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Gila River Indian Community

Gila River Indian Community. Enforcement Case Study Daniel Blair, Compliance and Enforcement Mgr. 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

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Gila River Indian Community

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  1. Gila River Indian Community Enforcement Case Study Daniel Blair, Compliance and Enforcement Mgr.

  2. 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

  3. Gila River Indian Community Monitoring Stations Industrial Parks Sand & Gravel

  4. 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)

  5. AQMP Background

  6. AQMP Elements • 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 • 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

  7. GeneralChemical

  8. GC Background • Ferric Chloride & Aluminum Sulfate Production Plant • Ferric Chloride - HCl, water and iron oxide • Aluminum Sulfate – Sulfuric Acid, water and alum • GC recently purchased facility from Chalum and upgraded to include ferric chloride process (GC conducted Community meetings requesting new process) • Installed state of the art equipment • New tanks, automatic overfill equipment, safety equip. etc.

  9. General Chemical • Community members and DEQ had a concern about HCl storage (Rail Cars) • Odors Acid Vapors • Spills • Accidents • GC Assured the Community that there would not be any problems

  10. GC Enforcement Action • Observed “Red” plume from behind Rail Cars • Tote unloading equipment not operating properly • Observed numerous other waste violations

  11. GC Enforcement Action • Conducted full inspection (Air & Waste) • Issued a Notice of Violation (NOV) Air & Waste Violations • Offer to convene Enforcement Conference • Potential violation 3.4 million (calculated) • Issued Consent Order with $25,000 penalty • Required Corrective Action Plan (CAP) with enforceable requirements and timelines • GC complied with all requirements

  12. GC Enforcement Action • GC scraped up all spilled iron oxide and hauled it to landfill • Repaired containment areas, sumps etc. • Reengineered Tote Unloading System (observed restart) • Submitted iron oxide storage plan • Submitted Air Quality Operating Permit Application • Paid $25,000 penalty

  13. Things to Consider Before Conducting Enforcement Action • Legal Authority • Tribal ordinances • Delegation of Federal NSR program • Leases etc. • Permits • Documentation of Violation • Complaint reports • Inspection reports • VE sheets • NOVs/Orders • Pics

  14. Things to Consider Before Conducting Enforcement Action • Notification of Proposed Enforcement Action to • Tribal Law Office/Attorneys • Tribal Council ? • EPA • Other Affected Parties (e.g., Industrial Park Board, GRSG etc.)

  15. Contact Information • Will Antone III, Air Quality Specialist • PO Box 97 Sacaton, AZ 85147 • (520)562-2234 • wantone3@gilanet.net • Dan Blair, Compliance & Enforcement Manager • PO Box 97 Sacaton, AZ 85147 • (520)562-2234 • air@gilanet.net

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