### 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 shouldbe prohibited unless there is no local organized garbage collection service and ajustification can be made for not composting. Open burning of tree trimmings could be permitted ifthe material is required to be dned for at least 30 days. Paragraph 4.1.A.6: "Smaller" piles is vague and could be better describedby limitingthe 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 Manufacturingand Rework 

### The ordinance should list specific test methods for determining compliance with the rule, such as VOC determinationMethod 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 MariellaPage 1of 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/USEPA/US@,EPA,Jefferson Wehling/R9/USEPA/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 shouldbe prohibited unless there is no local organized garbage collection service and a justification can be made for not composting. Open burning oftree trimmings couldbe permitted 

### ifthe material is required to be dried for at least 30 days. Paragraph4.1 .A.6:"Smaller" piles is vague and couldbe better describedby limitingthe pile dimensions. Paragraph4.1

### .B.1: "High winds is vague and could be better defined as winds greater than 

### 10miles per hour.

Part

### VII, Section 2.0, Aerospace Manufacturingand Rework 

### The ordinance should list specifictest 

### methods for determining compliance with the rule, such as VOC 

### determinationMethod 25, 

### capture and controlMethods 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 7:49AM 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 Reservationis 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 asPriority I11 for NO2 (bothMaricopa and Pinal portions), CO and 03(Pinal County) and SOX (Maricopa County) See 40 CFR 52.121 (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 episodeplans those portions ofPriority 

### 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 assumingthat EPA would exercise the discretion to exempt GRIC to the extent allowed under 40 CFR 51.152(d),GRIC would not be subject to the episodeplan requirementfor any pollutant for any portion ofthe Reservation except for that portion of the Reservationthat 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 correctthe boundary of the Phoenix PM- 10Nonattainment 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 episodeplan would be required for PM- 10 either. (7) However, if GRIC decides not to request EPA to correct the PM-10 Nonattainment Areaboundary and decidesto 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 sourcesto assist them in developing an approvable plan: 40 CFR part 5 1, appendix

### L and Maricopa County Regulation VI:



## - 40 CFR part 51, appendix

### L provides guidanceon regulationsthat fulfill the emergency episode plan requirement. Note that EPA has the discetion to limitthe emission control actions required as part ofthe 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 ofthe emergency episode plan could be limitedtojust the sourcesthat have PTEs greater than 100tpy (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 approvedby 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) 947-3571Page 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/USon 08/25/2005 07:44 

### AM

-----

Doug7 Andy, After I re-reviewed Method 9 and the Secondary Aluminumrule from Gila River, 

### I still recommend section 2.1 of the rule more clearly state the intent ofthe 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 oftime (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., 12readings 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 12consecutive 15 second readings (i.e., 3 minutes) averaged exceed 20%. Stan

### Page 1of 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: Commentson GRIC Title 17, Section 8 (NESHAPs) 

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

## ----- Forwarded by Doug McDanielIR9NSEPAAJSon 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 similarcomments could be made about Section 7.2. 

### As mentioned on the conferencecall this morning, these recommendations are primarily aimed at reducing potential confusion for sources. However, given that Sections7 and 8 are locally adopted rules and federal approval is not mandatory, 

### I don'tthink it's a 

### deal breaker if GRIC DEQ decides not to make any changesto 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 authoritiesthat 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 shouldbe aware that the Director of the GRIC DEQ does not replace the "Administrator"

### Page 2 of 2

from a federalpoint ofview until the GRIC DEQ has been officially delegated the standard. For example, if a sourcereports 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 ofthis 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 6 1 or 63 that have been delegatedto GRIC DEQ, "Administrator" means the Director ofthe Gila River Indian Community Department ofEnvironmental Quality except that the Director shall not be authorized to make decisionsregarding 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. $61.04. All requests, reports, applications, submittals, and other communications to the Director pursuant to this section shall be submittedto the Gila River Indian Community Department ofEnvironmental 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 sentto EPA. C. The Director shall not be delegated authority to deal with equivalency determinationsthat are nontransferable through Section 112(e)(3)ofthe Act.

