                                       
         Technical Support Document for Review of Request for Coverage
Request for Coverage under the General Air Quality Permit for New or Modified Minor Source Hot Mix Asphalt Plants in Indian Country
                                       
              Fann Contracting Inc., HP04 Portable Asphalt Plant
                                       
                                 June 3, 2022

Applicant:
Andrew Rice, EHS Officer
Fann Contracting Inc.
6725 Generational Lane
Prescott, Arizona  86301
Source:
HP04
Source Location:
Weeminuche Pit, Milepost 1.5 US 160, Cortez, Colorado 81321, on the Ute Mountain Ute Reservation (Latitude 37°00'31.8", Longitude 109°00'42.0")
Source Technical Contact:
Andrew Rice, Fann Contracting, Inc., 
(928) 778-0170, andrew@fanncontracting.com


Application #:
GEN-UM-000015-2022.001
Docket:
EPA-R08-OAR-2022-0297
Summary
Pursuant to the provisions of Clean Air Act (CAA) sections 110(a) and 301(d) and the Federal Indian Country Minor New Source Review (NSR) Program at Code of Federal Regulations (CFR) title 40, sections 49.151-161 (Tribal Minor NSR Program), the United States Environmental Protection Agency Region 8 is approving a Request for Coverage under the General Air Quality Permit for New or Modified Minor Source Hot Mix Asphalt Plants in Indian Country (HMA General Permit) to Fann Contracting, Inc., (Fann or Applicant) for the construction and operation of a new hot mix asphalt plant. Fann's new hot mix asphalt plant will be located at the Weeminuche Pit, Milepost 1.5 US 160, Cortez, Colorado 81321, on the Ute Mountain Ute Reservation (Latitude 37°00'31.8", Longitude 109°00'42.0"). The HMA General Permit, the permit under which the Applicant is seeking coverage, was issued by the EPA under the Tribal Minor NSR Program on May 1, 2015, with an effective date of June 1, 2015. See 80 FR 25068 (May 1, 2015).
This technical support document (TSD) provides the EPA Region 8's analysis of whether the Source is within the category of emissions sources to which the HMA General Permit applies and whether the source meets the criteria to be eligible for coverage under the HMA General Permit. This analysis and other information required by 40 CFR 49.157(a) will be made available to the public through the online docket for this action and, as applicable, at the EPA Region 8 office. Additional information for accessing the publicly available information is provided at the end of this TSD.
Source Description and Project Summary
On March 1, 2022, the EPA Region 8 received an initial Request for Coverage under the HMA General Permit from Fann for the construction and operation of a portable HMA plant, facility name HP04, at the Weeminuche Construction Authority's Four Corners Gravel Pit (Weeminuche pit), Milepost 1.5 US 160, near Cortez, Colorado, on Indian country lands within the Ute Mountain Ute Reservation (the Source). 
Fann is proposing to construct and operate a portable facility to produce asphalt from a drum mix plant. The process to manufacture asphalt begins with aggregate loaded into several hoppers and conveyed at specific rates to a pugmill. The pugmill mixes the material and a mineral admixture is added. The material is then conveyed into the drum dryer and paving grade oil is added. Recycled asphalt product (RAP) is also added to the drum at this time. Particulates and other emissions from the drum dryer are ducted to a fabric filter baghouse. After blending and heating, the final asphalt product is elevated via a drag conveyor to the surge hopper. The surge hopper loads the loadout silo, and the loadout silo then dumps finished asphalt into a truck for transport to various paving project locations.

Fann has requested approval for coverage under the General Permit using distillate fuel (diesel) in the interim while the EPA processes an application for a synthetic minor NSR permit for the operation to use used oil, which is not allowed under the General Permit. Documentation of emissions calculations and ESA/NHPA evaluation for the plant, necessary to evaluate the request for coverage under the General Permit, was provided in the synthetic minor NSR application (dated March 1, 2022), which is included in the docket for this General Permit approval. On March 2, 2022, Fann submitted additional clarifying information regarding the request for approval. On March 23, 2022, Fann verified that the plant operations will not be under the control of the gravel pit operator, Weeminuche, but will be fully operated independently by Fann through an agreement with Weeminuche to co-locate on the gravel pit property.
The EPA notes that Fann has also submitted applications for coverage under the HMA General Permit and for a similar synthetic minor permit for another plant, HP03, at the same location as proposed for HP04 (see docket #EPA-R08-OAR-2022-0297 and #EPA-R08-OAR-2022-0296). The applicant has indicated that both HP03 and HP04 will not operate at the proposed location at the same time. The Agency may take additional action on the coverage of the Source under the HMA General Permit following issuance of source-specific synthetic minor permits for the HP03 and HP04 plants at the proposed project location.
In response to these submittals, the EPA determined that we received sufficient information to demonstrate eligibility for coverage under the HMA General Permit and, thus, the Applicant had submitted a complete Request for Coverage. Accordingly, we refer hereinafter to the March 1, 2022, Request for Coverage submittal and subsequent addenda to that request (and all attachments to those submittals), collectively, as the "Request for Coverage." This TSD describes our analysis of the Applicant's Request for Coverage for the Source and the legal and factual basis for our approval.

