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One Tribe’s Approach to TIP Development: The Gila River Experience

One Tribe’s Approach to TIP Development: The Gila River Experience. Dan Blair, Air Quality Specialist Gila River Indian Community Department of Environmental Quality. Background: Gila River Indian Community. Central Arizona, adjacent to Phoenix Akimel O’odham (Pima) & Pee Posh (Maricopa)

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One Tribe’s Approach to TIP Development: The Gila River Experience

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  1. One Tribe’s Approach to TIP Development:The Gila River Experience Dan Blair, Air Quality Specialist Gila River Indian Community Department of Environmental Quality

  2. Background:Gila River Indian Community • Central Arizona, adjacent to Phoenix • Akimel O’odham (Pima) & Pee Posh (Maricopa) • Located in Maricopa & Pinal counties • Established in 1859 by Executive Order • 374,000 acres • Population 15,500 people (on reservation)

  3. Industrial Facilities Three industrial parks, 45 businesses & industries • Medical waste incinerator • Aluminum-extrusion plants (3) • Largest hazardous-waste TSD in AZ • Explosive manufacturer • Extremely hazardous gas storage facility • Sand and gravel plants (3)

  4. Industrial Facilities (cont.) • 3 million shredded tires • Cotton Gin & delinting plants • Agricultural chemical supply (3) • Turbine test facility • Concrete block manufacturer • Mobile home manufacturer • Aerospace remanufacture/rework facility

  5. Other GRIC-Area Sources • 40,000 agricultural acres • Acreage will increase to 140,000 over next 10 years • Interstate 10 bisects Community (largest source of air pollution)

  6. GRIC Air Quality Program(Personnel) • Air Quality Specialists (3) • Air Quality Project Assistants (2) • GRIC Air Quality Team

  7. Air Quality Program(Daily Responsibilities) • Review proposals for new facilities-GRIC business & land development procedures • Review EA’s & EIS’s for new construction projects • Issue burn permits (landscape waste only) • Issue permit and conduct compliance activities under medical waste ordinance

  8. GRIC Air Quality Program(Daily Responsibilities- cont.) • Respond to air quality related complaints • Compliance assistance activities • Air quality monitoring activities • Conduct air quality outreach • Participate in Joint Air Toxic Assessment Project (JATAP)

  9. GRIC Air Program(Daily Responsibilities- cont.) • Review and comment on Title 5 permits • Participate in national tribal air quality working groups/initiatives • Conduct TIP development related task

  10. GRIC Air Quality Program Accomplishments • Needs assessment (identify sources, needs for air program) • Emissions Inventory • Identify problem sources/source classifications • Use EI info for monitor station design & location • Use EI info for designation under new NAAQS • Use as basis for TIP development

  11. GRIC Air Quality Program (Accomplishments) (cont.) • Mail-out packet for annual EI • Use annual EI to track reduction of pollutants • Applied for and received eligibility determination (TAS) • Applied for and received 105 grant funding

  12. GRIC Air Quality Program (Accomplishments) (cont.) • Submitted proposal and received funding to develop monitoring network • Developed QAPP for monitoring network (received Partial Approval May 2002) • Submitted designation recommendation under revised NAAQS (ozone, CO, PM)

  13. GRIC Air Quality Program (Accomplishments) (cont.) • Drafted TIP scoping document and received Tribal approval to develop TIP • Drafted first section of GRIC TIP and submitted for public comment (5/01) • Reviewed comments and drafted responses • Finalized revisions to GRIC Medical Waste Management Ordinance, submitted for public comment (6/01) • Final approval of MWO by Council 4/02

  14. TIP Development:Completed Tasks • Developed TIP concept paper • Developed TIP scoping document • Applied for 105 grant to develop TIP

  15. TIP Completed Tasks(cont.) • Applied for eligibility determination for Treatment as a State (TAS) • (6 month process) • GRIC received TAS under 106 water quality grant (1989) • 30-day review by EPA attorneys • 30-day review by Affected Governmental agencies (boundaries only)

  16. TIP Completed Tasks(cont.) • EPA approved 105 grant funding for ongoing Air Quality Program 3/31/99 • TAS approved by EPA 3/31/99 • Received EPA funding award as amendment to 105 grant for development of 3 monitoring stations 2/2000

  17. TIP Completed Tasks(cont.) • Designed monitoring network after consultation with State and local monitoring personnel • Conducted extensive outreach efforts to gain support for GRIC TIP • Drafted first section of GRIC TIP and submitted for public comment 5/01 • Received comments & drafted responses 6/02 • Purchased air samplers and met equipment

  18. TIP Completed Tasks(cont.) • Set up 3 stations (PM10, PM2.5,, ozone, met) • Drafted and revised Technical Support Documents (TSDs) • Developed draft TIP regulations (Section II & III of GRIC TIP) • Regulations for specific categories of sources • Regulations for permitting, enforcement, appeals etc.

  19. Proposed TIP Elements • Permitting Program • Area/small source permitting program • Synthetic minor permitting program • HAPs sources permitting program • GRIC will not initially develop pre-construction NSR or PSD permit programs • GRIC will develop a Non-TIP - Title 5 Operating Permitting Program

  20. Proposed TIP Elements (cont.) • Legal Authorities • General Authority Ordinance/Reg. • GRIC Tribal Courts • GRIC Tribal Law Office • Develop legal authorities where lacking (e.g. appeals process) • Develop enforcement process (e.g. DEQ enforcement policy)

  21. Proposed TIP Elements (cont.) • Legal Authorities • Develop rules/regs./ordinances • Reference by rule NSPS, NESHAPS, Federal Regulations • Adopt provisions of local agency rules/regs.

