informed on all aspects of 

compliance and enforcement. Please don't surprise them. If they are informed of any 

problems they will correct the problem if given a chance. GRIC DEQ informed them 

that the DEQ is committed to worlung with them through compliance assistance. 

+ GRIC S&G asked that we separate their operations from those of United Metro so that 

they are not responsible for any violations that may occur from operation of United 

Metro's facilities. 

+ GRIC DEQ personnel requested a tour of the facility. Conducted the tour on 7/29/03. 
Thermo Rock (Robin Torro Mgr) 

+ Robin indicated that they were in the process of painting the duct work per a requirement 

of the Lone Butte Industrial Park. 

+ Robin indicated that they did install a new baghouse. 

+ Robin indicated that she had not reviewed the ordinance thoroughly but did have some 

comments. 

+ Robin questioned the requirement to document pressure drop readings every hour. She 

indicated that this would be very burdomsome and recommended changing the 

requirement to once per shft. I indicated that we were reviewing this requirement. 

+ Robin asked how often they would be required to test the baghouses. I indicated that we 

were looking into inserting the frequency for testing in the ordinance (e.g., every 5 yrs). 

+ Robin asked if every baghouse needed to be tested and recommended that a size cutoff 

be established for testing. 

+ I explained to Robin that their permit would be based ontheir emissions and that she 

needed to keep good records of all the material brought into the facility, total sweeps 

shipped offsite as waste, and total product shipped. I indicated that her facility was close 

to the major source threshold and that it was in her best interest to accurately document 

throughput to document that they were not above the major source threshold. She also 

indicated that the operate 24 hrs per day. I informed her that fugitive emissions will be 

added when calculating their emissions. 

+ Robin requested copies of log sheets for documenting pressure drop on the baghouses 

and copies of O&M plan requirements. I indicated that we could supply the log sheets 

and would sent an application for submitting an O&M plan. 

+ We conducted a quick tour and observed that several baghouses either did not have 

magnehelic gauges or the gauges were inoperable. Emissions were observed from one of 

the baghouses. 

Superlite Block Company ( ) 

+ We met with Superlite Block personnel, I explained the ordinance and TIP and they 

indicated that they briefly reviewed the ordinance but would like to review it further and 

submit written comments. They did have some immediate comments. 

+ They had a question about documenting pressure drop every hour and indicated that they 

had no problem with documenting pressure drop every hour on the two big baghouses but 

didn't think this was necessary for the two passive baghouses on top of the silos. They 
recommended that we clarify this requirement in the ordinance. 

4 They recommended that we clarifjl which baghouses needed to be performance tested 

and the frequency of the testing. (e.g., annually or once per permit term.) 

4 They questioned whether a VE certified person needed to be onsite at all times and what 

the frequency for conducting VE's will be. I indicated that we would clarify both these 

issues in the ordinance. 

4 Superlite personnel also recommended that the record retention period be changed to 5 

years from 10 years. 

4 We conducted a tour and observed two separate operations (bagging and block 

manufacturing). The bagging operation is equipped with a rotary kiln (dryer) to dry 

aggregate before it is bagged as premix concrete and a large baghouse. The actual 

bagging operations also is equipped with a baghouse. The block process is located in the 

back of the facility with several silos being located on the west side of the property. 

United Metro (Archer Shelton) 

4 Archer recommended that the ordinance explain performance testing frequencies and 

indicated that the testing requirements should not apply to the passive baghouses on the 

cement and flyash silos. 

4 Define where the Method 9 readings are to be conducted (e.g., baghouse stack, silo, 

transfer points etc.) While in operation. 

4 Archer indicated that the state requires annual performance testing on hot plants with 

capacity of 100,000 tonslyr and once every three years for less than 100,000 tonslyr. 

4 No problem with documenting pressure drop every hour but consider allowing VE 

reading every hour in lieu of manometer readings every hour. Manometer read 

documentation requirement should not apply to passive baghouses (silos). 

4 Archer indicated that Maricopa County required performance testing every permit term 

(every 5 yrs). 

4 Mr. Shelton recommended revisions to section 6.1 A. 1. c. to read "Summary of 

throughput per month of basic raw materials" etc. 

4 Recommended revisions to section 6.1 A. 1. d. to read "Volume of concrete andlor 

weight of aggregate and asphalt products produced per day" 

4 Recommended revisions to section 6.1 A. 1. e. to read "Weight of aggregate" 
4 Recommended deleting "heating value data" not useful. 

