## Responses to Comments Submitted by Arizona Department of Environmental Quality Addressing the GRIC 

## TIP

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



### Comment: Under ADEQ's Tribal Government Policy, the Department "recognizes the sovereignty of Tribal governments and theirjurisdiction 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 ofthat capacity and commends the Community on the work and thought that obviously went into the development ofthe proposed TIP The following comments focus on the provisions of Part I1of the proposed TIP relating to non-title 

### V sources: The intent ofparagraphs 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 complywith source category specific emission limits and the otherrequirements applicable to an existingnon-Title 

### V source in paragraph (3) ofthis 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 followingprovisions to paragraph 4.4 

### (A) (5) relating to inspections: d. Sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliancewith the permit or other applicable requirements; and

e. Record any inspection by use ofwritten, 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 results in eitherpotential emissions of any new HAP wit& 

## 7 ofthree (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 ofHAPS already emittedby 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 greaterthan three hundred (300) pounds per year of any ultrahazardous air pollutant or combination ofultrahazardous air pollutants. As a conforming change, we suggest changingthe introduction to the definition or "Potential to Emit" at page 17to read: 

### "Potential to emit'' or 

### "potential emissions"means..

### ... The reference in 5.1 to "this subsection 5.2" shouldbe changedto read simply "subsection 5.2" Sections 5.8 and 5.9, which establish and excess emissions defense and excess emissions reporting requirements, arguablywould 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 casebut two. We did not think it necessary to explicitly authorize recording of inspections sincewe believe our existing authority covers this and we will consider moving subsections5.8 and 5.9 if Part I1 is ever revised at a later date. Other than these minor amendments,the suggestions were extremely constructiveand helpful."