The geographic area where the Source will be located is designated attainment, unclassifiable or attainment/unclassifiable under the CAA for all National Ambient Air Quality Standards (NAAQS) pollutants.

The source has a maximum capacity of 400 tons per hour. The proposed operation will include the equipment listed within the table below.
                                       
Table 1: List of Affected Emission Units
                                   Unit ID #
                    Description of Affected Emissions Unit
                            Maximum Rated Capacity
                             Date of Construction
HPDR01
Drum Dryer/Mixer with Baghouse (fabric filter); Distillate Fuel 
400 TPH; 132 MMBtu/hr
TBD
HPHT02
A/C Oil Above-Ground Storage Tank
20,000 gallons
TBD
HPFT02
Diesel Fuel Above-Ground Storage Tank
12,000 gallons
TBD
Aux Heater
Auxiliary Heater
1.8 MMBtu/hr
TBD
 
Background
The CAA provides the EPA with broad authority to protect air resources throughout the nation, including air resources in Indian country. Unlike states, Indian Tribes are not required to develop CAA new source review (NSR) permitting programs. See, for example, Indian Tribes: Air Quality Planning and Management, 63 FR 7253 (February 12, 1998) (also known as the Tribal Authority Rule, or TAR). In the absence of an adequately implemented the EPA‐approved NSR program on the Ute Mountain Ute Reservation, the EPA has the authority to implement a Federal Implementation Plan (FIP) in order to protect tribal air resources from impacts due to the construction of new or modified stationary sources of air pollutants. In 2011, the EPA finalized the Review of New Sources and Modifications in Indian Country (Tribal NSR Rule), codified at 40 CFR part 49, as part of a FIP under the CAA for Indian Country (see 76 FR 38748 (July 1, 2011)). Among other requirements, the Tribal NSR Rule set forth procedures and terms under which the Agency would administer a minor NSR permitting program in Indian country (MNSR Permit Program).
As part of the Tribal NSR Rule, the EPA adopted the option of developing general permits for certain categories of minor sources to which the MNSR Permit Program would apply. The purpose of a general permit is to provide for the protection of air quality while simplifying the permit issuance process for similar facilities in order to minimize the burden on the reviewing authority and the regulated sources. The EPA finalized the HMA General Permit effective June 1, 2015 (80 FR 25086 (May 1, 2015). New and modified minor sources that are true minor sources or major sources seeking to become synthetic minor sources may apply for coverage under the HMA General Permit if their potential to emit for new, modified and existing units is below major source thresholds and the source can meet the throughput limits and other terms and conditions set forth in the HMA General Permit. Sources seeking coverage under the HMA General Permit must also demonstrate that they meet certain additional eligibility criteria.

Applicability of the Tribal Minor NSR Program
The preconstruction permitting program is triggered for new or modified sources in locations covered by the Tribal NSR Program based on potential increases in air pollutants according to the applicability criteria in 40 CFR 49.153. Generally, source owners and operators first determine whether their new or modified source is subject to the CAA major NSR permitting program (pursuant to 40 CFR 52.21 for areas designated as attainment/unclassifiable for the NAAQS and/or 40 CFR 49.166 through 49.175 for areas designated as nonattainment for the NAAQS). For new or modified sources that are not subject to major NSR review, the owner and operator must evaluate whether the Tribal Minor NSR Program applies. 
The minor NSR permitting thresholds vary depending on whether the area in which the Source is or will be located is designated attainment and/or unclassifiable for the NAAQS, or designated nonattainment for the NAAQS. In this case, the Source is to be located within Montezuma County, Colorado within the Ute Mountain Ute tribal land which is designated attainment/unclassifiable under the CAA for all NAAQS pollutants. Thus, our consideration of the applicable permitting thresholds is based on the Tribal Minor NSR thresholds for attainment areas in Table 2 below.

