Responses to Comments Submitted by Alcoa Inc. 

Addressing the GRIC TIP 

GRIC Public Comment Period July 1,2006 thru July 31,2006 

RESPONSES TO PIMALCO 

Comment: "Section Summaries - Part 11: Permit Requirements - (C) General 

Concepts in the Permit Ordinance - (4) Emission limits and emission standards 

This section notes that the basis of emission limits are predicated upon Technical Support 

Documents (TSD) and that the TSD's will be presented with specific ordinances in the 

near future". 

Since the TSD forms the basis for regulatory framework, these TSD's should be provided 

for review. 

Response: "The Technical Support Documents for source category-specific ordinance 

have been and continue to be available at the GRIC DEQ offices and will be provided 

electronically upon request." 

Comment : "Part I1 Permit Requirements - 1.0 Definitions - Ultra Hazardous air 

pollutants: 

Pimalco previously commented on the Tribes newly defined ultra hazardous air 

pollutants which include chemicals listed at 112 (r) for accidental release prevention. 

Section 112 r chemicals were intended for accidental release 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 pollutants" be 

removed from the ordinance. 

Response: "The ordinance provides more stringent regulation of what are called ultrahazardous air pollutants. This is a characterization (as "extremely hazardous substances") 

adopted in Section 112 of the Clean Air Act. The reason that certain hazardous air 

pollutants were chosen for this designation is amply documented in the legislative history 

of Section 112 and the Community would be glad to provide references to this 

documentation if requested." 
Comment: 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 section be renamed to 

"Fugitive Emissions Limits" 

Response: "We agree with this comment and have amended the ordinance accordingly". 

Comment: Part VI Exemptions to the Degreasing and Solvent Metal Cleaning 

Ordinance 

Response: "We agree that the exception requires clarification. It has been limited to 

solvent cleaning operations specifically regulated by 'another Section in this Part VI."' 

Comment: Part MI Secondary Aluminum Production Ordinance 

Response: "This comment took us aback. The emission decrease requirement for VOCs 

in the proposed ordinance was specifically incorporated at the commenter's suggestion. It 

provides significant flexibility. Now the commenter is requesting an additional level of 

flexibility. The community does not believe that additional flexibility in this case is 

either warranted or necessary." 

Comment: Part I1 Accelerated Permit Processing 

Response: "We agree that it is desirable to have permit processing deadlines in the 

ordinance and eventually the community will adopt such deadlines. However, this is a 

new and unprecedented program for a tribe to adopt and implement and we simply lack 

adequate experience as far as processing pernlits to be able to adopt meaningful 

processing deadlines. We would note that non-Indian jurisdictions have typically had 

twenty or more years experience processing air quality permits before processing 

deadlines were adopted, so giving the Community at least some limited time to create the 

necessary track record hardly seems unreasonable." 

The decision to pay the extra fees necessary for accelerated permit processing is 

entirely within the discretion of the permit applicant. Payment does two things (neither 

of which requires processing deadlines): 

(1) Gives the applicant a priority position in the processing queue. 

(2) Provides the resources necessary to contract with an outside third party to 

assist in the permit processing. 

Whether these benefits justify the 50% surcharge is up to the permit applicant."