### Page 1of 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 14,20059:41 AM Subject: Fw:Comments on GRIC Title 17, Section 8 (NESHAPs) 

### Michelle, Tlus is the languagethat EPA suggest revising in Section 7.2and 8.2 of Part 11. I'm sure i sent it to you previously but I'm not surethat 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 8:40AM Subject:Fw: Comments on GRIC Title 17, Section 8 (NESHAPs)

>

### Thanks, Mae. Pat, here are theNESHAP comments. > 

### ----- Forwardedby Doug McDaniel/R9/USEPAlUSon 08/24/200508:34 AM >

## ----- > > 

### Mae > 

### Wang/R9/USEPA/US > 

### To > 

### 08/231200503:

### 1 6 

### Doug 

### M@-~.eBE/USEPA/USBEPA > 

### PM cc > 

### Andrew 

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

### CynthiaAllen/R9/USEPA/US@EEA, > 

### Roger Kohn/R9/USEPA/US@EPA > 

### Subject > 

### Comments on GRIC Title 17, > 

### Section 8 (NESHAPs) > > > > > > > > > 

### >HiDoug 

## - > >

### The following comments are related to the 8/5/05draft 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 thsmorning, >

### 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 decidesnot to make any changes to the >

### language, as long 

### as everyone agrees that the locally adopted language >

### is not binding on EPA. TheNESHAP delegationMOA will contain more >

### detailed explanations of the authorities that are transferred with the >

### delegation process. > > 

### 1. Sections 8.2.Aand 8.2.B: GRIC DEQ may choose to have the term > 

### "Administrator" refer to the Director ofthe GRIC DEQ when implementing >

### a standard as a matter of local law. However, sources shouldbe aware >

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

### from a federal point ofview until the GRIC DEQ has been officially >

### delegated the standard. For example, if a sourcereports only to the >

### Director of the GRIC DEQ (and not to EPA) when the applicablefederal > 

### standard has not yet been delegated, then the sourcewill actually be in >

### violation of the federalreporting requirement. > >

### 2. Section 8.2.C: I am not sure ofthe purpose ofthis 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 ofEnvironmental Quality except that the Director > 

### shall not be authorized to make decisionsregarding > 

### provisions that are not delegatedby EPA, such as the > 

### authority to approve alternate or equivalent test methods or > 

### alternate standards or work practices, except

### as > 

### specificallyprovided for in Part 63, SubpartB. > > 

### B. From the general standardsidentified 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 submittedto the > 

### GilaRiver Indian Community Department of Environmental > 

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

### any notificationsand reports required by federal standards > 

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

### GRIC DEQ must be sentto EPA. > > 

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

### equivalency determinationsthat are nontransferablethrough > 

### Section 112(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 responseto 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 ofPart 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 delegationrequires 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 requirementsto 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 sinceto 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 310 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 additionto 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 airprogram 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 separateMOA'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 DepartmentofEnvironmentalQuality 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 anew 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 handlingrules, 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 collaboratewith 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

ATTACHMENTA: COMMENTS ON GRICAIR QUALITYPROGRAM ORDINANCES, November30,2005 version
Part 

### III, Permits Program CommentI One ofthe suggested comments fiom ourJuly comment letterintroduced somenew language which is problematic. Sections3.9 @age37) and 2.2.C. (page 29) appear to allow title V sourcestojustify proposed "deviations"from conditionsin EPA-issued PSD permits in their title 

### V appIications. The terms and conditions ofPSDpermits are applicablerequirementsthat must be included in sources' title V pennib. Failureto include one ormore PSD permit conditions in aproposed title V permit may be grounds for 

### EPA objection. If a sourceneeds to revise conditionsin its PSD

### permit, it mustapply to EPA for a permit modification Butthe GRIC rulemust 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 GRlCDEQ 

### fix 

### this problem before submitting its permit program. Part V, Section2 FugitiveDust Comment 2
We suggestedthat unpaved haul roads and unpavedparking lots should be subjectto both a 20% opacity standard and a siltcontent standardof 6% forroads and 8% forparking lot.andora 0.33 ow. 

### ft. silt loading standard. While GRTC incorporatedthe 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 compliancewith 20% opacity.) Recommendation: thatthese sourcesbe subjectto both a 20% opacity standardand 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 atthe time the inspector

### is there (sometimes operations are halted when inspectors arrive). The options in sections4 and 5to applya dust palliative and gravel should be required to comply withthe siltcontent andlor silt loading standard aswell as 20% opacity.