Potential to emit (PTE) means the maximum capacity of a stationary source to emit an air pollutant under its physical and operational design. PTE is meant to be a worst-case emissions calculation and is used in many cases to determine the applicability of federal CAA requirements. Table 3 summarizes the Source's PTE and includes consideration of the applicable emissions limitations in the general permit. Because emissions of carbon monoxide (CO), nitrogen oxides (NOx), volatile organic compounds (VOC), particulate matter (PM) (including PM that is less than 2.5 μm in diameter (PM2.5) and less than 10 μm in diameter (PM10)) exceed the applicable minor NSR permitting threshold, and do not exceed the major source NSR thresholds, the Source is subject to the Tribal Minor NSR Program.

Emissions Calculations and Potential to Emit
The emission calculations for the Source are provided below in Table 3. The Tribal NSR Rule establishes specific PTE thresholds for new or modified stationary sources that trigger the requirement to obtain a preconstruction permit under the Tribal Minor NSR program. Table 2 lists the minor and major source thresholds pursuant to 40 CFR 49.153 (Tribal Minor NSR), and 40 CFR Part 52.21(b)(1)(i)(b) (PSD Major Source). 

Table 2. Source PTE & NSR Permitting Thresholds in tons per year (tpy)
                                   Pollutant
                          MNSR Thresholds for Attainment Areas
                    Major Source PSD Thresholds for Attainment Areas
                             Carbon monoxide (CO)
                                      10
                                      250
                             Nitrogen oxides (NOX)
                                      10
                                      250
                             Sulfur dioxide (SO2)
                                      10
                                      250
                       Volatile Organic Compounds (VOC)
                                       5
                                      250
                                      PM
                                      10
                                      250
                                     PM10
                                       5
                                      250
                                     PM2.5
                                       3
                                      250
                                     Lead
                                      0.1
                                       -
                                   Fluorides
                                       1
                                       -
                              Sulfuric acid mist
                                       2
                                       -
                               Hydrogen sulfide
                                       2
                                       -
                             Total reduced sulfur
                                       2
                                       -
                           Reduced sulfur compounds
                                       2
                                       -

The EPA's emissions analysis is available as part of our administrative record and summarized here. In this case, we have determined that the Source triggers the preconstruction permit requirements under the Tribal Minor NSR Program because its PTE exceeds permitting thresholds. As described previously, the Applicant is seeking to obtain coverage under the HMA General Permit in lieu of obtaining a site-specific permit and has indicated that it satisfies the eligibility criteria necessary to qualify for coverage. The HMA General Permit includes enforceable physical or operational limitations on the maximum capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of operation and/or on the type or amount of material combusted, stored, or processed. Our evaluation of whether the Source qualifies for the HMA General Permit included consideration of the limitations and controls required by the HMA General Permit.

Table 3. Facility‐wide Potential to Emit (PTE) Summary (includes permit controls)
                                       
                             Pollutant (tons/year)
                                    Process
                                      PM
                                     PM10
                                     PM2.5
                                      SO2
                                      NOx
                                      CO
                                      VOC
                                  Dryer/Mixer
                                     16.4
                                     11.5
                                     1.44
                                     5.48
                                     18.9
                                     64.7
                                     15.9
                             Load-out/Silo Filling
                                     0.55
                                     0.55
                                     0.55
                                       -
                                       -
                                     1.22
                                     8.02
                                   Conveying
                                     2.99
                                     1.10
                                     1.10
                                       -
                                       -
                                       -
                                       -
                                   Screening
                                     1.10
                                     0.37
                                     0.02
                                       -
                                       -
                                       -
                                       -
                                 Storage Piles
                                     1.80
                                     0.85
                                     0.13
                                       -
                                       -
                                       -
                                       -
                               Lime Silo Loading
                                     4.82
                                     4.82
                                     4.82
                                       -
                                       -
                                       -
                                       -
                               Auxiliary Heater
                                     0.11
                                     0.19
                                     0.14
                                      0.0
                                     1.13
                                     0.28
                                     0.02
                                     Total
                                     27.80
                                     19.32
                                     8.21
                                     5.49
                                     20.05
                                     66.24
                                     23.97
General Permit Eligibility Criteria
Based upon our review of the Request for Coverage, we have determined the Source qualifies for the HMA General Permit because it meets the following criteria:
 The Source is a minor source drum hot mix asphalt plant that is located in Indian Country;
 The Source only produces hot mix asphalt;
 The Source only uses distillate fuel in the dryer/mixer;
       The Source is located in an attainment/unclassifiable area for ozone, and the asphalt production rate will be equal to or less than 83,000 tons per month; 
 The asphalt dryer/mixer at your facility is controlled by a baghouse (fabric filter);
       You use only the following fuel(s) in the auxiliary heaters: natural gas, propane, distillate fuel and biodiesel; and
       The total maximum heat input capacity of the auxiliary heaters (including hot oil heaters) is equal to or less than 10 MMBtu/hour.
      
