Minor New Source Review Demonstration

The GRIC Tribal Council unanimously passed the GRICAir QualityManagement Program Plan (AQMP) on December 6,2006. The plan contains, among other things, requirementsfor complying with 40 C.F. R., Part 5 1.160(a) through (e) and section 1lO(a)(2)(C) of the Clean Air Act. Part I1 ofthe AQMP requires each facility to submit a complete permit application that contains the necessary informationto allow the GRIC DEQ to develop individual operatingpermits. 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 theNMQS or violate the GRIC AQMP. During the permit developmentprocess, an individual determination ofthe facility operations will be conducted,first, to determine whether the source or modification is "major," in which case GRIC will submitthe permit application to EPA; then, ifthe source/modification is not major, GRIC will evaluate it to determine 

### ifthe facilitywill be subjectto the GRIC Best Reasonable and Demonstrated Technology 

### (BRDT) emission limitation, equipment design or work practice standard. 

### In addition, Part 11, Section 4.0 ofthe GRIC AQMP contains detailed requirementsfor making modifications or revisions to existing facilities. The following detailed discussionwill further demonstratehow GRIC expectsto meet the requirements of40 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 implementingregulations) 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 ormod@ a source in an 

### attainment/unclassifiable area within the reservationmust first determine, 

### in accordancewith 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 ofthe GRIC reservation which is part ofthe Maricopa CountyPM- 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.

Ifthe project is not a "major stationary source" or "major modXcation" under EPA's NSR regulations, then the person must determine whether it is subjectto preconstruction review under GRIC's Non-Title V permit program. The calculation methodologyfordetermining applicability ofthe permit program depends on whether the project is a "new source" or a "modification" to an existing source.



### For "newsources ":Any person who proposes to construct a "new source" must calculate the source's "actual emissions" (as defined in Part 11, section 1.0ofthe AQMP) -which, for new Non-Title

### V sources,will be a projection based on "applicable control equipment requirements and projected conditionsof 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, section4.0 of theAQMP:

(a) more than 1ton per year (tpy) of any singlecriteria pollutant or air contaminantthat is subject to a New Source Performance Standard (i.e., a "regulated air pollutant"), or any combination ofhazardous air pollutants (HAPS); (b) more than 1000lbslyear of any single HAP; or (c) more than 300 lbslyear of any single or combination ofultrahazardous air pollutants.

New sources with "actual emissions" at or below these thresholds are exemptfrom 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) ofthe "modification" (as defined 

### in Part 11, section 1.0 ofthe AQMP). 

### Ifthe 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., 15tpy 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 combinationof 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 definitionof "significant," by the corresponding thresholds (e.g., 3 tpy for fluorides, 7 tpy for sulfuric acidmist, and 10tpy for hydrogen sulfide)



### In addition, any ofthe other changes listed under Part 11, section 5.5 ofthe 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 sourcemay proceed with it. Modification projects at existing sources that are

## not listed in Part 11, section 5.5 and result 

### in PTE increases belowthese thresholds are exemptfrom the requirement to obtain a permit revision from GRIC, but may be subjectto "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 ofeach 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, section2.1 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 informationwill be evaluated by GRIC Air Quality personnel or an outside contractor on

a case by case basis to determinewhether and what types ofcontrols must be installed. The RACT-BACT Clearing house will be consulted in each individual case to evaluate emission limitationsfor 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 stringentthan 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 QualityManagement Plan, a New Source Performance Standard (NSPS), or a MaximumAchievable 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 Communityhas adopted the National AmbientAir 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/unclassifiablefor

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 10microns 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 ofthe Community is located in Pinal Countywhich is currently designated as attainment for PMlo. GRIC monitors document that the air within the exterior boundaries ofthe Community currently meet theNAAQS for PMlo. GRIC monitors have documented exceedancesofthe standard during high wind episodes and monsoons and have documented some transport from neighboring jurisdictions that do impact PMloconcentrations at GRIC. GRIC has flagged the data under the Exceptional Events rule for high wind eventsthat were greater than 20 miles per hour as exceptional events and submitted documentation for 

### 3 exceptional events in 2007. 

### In addition, 2 exceptional eventswere flagged in 2008, and GRIC will prepare documentation for those events. GRIC also documented an exceedance ofthe PMlostandard onNovember 2,2007 as a result of a major road construction project within 100feet ofthe Casa Blanca monitoring station. A contractor failed to notify the GRIC DEQ ofthe 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 immediatelytake 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 ofthe PMlostandard 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 collectedbetween 2002 and 2004 which documentedthat PM2.5 concentrations at GRIC were very low. EPA Region 