### GRIC should not assumethat dustpalliativesand gravel will be applied in away that achievesthe minimum level of controlprovided by the siltcontentkilt loading standard,particularly over time as the surfacedeteriomtes.'' 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 forunpavedparking lotsbe added that mirrors theunpaved 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 sourcesbe subject to this stabilizationtest For example, thismethod should apply to Table 1 "Temporary StabiIizationDuring Weekends, etc...". Typically, fugitive dustrules 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. Comment5 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 unpavedparking lot use). We recommend that section 3ofAppendix C, Maricopa Countyregulations, be adoptedby reference into section 12 and cross-referenced inthe 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 Comment8 Overall, the changesto this ordinancelook good, except for a confusingtypo, as foIlows. Section 5.1(A)(3)(d) - Someonetyped the number 9 instead ofa left parenthesis, andthe result is confusing. The section should read asfollows. d. Carbon adsorption system, with ventilation greaterthan or equal to fifteen (15) cubicmeters per minuteper squaremeternmef4)~m3/minlm2) (fifty (50) cubicfeet 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" shouldhave an apostrophe, as follows. A. Workloads shall not occupy more than halfofthedegreasersdepreaser's evaporative surfacearea.

Part VII, Section 2.0, Aerospace Comment 9
In Section5.1, the rule allows for monthly averaging to determinecompliance. Allowing monthly averagingisnot consistentwith the aerospacemanufacturing 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 demonstratethat the following criteriahave been met: (I) dailyemission 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 andno longerthan 30 days; and, (4) averaging will not jeopardizetheNAAQS or ReasonableFurther Progressrequirements and that maximum daily VOC emissionsare consistentwith the area's compliance or maintenanceplan. These conditionsare describedwithin "AveragingTimes for Compliance with VOC Limits: SIPRevision Policy," John O'Connor, USEPA/OAQPS, dated January 20, 1984. We speculatethat states and localities have notpursued monthly averaging-within aerospace rules because (1) they cannot meet these criteria, (2) the 8hour and 24hour compliance time frames ofthe ozoneNAAQSpreclude monthly averaging, and (3) the problematicairtoxicsand environmental justice issues associated with elevated daily VOC emissionshm aerospace coating operations under a monthly averagingregime.

## 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 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 listingit 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#): Michellewill 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 addressthe 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 section4.1 (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 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 deletehousing 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 emissionsentering and exiting ECS), EPA method 204 A-F (capture and control) and a formula for calculatingTotal VOC vapor pressure. Fugitive Dust Ordinance: Comment #29 Michelle was goingto originallyhold 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 accordancewith the appropriate test method in section 12.0. Michelle will also move the current section 12to 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 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 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 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 & 

### SolventMetal Cleaning Comment #44 EPA recommended specificrequirementsbe added for O&M Plans. EPA sent recommended language to add but it does not address Comment #44. The language providedby EPA is more vague than the language originallyin the ordinance. 

### I recommend leaving the ordinanceunchanged sowe 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 ofthe ordinances. Comment #45 We have not received any guidance concerning Initial Compliance Certification. Again, I recommend leavingthe ordinances unchanged. If we change this ordinancewe will have to change several of the ordnances. SecondaryAluminum 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 (VisibleEmissions) Michelle will add a statement "as determined by applyingEPA 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 EnvironmentalHealth ServicesOn 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 ofthe comments and responses are included below. Maricopa County suggested that GRIC revise the Table of Contents to ensure that the name ofthe Part listed in the Table of Contents match the heading in each ofthe Parts throughout the document. The GRIC Air Program will review and revise headings and Table of Contents as appropriate. The format ofthe 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 revisingPart I, Section 2.3 "Incorporated Materials" to include a revised date for referencing amended provisions of 40 Code ofFederal Regulations. The Air Program will revise this sectionfrom July 1,2001to May 13, 2005. In addition, the Air Program will include references to the new 40 CFR's promulgated up to May 13,2005in 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 1,2004to a more current date and include all the New SourcePerformance 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 federalregister notice that applies to medical waste incineratorsand not a federal rule. The GRIC Air Program will delete Part 11, Section 7.1 (B) (9). 

### Maricopa County personnel suggestedthat GRIC change the adoption date in Part 11, Section 8.

### I (A) and (B) 

### from November 1,2004to a more current date and include all the National Emissions Standardsfor 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 ofMay 13,2005and 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 Solventmetal 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 suggestedthat GRIC revise Part VI, Section 2.0 (VOC Usage, Storageand Handling ordinance), Section 3.0 (Degreasingand SolventMetal Cleaningordinance) and Part VII, Section 2.0 (Aerospace Manufacturingand Rework Operations), to include the revised definitionofNon-Precursor Organic Compound which includes exclusionspromulgated by EPA on November 29,2004. The GRIC Air Program will replace the definition ofNon-Precursor Organic Compound in the draft VOC Usage, Storage and Handling ordinance,the Degreasing and Solvent Metal Cleaningordinance and the Aerospace Manufacturing and Rework Operations ordinance with the updated EPA definition. Maricopa County suggests adding test method language to Subsection 5.0, ofPart VII, Section 2.0 for determiningVOC 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 determinedby manufacturer's supplieddata or Method 24 of40 CFR part 60, Appendix A. If there is a discrepancy between the manufacturer's formulationdata and the results ofthe 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 requirementsbecause monitoring indicatesa direct contribution to violations ofthe NAAQS from Non-Metallic Mineral Mining operations in the SaltRiver area. Since GRIC is a rural Community very different fromthe Maricopa County metropolitan area and monitoring does not indicate any impact on the NAAQS from particulatematter emissions generated by Non-metallic mineral mining operations at GRIC, the Community does not see any air pollution benefit from implementingthis 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 1.0add Prohibitions (e.g.,no cutback asphaltic materials, No off specification fuels) 