As discussed further below, the Applicant has met the eligibility criteria related to listed species and historic properties.

Listed Species‐Related Eligibility Criteria
The EPA developed eligibility criteria related to species that are listed as endangered or threatened under the Endangered Species Act that applicants must satisfy to qualify for coverage under the HMA General Permit. Appendix A to the Request for Coverage form for the HMA General Permit provides detailed screening procedures for applicants to follow to assess the potential impacts of their sources on federally‐listed species and their critical habitat. To be eligible for coverage under the General Permit, sources must demonstrate that they have satisfactorily completed the screening procedures and that they meet one of the species‐related eligibility criteria, provide sufficient documentation supporting the criterion selected and obtain confirmation from the EPA that they have done so.
The Request for Coverage states that the Source meets Criterion A of Appendix A with respect to listed species protection. 

Fann included a Biological Assessment for the Weeminuche Hot Plant Location (see synthetic minor permit application in the Docket, dated March 1, 2022, Document ID #EPA-R08-OAR-2022-0297-0005) The assessment relied on data from the U.S. Fish and Wildlife Service as of February 23, 2022. Fann concluded that due to the existing developed use of the Weeminuche pit property, the Source activities will not have an adverse effect on endangered plants or animals. The Source area is already devoid of flora as it is a working mine. The area is already fenced to prevent species from coming into contact with equipment. The area is also bermed on all sides to prevent water runoff carrying contaminants.

After review and consideration of this information and documentation, the EPA agrees that the Applicant has completed the species‐related screening procedures and has demonstrated, providing appropriate documentation, that the proposed Source meets Criterion A of the listed species‐related eligibility criteria for coverage under the HMA General Permit.

Historic Properties‐Related Eligibility Criteria
The EPA developed the screening process in Appendix B of the Request for Coverage form to enable source owners/operators to appropriately consider the potential impacts, if any, resulting from the construction, modification and/or operation of a new or modified emission source on historic properties and, if applicable, to determine whether actions can be taken to mitigate any such impacts. To be eligible for coverage under the HMA General Permit, sources must demonstrate that they have satisfactorily completed the screening procedures and that they meet one of the historic property‐related eligibility criteria, provide sufficient documentation supporting the criterion selected and obtain confirmation from the EPA that they have done so.
With respect to the Source, Fann indicated in the Request for Coverage that the screening process in Appendix B of the Request for Coverage form had been completed to determine if the construction, modification or operation of the Source has the potential to cause effects to historic properties. 

The application included a May 12, 2009, letter from the U.S. Bureau of Indian Affairs Southwest Region for the proposed construction of the Weeminuche pit. Three archeological sites, 5MT19089, 5MT19090, and 5MT19094, were encountered during the survey. It was determined that these sites would not be impacted by the proposed gravel mining operations at the site. The application also included a May 12, 2010, letter referencing the 2009 letter and a May 12, 2010, re-survey. The survey found that the fencing is at least 100-150 feet from the sites, that the previous report is correct, and that areas proposed for future projects were well away from the sites.

Based on the documentation provided in the Request for Coverage, the EPA has concluded that Fann has demonstrated that it has satisfactorily completed the historic property‐related screening procedures, that the Source meets the historic property‐related eligibility criteria for the HMA General Permit of No Historic Properties Affected and that Fann has provided sufficient documentation supporting the criterion selected. 

Environmental Justice
The EPA believes the human health or environmental risk addressed by this action will not have potentially, disproportionately high and adverse human health or environmental effects on communities of color, low-income or indigenous populations. The EPA's primary goal in developing the HMA General Permit is to ensure that air resources in Indian country will be protected in the manner intended by the CAA.

