### Summary of Comments from Outreach Efforts on the Draft Aerospace Manufacturing and Rework Operations Ordinance Triumph Precision Casting (DickRansom, Dam Truong, Terry Crow) 

# + Met with TPC personnel and explained the GRIC TIP process and the draft ordinance for Aerospace ManufacturingKework Operations. TPC personnel indicated that the ordinance may not apply to their operationsdue to the very low usage of VOCs. They indicated that all their VOC emissionsdo not exceed 25#/day as indicated in section 1.0 A. of the ordinance. 

# + I informed TPC that VOC emissionsfrom all three Triumph operations may be aggregated as a total to determine if this ordinance applies. I also explained that the federal definition ofcontiguous operationswould have to be researched to determine whether emissions from all three facilities would be aggregated or whether each facility's emissions would be calculated separately. I informedthem that I would research the federal definition and get back with them. 

# + I also indicated that the applicabilitylevel of25# of VOC emissions/day PTE may be lowered. 

# + TPC personnel informed us that there are three separate operations all operated under the Triumph Corp. parent company. The companies are Triumph Precision Castings (TPC), Thermal Processing Unit (TPU a division ofAMTI), and Industrial Gas Turbines (IGT). TPC cast turbine fanblades and components for NUS and for IGT. TPU does rework operations on turbine fan blades forAPUs for airplanes. IGT dismantles industrial turbines for power generation, repairs and reassemblesthe turbines. This facilitymay not fall under the definitionofLLAerospace Manufacturingor Rework Facility" in accordance with section 2.5 of the ordinance. 

# + TPC personnel indicated that they have very minimal air emissionsmostly fiom burning of natural gas in their furnaces. VOC emissions are extremely low. 

# + TPC personnel indicated that they would further review the ordinance and submit comments. 

### Thermal Processing 

### Unit (TPU a division of

### AMTI) Paul Coleman 

### 5/27/03 

# + Mr. Coleman indicated that TPU will be purchasing a new Vapor Degreaser containing TCE due to the requirementby DOD customers. 

### I informed

### Mr. Coleman that the Degreaser must comply with federal requirements and the GRJC solvent cleaning ordinance. I informedMr. Coleman that the draft GRIC ordinance and the federal rule contain identical requirements.

# + Explained to Mr. Coleman that we needed to research the definition of contiguousto determine ifemissions from all three triumph facilities will be aggregated. 

# + Mr. Coleman indicated that even if all three facilities are aggregated, they will not exceed the 251bs /daythreshold. 

# + Mr. Coleman indicated that they do platinum coating of some parts. 

# + Mr. Coleman indicated that he would send a letter from the manufacturer ofthe Vapor Degreaser indicating that it meets all the federal requirements. 

### Industrial Gas Turbines (IGT) Settingup meet

### Summary of Comments from Outreach Efforts on the Draft Aluminum Ordinance Pirnalco (Amy Vasquez, William Pottgen,Pat Gorman, Butch Sorensen via phone) 

# + Add "Chips and run around scrap'' to section 2.2 of definitions. 

# + Add "halogenated materials" to section 2.2. 

# + Alcoa considers external scrap to be dirty scrapbut is not "dirty" as definedby federal definition. 

# + Add page #s 

# + GRIC may want to add a referenceto the MACT Standard for dioxin

### RRR. 

# + GRIC may want to add an alternate method 22 in lieu ofMethod 9. 

# + Delete sentence#2 in section 3.2

### B. 

# + Add prohibitions. 

# + Pimalco personnel expressed concern about 3.3B, 2. a.&b. 

# + Consider deleting section 3.4. 

# + Section 4.2 needs to be clarifiedto state what istobe tested (e.g.electric furnace) 

# + Section 4.2 

### B. 1. ,the ArizonaAmbient Air Quality Guidelines for Chlorine and Hydrogen Chloride should not be used as 

### a controltechnology requirement. Recommend a mACT standard if applicable. 

# + Section 4.2 E., where are VEs to be conducted? 

# + Section 5.1consider adding alternate method 22. 

### Alexco (JerryWise, Robert Jackson) 

# + Alexco personnel didn't have many comments because most ofthe requirements in the ordinance wouldn't applyto Alexco facility. This facility does not have furnaces for melting aluminum but have natural gas fired ovens for heat treatment of extruded parts. In addition, emissions of VOCs are minimal and result from ink printing and limited solvent cleaning.