  22. Proposed TIP Elements(cont.) • Compliance Inspection Program • Annual inspections for major sources • Biannual inspections for small/area sources • Performance testing requirements

  23. Proposed TIP Elements(cont.) • Ambient Monitoring Program • Monitor for PM10, PM2.5 and ozone • Meteorological stations

  24. Proposed TIP Elements(cont.) • Dust Control Program • Construction sites • Agricultural operations (BMPs)

  25. Proposed TIP Elements(cont.) • Stakeholder Participation • State, county, city, community, industry, agriculture, Tribal officials • Meetings with ADEQ, MAG, Chandler, Phoenix, tribal community • GRIC Departments, organizations

  26. Proposed TIP Elements(cont.) • Public Notice/Comment Period • Open houses • Advertise TIP in local newspapers • Hold public meetings/hearings

  27. Proposed TIP Elements(cont.) • Submittal Process for Final Draft of TIP • Present to NRC • Present to Council for resolution for approval • Submit final draft to EPA for approval

  28. GRIC TIP Stakeholder Participation Process • TIP Concept paper • Summary described benefits of TIP, funding sources, EPA regulation vs Tribal etc. • Proposal describing need, AQ issues, goals & objectives • Presented to NRC and Council • Received direction to develop TIP scoping document

  29. GRIC TIP Stakeholder Participation Process (cont.) • Council resolution approving proposal to EPA for funding to develop a TIP • Developed draft scoping document (used for all outreach efforts) • Executive summary of scoping document • Definitions

  30. GRIC TIP Stakeholder Participation Process (cont.) • Outreach meetings to discuss elements of scoping document • ADEQ • Maricopa County Environmental Services • Maricopa Association of Governments • Pinal County • City of Chandler

  31. GRIC TIP Stakeholder Participation Process (cont.) • City of Phoenix • Sun Lakes • Salt River Indian Community • Fort McDowell • 7 GRIC Districts

  32. GRIC TIP Stakeholder Participation Process (cont.) • Conducted Open House on scoping document • Mass mailing of scoping document (150) • 2-presentations on proposed scoping document elements • Question and comment sheets • Approximately 50 attendees

  33. GRIC TIP Stakeholder Participation Process (cont.) • Developed summary of comments from stakeholder meetings and open house • Presented summary of comments and responses to NRC, Council, Districts • Drafted Section I of the GRIC TIP (4/00), presented to NRC, Council, Districts

  34. GRIC TIP Stakeholder Participation Process (cont.) • Returned To NRC with packet containing scoping document, Section I of TIP and Medical Waste Ordinance and circuit court decision on TAR • Meeting with ADEQ to discuss scoping document, Section I of TIP, etc.

  35. GRIC TIP Stakeholder Participation Process (cont.) • Special breakfast meeting at request of NRC to discuss progress of TIP, scoping document, MWO • Council meeting with Scoping Document, summary of comments/responses, AQ chart, definitions, funding summary, values of AQ program (received final approval of scoping document)

  36. GRIC TIP Stakeholder Participation Process (cont.) • Meetings with NRC and Council (8/00-11/00) • Revisions to MWO • Resolution for GRIC designation recommendation under 8 hour ozone NAAQS • NCAI resolutions • Unanimous approval of GRIC resolution • Unanimous approval of NCAI resolutions

  37. GRIC TIP Stakeholder Participation Process (cont.) • Council meeting (12/00) • Section I of TIP with outline and chart • Section I of TIP unanimously approved to submit for public comment (45 days) • NRC meeting • AISES air video

  38. GRIC TIP Stakeholder Participation Process (cont.) • NRC Meeting • Section I of TIP with outline and chart • Virgil Masayesva and David LaRoche (ITEP) • Doug McDaniel (EPA) • Section I of TIP unanimously approved

  39. GRIC TIP Stakeholder Participation Process (cont.) • Council meeting • Medical Waste Ordinance • Administrative procedures/appeals process • Recommended special Council meeting

  40. GRIC TIP Stakeholder Participation Process (cont.) • Special Council Meeting • Medical Waste Ordinance • Administrative procedures/appeals process • Dean Suagee-Vermont Law School presented • Attended by GRIC Departments and Law Office

  41. GRIC TIP Stakeholder Participation Process (cont.) • Submitted Section I of GRIC TIP for public comment 45 days (mid May 2001)

  42. GRIC TIP Stakeholder Participation Process (cont.) • Lessons Learned • Summarize all technical documents/ proposals • Develop consistent process for submitting documents to decisions makers (e.g. NRC, Council, Districts) • Document all questions and comments

  43. GRIC TIP Stakeholder Participation Process (cont.) • Lessons Learned • Expect the Unexpected (opposition from anywhere-questions from left field) • Once is not enough! Be repetitive! • Education is the key • Assume no one knows anything about CAA • Simplify technical docs into layman's terms • Spell out acronyms, include maps/pictures/graphics

  44. GRIC TIP Stakeholder Participation Process (cont.) • Patience • Perseverance

  45. GRIC Medical Waste Management Ordinance Development • Medical Waste Incinerator located at GRIC in 1993 • GRIC drafted MWO in 1993 to regulate storage, handling and treatment of HMI waste • No federal emission limits at this time

  46. MWO Development (cont) • EPA promulgated federal guidance 40 C.F.R subpart Ce for HMIWIs • Guidance had emission limits more stringent than existing GRIC MWO • EPA promulgated Federal Rule, HHH • Fed guidance and rule contained addition requirements (testing, training, reporting, waste reduction etc.)

  47. MWO Development (cont) • DEQ felt that existing ordinance needed revision • DEQ research discovered a permit with more stringent emission limits than Feds (Bay Area incinerator) • Bay area emission limits based on health assessment • GRIC adopted Bay Area limits

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