Responses to Comments Submitted by 

Arizona Department of Environmental Quality 

Addressing the GRIC TIP 

GRIC Public Comment Period July 1,2006 thru July 31,2006 

Comment: 

Under ADEQ's Tribal Government Policy, the Department "recognizes the sovereignty 

of Tribal governments and their jurisdiction over lands within Indian Country as defined 

by federal law" and "supports the strengthening of Tribal capacity for environmental 

management and regulation." ADEQ views the proposal of the GRIC TIP as an 

important milestone in the development of that capacity and commends the Community 

on the work and thought that obviously went into the development of the proposed TIP 

The following comments focus on the provisions of Part I1 of the proposed TIP relating 

to non-title V sources: 

The intent of paragraphs 4.2(A) (1) and (2) appears to be to create two distinct sets of 

new non-title V sources, those that are subject to BRDT and those that are not. Paragraph 

4.2 (A) (I), however, only refers to the BRDT threshold for criteria pollutants, which 

makes the intent somewhat unclear. You may want to consider revising the paragraph as 

follows: 

1. Any new non-Title V source 

~ . . not identified in paragraph 

(2) of this section shall comply with source category specific emission 

limits and the other requirements applicable to an existing non-Title V 

source in paragraph (3) of this section. 

If you do not make the change, you should at least delete the words "or more" from this 

paragraph. 

You may want to consider adding the following provisions to paragraph 4.4 (A) (5) 

relating to inspections: 

d. Sample or monitor, at reasonable times, substances or parameters for the 

purpose of assuring compliance with the permit or other applicable 

requirements; and 

e. Record any inspection by use of written, electronic, magnetic or 

photographic media. 
We have found this authority, particularly that addressed in paragraph e, to be invaluable 

in our compliance and enforcement program. 

Section 5.1 appears to list changes that require any form of permit revision, not just 

significant revisions, which are addressed separately in section 5.5. We therefore suggest 

changing the title of this section to read "Changes Requiring a Permit Revision.'' 

The phrase "emissions.. ..with the potential to emit" in subsections 5.1 (A) (7) and (8) is 

somewhat unclear. We suggest revising these provisions as follows: 

7. A change that 

7 

results in either potential emissions of any new HAP wit& 

of three (3) tons per year or in an increase of the 

source's potential to emit equal to or greater than three (3) tons per year of 

any individual HAP of five (5) tons per year of any combination of HAPS 

already emitted by the source; 

8. Changes that result in potential emissions of any new ultrahazardous air 

pollutant equal to or greater than three hundred 

(300) pounds per year or result in an increase in the source's potential to 

emit equal to or greater than three hundred (300) pounds per year of any 

ultrahazardous air pollutant or combination of ultrahazardous air 

pollutants. 

As a conforming change, we suggest changing the introduction to the definition or 

"Potential to Emit" at page 17 to read: 

"Potential to emit'' or "potential emissions" means.. ... 

The reference in 5.1 to "this subsection 5.2" should be changed to read simply 

"subsection 5.2" 

Sections 5.8 and 5.9, which establish and excess emissions defense and excess emissions 

reporting requirements, arguably would be better placed in a separate section, since they 

do not directly relate to permit revisions. 

Response: 

"We very much appreciate these comments. The editorial suggestions were well taken 

and were adopted in every case but two. We did not think it necessary to explicitly 

authorize recording of inspections since we believe our existing authority covers this and 

we will consider moving subsections 5.8 and 5.9 if Part I1 is ever revised at a later date. 

Other than these minor amendments, the suggestions were extremely constructive and 

helpful."