Minor New Source Review Demonstration 

The GRIC Tribal Council unanimously passed the GRIC Air Quality Management 

Program Plan (AQMP) on December 6,2006. The plan contains, among other things, 

requirements for complying with 40 C.F. R., Part 5 1.160(a) through (e) and section 

1 lO(a)(2)(C) of the Clean Air Act. Part I1 of the AQMP requires each facility to submit a 

complete permit application that contains the necessary information to allow the GRIC 

DEQ to develop individual operating permits. The permit application forms require 

applicants to submit the information necessary for the GRIC DEQ to evaluate the air 

pollutant emissions of each facility on a case by case basis. In addition, the GRIC AQMP 

establishes emissions limitations, operating requirements and work practices to ensure 

emissions do not cause an exceedance of the NMQS or violate the GRIC AQMP. During 

the permit development process, an individual determination of the facility operations 

will be conducted, first, to determine whether the source or modification is "major," in 

which case GRIC will submit the permit application to EPA; then, if the 

source/modification is not major, GRIC will evaluate it to determine if the facility will be 

subject to the GRIC Best Reasonable and Demonstrated Technology (BRDT) emission 

limitation, equipment design or work practice standard. In addition, Part 11, Section 4.0 

of the GRIC AQMP contains detailed requirements for making modifications or revisions 

to existing facilities. The following detailed discussion will further demonstrate how 

GRIC expects to meet the requirements of 40 C.F.R, 51.160(a)-(e). 

1 .) Applicability 

First, any "major stationary source" or "major modification" (as defined in the CM 

and EPA's implementing regulations) proposing to locate in an attainment/unclassifiable 

area within the GRIC reservation is subject to the federal Prevention of Significant 

Deterioration (PSD) permitting requirements at 40 C.F.R. 5 52.21. As such, any person 

who proposes to construct or mod@ a source in an attainment/unclassifiable area within 

the reservation must first determine, in accordance with the applicable requirements of 

40 C.F.R. 52.21: (I) for a new source, the potential to emit ofthe source, or (2) for a 

modification to an existing source, the emissions increase of the project. Ifthe project 

constitutes a "major stationary source" or "major modification" under section 52.21, 

the person must apply for a PSD permit from EPA. For a "major stationary source" or 

"major modification" proposing to locate in a nonattainment area - i.e., in the northern 

portion of the GRIC reservation which is part of the Maricopa County PM- 10 

nonattainment area - the project proponent should consult with EPA to determine the 

applicable permitting requirements. GRIC commits to consult with EPA Region I. as 

necessary to ensure that major sources and major modifications are appropriately 

identified and referred to EPA. 

If the project is not a "major stationary source" or "major modXcation" under EPA's 

NSR regulations, then the person must determine whether it is subject to preconstruction 

review under GRIC's Non-Title V permit program. The calculation methodology for 
determining applicability of the permit program depends on whether the project is a 

"new source" or a "modification" to an existing source. 

For "new sources ": Any person who proposes to construct a "new source" must 

calculate the source's "actual emissions" (as defined in Part 11, section 1.0 of the 

AQMP) - which, for new Non-Title V sources, will be a projection based on "applicable 

control equipment requirements and projected conditions of operation." If the new 

source would have the following levels of "actual emissions," it may not be constructed 

until it is authorized in a "Non-Title V permit" issued by GRIC in accordance with the 

requirements of Part 11, section 4.0 of the AQMP: 

(a) more than 1 ton per year (tpy) of any single criteria pollutant or air 

contaminant that is subject to a New Source Performance Standard (i.e., a 

"regulated air pollutant"), or any combination of hazardous air pollutants 

(HAPS); 

(b) more than 1000 lbslyear of any single HAP; or 

(c) more than 300 lbslyear of any single or combination of ultrahazardous air 

pollutants. 

New sources with "actual emissions" at or below these thresholds are exempt from 

preconstruction permit review. Part 11, section 2.1 (c). Any new source that is 

categorized as a "de minimis facility" under Part 11, section 2.1 (c)(2) is also exempt from 

preconstruction review. 