# + 2.15 Elaborate on definition of "Fugitive emission" 

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

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

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

# + 3.2 A. Applicability

### - Mineral filler shouldbe changedtoread "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 of40 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 consultantsfor 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 operatorsbut one landownerllease? GRIC answered that each operatormust acquiretheir 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 10years 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 separatetheir operations from those of United Metro so that they are not responsible for any violations that may occur from operation ofUnited Metro's facilities. 

# + GRIC DEQ personnel requested a tour ofthe facility. Conductedthe 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 requirementto documentpressure drop readings every hour. She indicated that this would be very burdomsome and recommended changingthe requirementto 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 

### explainedto 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 facilitywas close to the major source threshold and that it was in her best interest to accurately document throughputto 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 supplythe log sheets and would sent an application for submittingan 

### 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 SuperliteBlock personnel, I 

### explainedthe ordinance and TIP and they indicated that they briefly reviewed the ordinancebut would like to review it further and submit written comments. They did have some immediate comments. 

# + They had a question about documentingpressure drop every hour and indicatedthat 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 ofthe 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 ofthe 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 

### Superlitepersonnel 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 equippedwith 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 ofthe facility with several silos being located on the west side of the property. United Metro (Archer Shelton)
4 

### Archer recommendedthat the ordinance explain performance testing frequencies and indicatedthat 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 100,000tonslyr and once every three years for less than 100,000tonslyr.
4 

### No problem with documentingpressure drop every hour but consider allowingVE 

### 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 everypermit term (every 5 yrs).
4 Mr. 

### Shelton recommended revisionsto section 6.1A. 1.c. to read "Summary of throughputper month ofbasic 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 revisionsto section 6.1A. 

### 2. a. to include an exclusion of hourly manometer readings for passive baghouses (silo). Possibly revise the definitionof baghouse to exclude bin vent or silobaghouse.
4 Recommended revisions to section 6.1 C.

### to read Syearsrather than 10years. 4 Recommended adding an explanation ofthe frequency for conducting VEs to section 7.1

-- 4 Recommended adding an explanation ofthe frequency for conductingperformance test to section 7.2.
4 Mr. Shelton also made several recommendationsto the 

### TSD for

### NMMM.

### Summary of Comments from Outreach Efforts on the Draft Aerospace Manufacturing and Rework Operations Ordinance Triumph Precision Casting (DickRansom, 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 emissionsdo not exceed 25#/day as indicated in section 1.0 

### A. of the ordinance. 

# + I informed TPC that VOC emissionsfrom 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 

### informedthem that I 

### would research the federal definition and get back with them. 

# + I also indicated that the applicabilitylevel 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 reassemblesthe turbines. This facilitymay not fall under the definition of LLAerospace Manufacturingor Rework Facility" in accordance with section 2.5 of the ordinance. 

# + TPC personnel indicated that they have very minimal air emissionsmostly 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 requirementby 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 contiguousto 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 ofthe Vapor Degreaser indicating that it meets all the federal requirements. 

### Industrial Gas Turbines (IGT) Settingup 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 scrapbut 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 ofMethod 9. 

# + Delete sentence #2 in section 3.2

### B. 

# + Add prohibitions. 

# + Pimalco personnel expressed concern about 3.3B, 

### 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 ofthe 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 unsuccessfulto 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 ofMethod 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 

### Section4.2B. 1. 

### , the Arizona Ambient Air Quality Guidelines for Chlorine and Hydrogen Chloride should not be used as a controltechnology requirement. Recommend a mACT standardif 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 commentsbecause most of the requirements in the ordinance wouldn't apply to Alexco facility. This facility does not have furnaces for melting aluminumbut have natural gas fired ovens for heat treatment of extrudedparts. 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 surroundiilgjurisdictions. 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 verjrglad 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.