### Kaiser Aluminum (Jim Thomas) 

# + Set up meetings with Jim Thomas but the meetings were cancelled by Mr. Thomas. Janet has continued to try and set up a meeting with Kaiser personnel but has been unsuccessfulto date.

### Summary of Comments from Outreach Efforts on the Draft Aluminum Ordinance Pimalco (Amy Vasquez, William Pottgen, Pat Gonnan, Butch Sorensen via phone)
4 Add "Chips and run around scrap" to section2.2 of definitions.
4 Add "halogenated materials" to section 2.2.
4 Alcoa considers external scrap to be dirty scrapbut is not "dirty" as defined by federal definition.
4 Add page #s
4 GRIC may want to add a referencetothe MACT Standard for dioxin

### RRR.
4 GRIC may want to add an alternate method 22 in lieu ofMethod 9.
4 Delete sentence#2 in section 3.2 

### B.
4 Add prohibitions.
4 Pimalcopersonnel expressed concern about 3.3

### B, 2. a.& b.
4 Consider deleting section 3.4.
4 Section 4.2 needs tobe clarified to state what isto 

### be tested (e.g. electric furnace)
4 Section4.2B. 1. 

### , the Arizona Ambient Air Quality Guidelines for Chlorine and Hydrogen Chloride should not be used as a controltechnology requirement. Recommend a mACT standardif applicable.
4 Section 4.2 E., where are VEs tobe conducted?
4 Section 5.1 consider adding alternatemethod 22. 

### Alexco (JerryWise, Robert Jackson)
4 Alexco personnel didn't have many commentsbecause most of the requirements in the ordinance wouldn't apply to Alexco facility. This facility doesnot have furnaces for melting aluminumbut have natural gas fired ovens for heat treatment of extrudedparts. In addition, emissions ofVOCs are minimal and result from ink printing and limited solvent cleaning.

### KaiserAluminum (Jim Thomas) 

# + Setup meetings with Jim Thomas but the meetings were cancelled by Mr. Thomas. Janet has continued to try and set 

### up a meeting with Kaiser personnel but has been unsuccessful to date.GILA RIVER INDIAN COMMUNITY DEPARTMENT OF ENVIRONMENTAL QUALITY MEMORANDUM
DATE.: May I 1,2005 TO: Richard Narcia, Governor Mary Thomas, Lt. Governor
FROM: Pat Mariella, DEQ '? 

# 1 b-----, RE: Tribal Implementation Plan for Air Quality
Cc: Gary Bohnee, Chief of Staff wlo attachments

The DEQ Air Team met with the Natural Resources Standing Committee yesterday and received approval to take the Tribal In~plementation Plan (TIP) proposed ordinances out for public comment. The DEQ will also hold a public hearing on the TIP. June 22, 2005 in District 4.
We have attached the complete proposed TIP along with brief sunlnlaries of each section. In addition. the DEQ has developed a brochure (enclosed) to use as part of the Community outreach that highlights the key points. The Air Team will present the TIP in each district during the public coillillent period which goes from May 13 (publication in the Gila River Indian News) to Julj- 1, 2005. There will also be request for comment. as required by the Clean Air Act, in the Arizona Republic's public notice section. We also have a TIP stakeholders list that iilcludes affected businesses. GRIC departnleilts aswell as surroundiilgjurisdictions. We will be sending the public coinmeilt notice to these stakeholders. After the public conlnlent period closes,the DEQ will review the coillilleilts and develop proposed changes to the TIP ordinances, as appropriate. The comments, the DEQ responses and the changes will be presented to Legislative and Natural Resources Committees as well as Council for final approval and enactment. LJnfortunatelj.. the special work session on the TIP for you and Council scl~eduled April 28 was cancelled by hTRC when Council called a special meeting for that daq.. We are working with NRC to reschedule the presentation and will malte sure that you get notice as soon as possible. We would also be verjrglad to make a preseiltation for you at a separate time. if you would like. Please let us know what works best for you. Thank you.