For "existing sources ": Any person who proposes to mod* an existing source must 

calculate the "potential to emit" (PTE) of the "modification" (as defined in Part 11, 

section 1.0 of the AQMP). If the modification project would result in the following 

potential emission increases, it may not be constructed until it is authorized in a 

"sigtllficant permit revision" from GRIC: 

(a) an increase in the source's PTE of any single criteria air pollutant by at least 25 

tpy a threshold listed in the definition of "significant," whichever is lower 

(e.g., 15 tpy for PM10); 

(b) a PTE of at least 3 tpy of any new HAP; 

(c) an increase in the source's PTE by at least 3 tpy of any individual HAP or 5 tpy ~f 

any combination of HAPS; 

(d) a PTE of at least 300 lbs/yr of any new ultrahazardous air pollutant, or 

(e) an increase in the source's PTE by at least 300 lbs/yr of any ultrahazardous air 

pollutant or combination of ultrahazardous air pollutants; 

(f) an increase in the source's PTE of any other pollutant listed in the definition of 

"significant," by the corresponding thresholds (e.g., 3 tpy for fluorides, 7 tpy for 

sulfuric acid mist, and 10 tpy for hydrogen sulfide) 

In addition, any of the other changes listed under Part 11, section 5.5 of the AQMP (e-g., 

a change to a synthetic minor emission limit established under Part 11, section 4.2(C)) 

must be authorized through a "significant permit revision" from GRIC before the source 
may proceed with it. Modification projects at existing sources that are not listed in Part 

11, section 5.5 and result in PTE increases below these thresholds are exempt from the 

requirement to obtain a permit revision from GRIC, but may be subject to "minor 

modification" or notice requirements under Part 11, sections 5.2 or 5.4. 

2.) Control technology review 

The GRIC AQMP contains emission limits and emission standards that are generally 

based on the technology available to control emissions. GRIC has also developed a 

control standard, called Best Reasonable Demonstrated Technology (BRDT), which 

establishes emission limitations, equipment design requirements, work practices or 

operational standards based on the maximum degree of reduction of each criteria 

pollutant or hazardous air pollutant determined on a case by case basis. Each facility 

with emissions in excess of the thresholds established in Part 11, section 2.1 of the AQMP 

must submit a permit application in accordance with Part 11, Section 2.2 and provide 

process and emission information in accordance with Part 11, Section 3.3. This 

information will be evaluated by GRIC Air Quality personnel or an outside contractor on 

a case by case basis to determine whether and what types of controls must be installed. 

The RACT-BACT Clearing house will be consulted in each individual case to evaluate 

emission limitations for like processes and operations. The GRIC pennits will contain 

emission limits, emission standards and operating requirements consistent with 

established limits in the RACT- BACT clearing house. In some instances, GRIC may 

adopt requirements that are more stringent than RACT or BACT. In no event will BRDT 

be less stringent than the most stringent source-category specific emission limitation in 

Part VII of GRIC's Air Quality Management Plan, a New Source Performance Standard 

(NSPS), or a Maximum Achievable Control Technology 0. Also BRDT will 

generally be at least equivalent to EPA's RACT standards, and in some cases as stringent 

as BACT or LAER, as determined on a case-by-case basis. 

3 .) Current air quality designations 

The Gila River Indian Community has adopted the National Ambient Air Quality 

Standards (NMQS) as GRIC Standards in Part I, section 4.0 of the AQMF'. The GRIC 

AQMP was developed on the basis that all GRIC lands are attainment/unclassifiable for 

ozone. The U.S. EPA designated all of GRIC as attainment under the 8-hour ozone 

standard in 2004. In addition, GRIC is also designated attainment for lead, carbon 

monoxide, nitrogen oxides and sulfur oxides. 

Currently the northern portion of GRIC lies within the Maricopa County non-attainment 

area for particulate matter 10 microns in size and smaller (PMlo). Approximately 92,000 

acres of GRIC on the northern boundary was included in the Maricopa County nonattainment area when it was designated by EPA as non-attainment. This area is 

classified as a serious non-attainment area. The remainder of the Community is located 

in Pinal County which is currently designated as attainment for PMlo. GRIC monitors 

document that the air within the exterior boundaries of the Community currently meet the 
NAAQS for PMlo. GRIC monitors have documented exceedances of the standard during 

high wind episodes and monsoons and have documented some transport from 

neighboring jurisdictions that do impact PMlo concentrations at GRIC. GRIC has 

flagged the data under the Exceptional Events rule for high wind events that were greater 

than 20 miles per hour as exceptional events and submitted documentation for 3 

exceptional events in 2007. In addition, 2 exceptional events were flagged in 2008, and 

GRIC will prepare documentation for those events. GRIC also documented an 

exceedance of the PMlo standard on November 2,2007 as a result of a major road 

construction project within 100 feet of the Casa Blanca monitoring station. A contractor 

failed to notify the GRIC DEQ of the proposed project and did not acquire an Earth 