### IXallowed GRIC to terminate operation of the PM2.5 monitors due to the very low concentrations and similar data being collectedby neighboring jurisdictions. GRIC received a letter from EPA Region 

### IX

onAugust 22,2008 indicatingthat EPA intended to designate GRIC 

### attainment/unclassifiableunder the 2006 24-hour PM2.5NAAQS. The letter also indicated that EPA intended to make the final designation decisionsby December 18, 2008. EPA made final designations decisionson 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 sourceswere only in operation for a short period oftime towards the end of2007 and GRIC is only using facility data from 2006 far the updated Emission Inventory. GRIC will include emissionsfrom these four facilities and updated emissions estimatesfor any facilities that have modified or expanded operations in subsequentemission 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 continueuntil all sources required to have a permit within the community arepermitted. All permitted sources will be required to submit an annual emission inventory to the GRIC DEQ as a condition of their operatingpermit. 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. Sincemost ofthe existing facilities operating at GRIC have not changed operationsor 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 Communitythat will require an air qualityoperating pennit to continue operations within the Community. There is currentlyone (1) Major source (Title

### V) facility (Pimalco) and the GRIC Air 

### Program has had discussionswith Pimalco concerningtheir optionsfor applying for a syntheticminor permit. The remaining approximately 49 facilities are considered Non-Title V facilities. Several sources have terminated operations since 1997 including the Stericyclemedical 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 SuperliteBlock, Triumph Precision Castings,Triumph Turbines, Loves Truckstop and Beaudry RV while Champion Homes and Classey Closets have increased in size. The majority ofthe non-Title-Vfacilities at GRIC are considered very small sources of air pollution. 

### An estimated 10non-TitleV facilitieshave 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 1997emissionsinventory using data from 2006. The 1997emissions inventory documentedthat the largest source of air pollution
at GRIC was Interstate 10which traversesthe Communitybetween Phoenix and Tucson. The 2007 emissions inventory indicates that emissions from all sourceswere as follows:

Emissions (tonslvr)



# I sources) 

# 1

all Sources (stationary, mobile, and

non-point

Emissions ofPMloat GRIC were generatedby vehicle traffic on unpaved roads, on road vehicle emissions, agricultural tillage and non-title

### V stationary sources. Mobile sources and area sources accounted for 1062tons ofPMloout ofthe total 2109 tons. Stationary sources generated 1047 tons of PMlowith 888 tons of PMlo were generated by two sand and gravel mining and crushing operations operatedby Gila River Sand and Gravel. Emissions of carbon monoxide at GRIC can be attributed almost entirely to on road 

## . ,



### PMlo 2109 tons

Sox 3 

### 1tons non-Title V (stationary)

sources CO 10,810tons

PMlo 1,047tons NOx 2,275 tons

CO 161tons VOC 1,126 tons Sox 68 tons

NOx

' 

### 175tons VOC 142tonsvehicle emissions

### with 10,588 tons of the total 10,810tons 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 ofvehicle miles traveled on Interstate 10 and Maricopa roads through the Community. Emissions ofnitrogen oxides

are again mostly generated by on-road vehicle traffic 

### with 2,055 tons ofNOx being generated by vehicles out ofthe total 2,275 tons ofNOx 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 slightlyhigher basis. On road vehicle traffic emissions are responsible for 929 tons ofthe 1,126 tons ofVOCs emitted in 2006.

The Gila River Indian Community is located south ofthe Phoenix metropolitan area which is one ofthe fastest growing metropolitan areas in the nation and is designated as a serious non-attainment area under the 8-hour ozoneNAAQS. 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 pollutionproblems. 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 heavyvehicle traffic, extensive industry, congestion or major air pollution problems generated by sourceswithin the Community, althoughtransport of air pollutants especially ozone and PMlofrom neighboring jurisdictions is a concern. Emissions of
precursors to ozone (NOx &VOCs) generated within the Community are minuscule comparedto the huge amount ofozone precursors generated within the greater Phoenix metropolitan area. The 1997emissions inventory documents that emissions ofVOCs fromthat portion of GRIC which lies within Maricopa County were less than .002%of the VOC emissions in the Phoenix nonattainment area. In addition, emissions ofNOx from that portion of GRIC which lies within Maricopa County were less than .006% of the NOxemissions from the Phoenix nonattainment area. Total emissionsfiom the Communityhave 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 Communityhas been monitoring for ambient concentrations of PMlosince 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 ofthe PMlostandard 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 documentedby 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 exceedancesofthe PMlostandard within the exterior boundaries ofthe Community.GRIC has taken actions to reduce anthropogenic (man made) sources of PMloby implementingordinances under the GRIC AQMP designed to reduce dust emissionfrom 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 affectedby 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 PMloemissions 

### within the Community.