4 Recommended revisions to section 6.1 A. 2. a. to include an exclusion of hourly 

manometer readings for passive baghouses (silo). Possibly revise the definitionof 

baghouse to exclude bin vent or silo baghouse. 

4 Recommended revisions to section 6.1 C. to read Syears rather than 10 years. 

4 Recommended adding an explanation of the frequency for conducting VEs to section 7.1 

- - 

4 Recommended adding an explanation of the frequency for conducting performance test 

to section 7.2. 

4 Mr. Shelton also made several recommendations to the TSD for NMMM. 
Summary of Comments from Outreach Efforts on the 

Draft Aerospace Manufacturing and Rework Operations Ordinance 

Triumph Precision Casting (Dick Ransom, Dam Truong, Terry Crow) 

+ Met with TPC personnel and explained the GRIC TIP process and the draft ordinance for 

Aerospace ManufacturingKework Operations. TPC personnel indicated that the 

ordinance may not apply to their operations due to the very low usage of VOCs. They 

indicated that all their VOC emissions do not exceed 25#/day as indicated in section 1.0 

A. of the ordinance. 

+ I informed TPC that VOC emissions from all three Triumph operations may be 

aggregated as a total to determine if this ordinance applies. I also explained that the 

federal definition of contiguous operations would have to be researched to determine 

whether emissions from all three facilities would be aggregated or whether each facility's 

emissions would be calculated separately. I informed them that I would research the 

federal definition and get back with them. 

+ I also indicated that the applicability level of 25# of VOC emissions/day PTE may be 

lowered. 

+ TPC personnel informed us that there are three separate operations all operated under the 

Triumph Corp. parent company. The companies are Triumph Precision Castings (TPC), 

Thermal Processing Unit (TPU a division of AMTI), and Industrial Gas Turbines (IGT). 

TPC cast turbine fan blades and components for NUS and for IGT. TPU does rework 

operations on turbine fan blades for APUs for airplanes. IGT dismantles industrial 

turbines for power generation, repairs and reassembles the turbines. This facility may 

not fall under the definition of LLAerospace Manufacturing or Rework Facility" in 

accordance with section 2.5 of the ordinance. 

+ TPC personnel indicated that they have very minimal air emissions mostly fiom burning 

of natural gas in their furnaces. VOC emissions are extremely low. 

+ TPC personnel indicated that they would further review the ordinance and submit 

comments. 

Thermal Processing Unit (TPU a division of AMTI) Paul Coleman 5/27/03 

+ Mr. Coleman indicated that TPU will be purchasing a new Vapor Degreaser containing 

TCE due to the requirement by DOD customers. I informed Mr. Coleman that the 

Degreaser must comply with federal requirements and the GRJC solvent cleaning 

ordinance. I informed Mr. Coleman that the draft GRIC ordinance and the federal rule 

contain identical requirements. 
+ Explained to Mr. Coleman that we needed to research the definition of contiguous to 

determine if emissions from all three triumph facilities will be aggregated. 

+ Mr. Coleman indicated that even if all three facilities are aggregated, they will not 

exceed the 251bs /day threshold. 

+ Mr. Coleman indicated that they do platinum coating of some parts. 

+ Mr. Coleman indicated that he would send a letter from the manufacturer of the Vapor 

Degreaser indicating that it meets all the federal requirements. 

Industrial Gas Turbines (IGT) Setting up meet 
Summary of Comments from Outreach Efforts on the 

Draft Aluminum Ordinance 

Pirnalco (Amy Vasquez, William Pottgen, Pat Gorman, Butch Sorensen via phone) 

+ Add "Chips and run around scrap'' to section 2.2 of definitions. 

+ Add "halogenated materials" to section 2.2. 

+ Alcoa considers external scrap to be dirty scrap but is not "dirty" as defined by federal 

definition. 

+ Add page #s 

+ GRIC may want to add a reference to the MACT Standard for dioxin RRR. 

+ GRIC may want to add an alternate method 22 in lieu of Method 9. 

+ Delete sentence #2 in section 3.2 B. 

+ Add prohibitions. 

+ Pimalco personnel expressed concern about 3.3 B, 2. a.& b. 

+ Consider deleting section 3.4. 

+ Section 4.2 needs to be clarified to state what is to be tested (e.g. electric furnace) 

+ Section 4.2 B. 1. , the Arizona Ambient Air Quality Guidelines for Chlorine and 

Hydrogen Chloride should not be used as a control technology requirement. Recommend 

a mACT standard if applicable. 

+ Section 4.2 E., where are VEs to be conducted? 

