GRIC Tribal Implementation Plan Development Dan Blair Air

GRIC Tribal Implementation Plan Development Dan Blair, Air Program Mgr. Gila River Indian Community (GRIC) Department of Environmental Quality 1

Background: Gila River Indian Community Ø Akimel O’odham (Pima) & Pii Pash (Maricopa) Ø Located in Maricopa & Pinal counties Ø Established in 1859 by Executive Order Ø 374, 000 acres Ø Population 15, 500 (on- reservation) 2

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Industrial Facilities Ø Three industrial parks, 45 businesses & industries Ø Other GRIC-area sources Ø 40, 000 agricultural acres ØAcreage will increase to 140, 000 over next 10 years ØInterstate 10 bisects Community (largest source of air pollution) ØEncroachment 4

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Why GRIC Developed a Comprehensive Air Quality Program Ø Strengthen GRIC tribal sovereignty Ø GRIC vs EPA regulation Ø Fill Tribal GAP Ø Protect human health and environment Ø Protect GRIC cultural heritage as agricultural society Ø Strengthen economic development opportunities Ø Manage air emissions from industry + area sources 12

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GRIC Air Quality Management Plan (TIP) Development Process Ø Needs assessment (identify sources, need for air program) Ø Emissions Inventory (1997) Ø Applied for and received eligibility determination (TAS) under section 105 of the CAA (1998) Ø Applied for and received 105 grant funding from EPA Region IX (1998) 14

GRIC TIP Stakeholder Participation/Outreach Process Ø Met with agencies to discuss elements of TIP scoping document (outline of TIP and key approaches) ØADEQ ØMaricopa County Environmental Services ØMaricopa Association of Governments ØPinal County ØCity of Chandler 15

GRIC TIP Stakeholder Participation/Outreach Process (cont. ) Also met with Ø 7 GRIC districts Ø City of Phoenix Ø Sun Lakes Ø Salt River Indian Community Ø Fort Mc. Dowell Yavapai Ø Industry 16

GRIC TIP Stakeholder Participation/Outreach Process (cont. ) Ø Developed TIP scoping document, obtained public comment, received Council approval to develop TIP (Nov. 99) Ø Conducted open house on scoping document to gain input/comments Ø Mass mailing of scoping document (150) Ø Implemented systematic, thorough plan for outreach and participation 17

GRIC Air Quality Management Plan (TIP) Development Process Ø Drafted Phase I of GRIC TIP and submitted for public comment (May 2001) Ø Enacted by council Aug. 2002 Ø Drafted Phase II ordinances (13) Ø Developed TSDs for categoryspecific ordinances (Phase II) 18

GRIC Air Quality Management Plan (TIP) Development Process Ø Conducted extensive outreach on Phase II of TIP (13 ordinances) Ø Held 45 -day public comment period and public hearing (May-June 2005) Ø Mass mailing of TIP (150) Ø Received 100+ comments on TIP and drafted responses 19

GRIC Air Quality Management Plan (TIP) Development Process Ø Made numerous revisions to TIP ordinances based on comments Ø EPA requested technical revisions Ø TIP with technical revisions to Committee/Council for approval (again) Ø Held a second public comment period and second public hearing (July 2006) 20

GRIC Air Quality Management Plan (TIP) Development Process Ø TAS application approved by Council (Nov. 2006), submitted to EPA Ø Air Quality Management Program Plan (TIP) approved by Council (Dec. 2006) Ø The plan became enforceable under the Community’s sovereign authority December ‘ 06 Ø Submitted AQMP (TIP) to EPA for federal enforceability (Feb. 2007) 21

GRIC Air Quality Management Plan (TIP) Development Process Ø GRIC continued to work on TIP support documents Ø TSDs, permit applications, public notice records, public hearing records (2), Capability, EI, Criminal MOA, NESHAP MOA, NSPS Delegation letter, Minor NSR demonstration, maps 22

GRIC Air Quality Management Plan (TIP) Development Process Ø EPA has 6 month for completeness determination Ø EPA has another (1) year to approve plan Ø EPA Region 9 Administrator signed final approval of GRIC AQMP Jan. 19 2011 at regular Council meeting 23

AQMP (TIP) Outline Ø Part I. General Provisions Ø Part II. Permit Requirements Ø Part III. Enforcement Ø Part IV. Administrative Appeals Ø Part V. Area Source Emissions Limits ØOpen Burning ØFugitive Dust 24

AQMP (TIP) Outline (cont. ) Ø Part VI. Generally Applicable Individual Source Requirements Ø Visible Emissions Ø VOC Usage Storage & Handling Ø Solvent Metal Cleaning Ø Part VII. Source-Category Specific Emission Limits Ø Secondary Aluminum Ø Aerospace Manufacturing and Rework Operations Ø Non-Metallic Mineral Mining 25

GRIC Air Quality Program (TIP) “Stumbling Blocks/Delays” Ø Several TIP ordinances not approvable as TIP elements (e. g. , Title V, NESHAPs, NSPS, MACT standards) Ø Revised TIP to “Air Quality Management Plan” Ø Developed MOAs Ø Second public hearing & comment period Ø TAS submittal process 26

GRIC Air Quality Program (TIP) “Stumbling Blocks/Delays” Ø EPA determination on how to deal with Title V Program (not a TIP element) Ø EPA will not Act on Title V Program Ø GRIC has revised and resubmit Part 70 Program to EPA (Aug. 2012) 27

GRIC AQMP Final Approval (TIP) approved by Council DEC. 2006 Submitted AQMP (TIP) to EPA for federal enforceability) Submitted support document packet for AQMP (TIP) AQMP Support Docs: TSDs, permit Feb. 2007 April 2009 applications, public notice records, public hearing records (2), Capability, EI, Criminal MOA, NESHAP MOA, NSPS delegation letter, Minor NSR demonstration, maps 28

GRIC Air Quality Program (Next Steps/ Challenges) Ø Currently issuing air quality operating permits under tribal authority (16 issued & 5 in the process) Ø Issue earth moving permits/ dust control plans (approx. 20 -30 /yr) Ø Conduct compliance assistance/ enforcement activities Ø Revise/update GRIC AQMP 29

GRIC Air Quality Program (TIP) Questions? 30