Alcoa Inc. 

July 28, 2006 

Gila River lndian Community 

Department of Environmental Quallty 

P.O.Box 97 

Sacaton, AZ 85247 

Alcoa Engineered 

! c., r-1, . Pknab Operations I , ,"., ; ' , I? ! .' ! f : 1 6833 west Wills Road 

I TeC: 1 520 796 1 OD8 

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Certified Mail 7006 01 00 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: 

Please find 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 Industrial park 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 Environmental Quality. 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. 

Since the 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 1 12 (r) for accidental release prevention. Section 1 12 r chemicals 

were intended for accidental reIease prevention under CAA and were not intended as a 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 technology or health based standard and appears to 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 __ specifically regulated under this ordinance". 

-- .- - -.) 

The exemption language at Part V1, Section 3.0, 1.2 Exe reads: "Solvent cleaning 

operation specifically regulated by another Section in th This exemption should read: 

"Any other VOC source 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 achieving the VOC requirements and also to address secondary 

aluminum facilities that do not have tube mill solvent operations, Section 2.2 should be preceded 

with the following language to allow the flexibility of meeting the VOC requirements under 

Section VII: 

"The owner or operator of a source subject to this section shall have the option of meeting the 

requirements VOC reduction requirements specged below or meeting the requirements specijied 

at Part Vi, Section 2.0 VOC Usage, Storage and Handling and Part Vi, Section 3.0 Degreasing 

and Solvent Metal Cleaning. " 

This language will allow for flexibility in achieving VOC reductions. 

Part 11 - Permit Requirements, Section 11.6 Accelerated Application Processing Fees 

The draft ordinance provides for an accelerated processing of air permits that entails a 50% 

surcharge over existing permit processing rates. The surcharge is 50% over standard charges qvlZ (currently $40,000 maximum) and provides for a 120 day turnaround for major modifications 

under Section 1 1.6 in the ordinance. 

Pimalco is opposed to the concept of an accelerated application processing fee without having 

any statutory timeframe for normal permit application processing turnaround. Without a 

statutorily defined turnaround period, delays in the process can effectively force pennit 

applicants to seek the accelerated turnaround just to get a permit. 

The draft ordinance provides 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 section for "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 chose to pay the proposed "Accelerated Application 

Processing Fee". As such, the "Accelerated Application Processing Fee" can become a de-facto 

.SPA surcharge for permit review. 

As a component of assuming primacy of the air programs from U.S. EPA, GRlC should establish 

saecific time periods for determination on permit amlications. This would eliminate any 

subjectivity or differences in permit application approval time fiames from source to source and 

provide a uniform structure for approval. 

Page 3 7128,2006 

7-27-2006 TIP Comments