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How to Develop a Permit— T he Process and Implementation. Gila River Indian Community By Will Antone III, Air Quality Specialist. Summary of Presentation. Community Background Air Quality Management Plan Permit Process Review Technical Support Document Overview of Permit
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How to Develop a Permit—The Process and Implementation Gila River Indian Community By Will Antone III, Air Quality Specialist
Summary of Presentation Community Background Air Quality Management Plan Permit Process Review Technical Support Document Overview of Permit Enforcement Case Study
Gila River Indian Community Background • Established in 1859 by Executive Order • Consists of two (2) tribes • Akimel O’odham (Pimas) – Districts 1 thru 5 • Pii-Pash (Maricopas) – Districts 6 & 7 • Landbase • 374,000 Acres • Population • On reservation 15,000 • Off reservation 5,000
Gila River Indian Community Monitoring Stations Industrial Parks Sand & Gravel
Industry Background • Two industrial parks, 50 businesses & industries • Pacific Scientific, Triumph, Local Motors, Superlite Block, Pimalco, Champion Homes, etc. • Other GRIC-Area Sources • 40,000 agricultural acres • Acreage will increase to 146,000 over next 10 years • Interstate 10 bisects Community • (largest source of air pollution)
Air Quality Management Plan • Part I. General Provisions • Part II. Permit Requirements • Part III. Enforcement Ordinances • Part IV. Administrative Appeals • Part V. Area Source Emission Limits • Open Burning • Fugitive Dust
Air Quality Mgmt. Plan (cont.) • Part VI. General Requirements • Visible Emissions • VOC Usage, Storage, Handling • Degreasing, Solvent Metal Cleaning • Part VII. Source/Category Specific Emission Limits • Secondary Aluminum Processing • Aerospace Manufacturing and Rework Operations • Non-Metallic Mineral Mining and Processing
Permit Process • Mail permit packet to facility • Application, O&M Guidelines, Dust Control Plan, offer to meet • Permit meeting • Background information • AQMP overview • Application review • Timeframe • Contact information
Permit Process (cont.) • Completeness check • Request additional information • Additional on-site meeting, if necessary • Draft Permit • Research GRIC regulations, federal regulations, and emission factors • Technical Support Document • Emission calculations
Permit Process (cont.) • Mail final permit to facility 2 weeks prior to 30-day public comment period • Permit invoice • 30-day public comment period • Notice publish in local paper (Gila River Indian News) • Respond to comments, if necessary • Hold public hearing, if necessary • Issue air quality operating permit
CEMEX Enforcement Action • AQP observed emissions from Asphalt Plant • Conducted an inspection on San Tan Plant • Lead to inspection of Maricopa Plant • Observed visible emissions • Conducted visible emissions readings (U.S. EPA Method 9) on baghouse, passive baghouses and asphalt silo • Exceeded emission limitations • 7% Opacity limitations for storage silo • 20% Opacity limitations for baghouse
U.S. EPA Method 9 Visible Emissions Observations
CEMEX Enforcement Action (cont.) • Completed inspection report • Internal meetings discussing enforcement action • Research regulating authorities • Research facility background and track record • Decision on enforcement route in accordance with AQMP • Issued three (3) NOVs • Offered an opportunity to meet to discuss corrective actions
CEMEX Enforcement Action (cont.) • Received “NO” response from CEMEX • Proceeded with a Compliance Order and issued a $15K administrative penalties • $5K per violation per day • Issued letter to CEO of CEMEX • Website claimed CEMEX environmentally conscious company
CEMEX Enforcement Action (cont.) • CEMEX Environmental personnel arranged meeting • CEMEX signed order and paid $15K penalty • CEMEX submitted a Corrective Action Plan
Highlights Conducted enforcement actions using tribes inherent sovereign authority Other jurisdictions all had enforcement actions against CEMEX, sought advice from Air Quality Program on compliance strategies Achieved compliance and working relationship with CEMEX
Questions? Gila River Indian Community Dept. of Environmental Quality Will Antone III, Air Quality Specialist (520) 562-2234 Willard.AntoneIII@gric.nsn.us