The HMA General Permit will limit adverse impacts by restricting operations and emissions. In addition, the HMA General permit is part of a preconstruction permitting program for minor sources in Indian country that is comparable to similar programs in neighboring states that, upon promulgation in 2011, filled a regulatory gap that did not previously evaluate or restrict minor sources of emissions in Indian country, while the emissions from similar sources in state jurisdiction were regulated
      
This permit action would authorize the construction of a hot mix asphalt plant. The EPA reviewed the area around the facility encompassing a one- and three-mile radius from the location. EJScreen indicates there are no persons within a one-mile radius and twelve people who live within a three-mile radius. , The area within a three-mile radius encompasses the four corners of Utah, Colorado, New Mexico, and Arizona, as well as portions of the Ute Mountain Ute and Navajo Reservations.

The EJScreen results indicate that the area within a three-mile radius of the project area exhibits an EJ index at the 92nd percentile, nationally, for ozone, meaning that 8 percent of areas nationally report higher results for that particular index (which is based on a combination of summer seasonal average of daily maximum 8-hour concentration in air (ppb) for ozone combined with population demographics) than the project area. This percentile suggests that there is a potential for an air quality issue in the area around the facility and a potential EJ concern. The EJScreen results also indicate that the incidence of people of color and low-income population in the area within a three-mile radius of the project area is 99% and 59%, respectively which is much higher than the state average for both.

This HMA plant would emit new ozone precursor pollutants. The operational limits set by the HMA general permit result in an estimated potential to emit of 20 tons of NOx and 24 tons of VOCs. The ozone precursor pollutants, namely NOx, would be emitted from stacks that are 12 feet aboveground or less. The Agency believes that the relatively small emission of ozone precursors in an area with no inhabitants within one mile is unlikely to present an impact to communities overburdened with ozone. The EPA does not attribute emissions from one source as a concern for impacting ozone concentrations or design values, as emissions tend to dissipate at short distances from the source boundary (less than 1 mile).

However, the Agency also considered a three-mile radius due to the lack of demographics in the one-mile radius of the source. As mentioned above, the three-mile radius resulted in a 92[nd] percentile for the EJ index, nationally, for ozone. The ozone value provided by EJScreen for the summer seasonal average of daily maximum 8-hour concentrations is 55.7 ppb. While a high ozone value nationally, this value falls in the 32[nd] percentile for the state of Colorado, indicating that this is not a unique environmental indicator for the local community within three miles of the source.

EJScreen does not directly model all Criteria Air Pollutants (e.g., NOx and VOCs). Instead, EJScreen uses a downscaling fusion model that relies on both air quality monitoring data from NAMS/SLAMS and numerical outputs from the Models-3/CMAQ. EJScreen also relies on the most recently available data for both environmental and demographic indices. There is the potential for considerable uncertainty in a screening analysis for ozone relying on EJScreen. 

EJScreen indicates the nearest regulated air facility for air pollution is 6.6 miles north (Geodyne Resources, facility ID CO0000000808300058, SIC Code 1311). Ozone daily AQI values for Montezuma county from 2015 to 2021 indicate a limited number of days occur in which the air quality index is "Unhealthy for Sensitive Groups," while most days are "Good" or "Moderate." 

The EPA sets NAAQS for ozone. The HMA general permit was designed to be protective of the NAAQS and Region 8 therefore believes that the HMA General Permit is appropriately protective with respect to the Source. As stated previously, there is no population residing within one mile of the project area and the emissions from the source are expected to dissipate over short distances. EJScreen estimates that the approximate population within three miles of the source is twelve people. The nearest regulated source of air pollution to the source is 6.6 miles north and the AQI values for Montezuma County are generally "Good" or "Moderate." 

