## GRIC TIP Revisions in response to the 3hour conference call 

## with 

## EPA on 8-23-05

On 8-29-05 Janet, Daniel and Michelle conducted a conference call to discuss TIP changes that needed to be made in response to the EPA Conference call. In addition, Daniel is researchng additional support documentation. Please find following a summary of the changes. 

### If anyone has any other changes please let me or Michelle know. Part 

### IIPermit Requirements EPA Comment#15: Michelle will add overall language to state that we are incorporating Part 70 as ofthe Re-notice date for the 

### TIP. She will add place holders for the unknown date. It is felt that it is easierto insert this language in one place rather than listingit in each area where Part 70 is mentioned. EPA Comment#17: Michelle will delete the first "Title 

### V Permit" in the last sentenceof 

### 3.9 of Part 11. EPA Comment (No#): Michellewill add the language submitted by EPA for sections 7.2 and 8.0 (Part 

### 11)referencing the "Administrator" and Director of GRIC DEQ. This section will indicate that the "Administrator" will mean "Dirctor" onceEPA delegates the NESHAPs programs. MOA Agreement: MOA is only required for NESHAPs. Part 70, NSPS and TIP are delegatedthrough program approval. Part 70 delegation requires a more complete description of eligibility (in addition to TAS eligibility statement)to addressthe elements of 70.4 (e.g.,Permit Application forms) MOA needs to clarifl that "Administrator" means Director of GRIC in 7.2 & 8.0 only afterthe programs are approved. Open Burning: Do we need to make open burning federally enforceable or do we keep it local? Michelle will add a requirement to bum only dry materials in section4.1 (A). Michelle will add a definition of "Smaller Piles" (e.g.,4ft x4ft) Michelle will add a definition ofhigh winds that will apply 

### to commercial bums only (e.g., 10mph)Question for Pat Were we going to delete any reference to a burn prohibition in section 3.1 (last sentence)and deletehousing development area? I believe the decision to delete the reference to ban burning in housing developments came after the TIP went out for public comment. Aerospace Ordinance: Michelle will add testing requirements to include EPA Method 24 (VOC Content of Coatings), Method 25 and submethods and Method 18 (VOC content of gaseous emissionsentering and exiting ECS), EPA method 204 A-F (capture and control) and a formulafor calculatingTotal VOC vapor pressure. Fugitive Dust Ordinance: Comment #29 Michelle was goingto originallyhold off on making changes to the fugitive dust ordinance but after much thought there would probably be an approvability problem if the changes were not made. So, unless anyone will have a high degree of heart burn over adding the silt loading requirements and test methods for unpaved roads and unpaved parking lots we shouldprobably add these requirements. Any thoughts? Comment#3 1 Roger recommended adding "trips" to section 4.0 to read "20 vehicle trips /day" Michelle will make this revision. Comment #33 Michelle will add "in accordancewith the appropriatetest method in section 12.0. Michelle will also move the current section 12to 13 and add the test methods from Maricopa County Rule 3 10 and appendix C to the new section 12. Comment#35 Dan reviewedMaricopaCounty Rule 3 10 (table 9) and the blasting requirements include "discontinue blasting in winds > 25mph and pre-water and stabilizearea where vehicle traffic occurs. Michelle will add table 9 from Maricopa countyRule 310. Comment#37,38,39: Michelle and 

### Dan will work together to add the necessary test methods to section 12.0 from Maricopa County Rule 310 and appendix C. Maricopa County Appendix C is 22 pages long and explains how to conduct each test method includingthe infamousball drop method. Do we need to include appendix C if we add these test methods? I have mixed feelings about adding these test methods and thought that Tribes could sever things that didn't make sinceto implement. 

### I don't know if EPA is considering these test methods as meeting RACT or RACMS. It is my understanding that Maricopa County Rule 310 is the equivalent of BACT or BACMs. They are implementing these requirements to meet the SIP.

### Comment #40: Michelle will revise the current definition in Part I1 and the ordinance of "owner andlor operator" to reflect the definition in Maricopa County Rule 310, section 220. Degreasing & 

### SolventMetal Cleaning Comment #44 EPA recommended specificrequirementsbe added for O&M Plans. EPA sent recommended language to add but it does not address Comment #44. The language providedby EPA is more vaguethan the language originallyin the ordinance. 

### I recommend leaving the ordinanceunchanged sowe have flexability to fit O&M plans to specific types of control equipment. If we change the O&M requirements in this ordinance we will have to change several ofthe ordinances. Comment #45 We have not received any guidance concerning Initial Compliance Certification. Again, I recommend leavingthe ordinances unchanged. If we change this ordinancewe will have to change several of the ordnances. SecondaryAluminum Ordinance Comment #46 Mchelle will add "the requirements in this ordinance are in addition to the federal MACT standards @

### 40CFR7 Part 63, Subpart

### RRR." Comment#54 (VisibleEmissions) Michelle will add a statement "as determined by applyingEPA Method 9 

### protocol."