Moving Permit or submit a Dust Control Plan. Air quality program staff received a 

complaint concerning dust from the construction project and responded. GRIC air 

program staffrequired the contractor to immediately take action to reduce dust (e.g., 

water roads and work area) from construction activities and vehicle traffic. In addition, 

GRIC air program staffrequired the contractor to acquire an Earth Moving Permit and 

submit a Dust Control Plan which eliminated the dust problem. This exceedance was 

also flagged due to noncompliance with the GRTC AQMP. No further exceedances of the 

PMlo standard have been documented within the exterior boundaries of the Community. 

The GRIC Air Program was monitoring for PM2.5 in two locations throughout the 

Community. Data was collected between 2002 and 2004 which documented that PM2.5 

concentrations at GRIC were very low. EPA Region IX allowed GRIC to terminate 

operation of the PM2.5 monitors due to the very low concentrations and similar data 

being collected by neighboring jurisdictions. GRIC received a letter from EPA Region IX 

on August 22,2008 indicating that EPA intended to designate GRIC 

attainment/unclassifiable under the 2006 24-hour PM2.5 NAAQS. The letter also 

indicated that EPA intended to make the final designation decisions by December 18, 

2008. EPA made final designations decisions on December 22,2008. 

4.) Emissions inventory 

The GRIC Air Program has been working with an outside consultant and completed an 

updated emissions inventory. The inventory includes updated emission calculations for 

mobile sources which utilized Maricopa Association of Governments (MAG) emission 

factors. Emissions for four (4) new stationary non-title V sources were not included in 

this emissions inventory because these sources were only in operation for a short period 

oftime towards the end of 2007 and GRIC is only using facility data from 2006 far the 

updated Emission Inventory. GRIC will include emissions from these four facilities and 

updated emissions estimates for any facilities that have modified or expanded operations 

in subsequent emission inventories. The Community's Air Quality Program is in the 

process of developing their first set of Non-Title V air quality permits for several 

industries located on the Community. This process will continue until all sources 

required to have a permit within the community are permitted. All permitted sources will 

be required to submit an annual emission inventory to the GRIC DEQ as a condition of 

their operating permit. The revised emission inventory also reflects those facilities that 

have terminated operations at GRIC. Emission estimates for the remainder of the 
facilities will reflect the emissions from operations in 1997. Since most of the existing 

facilities operating at GRIC have not changed operations or increased in size, GRIC 

decided not to develop an entirely new emissions inventory for the AQMP submittal 

packet. 

5) Air pollution sources 

There are approximately 50 industrial facilities located within Gila River Indian 

Community that will require an air quality operating pennit to continue operations 

within the Community. There is currently one (1) Major source (Title V) facility 

(Pimalco) and the GRIC Air Program has had discussions with Pimalco concerning their 

options for applying for a synthetic minor permit. The remaining approximately 49 

facilities are considered Non-Title V facilities. Several sources have terminated 

operations since 1997 including the Stericycle medical waste incinerator, Arizona 

Processing (cotton seed delinting facility), Phillips Services (copper wire recycler) and 

Fertizona Coolidge (agricultural chemical supply). A few new facilities have located at 

GRIC since 1997 including Superlite Block, Triumph Precision Castings, Triumph 

Turbines, Loves Truckstop and Beaudry RV while Champion Homes and Classey Closets 

have increased in size. The majority of the non-Title-V facilities at GRIC are considered 

very small sources of air pollution. An estimated 10 non-Title V facilities have emissions 

exceeding 5 tons per year of a criteria pollutant while the remainder are well under 5 

tons. The GRIC Air Program has updated the 1997 emissions inventory using data from 

2006. The 1997 emissions inventory documented that the largest source of air pollution 

at GRIC was Interstate 10 which traverses the Community between Phoenix and Tucson. 

The 2007 emissions inventory indicates that emissions from all sources were as follows: 

Emissions (tonslvr) 

I sources) 1 

all Sources 

(stationary, 

mobile, and 

non-point 

Emissions of PMlo at GRIC were generated by vehicle traffic on unpaved roads, on road 

vehicle emissions, agricultural tillage and non-title V stationary sources. Mobile sources 

and area sources accounted for 1062 tons of PMlo out of the total 21 09 tons. Stationary 

sources generated 1047 tons of PMlo with 888 tons of PMlo were generated by two sand 

and gravel mining and crushing operations operated by Gila River Sand and Gravel. 