The Ute Mountain Ute Tribe Air Quality Program received copies of all materials related to the Request for Coverage under the HMA General Permit and was included in all communications with Fann regarding the request. Further, upon receipt, the EPA made all information related to the EPA's Approval for Coverage under the HMA General Permit accessible online to the general public for review until the approval was issued, during which time anyone could object to the appropriateness of this particular source's coverage under the HMA General Permit. The Agency is concurrently evaluating an application for a synthetic minor permit for the same source to allow the use of waste oil instead of diesel (waste oil is not permissible under the HMA General Permit). The Agency may revisit this HMA General Permit approval, if additional information makes apparent the need for additional protections. 
Public Participation
As described in 40 CFR 49.157, issuance of general permits pursuant to the MNSR Permit Program must meet public participation requirements. Before issuing a permit under the MNSR Permit Program, the EPA must prepare a draft permit and must provide adequate public notice to ensure that the affected community and the public have access to the draft permit information. The public notice must provide an opportunity for a 30‐day public comment period and notice of a public hearing, if any, on the draft permit. Consistent with these requirements, during the development of the proposed HMA General Permit, the EPA followed the applicable public participation process and received numerous comments. The EPA considered and addressed these comments in its issuance of the final HMA General Permit (see 80 FR 25068 (May 1, 2015)).
For coverage of a particular source under the HMA General Permit, the EPA's analysis of whether the source is within the category of emissions sources to which this General Permit applies, including whether the source meets the criteria to be eligible for coverage under the general permit, must be made available to the public. While the EPA was in the process of reviewing the Request for Coverage for the Source under the HMA General Permit, certain supporting documentation, including the Request for Coverage, any additional information requests made by the EPA to the Applicant and any additional information submitted by the Applicant, were made available to the public on the EPA website at: http://www.epa.gov/caa-permitting/caa-permit-public-comment-opportunities-region-8. The EPA has described its analysis in this TSD, which will be made accessible, along with the EPA's Approval of the Request for Coverage for the Source under the HMA General Permit and all supporting documentation (the Administrative Record), on the EPA website at:
http://www.epa.gov/caa-permitting/caa-permits-issued-epa-region-8.  

Approval of Request for General Permit Coverage
The EPA has carefully reviewed the Request for Coverage, and other relevant information, to determine whether the Source meets all of the criteria to qualify it to apply for coverage under this General Permit. Based on our review of, and in reliance on, all of the information and representations provided in the Request for Coverage, the EPA has determined that the Source meets all such criteria, is eligible for coverage under the HMA General Permit and is approving the Request for Coverage for the Source. The EPA's review with respect to some of these criteria was discussed in more detail throughout this TSD.
Additionally, Fann submitted documentation to indicate HP04's 1,110 horsepower diesel-fired generator engine is portable or transportable and thus is considered a non-road engine per 40 CFR 1068.30 (see Request for Coverage Revision in the Docket, dated March 3, 2022, Document ID #EPA-R08-OAR-2022-0286-0002). The EPA' s Approval of the Request for Coverage for the Source is based in part on representations by Fann in the Request for Coverage and subsequent communications that the engine powering the equipment at the Source is a nonroad (mobile) engine that will operate at the site identified above for a period of less than one year. We note that if such engine and/or replacement engines intended to perform the same or a similar function are intended to be utilized for hot mix asphalt production operations at the Weeminuche Pit for a period of at least 12 consecutive months (or for a shorter time, if operations are·conducted on a seasonal basis for consecutive seasons), or are actually utilized for this length of time, the engine would be considered a stationary source and subject to further requirements under the HMA General Permit. In that case, the Source would not be eligible for coverage based on the current Request for Coverage, which does not indicate that any stationary engines will be utilized for the Source.
 
Final Agency Action  -  Judicial Appeal 
The EPA's Approval of the Request for Coverage ("Approval") for the Source is a final agency action for purposes of judicial review only for the issue of whether the Source qualifies for coverage under the HMA General Permit. 40 CFR 49.156(e)(6). Any petition for review of this approval action must be filed in the United States Court of Appeals for the appropriate circuit pursuant to CAA section 307(b).
Public Availability of Information
The EPA's Approval, this TSD and all other supporting information for this action are available through the online docket at www.regulations.gov, Docket ID:EPA-R08-OAR-2022-0297. If you have trouble accessing materials, please contact the EPA Region 8 contact listed below. 
Daniel Fagnant
Air and Radiation Division (8ARD-PM)
U.S. Environmental Protection Agency, Region 8 
1595 Wynkoop Street
Denver, Colorado  80202
Phone: (303) 312-6927  
E‐mail: fagnant.daniel@epa.gov

Paper copies of these documents can be sent to individuals upon request in accordance with Freedom of Information Act requirements as described on the EPA Region 8 website at http://www.epa.gov/region8/epa-region-8-foia-office-contact.


The EPA is also providing this TSD and our Approval of Request for Coverage for the Source to:

Scott Clow, Environmental Programs Director 
Ute Mountain Ute Tribe
Environmental Programs Department
P.O. Box 448
Towaoc, Colorado  81334
(970) 564-5432
sclow@utemountain.org