+ Section 5.1 consider adding alternate method 22. 

Alexco (Jerry Wise, Robert Jackson) 

+ Alexco personnel didn't have many comments because most of the requirements in the 

ordinance wouldn't apply to Alexco facility. This facility does not have furnaces for 

melting aluminum but have natural gas fired ovens for heat treatment of extruded parts. 

In addition, emissions of VOCs are minimal and result from ink printing and limited 

solvent cleaning. 
Kaiser Aluminum (Jim Thomas) 

+ Set up meetings with Jim Thomas but the meetings were cancelled by Mr. Thomas. 

Janet has continued to try and set up a meeting with Kaiser personnel but has been 

unsuccessful to date. 
Summary of Comments from Outreach Efforts on the 

Draft Aluminum Ordinance 

Pimalco (Amy Vasquez, William Pottgen, Pat Gonnan, Butch Sorensen via phone) 

4 Add "Chips and run around scrap" to section 2.2 of definitions. 

4 Add "halogenated materials" to section 2.2. 

4 Alcoa considers external scrap to be dirty scrap but is not "dirty" as defined by federal 

definition. 

4 Add page #s 

4 GRIC may want to add a reference to the MACT Standard for dioxin RRR. 

4 GRIC may want to add an alternate method 22 in lieu of Method 9. 

4 Delete sentence #2 in section 3.2 B. 

4 Add prohibitions. 

4 Pimalco personnel expressed concern about 3.3 B, 2. a.& b. 

4 Consider deleting section 3.4. 

4 Section 4.2 needs to be clarified to state what is to be tested (e.g. electric furnace) 

4 Section 4.2 B. 1. , the Arizona Ambient Air Quality Guidelines for Chlorine and 

Hydrogen Chloride should not be used as a control technology requirement. Recommend 

a mACT standard if applicable. 

4 Section 4.2 E., where are VEs to be conducted? 

4 Section 5.1 consider adding alternate method 22. 

Alexco (Jerry Wise, Robert Jackson) 

4 Alexco personnel didn't have many comments because most of the requirements in the 

ordinance wouldn't apply to Alexco facility. This facility does not have furnaces for 

melting aluminum but have natural gas fired ovens for heat treatment of extruded parts. 

In addition, emissions of VOCs are minimal and result from ink printing and limited 

solvent cleaning. 
Kaiser Aluminum (Jim Thomas) 

+ Set up meetings with Jim Thomas but the meetings were cancelled by Mr. Thomas. 

Janet has continued to try and set up a meeting with Kaiser personnel but has been 

unsuccessful to date. 
GILA RIVER INDIAN COMMUNITY 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

MEMORANDUM 

DATE.: May I 1,2005 

TO: Richard Narcia, Governor 

Mary Thomas, Lt. Governor 

FROM: Pat Mariella, DEQ '? 1 b-----, 

RE: Tribal Implementation Plan for Air Quality 

Cc: Gary Bohnee, Chief of Staff wlo attachments 

The DEQ Air Team met with the Natural Resources Standing Committee yesterday and received 

approval to take the Tribal In~plementation Plan (TIP) proposed ordinances out for public 

comment. The DEQ will also hold a public hearing on the TIP. June 22, 2005 in District 4. 

We have attached the complete proposed TIP along with brief sunlnlaries of each section. In 

addition. the DEQ has developed a brochure (enclosed) to use as part of the Community 

outreach that highlights the key points. The Air Team will present the TIP in each district 

during the public coillillent period which goes from May 13 (publication in the Gila River Indian 

News) to Julj- 1, 2005. There will also be request for comment. as required by the Clean Air 

Act, in the Arizona Republic's public notice section. We also have a TIP stakeholders list that 

iilcludes affected businesses. GRIC departnleilts as well as surroundiilg jurisdictions. We will 

be sending the public coinmeilt notice to these stakeholders. 

After the public conlnlent period closes, the DEQ will review the coillilleilts and develop 

proposed changes to the TIP ordinances, as appropriate. The comments, the DEQ responses and 

the changes will be presented to Legislative and Natural Resources Committees as well as 

Council for final approval and enactment. 

LJnfortunatelj.. the special work session on the TIP for you and Council scl~eduled April 28 was 

cancelled by hTRC when Council called a special meeting for that daq.. We are working with 

NRC to reschedule the presentation and will malte sure that you get notice as soon as possible. 

We would also be verjr glad to make a preseiltation for you at a separate time. if you would like. 

Please let us know what works best for you. 

Thank you.