## Responses to Comments Submitted by Alcoa Inc. Addressing the GRIC 

## TIP

GRIC Public Comment Period July 1,2006thru 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 ordinancesin the near future". Sincethe 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 : 

### "PartI1 Permit Requirements 

### - 1.0 

### Definitions 

### - Ultra Hazardous air pollutants: Pimalco previously commented onthe 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 shouldnot be included as a permit parameter. Specifically, the ordinance indicates a regulatory threshold of 300 pounds forpermitting 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 airpollutants"be removed from the ordinance.


### Response: "The ordinance provides more stringent regulation of what are called ultrahazardous airpollutants. 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 designationis 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 sectionrefers to fugitive dustproducing activities that generate emissions.Under the CAA, an "area source" is a sourcethat emits less than major sourcethresholds of hazardous air pollutants. Because ofthis,Pimalco is concerned that this duel meaning may lead to confusion and ambiguity.Pimalco requests that this sectionbe 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 specificallyregulated by 'another Section in this Part VI."' 

### Comment: Part MISecondary Aluminum Production Ordinance Response: "This comment took us aback. The emission decrease requirement for VOCs in the proposed ordinance was specifically incorporatedat 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 createthe necessary track record hardly seemsunreasonable." 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 ofwhich 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."