Emissions of carbon monoxide at GRIC can be attributed almost entirely to on road 

. , 

PMlo 

2109 tons 

Sox 

3 1 tons 

non-Title V 

(stationary) 

sources 

CO 

10,810 tons 

PMlo 

1,047 tons 

NOx 

2,275 tons 

CO 

161 tons 

VOC 

1,126 tons 

Sox 

68 tons 

NOx 

' 175 tons 

VOC 

142 tons 
vehicle emissions with 10,588 tons of the total 10,810 tons of CO being generated by on 

road vehicle traffic. This represents a large increase from 4,108 tons of CO generated in 

1997. This increase can be attributed to a huge increase of vehicle miles traveled on 

Interstate 10 and Maricopa roads through the Community. Emissions of nitrogen oxides 

are again mostly generated by on-road vehicle traffic with 2,055 tons ofNOx being 

generated by vehicles out of the total 2,275 tons of NOx Community wide. The largest 

source ofvolatile Organic Compounds (VOCs) is again on road vehicle traffic although 

other sources do contribute to this category on a slightly higher basis. On road vehicle 

traffic emissions are responsible for 929 tons of the 1,126 tons ofVOCs emitted in 2006. 

The Gila River Indian Community is located south of the Phoenix metropolitan area 

which is one of the fastest growing metropolitan areas in the nation and is designated as 

a serious non-attainment area under the 8-hour ozone NAAQS. The Phoenix metropolitan 

area is home for over 4 million people and along with the dense population comes heavy 

vehicle trafTic, extensive industry, congestion and air pollution problems. In contrast, the 

Gila fiver Indian Community is home to approximately 15,500 Community members 

over an area of 561 square miles. Community members do not have to contend with 

heavy vehicle traffic, extensive industry, congestion or major air pollution problems 

generated by sources within the Community, although transport of air pollutants 

especially ozone and PMlo from neighboring jurisdictions is a concern. Emissions of 

precursors to ozone (NOx & VOCs) generated within the Community are minuscule 

compared to the huge amount of ozone precursors generated within the greater Phoenix 

metropolitan area. The 1997 emissions inventory documents that emissions of VOCs 

from that portion of GRIC which lies within Maricopa County were less than .002% of 

the VOC emissions in the Phoenix nonattainment area. In addition, emissions of NOx 

from that portion of GRIC which lies within Maricopa County were less than .006% of 

the NOx emissions from the Phoenix nonattainment area. Total emissions fiom the 

Community have not been and are not now suEcient to cause or contribute to a violation 

of the eight-hour ozone standard or otherwise have a measurable impact on the Phoenix 

non-attainment area. In addition, GRIC ozone monitors have not registered a violation 

of the ozone NAAQS since GRIC began monitoring for ozone in July 2002. After 

evaluating these factors and numerous other factors submitted in the GRIC 8-hour ozone 

designation recommendation, EPA designated GRIC attainment and removed GRIC fiom 

the Phoenix ozone non-attainment area. 

The Gila fiver Indian Community has been monitoring for ambient concentrations of 

PMlo since 2005. This data has been collected under an EPA approved Quality 

Assurance Project Plan (QAPP) and is available through the AQS data base maintained 

by EPA. GRIC has documented exceedances of the PMlo standard during high wind 

episodes (20 miles per hour or greater) and has flagged these exceedances as exceptional 

events. The final exceedance of the standard was documented by the GRIC air 

monitoring network and was attributed to non-compliance with the GRIC AQMP. GRIC 

Air Program personnel implemented a Compliance and Enforcement action to eliminate 

the non-compliant activities. With the exceptions of the events listed herein, GRIC has 

not documented any other exceedances of the PMlo standard within the exterior 

boundaries of the Community. 
GRIC has taken actions to reduce anthropogenic (man made) sources of PMlo by 

implementing ordinances under the GRIC AQMP designed to reduce dust emission from 

earth moving operations and operation of industrial facilities. In addition, GRIC is in the 

process of drafting air quality operating permits with enforceable emission limitations 

for sources affected by the GRIC Non-metallic Mineral Mining Ordinance (e.g., asphalt 

plants, concrete plants, sand and gravel mining and crushing operations etc.). The GRIC 

Air Program also requires Earth Moving Permits and Dust Control Plans for any earth 

moving operations one (1) acre in size. The dust control measures being implemented by 

the GRIC Air Program are expected to reduce PMlo emissions within the Community.