Jul 28. 06 04: 53p ARPA 

ARIZONA 

ROCK 

PRODUCTS 

ASSOCIATION 

July 27,2006 

Daniel Blair 

Air Quality Specialist 

Gila River Indian Community 

Department of Environmental Quality 

P.O. Box 97 

Sacaton, Arizona 85247 

Dear Mr. Blair, 

The Arizona Rock Products Association (ARPA) would like to thank the Gila River 

Indian Community Department of Environmental Quality (GRIC DEQ) for the opportunity to 

submit formal comments in response to the recently drafted Tribal Implementation Plan (TIP). 

We would like to extend appreciation for the good faith the Gila River Indian Community 

has displayed by conducting workshops and maintaining communications with stakeholders as 

the proposed TIP was developed. We share a mutual goal of fostering a regulatory structure that 

results in real environmental and public health benefits while maintaining a strong and vibrant 

base for economic development and opportunity within the Gila River Indian Community. 

Further, coordinated efforts between the regulated community and the regulating agencies will 

continue to be necessary in order to eliminate rule ambiguity, compliance uncertainty, and . 

enforcement errors. Joint efforts will also lead to the continued development of alternative 

approaches that facilitate compliance and protect environmental and public health. 

Following are ARPA's general and section specific comments to the TIP: 

Since the final TIP and development of a permitting program is one of the lengthiest most 

comprehensive air quality documents ever proposed by GRIC, the continued input of the 

regulated community is critical to developing an effective and workable plan. ARPA, once 

again, appreciates the opportunity to be involved in this significant process and requests to 

participate in future stakeholder meetings. 

It is our understanding that since the TIP is contingent on Reasonably Achievable 

Control Measures (RACM) only technically and economically feasible alternative control 

measures that satisfy the objective outlined in the TIP wouId be considered and incorporated into 

the final plan. As discussed in a meeting with Dan Blair of GRIC DEQ, some of the measures in 

the TIP contain options that map not be technically or economically feasible or pose implementation 

91 6 West Adams Street Phoenix. AZ 85007-2732 

(602) 271-0346 Fax (602) 255-0363 E-Mail: arpa@prirnenet.com 
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Jul 28. 06 04:54p ARPA 4 

challenges fiom an administrative standpoint. Further, ARPA has provided concrete information 

demonstrating concerns with specific measures and provisions of the TIP from a technical or 

economic standpoint. 

ARPA requests an Economic, Small Business, and Consumer Impact Statement. With 

respect to the proposed TIP the Impact Statement should provide a comprehensive economic and 

technical review of the candidate control measures necessary for compliance. For example, the 

TIP does not identify the emission reductions expected from the imposition of various control 

practices, nor does it calculate the expected reduction in emissions per dollar spent on control. 

Without this analysis, it is impossible to determine whether the proposed controls are effective at 

all, let alone cost-effective. It is not enough to simply include a measure used in another 

jurisdiction without conducting a GRIC-specific economic and technical feasibility analysis. 

First, considering what the measures are, there is no guarantee that other jurisdictions conducted 

the analyses required by Federal law when they adopted various requirements. 

ARPA appreciates administrative consideration of alternative emission controls. This 

approach will provide benefits to all because it would foster control technology innovation by 

allowing regulated companies to develop and implement improved control measures that address 

the specific and unique conditions they face. By including a provision in Section VII of the TIP 

that includes allowances for alternative measures that achieve equivalent or better emissions 

control, operations are provided with the opportunity to demonstrate why a control measure is 

not possible, applicable or effective in a specific situation and to make a showing of an 

equivalent or better alternative that would meet the requirements of the rule. 

SpecificComments Reaardinp the Gila River Indian Community TIP in Its Current Form: 

PART V. Area Source Emission Limits 

4.0 Unpaved Parking Lots - Is there a list of dust palliatives approved by the Department, 

and can ARPA get a copy of those recommendations? 

O Unpaved HauWAccess Road - ARPA requests that "apply water" be the primary dust 

control option in section 5.1. 

10.2 Bulk Material Hauling On-Site Within the Boundaries of the Work Site 

C. Trackout control device - ARPA is unable to locate Table 1 (Trackout - 1 J, 2J, 3J) 

of this section. 

1 0.5 Open Storage Piles 

10.5(B)1. - Stockpiles are active and routinely change shape or position. They cannot be 

covered. ARPA requests to see a qualifier placed in this language that this option was 

intended for "small piles" as stated in a meeting with GRIC DEQ, rather than large 

working stockpiles that are representative of our industry. 
Jul 28 06 04:54p RRPA 

During a wind event covering stockpiles would create incredible safety and logistical 

issues. The rock products industry does not consider this measure a viable option for our 

operations under any circumstances. 

ARPA Safety Compliance Concerns Regarding Attempting to Cover Stockpiles: 

30 CRF 56/57.11001 - Safe means of access shall be provided and maintained to all 

working places. 

30 CFR 77.205(a) - Safe means of access shall be provided and maintained to all 

working places. 

These standards require that safe access be provided to any place in or about a mine 

where work is being performed. 

Issues to Consider in Determining Compliance: 

Is permanent or temporary access provided to all working places? 

Are miners climbing the equipment or machinery to access work places? 

Are fall-of-person hazards created by a lack of a stairway, ladder, ramp, or by the 

"sail effect" that might carry a worker into a fall hazard event? 

30 CFR 656157.15005 Safety belts and lines - Safety belts and lines shall be worn 

when persons work where there is danger of falling; a second person shall tend the 

lifeline when bins, tanks, or other dangerous areas are entered. 

30 CFR 477.171 0 (g) - Safety belts and lines where there is danger of falling; a 

second person shall tend the lifeline when bins, tanks, or other dangerous areas are 

entered. 

10.5(B)2. - Apply water to maintain a soil moistwe content at a minimum of hvelve (12) 

percent is unnecessary. According to the revised AP-42 Emission Factors > 1.5% 

moisture content is considered "controlled'' material. 

ARPA requests the addition of maintaining a visible crust meets stabilization 

requirements in this section. 

12.1 (A) - ARPA has concerns with the adoption of Maricopa County Appendix C which 

would include test methods that are not currently necessary for compliance with the TIP. 

(i-e. stabilization for open areas other than construction sites) Further, Modified Method 9 

is under litigation and should not be considered in the TIP. 

PART VII. SourcelCategory Specific Emission Limits for Existing and New Sources 

3.1 - Do the opacity standards for specific pieces of in this section only apply to new 

facilities since the numbers come from the New Source Performance Standards? Are 

applicable facilities in operation before 1983 exempt? 
Jul 28 06 04: 54p RRPR 

7.2 - ARPA members are concerned about the amount of recordkeeping required in this 

section and are not certain of the environmental benefits. In the meeting with GRIC 

DEQ, ARPA members requested GRIC DEQ to consider the idea of "visual surveys" 

with daily checklists and quarterly Method 9's. 

ARPA is also concerned with the amount Smoke School is currently being offered and 

who will be conducting the training in the future. Can GRIC DEQ assist with this? 

ARPA has also has concerns with the current compliance schedule, but understands that 

it is the intention of the GRIC DEQ to work with companies to raise awareness regarding TIP 

requirements and compliance assistance. ARPA requests further flexibility, due to control 

device availability, associated costs, administrative and implementation challenges, be exercised. 

We once again extend our appreciation for the opportunity to meet with members of the 

GRIC DEQ and comment on the proposed TIP. We hope our comments receive thoughtful 

consideration as the TIP package is finalized. Please feel free to contact us if you have any 

questions regarding this issue. 

Steve ~russell' 

Community Relations Director