Summary of Comments from Outreach Efforts on the 

Draft Aerospace Manufacturing and Rework Operations Ordinance 

Triumph Precision Casting (Dick Ransom, 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 operations due to the very low usage of VOCs. They 

indicated that all their VOC emissions do not exceed 25#/day as indicated in section 1.0 

A. of the ordinance. 

+ I informed TPC that VOC emissions from all three Triumph operations may be 

aggregated as a total to determine if this ordinance applies. I also explained that the 

federal definition of contiguous operations would 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 informed them that I would research the 

federal definition and get back with them. 

+ I also indicated that the applicability level of 25# 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 of AMTI), and Industrial Gas Turbines (IGT). 

TPC cast turbine fan blades and components for NUS and for IGT. TPU does rework 

operations on turbine fan blades for APUs for airplanes. IGT dismantles industrial 

turbines for power generation, repairs and reassembles the turbines. This facility may 

not fall under the definition of LLAerospace Manufacturing or Rework Facility" in 

accordance with section 2.5 of the ordinance. 

+ TPC personnel indicated that they have very minimal air emissions mostly 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 requirement by DOD customers. I informed Mr. Coleman that the 

Degreaser must comply with federal requirements and the GRJC solvent cleaning 

ordinance. I informed Mr. 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 contiguous to 

determine if emissions 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 /day threshold. 

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

+ Mr. Coleman indicated that he would send a letter from the manufacturer of the Vapor 

Degreaser indicating that it meets all the federal requirements. 

Industrial Gas Turbines (IGT) Setting up 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 scrap but is not "dirty" as defined by federal 

definition. 

+ Add page #s 

+ GRIC may want to add a reference to the MACT Standard for dioxin RRR. 

+ GRIC may want to add an alternate method 22 in lieu of Method 9. 

+ Delete sentence #2 in section 3.2 B. 

+ Add prohibitions. 

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

+ Consider deleting section 3.4. 

+ Section 4.2 needs to be clarified to state what is to be tested (e.g. electric furnace) 

+ Section 4.2 B. 1. , the Arizona Ambient Air Quality Guidelines for Chlorine and 

Hydrogen Chloride should not be used as a control technology requirement. Recommend 

a mACT standard if applicable. 

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

+ Section 5.1 consider adding alternate method 22. 

Alexco (Jerry Wise, Robert Jackson) 

+ Alexco personnel didn't have many comments because most of the requirements in the 

ordinance wouldn't apply to 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 

unsuccessful to 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 section 2.2 of definitions. 

4 Add "halogenated materials" to section 2.2. 

4 Alcoa considers external scrap to be dirty scrap but is not "dirty" as defined by federal 

definition. 

4 Add page #s 

4 GRIC may want to add a reference to the MACT Standard for dioxin RRR. 

4 GRIC may want to add an alternate method 22 in lieu of Method 9. 

4 Delete sentence #2 in section 3.2 B. 

4 Add prohibitions. 

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

4 Consider deleting section 3.4. 

4 Section 4.2 needs to be clarified to state what is to be tested (e.g. electric furnace) 

4 Section 4.2 B. 1. , the Arizona Ambient Air Quality Guidelines for Chlorine and 

Hydrogen Chloride should not be used as a control technology requirement. Recommend 

a mACT standard if applicable. 

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

4 Section 5.1 consider adding alternate method 22. 

Alexco (Jerry Wise, Robert Jackson) 

4 Alexco personnel didn't have many comments because most of the requirements in the 

ordinance wouldn't apply to 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 

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 as well as surroundiilg jurisdictions. 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 verjr glad 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.