# Alcoa 

# Inc.

July 

### 28, 

### 2006 Gila River lndian Community Department 

### of EnvironmentalQuallty P.O.Box 

### 97 Sacaton, 

### AZ 85247 Alcoa Engineered !c., 

## r-1,

. Pknab Operations I

,,"., ; '

, I? !

### .' ! f 

### :1 6833west Wills Road

I TeC: 1 520 796 1OD8 I--.-. Fax 1 480 598 2278 

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Certified Mail 

### 7006 

### 0100 0001 

### 541 6 7699 Return Receipt Requested



### Subject: Comments 

### on Gila River lndian Community (GRIC) Tribal lmpiementation Plan (TIP) 

### for Air 

### Quality Management Dear GRIC Representative: Pleasefind the enclosed comments on the Gila River lndian Community (GRIC) Tribal Implementation Plan (TIP) for Air Quality Management. These formal comments have been prepared and submitted on behalf of Pimalco. Pimalco is located on the Lone 

### Butte Industrialpark of the Gila River lndian Community and is currently permitted as 

### a Title 

### V source by 

### U.S. EPA. These comments are being submitted in accordance with the public notice requirements specified by the Gila River lndian Community Department of EnvironmentalQuality. If you have any questions or need additional information, please contact Mr. Ryan Richards of my staff at 1480-598-2236 or via email at 

### rvan.richards@alcoa.com. Sincerely,

Location Manager Pimalco 

### CC: Clay Long, 

### PE 

## - Manager of Environmental Services -Alma Engineered File

### Pimalco Comments on 

### Gila River Indian Community (GRIC) 

### Tribal Implementation Plan 

### (TIP) for 

### Air Quality Management July 2006

5 

### Section Summaries

## - Part 11: 

### Permit Requirements

# - (C) 

### General Concepts in 

### the Permit 

## /( %id,rdinance 

## -(4) Emission limits and emission standards 

### \& This section notes that the basis of emission limits are predicated upon Technical Support &do.* Docutnents 

### (TSD) and that 

### the TSD's will be presented with specific ordinances in the nertr future. Sincethe 

### TSD forms the basis for regulatory framework, these TSD's should be provided for review. 

### Part 11. 

### Permit Requirements

## - 1.0 

### Definitions

# - Ultra Hazardous air pollutants: Pirnalco previously commented on the Tribes newly defined ultra hazardous air pollutants which 

# dr include chemicals listed at 112 

### (r) for accidental release prevention. Section 112

### r chemicals were intended for accidental reIease prevention under CAA and were not intended 

### asa permit parameter. Based on this, the ordinance should only address criteria and hazardous air pollutants 

### as defined 

### in the Clean Air Act and should not be included 

### as a permit parameter. Specifically,

### the ordinance indicates 

### a regulatory threshold of 

### 300 

### pounds for permitting purposes. This threshold 

### has no technologyor health based standard and appearsto be arbitrary and capricious with no scientific basis. Based on this, Pimalco requests that the concept of "ultra hazardous air poilutants" be removed fkom 

### the ordinance.

P 

### Part V 

### - Area Source Emission Limits 

# - This section refers to fugitive dust producing activities that generate emissions. Under 

### the CAA, an "area source" is a source that emits less than major source thresholds of hazardous 

### air pollutants. Because of this, Pimalco is concerned that this duel meaning may lead to confusion and ambiguity. Pimalco requests that this 

### Part 

### VI 

# - Area Source Emission Limits 

# - Cleaning

## - 1.2 

### Exemptions --I_ 

# __ _ This language should be modified to read exactly as the exemption language at Part VI, Section 

### 2.0

### VOC Usage, Storage and Handling, 1.2.D which reads "Any other VOC 

### - source category

__ specificallyregulated under this ordinance".

-- .- - -.) The exemption language at 

### Part V1, Section 3.0, 1.2 Exe reads: "Solvent cleaning operation specificallyregulated by another Section in 

### th This exemption should read: "Anyother VOCsource cateaurv s~eci fical& redated

~4"",. Page? 

## ?',@<+ 

## .k)-,. 7RSR006 7-27-2006 TIP Comments

### Part VII -Source Specific Emission Limits for Existing and 

### New Sources 

## -Section 1.0 

### Secondary Aluminum Production 

## - Section 2.2 Volatile Organic 

### Compounds To provide flexibility in achievingthe VOC requirements and 

### also to address secondary aluminum facilitiesthat do not have tube mill solvent operations, Section2.2 should 

### be preceded with the following language to allow the flexibility of meeting the VOC requirements under Section 

### VII: "The owner or operator ofa source subject to this section shall have the option ofmeeting the requirements VOCreduction requirements specged below or meeting the requirements specijied at Part Vi,Section 2.0 

### VOC Usage, Storage and Handling andPart 

### Vi,Section 

### 3.0Degreasing andSolvent Metal Cleaning. " This language will allow for flexibilityin achieving

### VOC reductions. 

### Part 11

# -Permit Requirements, Section 11.6 

### Accelerated Application Processing Fees The draft ordinanceprovides for an accelerated processing of air permits that entails a 50% surcharge over existingpermit processingrates. 

### The surcharge is 

### 50% over standard charges 

# qvlZ (currently $40,000

### maximum) and provides for a 

### 120day turnaround for major modifications under Section 11.6in the ordinance. Pimalco is opposed to the concept of an accelerated application processing fee without having any statutory timeframe for normal permit application processingturnaround. Without a statutorily defined turnaround period, delays in the process can effectivelyforce pennit applicantsto seek the accelerated turnaroundjust to get a permit. The draft ordinanceprovides for a generous funding mechanism for permit processing fees. Based on this, the ordinance should provide a defined period for permit review and issuance 

### as a baseline. Then if 

### an applicant wishes to have it's permit reviewed 

### in an accelerated manner, they could opt for the 50% accelerated processing fee. Eliminate the sectionfor "Accelerated Application Processing Fee" and replace it with "Time Periods for Determination on Permit Applications". 'The current ordinance does not provide for 

### any time period for reasonable review of a permit application. As such, any permit could be held indefinitely unless the permit applicant choseto pay the proposed "Accelerated Application ProcessingFee". As such, the "Accelerated Application Processing Fee" can become 

### a de-facto 

### .SPA surcharge for permit review. As a component of assumingprimacy of the air programs from 

### U.S. EPA, 

### GRlCshould establish saecifictimeperiods for determination onpermit amlications. This would eliminate 

### any subjectivity or differences in permit application approval time fiames from sourceto source and provide a uniform structure for approval.

Page 3 7128,2006 7-27-2006 TIP Comments